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In accordance with OAC rule 3745-77-03 the Title V applicant must state that the facility will meet in a timely manner applicable requirements that become effective during the permit term.

48. How do you calculate "potential to emit" when determining whether an emission unit is insignificant?

In this case you determine the potential to emit on the basis of your annual maximum uncontrolled emission rate. Please note that if you have federally enforceable operating schedule restrictions then you base your maximum rate on the federally enforceable maximum hours of operation rather than 8,760 hours of operation.

49. What is the definition of a "Trade Secret" that warrants confidential protection under Ohio Revised Code (ORC) Section 3704.08?

The definition of "Trade Secret" appears in ORC Section 1333.61(D) that reads as follows: "Trade Secret" means information, including the whole or any portion or phase of any scientific or technical information, design, process, procedure, formula, pattern, compilation, program, device, method, technique, or improvement, or any business information or plans, financial information, or listing of names, addresses, or telephone numbers that satisfies both of the following:

(1) It derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use.

(2) It is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

Note: There is considerable case law that clarifies this definition. Should you have questions please contact Bryan Zima, Esq., Ohio EPA Legal Staff for assistance.

Air Services

1. If you have several sources on one line, and have negotiated a common capture test for an entire line, is it necessary to calculate capture efficiencies for each source?

Yes, the company will have to give the best estimate possible for emissions from the individual emissions units.

2. Efficiency - Will the flash zones should be included with spray booths?

Yes, the flash zones should be included with spray booths.

3. There is no guidance for calculating emissions of some HAPS. Will the agency be issuing some guidance?

HAPS only need to be included as regulated pollutants if there is a specific applicable requirement or the facility is Major for that HAP. The company will have to provide its best estimate for the emissions and there may not be an approved test method for that HAP.

4.Control Equipment/Exhaust Equipment - Does the agency intend to have each water wash in a paint booth created as a control device?

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