Air Permitting LIVE s3

Stars2/ Permitting Call https://ohioepa.webex.com 1/17/2017  Meeting found under "Meeting Center" 9:30AM-11:30AM  Password for meeting: stars24u  Call in # 1-877-668-4490 Access code: 639 921 250

# Topic Speaker

1 Terri Dzienis - Canton John Paulian When entering paper copy emission test reports, you have to enter them as a compliance report and an emission test in STASR2. When entering them as a compliance report of “emissions/stack testing” report type, when is it appropriate to use the “NSPS Initial Test Results” category versus “Emission/Stack Test Results”? If the test report is for both NSPS test results and other permit requirement test results, which category do you choose? Do you enter the same report 2 times under each category?

2 Laura Miracle – ARAQMD Mike Hopkins/ For a Title V facility, concerning one time notifications and initial compliance reports Andrew Hall Should the requirement be left in the Title V permit if the notification has already been submitted?

For example: OAC rule 3745-21-14 as a requirement for an applicability notification and an initial compliance status report. If the facility has submitted the notification and the initial compliance report can this requirement be remove from the Title V permit? If the Permit to Install is subsequently modified, should you leave the applicability notification and the initial compliance status report requirements in the PTI even if they have already been submitted? Would the same apply to Federal MACT standards and NSPS rules?

3 Jim Braun - Admin Mod guidance review Mike Hopkins/  Group discussion of attached document Jim Braun

4 Miki Riffle - Blue Racer Midstream Question Elisa Thomas/ Andrew Hall What needs to happen to a workflow for Title V RAPM involving transfer of ownership only; no other changes submitted to application. How should the DO/LAA permit reviewer process the APA, and how do I process it through the workflow since the transfer will not be reflected until the next renewal issuance?

Scenario: Title V facility who has reported the change in ownership to me via APA via Air Services. The change in ownership appears to be the only change. East Ohio Gas bought Blue Racer Midstream effective December 1, 2016 (0630000104). When I review the Transfer of Ownership document, the new TV owner is required to notify Ohio EPA via the APA, but further down, under the “Permit modifications based on transfer of ownership”, it indicates that we do not routinely modify documents when transfer of ownership occurs unless the permit needs to be modified for other reasons, and that the transfer will be reflected in the next renewal issuance.

Current TV transfer of ownership guidance says:

5 CY 2016 fee emissions/emissions inventory reporting Elisa Thomas Review things that Air Services users will see that may generate calls to DO/LAA staff.

6 Stars2 Demo of changes Elisa Thomas  Version 2.4.2 – Deployed Jan. 13, 2017 Ability to change referral start date for workflow task

Malfunction Reports and Intent to Test notifications were removed from aggregate ToDo list and are broken out as individual tasks. For malfunction reports, stack test results, and intent to test forms, Stars2 now displays the ToDo notification task more prominently when received. They were previously part of an aggregate task.

 Version 2.4.1 – Deployed Dec. 2, 2016 Application Validation now includes requirement of an attachment ‘Synthetic Minor Strategy Write Up / PTE Determination’ if applicant answers ‘Yes’ to the question:

7 Erica Engel-Ishida Sharepoint changes – Helpful Tips Erica Engel-Ishida Processing Admin Mod Requests – Discussion

Situation: A company has an initial permit issued for emissions units P001 through P020. At a later time, the company submits an Admin Mod application request that only includes P003, P008, and P015. On the Permit Detail page, only emissions units P003, P008, and P015 are shown.

Temptation: Since we need to pull in the terms from the previous permit that was issued, the permit writer has often pulled in the terms for all of the emissions units from the previous permit in order to maintain some consistency. The permit writer has either done this on his/her own, or the company had requested that we include all of the emissions units in the Admin Mod permit.

Guidance: We should never issue a permit for an emissions unit where we did not receive an application for it. If the company desires to have every emissions unit in the proposed Admin Mod recommendation, we can do that, but the company will need to submit an Admin Mod application request that includes all of the emissions units. Note, if the Admin Mod request is submitted as a hard copy through the mail, then it will be up to the permit writer to enter the appropriate emissions units when entering the Admin Mod request in STARS2. The problem with processing a permit with emissions units that were not included in the Admin Mod application request is that the emissions unit in STARS2 won’t point to the current permit after the new Admin Mod permit gets issued.

Question 1: If the Admin Mod application request only includes a few emissions units, but the company wants to include all of the emissions units in the Admin Mod permit, can the DO/LAA use the “magic button” to include the other emissions units on the Permit Detail page? Answer: No. As noted above, the Admin Mod application request must include all of the emissions units if that’s what the company wants to have included in the Admin Mod permit. The emissions units that are shown on the Permit Detail page must match the emissions units that are included in the Admin Mod application request.

Question 2: If the Admin Mod is only needed for P003, P008, and P015 but the company submits the amended application to include all of the other emissions units, when we assess the permit fee, would we only assess the fee for P003, P008, and P015 and assign a zero fee for all of the other emissions units? Answer: At this time, a fee should not be assessed for emissions units that are not being administratively modified. However, there is some administrative burden for issuing a permit that isn’t strictly necessary for those extra emissions units so there’s an argument to be made either way. Consequently, the answer to this question might change in the future.

Question 3: From a legal perspective, if the Permit Detail page only identified a few emissions units for an Admin Mod, but we included all of the emissions units from a previous permit, would the permit that gets issued still be a legal binding document that the company needs to comply with for those additional emissions units? Answer: From a legal perspective, the only thing that matters is the permit document that was issued. The company would still have to comply with that permit. However, as noted above, the concern is that we may have a situation where we think a company has a permit that is expired when they actually received an updated permit that we did not realize it was processed because it was not recognized in STARS2 because it was not included in Admin Mod application request nor was it included on the Permit Detail page. Note: The Admin Mod “application” is not the same as a normal application. Instead, the Admin Mod “application” merely lists the emissions units that the company is requesting to be included in the Admin Mod permit along with the specific details of the Admin Mod request. Consequently, it is very easy for a company to include all emissions units in an Admin Mod request.

Question 4: Why is it beneficial to include all of the emissions units in an Admin Mod if only a few emissions units actually need the Admin Mod? Doesn’t that make minor source permits essentially the same as a Title V operating permit?

Response: Many minor facilities have requested to have all of the emissions units included in the Admin Mod because they like having to comply with only the most recently issued permit. It can get confusing when there are multiple permits issued. One company commented that they thought they no longer needed to comply with the terms for an emissions unit because it was not included in the most recently issued permit. Even though the concept is the same as a Title V operating permit by including all of the emissions units in an Admin Mod permit, minor facilities like the convenience of only complying with the most recent issued permit. Plus, when it comes time for renewal, all emissions units are supposed to be included in the Renewal permit anyway.

Taking This a Step Further 1: If we are able to include all emissions units in Admin Mod permits and Renewal permits, then could we take the same approach when processing a permit for a new emissions unit or a Chapter 31 modification and include all of the emissions units in the permit action? Response: Technically, this should be possible. However, as noted above, in order to include an emissions unit in a permit action, the company would need to submit an application for each emissions unit. This might not be an issue for facilities that only have a few emissions units, but could be a problem for companies that have many emissions units since new installation and Chapter 31 mod applications require complete information which is much different than the basic information needed for an Admin Mod. Plus, the application would have to be clear as to which emissions units the permit action is actually needed for especially for Chapter 31 modifications. Also need to be aware of how BAT is established for each emissions unit. This is where it is helpful to identify the date of installation in the Miscellaneous Section of the emissions unit terms. Also helpful to identify the previous permits that have been issued so that it’s clear when BAT was first established.

Step Further 2: What about doing this for PTIs for Title V facilities, could we always include all emissions units in the PTI so that only the most recently issued PTI is the permit of concern? Since the Title V permit contains all of the emissions units, why not have the PTI contain all of the emissions units? That way the two permits are matching up. Alternatively, why not eliminate the PTI, and have the Title V permit function the same as a PTIO or PTIO?

Response: As stated above, it could be possible to have the PTI include all of the emissions units. That would help to have it match up with the Title V permit. But, as mentioned, we would just have to be careful to make sure that the permit action being processed properly addresses the emissions units of concern. As far as eliminating the PTI altogether, that would require a rule change. There are some Title V companies that would like to eliminate the PTI since it is a hassle making sure both PTIs and Title V permits get processed when needed and having the terms match up.