Applying for a Permit
Additional PTI/PTIO Application Guidance
Prior to the installation of any new air contaminant emissions unit or the modification of an emissions unit, a Permit-to-Install (PTI) or Permit-to-Install and Operate (PTIO) must be applied for and issued as directed by OAC Chapter 3745-31. PTIs are issued to Title V facilities while PTIOs are issued to non-Title V facilities. The Ohio EPA defines a new emissions unit as any unit where the construction or modification commenced on or after January 1, 1974. Only after the PTI or PTIO is issued may a facility begin installation and/or construction of the emissions unit. A period of 18 months from the date of issuance is allowed for commencing construction.
You May Not Need To Submit An Application If....
The emissions unit(s) is exempt from a PTI or PTIO requirement by any of the three provisions below:
i. At maximum design operating conditions, could emit 10 pounds or less of any criteria pollutant per 24-hour period, without the use of air emission control equipment, AND
ii. At maximum design operating conditions, could emit less than 1 ton per year of any hazardous air pollutants (HAPs), as listed in Section 112b of the federal Clean Air Act.
C. The emission unit(s) qualifies for one of the Permit-By-Rule provisions listed in OAC rule 3745-31-03(A)(4).
If a PTI/PTIO Application is Needed....
Effective June 30,2008 Ohio EPA developed a new form applicable to both a PTI or PTIO applications. Please submit the following to your DO/LAA:
Download Permit Applications
1. Application for PTI/PTIO Section I, EPA Form 3150a
Only one of these forms is needed regardless of the number of emissions units being installed/modified. If your facility has no previous air permits, it will not have a facility ID Number. An ID Number will be assigned upon receipt. If this is the case, leave the Facility Information question regarding the facility ID Number blank.
2. Application for PTI/PTIO Section II, EPA Form 3150a
Make copies of Section II for each emissions unit. Complete and submit the forms to the appropriate DO/LAA. Additional information is needed in order to determine compliance with new regulations and/or policies.
3. Emissions Activity Category (EAC) Form(s)
A list of all of the available EAC Forms is included in the PTI/PTIO application instructions. Copies of the appropriate forms for your facility can be obtained from your DO/LAA. Make enough copies for each emissions unit. In order to facilitate review you may wish to staple Section II of Form 3150a and the EAC FORM for the same emissions unit, together.
Additional Information That May be Helpful to You....
4. Best Available Technology
Where reqiured, your application must demonstrate that the new emissions unit(s) will employ the best available technology (BAT) to minimize air contaminant emissions. The definition of BAT is:
"Best available technology" or “BAT” means any combination of work practices, raw material specifications, throughput limitations, source design characteristics, an evaluation of the annualized cost per ton of air pollutant removed, and air pollution control devices that have been previously demonstrated to the director of environmental protection to operate satisfactorily in this state or other states with similar air quality on substantially similar air pollution sources.
In other words, BAT is the use of a control technology at least as effective as those used by other similar emissions units. It is determined on a case-by-case basis. If the allowable emissions of an emissions unit is expected to exceed 50 tons per year, the applicant may be asked to do a study (called a BAT Study) to determine the appropriate control technology for the planned emissions unit(s). Contact your DO/LAA for more information on the need for a BAT study. The file BAT.ZIP (zipped, FoxPro 2.6) is available for download.
5. Toxic Air Contaminant Analysis
Toxic analysis may need to be performed for the emissions unit. Any compound identified in OAC rule 3745-114-01 is a toxic air contaminant. If the allowable emissions of a toxic air contaminant from an emissions unit is expected to exceed 50 tons per year, then computer modeling must be performed to determine the maximum ambient ground level concentration (MAGLC). The allowable MAGLC is the TLV value divided by 42.
The required input data for each egress point has already been requested in the application forms. For simple emission scenarios at a limited number of emissions units, the District or Local Air Agency office may perform the TSCREEN analysis for you. Complex emission scenarios should be analyzed by a computer modeling expert. A copy of the Division of Air Pollution Control’s Engineering Guideline #69 (PDF) can be downloaded.
6. Additional Information Resources
a. The Ohio EPA, Division of Air Pollution Control (DAPC) World Wide Web Page can be found at http://www.epa.ohio.gov/dapc/Home.aspx Information about the Division of Air Pollution Control, the rules and policies, modeling information, application forms, and much more is available.
b. Office of Compliance Assistance and Pollution Prevention
If your company is independently owned, and has less than 100 employees, the Ohio EPA’s Office of Compliance Assistance and Pollution Prevention (OCAPP) at (800) 329-7518 or (614) 644-3469 is also available to provide free and confidential assistance with completing permit applications.
c. DAPC has developed an Ohio BAT Database which contains information about what control technologies other facilities have been required to employ. This is available on our Web Page at www.epa.ohio.gov/dapc/files/files.aspx.
d. Your equipment supplier or consultant may be able to help you in determining what BAT is since they should have experience with supplying equipment in other areas of the State and might know what has been required elsewhere.
e. Your District Office or Local Air Agency ( DO/LAA) representative (permit reviewer) will be able to advise you on many aspects of your application. Please do not hesitate to ask for a meeting in advance of your submittal to get a good idea of what you need to submit to have a complete application.
f. Air pollution control equipment that you install may be eligible for certain tax exemptions. Please contact John Nolf of the Ohio Department of Taxation at (614) 466-8613 for additional information.
For facilities subject to the Title V permitting requirements; a revised Title V application will be required. In some cases this revised Title V application may be required before you can begin operating a change authorized for installation through a PTI. In some cases you may be required to obtain a final issued revised Title V permit before beginning operation. In other cases you may be able to wait up to one year from the start-up date if you comply with all the requirements contained in the PTI and all applicable air pollution laws, regulations and policies. For information on Title V revisions please see the available Guidance for incorporating facility changes into a Title V Permit:
SEND THE COMPLETED FORMS TO YOUR DISTRICT OR LOCAL AIR AGENCY OFFICE
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