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trying to show compliance with, such as SO2 , then a program for fuel sampling or CEMS would be more likely to be approvable than a stack test.

33. USEPA has insisted that all chrome plating operations be in the Title V program; however, most of these emission units are less than 10 tons per year of emissions. What are the fees for these small sources?

Chromium is charged under the fee program as particulate matter. It is possible that an entity be in Title V because of the MACT, yet pay no fee if the emit less than one ton per year.

34. For those facilities on the borderline, that are greater than 20% of the major definition for any pollutant but less than 50%, can they get the two year extension for filing either a FEPTIO or Title V permit if they agree to keep records on site?

Yes, see Engineering Guide #61.

  • 35.


  • 36.

    Definition of "insignificant" as it relates to HAPS.

Insignificant activities excludes HAPS unless de minimus (<1 ton) or is considered a R & D. The history of this confusion stems from USEPA's preamble discussion on how R & D sources would be treated special and then USEPA failed to exempt them from the requirements of Part 70. USEPA promises to fix this oversight in future Part 70 revisions but in the mean time, they would be considered "insignificant" in accordance with the definition in ORC section 3704.01 and the Engineering Guide but would be on the state only side of the permit as far as federal enforceability goes. R & D exemption would prevail over the HAP (that is if it meets the definition of R & D and emits > one ton a year of HAPS, it is still considered "insignificant").

37.Definition of Small Business. What about the HAPS? Who is eligible for assistance through the small business technical assistance program?

Concern was expressed that if a facility is a small emitter but happens to be in a MACT category, they cannot get assistance because they will automatically be in Title V. The DAPC is using the 50 ton per year definition as actual emissions, not potential to emit. A facility may seem to be small enough to qualify for assistance but if the facility is owned by a parent company, it does not qualify for assistance.

38.For the Title V applications, do facilities have to consider fugitive emissions if not addressed in the NSPS?

Only fugitive emissions are considered for the 28 major facilities categories. If the NSPS doesn't address fugitive emissions, then it doesn't have to be looked at except for the state side of the permit for BAT.

39. A brick ceramic kiln indicated that its actual emissions of SO2 taken from a 1989 stack test qualified them as non-Title V (89 tons per year) even though their allowable for both the USEPA and State permits would put them in Title V. Does Engineering Guide # 61 deal with this situation.

The stack test is only a snapshot of what the emissions are from the facility. There is no enforceable provision in the current permit to hold them to the quality of clay and operational practices that would ensure continuous compliance with 89 tons per year. They need a FESOP, but more importantly they need to pay a fee. The Engineering Guide #61 enables a facility to delay the need for a Title V permit for 2 years.

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