On January 5, 2011, the Ohio Environmental Protection Agency (Ohio EPA) updated Engineering Guide #71, which outlines the requirements for reporting very low-emitting units in Fee Emission Reports (FER) and Emission Inventory Summaries (EIS), to include new reporting exemptions and lead (Pb) reporting requirements. Previously, de minimis emission units and non-de minimis emission units with actual emissions less than 1 ton per year (tpy) were considered exempt from emissions reporting. The first change extends the reporting exemption to emissions units that are categorically exempt from permitting under OAC 3745-31-03(A)(1)-(3). The second change requires facilities that have plant-wide lead emissions greater than 0.5 tons per year (tpy) to report lead emissions for every contributing emissions unit, regardless of the amount. This includes lead emissions from otherwise exempt sources (e.g., de minimis sources, categorically exempt sources, or sources with actual emissions < 1 tpy), although Ohio EPA has provided that only lead emissions must be reported for these otherwise exempt sources. This second change is being made in response to U.S. EPA’s newly revised ambient monitoring network requirements associated with the 2008 revised National Ambient Air Quality Standard (NAAQS) for lead. The new rules require ambient monitors to be placed near facilities that have actual plant-wide lead emissions in excess of 0.5 tpy.
If you have more questions concerning these updates please call Amanda Adams at 614-433-0733.