Terms Last Revised: 5/31/2016

K1 Compliance Methods Requirements

This section addresses the methods that will be used to determine compliance with each emission limitation specified in the permit. The compliance method may refer to:

1. a specific U.S EPA reference test method(s),

2. the use of an AP-42 emission factor in conjunction with a maximum or actual raw material or production process rate,

3. the use of a facility test factor or accepted industry emission factor in conjunction with a maximum or actual raw material or production process rate,

4. an OAC rule which defines how compliance with a rule-based emission limitation will be demonstrated,

5. an approved Ohio EPA/U.S. EPA site-specific compliance protocol, or

6. a combination of methods, if several different but equivalent methods would allow compliance with the specified emission limitation to be demonstrated.

The examples in the following term and condition are not all-inclusive and Ohio EPA District Office and local air agency staff should work with the permittee to define how compliance with each emission limitation in the permit will be demonstrated.

The following term and condition should be used in all permits containing any emissions limitation. Please replace the X’s with the following:

XXXX1 - identify each of the emission limitations in Section A.I. of this permit

XXXX2 - for each emission limitation, enter the applicable compliance method(s)

XXXX3 - enter the applicable numerical limitation per unit of raw material or production

Type of Emissions Limitation / Applicable Compliance Method
for a process emissions unit with stack discharge and a stack limitation in terms of lbs of particulate emissions/hr from OAC Chapter 3745-17, where stack testing is not the primary means of determining compliance (e.g., small emissions unit that is well controlled) / “either multiply the particulate emissions factor of [XXXX3] pound(s) of particulate emissions per unit [of raw material or production] by the maximum hourly [raw material or production] rate or use OAC rule 3745-17-03(B)(10)”
for a process emissions unit with stack discharge and a stack limitation in terms of lbs of particulate emissions/hr from OAC Chapter 3745-17, where stack testing is not feasible / “multiply the particulate emissions factor of [XXXX3] pound(s) of particulate emissions per unit [of raw material or production] by the maximum hourly [raw material or production] rate”
for a process emissions unit with stack discharge and a stack limitation in terms of lbs of particulate emissions per hr from OAC Chapter 3745-17, where stack testing is the only acceptable method of determining compliance / “OAC rule 3745-17-03(B)(10)”
for a fugitive dust emissions unit with a limitation of no visible emissions with or without a certain time exemption from OAC rules 3745-17-07, -08, -12 or -13 (e.g., except for a period of time not to exceed one minute during any sixty-minute observation period) / “OAC rule 3745-17-03(B)(4)”
for a stack emissions unit with a visible particulate emissions limitation from OAC rules 3745-17-07(A)(1), -12 or -13 in terms of percent opacity, taken as a six-minute average / “OAC rule 3745-17-03(B)(1)”
for a fugitive dust emissions unit with a visible particulate emissions limitation from OAC rule 3745-17-07(B)(1) in terms of percent opacity, taken as a three-minute average / “OAC rule 3745-17-03(B)(3)”
for a fugitive dust emissions unit with a visible particulate emissions limitation from NSPS in terms of percent opacity, taken as a six-minute average / “Method 9 of 40 CFR Part 60, Appendix A”
for coating or printing emissions units subject to OAC rule 3745-21-09 with a VOC content limitation and which are located within one of the counties specified in paragraph (A) of OAC rule 3745-21-09 (Note: if any such coating has not been analyzed using Method 24 or 24A since January 1, 1991, the permittee must either conduct a Method 24 or 24A analysis of the coating or obtain a Method 24 or 24A analysis of the coating from the coating supplier within one year after the effective date of this rule.) / “OAC rule 3745-21-10(B). USEPA Methods 24 and 24A shall be used to determine the VOC contents for (a) coatings and (b) flexographic and rotogravure printing inks and related coatings, respectively. If, pursuant to Method 24 as outlined in 40 CFR Part 60, Appendix A, an owner or operator determines that Method 24 or 24A cannot be used for a particular coating or ink, the permittee shall so notify the Administrator of the USEPA and shall use formulation data for that coating or ink to demonstrate compliance until the USEPA provides alternative analytical procedures or alternative precision statements for Method 24 or 24A.”
for coating or printing emissions units subject to OAC rule 3745-21-09 and with a volatile organic compound content limitation and which are not located within one of the counties specified in paragraph (A) of OAC rule 3745-21-09 / “OAC rule 3745-21-10(B). Formulation data or USEPA Method 24 (for coatings) or 24A (for flexographic and rotogravure printing inks and related coatings) shall be used to determine the organic compound contents of the coatings and inks.”
for uncontrolled coating or printing emissions units subject to lbs/hr and lbs/day organic material emissions limitations from OAC rule 3745-21-07(G) / “Daily record keeping of coating or ink usage, organic compound content of each coating or ink, and operating hours per day for each unit. Formulation data or USEPA Method 24 (for coatings) or 24A (for flexographic and rotogravure printing inks and related coatings) shall be used to determine the organic compound contents of the coatings and inks.”
for a process fugitive emissions unit subject to a tons of particulate emissions per year limitation from a PTI with no compliance method specified / “multiply the particulate emissions factor of [XXXX3] pound(s) of particulate emissions per unit [of raw material or product] by the actual annual [raw material usage or production] rate for the stack emissions and multiply the particulate emissions factor of [XXXX3] pound(s) of particulate emissions per unit [of raw material or product] by the actual annual [raw material usage or production] rate for the fugitive emissions”

(1)  Compliance with the emission limitation(s) in Section A.I. of these terms and conditions shall be determined in accordance with the following method(s):

Emission Limitation

[XXXX1]

Applicable Compliance Method

[XXXX2]