CAM in Ohio Title V Permits

1. CAM in Ohio Title V Permits Andrew Hall, Ohio EPA CAM/GHG Training August 22, 2011

3. CAM – Ohio EPA Resources • Ohio EPA Answer Place #2269 • Link to the CAM rule 40 CFR Part 64 • Overview of CAM • Latest copy of CAM spreadsheet

6. Calculating Pre-control Emissions • PTE Determination by Emissions Unit (usually) • Use best available information • Actual emission test data –vs- AP-42 emission factors • Always check Fee Emission Reports (FERs) in STARS2 • Look at historical data (max. production, emission rates etc…)

10. Calculating Pre-control Emissions • Based on 97% DE of the RTO and FER it would appear that CAM is applicable • However – note Additional Term and Condition b)(2)c. • K005 and K009 are controlled by same RTO • CAM not applicable on a per emissions unit basis • Explain this in Statement of Basis (SOB) • Indiana – detailed CAM applicability in T5 permit

12. CAM Plan Application/Forms • No set format (yet?) for Ohio • Most companies follow U.S. EPA examples on TTN • Burden is on facilities to submit CAM Plan satisfying Part 64 requirements • South Carolina DHEC has useful form Ohio could use

14. Boiler MACT in Title V’s • Ohio EPA began processing Title V Renewals • Boiler MACT Vacated 6/8/2007 • Vacated = “as if never existed”…MACT Hammer? • MACT Hammer = 112(j) case-by-case MACT • Ohio policy: optional 112(j) Parts 1, 2 applications • Ohio policy: 112(j) “placeholder” term and condition in Title V Renewals

15. Boiler MACT in Title V’s • New Boiler MACT rule 3/21/11 • Rule was “Stayed” (76 FR 28662, 5/18/11) • Stayed rule is not a vacatur: does not trigger 112(j) • New Boiler MACT rule is an Applicable Requirement

16. Boiler MACT in Title V’s • New Boiler MACT: Path Forward for Renewals • New Boiler MACT “Stayed” term and condition: “On May 16, 2011, U.S. EPA decided to Stay the Boiler MACT (40 CFR Part 63, Subpart DDDDD). This delay of effectiveness will remain in place until the proceedings for judicial review are completed or U.S. EPA completes its reconsideration of the rules, whichever is earlier, and the Agency publishes a notice in the Federal Register announcing that the rules are in effect.  Upon being effective, this emissions unit will be subject to 40 CFR Part 63, Subpart DDDDD.”

17. Boiler MACT in Title V’s • Final Title V Renewal with Boiler MACT “Stayed” term and condition • After FR notice that rule is in effect • Facility can submit MPM request • Ohio EPA will process MPM and include Boiler MACT in permit using Engineering Guide #76, Incorporation by Reference (IBR) approach

18. Boiler MACT and CAM Renewal Title V’s • Most Title V Renewals will need CAM Plans for boilers • Exempt from monitoring for MACT rule limits once Boiler MACT is effective • Suggest that permittee submit a CAM Plan patterned after the monitoring requirements of the Boiler MACT • See FAQ: Q&A#1

19. FAQs • Most Commonly Asked Questions (Ohio) • See attached, following these slides • A work in progress • U.S. EPA has many more FAQs

20. Questions? • CO Permit Contact • Andrew Hall: 614-644-3602 andrew.hall@epa.state.oh.us