EPA Outreach for Permits to Install and Operate

Ohio EPA, Division of Air Pollution Announces Early Stakeholder Outreach on Ohio’s Permits-to-Install New Sources and Permit-to-Install and Operate Rules

The Agency is seeking stakeholder input on potential amendments to rules within OAC chapter 3745-31. This chapter provides requirements for installation and modification of all new and existing air contaminant sources, as well as operation of those sources, where their operation is not subject to Title V requirements in OAC Chapter 3745-77.

Written comments will be accepted through close of business Friday, Friday, July 27, 2018. Please submit input to:

Mr. Paul Braun

Ohio EPA Division of Air Pollution Control

PO Box 1049 Columbus, Ohio 43216-1049




Along with the mandated 5-year review of the regulations, the following changes are under consideration:

  • new permanent exemptions under paragraph (B)(1) for certain rubber manufacturing operations, namely extrusion, milling, and calendering. The exemption thresholds will have units of pounds per hour and restrict PTE to less than five tons each for particulate matter and VOC per year, and one ton per year for hazardous air pollutants.
  • new permanent exemption under paragraph (B)(1) for temporary fuel-burning equipment (i.e., boilers or engines) used to replace main fuel-burning equipment during periods of maintenance or repair provided the actual and potential emissions of the temporary sources do not exceed that of the main sources, and the temporary source does not remain at the location for more than ninety consecutive days. This discretionary exemption does not apply to sources subject to the portable source requirements under paragraph (B)(1)(p) of this rule.
  • new permanent exemption under paragraph (B)(1) for wet cooling towers, water treating systems for process cooling water or boiler feedwater, and water tanks, reservoirs, or other water containers designed to cool, store, or otherwise handle water (including rainwater) that have not been used in direct contact with gaseous or liquid process streams containing carbon compounds, sulfur compounds, halogens or halogen compounds, cyanide compounds, chromium-based corrosion inhibitors, inorganic acids, or acid gases, and are not forced or induced draft cooling tower systems subject to a NESHAP requirement, that have a combination of water flow rate, total dissolved solids concentration, and percent drift that yields an PM emission level less than 5.0 tons per year according to a specified equation based on the internal recirculating flow rate and type of drift control technology.
  • new permanent exemption under paragraph (B)(1) for breweries of beer and flavored malt beverages, including packaging and labeling lines, having a production no greater than 60,000 barrels per year.
  • revisions to existing permanent exemption under (B)(1)(ii), for maintenance electric arc welding operations, that will extend applicability to production operations as well as maintenance, impose a limit on pounds of electrode consumed per day, and create a new exemption for all brazing and soldering operations.

Ohio EPA would especially like to hear information regarding the following from stakeholders who may be impacted by the new program.

  • Would this regulatory program have a positive impact on your business? Please explain how.
  • Would this regulatory program have an adverse impact on your business? If so, please identify the nature of the adverse impact (for example, license fees, fines, employer time for compliance).

You can depend on Compliance Technologies to keep you updated via our website at www.compliancetechnologies.biz and your business in-compliance with the air permits you require.  Just contact us.

For more details, see the entire OEPA announcement at http://epa.ohio.gov/Portals/27/regs/3745-31/3745-31_5-yr_ESO.pdf or Ohio EPA’s website for electronic downloading of the rule at: http://epa.ohio.gov/dapc/regs/3745_31.aspx.


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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