1
Ohio
EPA
Division
of
Air
Pollution
Control
Engineering
Guide
#
65
Question:

For
which
types
of
emissions
units
should
a
monitoring,
recordkeeping,
and
reporting
program
be
established
to
ensure
continued
compliance
with
applicable
emission
limitations
and
control
requirements?
In
the
absence
of
specific
requirements
which
have
been
approved
by
the
USEPA
as
part
of
the
Ohio
SIP,
what
would
constitute
reasonable
and
adequate
programs
for
such
emissions
units?
These
questions
are
particularly
relevant
to
a
Title
V
permit
applicant
who
must
propose,
within
the
"
Applicable
Requirements"
section
of
the
application,
reasonable
and
adequate
monitoring,
recordkeeping,
and
reporting
requirements.

[
These
questions
and
answers
were
created
by
the
Engineering
Section
of
the
DAPC
to
assist
State
permit
(
PTI
and
PTO)
and
Title
V
permit
applicants,
as
well
as
District
Office
and
local
air
agency
staff
who
will
be
reviewing
permit
applications
and
drafting
the
necessary
permits.]

Answer:

A
well­
designed
monitoring,
recordkeeping,
and
reporting
program
will
allow
the
permittee
to
obtain
and
document
information
for
an
emissions
unit
which
can
be
used
to
ensure
continued
compliance
with
the
applicable
emission
limitations
and
control
requirements
and
ensure
the
proper
operation
and
maintenance
of
any
control
equipment.
In
many
cases,
a
permittee
will
want
to
establish
some
type
of
program
for
almost
all
of
the
significant
emissions
units
at
a
facility.
Although
the
DAPC
believes
this
approach
would
be
the
most
beneficial
approach
for
the
permittee,
from
a
permitting
and
regulatory
standpoint,
the
DAPC
believes
that
it
would
be
acceptable
for
the
permittee
to
focus
on
emissions
units
which
(
a)
are
required
by
State
or
federal
law
to
2
establish
a
specific
type
of
program,
(
b)
generate,
either
individually
or
collectively
(
for
similar
emissions
units),
substantial
amounts
of
emissions
on
an
uncontrolled
basis,
or
(
c)
have
actual
emission
rates
that
are
close
to
the
allowable
emission
rates.
These
situations
are
described
in
more
detail
in
the
remainder
of
this
Guide.

Throughout
this
Guide,
"
monitoring"
refers
to
a
device,
equipment,
or
system
used
to
measure,
detect,
or
analyze
an
emission
or
operating
parameter
for
an
emissions
unit
or
for
an
air
pollution
control
device.
The
monitoring
may
be
continuous
or
periodic
and
may
be
automated
or
manual.
A
monitoring
system
may
be
equipped
with
an
automated
means
for
recording
the
emission
or
parameter
being
measured,
detected,
or
analyzed.
Also,
the
monitoring
system
may
be
equipped
with
an
alarm
or
other
mechanism
to
notify
personnel
that
the
emission
or
parameter
being
measured,
detected,
or
analyzed
is
above
or
below
an
acceptable
level.

"
Recordkeeping"
refers
to
the
maintenance
of
records
by
the
permittee
of
information
or
data
from
a
monitoring
system,
equipment
maintenance
plan,
inspection,
emission
test,
emission
unit
activity,
etc.
Recordkeeping
can
also
include
documentation
concerning
estimated
emissions,
material
usage,
and
hours
of
operation
for
an
emissions
unit
on
a
periodic
basis
(
e.
g.,
annually,
quarterly,
monthly,
daily,
or
hourly).

"
Reporting"
refers
to
the
submission
by
the
permittee
of
any
information,
notice,
or
report
to
the
Ohio
EPA
or
a
designated
local
air
agency.
The
reporting
can
be
periodic
(
e.
g.,
annually,
quarterly,
or
monthly)
or
triggered
by
the
occurrence
of
a
specific
event
such
as
a
failure
to
meet
a
specified
monitoring
level,
an
equipment
malfunction,
or
a
violation
of
an
emission
limitation.
The
reporting
may
be
written
or
verbal
or
both,
depending
upon
the
legal
requirements.

Some
emissions
units
are
required
by
the
following
State
or
federal
regulations
to
employ
continuous
emission
monitors
and
meet
specific
recordkeeping
and
reporting
requirements:


New
Source
Performance
Standards
(
NSPS)
3

National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)


Appendix
P
of
40
CFR
Part
51

40
CFR
Part
266
(
for
cement
kilns,
boilers
and
industrial
furnaces
that
burn
hazardous
wastes)


40
CFR
Part
503
(
for
sewage
sludge
incinerators)


Title
IV
of
the
Clean
Air
Act
(
for
utility
and
industrial
boilers
subject
to
the
acid
rain
provisions)


OAC
Chapter
3745­
75
(
for
infectious
waste
incinerators)


OAC
Chapter
3745­
57
(
for
hazardous
waste
incinerators)

The
emissions
unit
categories
subject
to
NSPS,
NESHAP,
and
Appendix
P
requirements
for
continuous
emission
monitoring
are
summarized
in
Engineering
Guide
#
52,
along
with
the
pollutants
required
to
be
monitored
for
each
category.

All
of
the
above­
mentioned
regulations
establish
mandatory
continuous
emission
monitoring,
recordkeeping,
and
reporting
requirements
for
the
affected
emissions
units.
Engineering
Guide
#
52
also
describes
several
situations
which
may
warrant
the
use
of
continuous
emission
monitors.
The
most
important
of
those
situations
are
described
below.

1.
The
emissions
unit
has
demonstrated
marginal
compliance
with
the
allowable
mass
rate
of
emission.
(
The
DAPC
considers
marginal
compliance
to
be
greater
than
80%
of
the
allowable
mass
rate
of
emission.)

2.
Method
9
readings
are
not
feasible
due
to
the
nature
of
the
operation
of
the
emissions
unit.

3.
Very
low
visible
emissions
levels
must
be
maintained
for
the
emissions
unit
to
ensure
compliance
with
a
very
stringent
allowable
mass
rate
of
emission.
4
4.
The
emissions
unit
has
a
history
of
periodic,
possibly
unexplained,
violations
of
OAC
rule
3745­
17­
07.

5.
The
use
of
a
continuous
emission
monitoring
system
for
a
coating
line
or
printing
line,
or
a
group
of
such
lines,
is
more
reasonable
(
both
technically
and
economically)
than
detailed,
daily,
line­
by­
line
recordkeeping
and
reporting
for
the
coatings
or
printing
inks
employed.
(
This
approach
has
been
successfully
used
in
situations
where
several
emissions
units
are
located
within
a
permanent
total
enclosure
and
vented
to
a
common
control
system.)

The
decision
to
pursue
continuous
emission
monitoring
in
these
situations
and
the
others
described
in
Engineering
Guide
#
52
will
normally
be
made
by
District
Office
or
local
air
agency
personnel,
after
appropriate
discussions
with
Central
Office
personnel
and
company
representatives.

Some
emissions
units
also
are
required
by
State
or
federal
regulations
to
employ
continuous
parametric
monitors.
Engineering
Guide
#
66
identifies
the
mandatory
continuous
parametric
monitoring
requirements
for
various
types
of
emissions
units.

The
remaining
portion
of
this
Engineering
Guide
is
intended
to
recommend
appropriate
terms
and
conditions
for
monitoring,
recordkeeping,
and
reporting
within
PTIs,
Title
V
permits
and
State
PTOs
for
emissions
units
that
are
not
subject
to
mandatory
continuous
emission
or
parametric
monitoring,
recordkeeping,
and
reporting
requirements.
Some
of
the
terms
and
conditions
in
the
STARS
library
are
derived
directly
from
federally
enforceable
requirements
in
the
Ohio
SIP,
as
identified
by
the
rule
citations
in
the
tables
that
follow.
However,
some
federally
enforceable
requirements
do
not
contain
corresponding
monitoring,
recordkeeping,
or
reporting
requirements.
At
Title
V
facilities
where
this
is
the
case,
applicants
must
propose
an
acceptable
monitoring,
recordkeeping,
and
reporting
program
(
which
may
consist
of
recordkeeping
only
in
appropriate
circumstances)
for
each
such
applicable
requirement.
Any
proposed
monitoring,
recordkeeping,
and
reporting
program
in
a
Title
V
permit
5
application
should
be
accepted
if
it
fulfills
the
requirements
of
OAC
rule
3745­
77­
07(
A)(
3)
and
is
enforceable.

The
following
guiding
principles
should
be
used
in
drafting
Title
V
permits:

1.
No
monitoring,
recordkeeping,
or
reporting
requirements
should
be
placed
in
the
federal/
State
enforceable
portion
of
a
Title
V
permit
unless
they
are
required
by
existing
federally
enforceable
requirements
(
e.
g.,
approved
SIP
rules
that
are
applicable
requirements,
NSPS,
MACT
standards,
etc.)
or
they
are
necessary
to
comply
with
the
requirements
of
OAC
rule
3745­
77­
07(
A)(
3)(
a)(
ii).

2.
Monitoring,
recordkeeping,
or
reporting
requirements
cannot
establish
new
performance
standards
or
increase
the
stringency
of
an
applicable
requirement.

3.
Any
monitoring,
recordkeeping,
and
reporting
requirements
that
are
not
federally
enforceable
requirements
should
not
be
included
in
a
permit
unless
they
are
necessary
and
reasonable.
In
general,
an
emissions
unit
that
would
meet
the
definition
of
"
insignificant
activities
and
emission
levels"
or
that
would
qualify
for
registration
status
would
not
be
subject
to
any
monitoring,
recordkeeping,
and
reporting
requirements
in
a
permit.

4.
Indicator
monitoring
shall
not
be
used
to
determine
direct
compliance
with
mass
emission
limits
unless
expressly
requested
by
the
applicant
and
approved
as
an
equivalent
or
alternative
for
determining
compliance.

PTIs
and
State
PTOs
should
similarly
incorporate
acceptable
monitoring,
recordkeeping,
or
reporting
requirements
within
the
terms
and
conditions,
following
the
same
guidelines
set
forth
in
(
2)
through
(
4)
above.
Any
proposed
monitoring,
recordkeeping,
and
reporting
program
in
a
PTI
or
State
PTO
application
should
be
accepted
if
it
fulfills
the
requirements
of
State
and
federal
law
and
is
enforceable.
6
The
types
of
emissions
units
for
which
monitoring,
recordkeeping,
and
reporting
are
recommended,
are
described
in
the
following
tables
by
type
of
pollutant.
For
each
type
of
emissions
unit,
the
table
recommends
the
elements
(
monitoring,
recordkeeping,
and/
or
reporting)
that
should
be
included
in
the
program
(
e.
g.,
for
some
emissions
units
recordkeeping
only
may
be
sufficient,
and
for
others,
recordkeeping
and
reporting
may
be
sufficient).
If
the
existing
federally
enforceable
requirement
specifies
a
particular
program
element,
then
the
rule
citation
appears
under
the
"
X"
in
the
appropriate
program
element
column(
s)
(
monitoring,
recordkeeping,
and/
or
reporting).
These
terms
and
conditions
should
be
included
in
the
federal/
State
enforceable
portion
of
the
permit.
If
no
rule
is
cited
in
these
columns
and
an
acceptable
program
has
not
been
proposed
by
the
permittee,
the
recommended
STARS
library
terms
and
conditions
should
be
included
in
the
permit,
provided
they
are
determined
to
be
necessary
and
reasonable
under
the
circumstances
involved.
The
last
column
provides
a
cross­
reference
to
the
STARS
library
of
terms
and
conditions
where
the
recommended
wording
for
that
program
element
is
contained.

SO2:

EMISSIONS
UNIT
DESCRIPTION
PROGRAM
ELEMENTS
STARS
LIBRARY
(
T&
Cs)
MONITORING
RECORDKEEPING
REPORTING
7
1.
coal­
fired
boiler,
>
10
mmBtu/
hr
and

100
mmBtu/
hr,
without
CEM
for
SO2
X
X
X
(
I.
6)

2.
coal­
fired
boiler,
>
100
mmBtu/
hr
and
<
1,000
mmBtu/
hr,
without
CEM
for
SO2
X
X
X
X
(
I.
4
or
I.
5)

3.
coal­
fired
boiler,


1,000
mmBtu/
hr,
>
15,000
TPY,
and
without
CEM
for
SO2
X
X
X
X
(
I.
3)

4.
coal­
fired
boiler,


1,000
mmBtu/
hr,
<
15,000
TPY,
and
without
CEM
for
SO2
X
X
X
X
(
I.
4
or
I.
5)

5.
any
coal­
fired
boiler
operated
by
the
State
of
Ohio
X
X
X
X
(
I.
8)

6.
oil­
fired
boiler,
>
10
mmBtu/
hr
and

100
mmBtu/
hr,
without
CEM
for
SO2
X
X
X
(
I.
7)

7.
any
fuel
burning
equipment
with
operating
rate
restrictions
X
X
X
X
(
I.
9)

8.
sulfur
recovery
plant
(
non­
NSPS)
X
(
CEM)
X
X
none
9.
coke
oven
battery
(
H2S
content
of
COG)
X
X
X
none
10.
FCC
unit
and
CO
boiler
X
(
CEM)
X
X
none
PARTICULATES:

EMISSIONS
UNIT
DESCRIPTION
PROGRAM
ELEMENTS
STARS
LIBRARY
(
T&
Cs)
8
MONITORING
RECORDKEEPING
REPORTING
1.
coal­
fired
boiler,
>
1
mmBtu/
hr
and
<
20
mmBtu/
hr,
and
subject
to
17­
10(
C)(
7)
X
(
ash
content)
X
X
(
R.
1
­
R.
3)

2.
coal­
fired
boiler,
uncontrolled
or
equipped
solely
with
mechanical
collectors
X
(
17­
07
(
A)(
1)(
d)
and
(
f)
for
sootblowing
and
intermittent
ash
removal
operations,
respectively)
none
3.
fuel
burning
equipment
which
have
been
derated
X
X
X
X
(
S.
3
&
S.
4)

4.
coke
oven
battery
(
lids,
charging,
doors,
offtake
piping,
and
combustion
stack)
X
X
X
X
(
T.
2
­
T.
4)

5.
BOF
shop
X
X
X
X
(
Z.
1,
Z.
2,
Z.
4
&
Z.
5)

6.
infectious
waste
incinerators,


1,000
lbs/
hr
X
X
X
X
(
N.
4.
a
&
N.
5)

7.
infectious
waste
incinerators,
>
1,000
lbs/
hr
X
X
X
X
(
N.
4.
b
&
N.
5)

8.
roadways
and
parking
areas
X
X
X
(
U.
5,
U.
8,
or
U.
9;
U.
11
&
U.
13
if
applicable
9
9.
landfills
used
for
the
disposal
of
asbestoscontaining
materials
X
X
X
(
O.
14
&
O.
15)

10.
controlled
emissions
units,
with
uncontrolled
particulate
emissions
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
J.
32­
J.
47,
as
applicable

11.
asphaltic
concrete
batch
plants
X
X
X
X
(
P.
11
&
P.
12;
or
P.
14
&
P.
15;
if
applicable
P.
19,
P.
20,
P.
21,
&
P.
23)

VOC:

EMISSIONS
UNIT/
CATEGORY
DESCRIPTION
PROGRAM
ELEMENTS
STARS
LIBRARY
(
T&
Cs)
MONITORING
RECORDKEEPING
REPORTING
10
1.
exempt
metal
furniture
coating
line,
<
15
lbs/
day
for
all
such
lines
[
21­
09(
I)]
X
(
B)(
3)(
b)
X
(
B)(
3)(
c)
X
(
B.
1.
a
&
B.
1.
b)

2.
exempt
misc.
metal
parts
coating
line,
<
15
lbs/
day
for
all
such
lines
[
21­
09(
U)(
2)(
h)]
X
(
B)(
3)(
b)
X
(
B)(
3)(
c)
X
(
B.
2.
a
&
B.
2.
b)

3.
exempt
misc.
metal
parts
coating
line,
<
8
or
10
gpd/
line
[
21­
09(
U)(
2)(
e)]
X
(
B)(
3)(
d)
X
(
B)(
3)(
e)
X
(
B.
3.
a
&
B.
3.
b)

4.
coating
line
or
printing
line
that
employs
only
complying
coatings
X
(
B)(
3)(
f)
X
(
B)(
3)(
g)
X
(
B.
4.
a
&
B.
4.
b)

5.
coating
line
or
printing
line
that
complies
by
means
of
a
daily
volumeweighted
average
VOC
content
X
(
B)(
3)(
h)
X
(
B)(
3)(
i)
X
(
B.
5.
a
&
B.
5.
b)

6.
coating
line
that
employs
control
equipment
and
is
subject
to
a
lbs
VOC/
gallon
of
solids
limitation
X
(
B)(
3)(
j)
&
(
n)
X
(
B)(
3)(
j)
X
(
B)(
3)(
k)
&
(
m)
X
(
B.
6.
a
&
B.
6.
b;
B.
6.
c
&
B.
6.
d;
B.
6.
e
&
B.
6.
f;
or
B.
6.
g
&
B.
6.
h)
11
7.
coating
line
or
printing
line
that
employs
control
equipment
and
is
subject
to
capture
and
control
efficiency
requirements
or
to
an
overall
control
efficiency
requirement
[
21­
09
(
B)(
6),
(
H),
(
Y),
(
NN),
(
PP),
and
(
XX)]
X
(
B)(
3)(
l)
&
(
n)
X
(
B)(
3)(
l)
X
(
B)(
3)(
m)
X
(
B.
7.
a
&
B.
7.
b;
B.
7.
c
&
B.
7.
d;
B.
7.
e
&
B.
7.
f;
or
B.
7.
g
&
B.
7.
h)

8.
an
emissions
unit,
other
than
a
coating
line
or
printing
line,
that
employs
control
equipment
and
is
subject
to
21­
09
(
O),
(
W),
(
X),
(
EE),
(
KK),
(
LL),
(
MM),
(
SS),
(
TT),
(
UU),
(
VV),
(
YY),
(
ZZ),
(
AAA),
or
(
BBB)
X
(
B)(
4)(
b)
&
(
d)
(
parametric
monitoring
of
the
control
equipment)
X
(
B)(
4)(
b)
X
(
B)(
4)(
c)
X
(
J.
32­
J.
47,
as
applicable

9.
guidecoat
or
surfacer
coating
line
[
21­
09
(
C)(
1)(
a)(
v)]
X
X
none
10.
topcoat
coating
operation
[
21­
09
(
C)(
1)(
c)]
X
X
none
11.
can
coating
operation
(
alternative
daily
emission
limitation)
[
21­
09
(
D)(
3)]
X
(
D)(
3)(
d)
X
X
(
B.
8.
b
&
B.
8.
c;
or
B.
8.
d
&
B.
8.
e)

12.
fixed
roof
storage
tank
[
21­
09
(
L)]
X
(
L)(
3)
X
(
L)(
4)
X
(
G.
3
&
G.
4)
12
13.
process
unit
turnaround
[
21­
09
(
M)(
3)]
X
(
M)(
3)(
b)
none
14.
use
of
cutback
asphalts
[
21­
09
(
N)]
X
(
N)(
4)
none
15.
cold
cleaner
[
21­
09
(
O)(
2)]
X
(
O)(
5)
X
(
C.
1.
g)

16.
open
top
vapor
degreaser
[
21­
09
(
O)(
3)]
X
(
parametric
monitoring
of
the
control
equipment
X
(
O)(
5)
X
(
C.
2.
g
or
C.
2.
h)

17.
conveyorized
degreaser
[
21­
09
(
O)(
4)]
X
(
parametric
monitoring
of
the
control
equipment
X
(
O)(
5)
X
(
C.
3.
g
or
C.
3.
h)

18.
bulk
gasoline
plant
[
21­
09(
P)]
X
(
P)(
4)
X
(
P)(
6)
X
(
P)(
7)
X
(
E.
4;
&
E.
5
&
E.
6,
or
E.
8
&
E.
9)

19.
bulk
gasoline
terminal
[
21­
09
(
Q)]
X
(
Q)(
3)
X
(
F.
3;
&,
if
applicable
F.
4
&
F.
5)

20.
gasoline
dispensing
facility,
Stage
I
[
21­
09
(
R)]
X
(
R)(
3)
X
(
R)(
5)
exempt
facilities
X
(
R)(
5)
exempt
facilities
X
(
Q.
5
&
Q.
7;
or
Q.
6
&
Q.
8)

21.
leaks
from
petroleum
refinery
equipment
[
21­
09
(
T)]
X
(
T)(
1)(
a)­
(
d)
X
(
T)(
1)(
e)­(
h)
X
(
T)(
1)(
i)
none
13
22.
gasoline
tank
truck
[
21­
09
(
V)]
X
(
V)(
1)(
a)
X
(
V)(
1)(
a)­(
f)
none
23.
external
floating
roof
storage
tank
[
21­
09
(
Z)]
X
(
Z)(
2)(
a)­
(
c)
X
(
Z)(
2)(
d)&
(
e);
(
Z)(
4)
X
(
Z)(
5)
X
(
H.
3
&
H.
4;
or
H.
5.
b
&
H.
5.
c)

24.
perchloroethylene
dry
cleaning
facility
[
21­
09
(
AA)]
X
(
AA)(
3)
X
(
AA)(
4)
X
(
D.
2­
D.
4;
or
D.
2,
D.
5
&
D.
6)

25.
petroleum
dry
cleaning
facility
[
21­
09
(
BB)]
X
(
BB)(
4)
X
(
BB)(
5)
none
26.
leaks
from
process
units
that
produce
organic
chemicals
[
21­
09
(
DD)]
X
throughout
(
DD)
X
throughout
(
DD)
X
throughout
(
DD)
none
27.
steel
door
wipe
cleaning
operation
[
21­
09
(
FF)]
X
X
none
28.
loading
rack
[
21­
09
(
GG)]
X
(
GG)(
6)
X
none
29.
PVC
film
casting
lines
and
associated
solvent
storage
and
mix
tanks
[
21­
09
(
HH)]
X
X
X
none
30.
sheet­
fed,
offset,
lithographic
printing
press
[
21­
09
(
II)]
X
(
II)(
2)
X
(
II)(
2)
&
(
3)
X
(
II)(
4)
none
31.
nitrile­
butadiene
rubber
production
operation
[
21­
09
(
JJ)]
X
(
JJ)(
1)
X
(
JJ)(
1)
X
(
JJ)(
1)
none
14
32.
methyltin
intermediates
production
process
[
21­
09
(
KK)]
X
(
KK)(
1)
X
(
KK)(
1)
X
(
KK)(
1)
none
33.
reactor
[
21­
09
(
LL)]
X
(
LL)(
3)(
a)
exempted
unit
X
(
LL)(
3)
(
a)
exempted
unit
none
34.
paint
manufacturing
operations
and
paint
laboratory
operations
[
21­
09
(
MM)]
X
(
MM)(
8)
&
(
9)
none
35.
mica
coating
or
laminating
line
[
21­
09
(
NN)]
X
(
NN)(
2)
X
(
NN)(
2)
none
36.
several
emissions
units
at
a
petroleum
refinery,
controlled
by
means
of
a
flare
[
21­
09
(
UU)]
X
(
DD)(
10)(
d)
(
parametric
monitoring
of
the
flare)
X
(
J.
39.
c
&
J.
39.
d)

37.
fluid
catalytic
cracking
unit
[
21­
09
(
VV)]
X
(
VV)(
1)(
e)
X
(
VV)(
1)(
e)
X
(
VV)(
1)
(
e)
none
38.
reactor
[
21­
09
(
ZZ)]
X
(
DD)(
10)(
d)
(
parametric
monitoring
of
the
flare)
X
(
J.
39.
c
&
J.
39.
d)

39.
gasoline
dispensing
facility
(
Stage
II)
[
21­
09
(
DDD)]
X
(
DDD)(
3)
X
(
DDD)(
2)
X
(
Q.
13
&
Q.
15;
or
Q.
14
&
Q.
16)
15
40.
any
controlled
emissions
unit,
with
uncontrolled
VOC
emissions
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
J.
32­
J.
47,
as
applicable

41.
any
controlled,

new
emissions
unit
that
is
not
subject
to
21­
09,
but
has
a
PTI
which
specifies
a
VOC
emission
limitation
and
the
uncontrolled
emissions
are
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
J.
32­
J.
47,
as
applicable

42.
any
uncontrolled,

new
emissions
unit
that
is
not
subject
to
21­
09,
but
has
a
PTI
which
specifies
a
VOC
emission
limitation
and
the
emissions
are
>
25
TPY
X
X
none
43.
multiple,
uncontrolled,

similar,
new
emissions
units
that
are
not
subject
to
21­
09,
but
have
a
PTI
which
specifies
a
VOC
emission
limitation
for
each
unit
and
the
combined
emissions
are
>
25
TPY
X
X
none
16
ORGANIC
COMPOUNDS:

EMISSIONS
UNIT
DESCRIPTION
PROGRAM
ELEMENTS
STARS
LIBRARY
(
T&
Cs)
MONITORING
RECORDKEEPING
REPORTING
1.
uncontrolled
coating
operation
that
is
subject
to
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and
is
not
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
9.
e
&
B.
9.
f;
B.
9.
g
&
B.
9.
h;
B.
10.
a
&
B.
10.
b;
or
B.
10.
c
&
B.
10.
d)

2.
uncontrolled
coating
operation
that
is
subject
to
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and
is
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
12.
a
&
B.
12.
b;
or
B.
12.
c
&
B.
12.
d)
17
3.
uncontrolled
coating
operation
that
is
required
to
employ
only
nonphotochemically
reactive
materials
and
is
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
14.
a
or
B.
14.
b;
and
B.
14.
c)

4.
controlled
oven
that
is
subject
to
the
3
lbs/
hr
&
15
lbs/
day
limitations
in
21­
07
(
G)(
1),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
13.
e
&
B.
13.
f
or
B.
13.
g
&
B.
13.
h;
&
J.
32­
J.
47,
as
applicable

5.
controlled
oven
that
is
subject
to
the
85%
overall
&
90%
destruction
efficiency
limitations
in
21­
07
(
G)(
1),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
13.
i
&
B.
13.
j;
B.
13.
k
&
B.
13.
l;
B.
13.
m
&
B.
13.
n;
B.
13.
o
&
B.
13.
p;
or
B.
13.
q
&
B.
13.
r)
18
6.
controlled
coating
operation
that
is
subject
to
the
8
lbs/
hr
&
40
lbs/
day
limitations
in
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
is
not
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
9.
a
&
B.
9.
b
or
B.
9.
c
&
B.
9.
d;
&
J.
32­
J.
47,
as
applicable

7.
controlled
coating
operation
that
is
subject
to
the
85%
overall
&
90%
destruction
efficiency
limitations
in
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
is
not
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
9.
i
&
B.
9.
j;
B.
9.
k
&
B.
9.
l;
B.
9.
m
&
B.
9.
n;
B.
9.
o
&
B.
9.
p;
or
B.
9.
q
&
B.
9.
r)
19
8.
controlled
coating
operation
that
is
subject
to
the
8
lbs/
hr
&
40
lbs/
day
limitations
in
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
is
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
12.
e
&
B.
12.
f
or
B.
12.
g
&
B.
12.
h;
&
J.
32­
J.
47,
as
applicable

9.
controlled
coating
operation
that
is
subject
to
the
85%
overall
&
90%
destruction
efficiency
limitations
in
21­
07
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
is
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
12.
e
or
B.
12.
g;
&
J.
32­
J.
47,
as
applicable
20
10.
controlled
emissions
unit
that
is
subject
to
21­
07
(
G)(
1)
or
(
G)(
2),
which
has
actual
emissions
>
80%
of
the
allowable
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
J.
32­
J.
47,
as
applicable

11.
uncontrolled
oven
that
is
subject
to
21­
07
(
G)(
1),
which
has
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
is
preceded
by
a
coating
operation
which
is
either
subject
to
21­
07
(
G)(
2)
or
required
to
employ
only
nonphotochemically
reactive
materials
X
X
X
(
B.
13.
a
&
B.
13.
b;
or
B.
13.
c
B.
13.
d)
21
12.
multiple,
similar,

uncontrolled
ovens
that
are
subject
to
21­
07
(
G)(
1),
which
have
actual
emissions
>
80%
of
the
allowable
hourly
or
daily
emission
rates
and/
or
uncontrolled
emissions
>
25
TPY,
and
are
preceded
by
a
coating
operation
which
is
either
subject
to
21­
07
(
G)(
2)
or
required
to
employ
only
nonphotochemically
reactive
materials
X
X
X
(
B.
13.
a
&
B.
13.
b;
or
B.
13.
c
B.
13.
d)

13.
multiple,
similar,
uncontrolled
coating
operations
that
are
subject
to
21­
07
(
G)(
2),
which
have
combined
emissions
>
25
TPY
and
are
not
followed
by
ovens
which
are
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
9.
e
&
B.
9.
f;
B.
9.
g
&
B.
9.
h;
B.
10.
a
&
B.
10.
b;
or
B.
10.
c
&
B.
10.
d)

14.
multiple,
similar,
uncontrolled
coating
operations
that
are
subject
to
21­
07
(
G)(
2),
which
have
combined
emissions
>
25
TPY
and
are
followed
by
ovens
which
are
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
12.
a
&
B.
12.
b;
or
B.
12.
c
&
B.
12.
d)
22
15.
multiple,
similar,
uncontrolled
coating
operations
that
are
required
to
employ
only
nonphotochemically
reactive
materials
and
are
followed
by
an
oven
which
is
subject
to
21­
07
(
G)(
1)
X
X
X
(
B.
14.
a
or
B.
14.
b;
and
B.
14.
c)

16.
any
controlled,

new
coating
operation
that
is
not
subject
to
21­
07
(
G),
but
has
a
PTI
which
specifies
allowable
hourly
and
daily
OC
emission
limitations,
and
either
the
actual
emissions
are
>
80%
of
the
allowable
emission
rates
and/
or
the
uncontrolled
emissions
are
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
B.
15.
e
&
B.
15.
f
or
B.
15.
g
&
B.
15.
h;
&
J.
32­
J.
47,
as
applicable

17.
any
controlled,

new
emissions
unit
that
is
not
subject
to
21­
07
(
G),
but
has
a
PTI
which
specifies
an
OC
emission
limitation
and
the
uncontrolled
emissions
are
>
25
TPY
X
(
parametric
monitoring
of
the
control
equipment)
X
X
X
(
J.
32­
J.
47,
as
applicable
23
18.
any
uncontrolled,

new
coating
operation
that
is
not
subject
to
21­
07
(
G),
but
has
a
PTI
which
specifies
allowable
hourly
and
daily
OC
emission
limitations,
and
either
the
actual
emissions
are
>
80%
of
the
allowable
emission
rates
and/
or
the
uncontrolled
emissions
are
>
25
TPY
X
X
X
(
B.
15.
a
&
B.
15.
b;
or
B.
15.
c
&
B.
15.
d)

19.
multiple,
uncontrolled,

similar,
new
coating
operations
that
are
not
subject
to
21­
07
(
G),
but
have
a
PTI
which
specifies
allowable
hourly
and
daily
OC
emission
limitations,
and
either
the
actual
emissions
are
>
80%
of
the
allowable
emission
rates
and/
or
the
uncontrolled
emissions
are
>
25
TPY
X
X
X
(
B.
15.
a
&
B.
15.
b;
or
B.
15.
c
&
B.
15.
d)
24
Some
new
emissions
units
may
be
subject
to
special
limitations
that
require
a
monitoring,
recordkeeping,
and
reporting
program.
The
most
commonly
encountered
situations
are
summarized
in
the
following
table:

TYPE
OF
LIMITATION
PROGRAM
ELEMENTS
STARS
LIBRARY
(
T&
Cs)
MONITORING
RECORDKEEPING
REPORTING
1.
daily
production
rate
X
X
X
(
V.
2
&
V.
3)

2.
monthly
production
rate
X
X
X
(
V.
2
&
V.
3)

3.
annual
production
rate
X
X
X
(
V.
2
&
V.
3)

4.
annual
production
rate,
based
upon
a
rolling
12­
month
summation
X
X
X
(
V.
5
&
V.
6;
or
V.
8
&
V.
9)

5.
annual
production
rate,
based
upon
a
rolling
365­
day
summation
X
X
X
(
V.
5
&
V.
6;
or
V.
8
&
V.
9)

6.
daily
coating
usage
X
X
X
(
W.
2
&
W.
3)

7.
monthly
coating
usage
X
X
X
(
W.
2
&
W.
3)

8.
annual
coating
usage
X
X
X
(
W.
2
&
W.
3)
25
9.
annual
coating
usage,
based
upon
a
rolling
12­
month
summation
X
X
X
(
W.
5
&
W.
6;
or
W.
8
&
W.
9)

10.
annual
coating
usage,
based
upon
a
rolling
365­
day
summation
X
X
X
(
W.
5
&
W.
6;
or
W.
8
&
W.
9)

11.
daily
operating
hours
X
X
X
(
X.
2
&
X.
3)

12.
monthly
operating
hours
X
X
X
(
X.
2
&
X.
3)

13.
annual
operating
hours
X
X
X
(
X.
2
&
X.
3)

14.
annual
operating
hours,
based
upon
a
rolling
12­
month
summation
X
X
X
(
X.
5
&
X.
6;
or
X.
8
&
X.
9)

15.
annual
operating
hours,
based
upon
a
rolling
365­
day
summation
X
X
X
(
X.
5
&
X.
6;
or
X.
8
&
X.
9)

16.
annual
emissions,
based
upon
a
rolling
12­
month
summation
X
X
X
(
Y.
2)

17.
annual
emissions,
based
upon
a
rolling
365­
day
summation
X
X
X
(
Y.
2)
26
18.
annual
emissions,
based
upon
a
rolling
12­
month
summation,
and
enforceable
monthly
limitations
are
required
either
during
the
first
12
months
of
operation
or
during
the
first
12
months
of
operation
after
issuance
of
the
permit
X
X
(
Y.
4)

19.
annual
emissions,
based
upon
a
rolling
365­
day
summation,
and
enforceable
monthly
limitations
are
required
either
during
the
first
12
months
of
operation
or
during
the
first
12
months
of
operation
after
issuance
of
the
permit
X
X
(
Y.
4)

It
is
not
possible
to
develop
an
exhaustive
listing
of
all
the
emissions
units
for
which
a
detailed
monitoring,
recordkeeping,
and
reporting
program
should
be
employed.
The
above
tables
should
cover
most
emissions
units;
however,
there
undoubtedly
will
be
types
of
emissions
units
that
do
not
fit
any
of
the
listed
descriptions.
In
such
cases,
if
the
emissions
unit
meets
one
or
more
of
the
following
criteria,
the
District
Office
or
local
air
agency
personnel
should
evaluate
the
feasibility
of
and
require,
if
determined
to
be
reasonable
and
beneficial,
a
detailed
monitoring,
recordkeeping,
and
reporting
program
to
27
ensure
continued
compliance
with
the
applicable
emission
limitations
or
control
requirements:

1.
The
actual
uncontrolled
emissions
from
the
emissions
unit
are
significant,
i.
e.,
generally
greater
than
25
TPY.

2.
The
combined,
actual
uncontrolled
emissions
from
the
emissions
unit
and
other
similar
emissions
units
at
the
facility
are
significant,
i.
e.,
generally
greater
than
25
TPY
as
a
combined
total.

3.
The
actual
emissions
from
the
emissions
unit
are
greater
than
80%
of
the
allowable
emission
rate.

4.
The
emissions
unit
emits
one
or
more
air
contaminants
which,
due
to
their
toxic
or
hazardous
nature,
could
pose
a
threat
to
public
health
if
the
control
device
is
not
operated
and
maintained
properly.

5.
The
emissions
unit
has
a
history
of
compliance
problems,
or
the
ability
of
the
emissions
unit
to
remain
in
compliance
over
the
long­
term
is
questionable.

As
mentioned
earlier,
the
program
designed
for
a
particular
emissions
unit
may
not
include
all
the
elements
of
monitoring,
recordkeeping,
and
reporting.
For
example,
for
some
emissions
units,
recordkeeping
only
may
be
sufficient,
and
for
others,
recordkeeping
and
reporting
may
be
sufficient.

For
significant
emissions
units
that
are
not
included
in
the
above
tables
and
do
not
meet
any
of
the
above­
mentioned
criteria,
a
Title
V
applicant
must
specify
in
the
electronic
application
the
"
proposed
approach
for
determining
compliance,"
the
"
proposed
compliance
monitoring
method,"
the
"
proposed
compliance
recordkeeping
method,"
and
the
"
proposed
compliance
reporting
method"
for
each
applicable
emissions
limit
or
control
requirement.
For
these
emissions
units,
a
detailed
monitoring,
recordkeeping,
and
reporting
program
will
not
be
required.
Any
simplified,
reasonable,
and
clearly
defined
program
will
be
acceptable
to
the
DAPC.
(
In
some
cases,
an
applicant
may
decide
to
develop
a
more
comprehensive
program
in
order
to
have
a
28
greater
assurance
of
ongoing
compliance
for
each
of
these
smaller
emissions
units.
That
approach
obviously
will
also
be
acceptable
to
the
DAPC.)

In
general,
to
obtain
a
Title
V
permit,
the
applicant
must
be
able
to
demonstrate
that
each
emissions
unit
is
in
compliance
with
each
applicable
emissions
limit
or
control
requirement.
For
the
smaller,
significant
emissions
units,
the
approach
used
by
the
applicant
to
initially
demonstrate
compliance
with
each
applicable
emission
limit
or
control
requirement
can
also
serve
as
the
basis
for
the
proposed
monitoring,
recordkeeping,
and
reporting
program
for
each
applicable
emission
limit
or
control
requirement
and
also
for
the
annual
certification
required
by
OAC
rule
3745­
77­
07
(
C)(
5).
The
following
examples
illustrate
how
this
approach
would
be
used:

Example
#
1:

!
an
emissions
unit
with
a
particulate
emission
limit
of
X
lbs/
hr
!
no
control
equipment
!
basis
for
the
initial
compliance
demonstration:
Calculations
were
performed
using
AP­
42
emission
factors
and
the
maximum
capacity
of
the
emissions
unit.

**********************************

The
following
statements
would
be
included
in
the
Title
V,
electronic
application:

Proposed
Approach
for
Determining
Compliance:
Calculations
using
AP­
42
emission
factors
and
the
maximum
capacity
of
the
emissions
unit
will
be
performed
to
demonstrate
compliance.

Proposed
Compliance
Monitoring
Method:
Not
Applicable
Proposed
Compliance
Recordkeeping
Method:
29
Any
changes
in
the
maximum
capacity
of
the
emissions
unit
shall
be
recorded
and
kept
on
file.

Proposed
Compliance
Reporting
Method:
The
compliance
status
of
the
emissions
unit
shall
be
reported
pursuant
to
the
annual
certification
required
by
OAC
rule
3745­
77­
07(
C)(
5).
Calculations,
using
AP­
42
emission
factors
and
the
maximum
capacity
of
the
emissions
unit,
shall
be
performed
to
quantify
the
particulate
emissions.

Example
#
2:

!
an
emissions
unit
with
a
particulate
emission
limit
of
X
lbs/
hr
!
control
equipment
employed
!
basis
for
the
initial
compliance
demonstration:
A
particulate
emission
test
was
conducted
while
the
emissions
unit
was
operating
at
or
near
its
maximum
capacity.

**********************************

The
following
statements
would
be
included
in
the
Title
V,
electronic
application:

Proposed
Approach
for
Determining
Compliance:
A
particulate
emission
test
will
be
conducted
periodically
(
at
intervals
consistent
with
the
frequency
required
in
past
Ohio
EPA
permits),
while
the
emissions
unit
is
operating
at
or
near
maximum
capacity,
to
demonstrate
compliance.

Proposed
Compliance
Monitoring
Method:
Monitoring
of
the
control
equipment
shall
be
performed
in
accordance
with
an
operation
and
maintenance
plan
that
is
consistent
with
the
manufacturer's
recommendations.

Proposed
Compliance
Recordkeeping
Method:
Records
of
inspections
and
maintenance
activities
for
the
control
equipment
shall
be
maintained
in
accordance
with
the
30
operation
and
maintenance
plan
for
the
equipment.
Records
shall
also
be
maintained
of
any
particulate
emission
tests
performed
for
the
emissions
unit.

Proposed
Compliance
Reporting
Method:
The
compliance
status
of
the
emissions
unit
shall
be
reported
pursuant
to
the
annual
certification
required
by
OAC
rule
3745­
77­
07(
C)(
5).
A
particulate
emission
test
shall
periodically
be
performed
to
determine
the
controlled
particulate
emission
rate
from
the
emissions
unit,
while
operating
at
or
near
its
maximum
capacity.

Example
#
3:

!
coating
operation
with
an
OC
emission
limit
of
8
lbs/
hr
!
no
control
equipment
!
basis
for
the
initial
compliance
demonstration:
The
applicant
demonstrated
through
calculations
that
at
"
worst
case"
conditions,
i.
e.,
at
the
highest
coatings
usage
rate
and
with
the
highest
OC
content
coatings,
the
OC
emissions
were
in
compliance
with
the
allowable
emission
rate.

**********************************

The
following
statements
would
be
included
in
the
Title
V,
electronic
application:

Proposed
Approach
for
Determining
Compliance:
Calculations
shall
be
performed
which
document
the
OC
emission
rate
from
the
emissions
unit
under
"
worst
case"
conditions,
i.
e.,
the
highest
coatings
usage
rate
and
the
highest
OC
content
coatings.

Proposed
Compliance
Monitoring
Method:
Not
Applicable
Proposed
Compliance
Recordkeeping
Method:
Any
changes
in
the
"
worst
case"
conditions
for
the
emissions
unit
shall
be
recorded
and
kept
on
file.
31
Proposed
Compliance
Reporting
Method:
The
compliance
status
of
the
emissions
unit
shall
be
reported
pursuant
to
the
annual
certification
required
by
OAC
rule
3745­
77­
07(
C)(
5).
Calculations
shall
be
provided
which
document
the
OC
emission
rate
from
the
emissions
unit
under
"
worst
case"
conditions,
i.
e.,
the
highest
coatings
usage
rate
and
the
highest
OC
content
coatings.

It
would
be
nearly
impossible
to
develop
enough
examples
to
cover
all
the
smaller,
significant
emissions
units.
However,
assuming
the
applicant
does
not
want
to
develop
a
more
detailed
monitoring,
recordkeeping,
and
reporting
program,
a
simplified,
reasonable
program
can
be
developed
for
any
emissions
unit
by
beginning
with
the
approach
used
to
demonstrate
compliance
with
the
applicable
emission
limit
or
control
requirement.

JO
May
17,
1996
revised
November
1,
1996
