Air Compliance and Permitting
The Clean Air Act legislation and subsequent Clean Air Act Amendments were put into law to regulate (with a goal to reduce) air pollution emissions in the United States. These pieces of legislation established air quality standards and emission limits applicable to a wide variety of sources of air pollution. The US EPA enforces the Clean Air Act requirements in part through requiring that facilities with sources of air pollution obtain and comply with air permits. Development of specific regulations and permit requirements was delegated to the State of Ohio and the Ohio EPA.
The Ohio State University operates in compliance with a “Title V Permit” written by the Ohio EPA in accordance with federal guidelines. This type of permit is assigned to facilities that have the “potential” to generate emissions in excess of certain thresholds. This permit identifies potential sources of air pollution at The Ohio State University main campus and specifies operating parameters for these sources where applicable.
Permit Terms and Conditions
The permit lists several sources at the University as being sources of air pollution emissions. The larger sources include the boilers at the McCracken Power Plant, boilers at Scott Hall, printing presses at the UniPrint, the gasoline dispensing facility at Transportation & Parking and miscellaneous sources at the Center for Automotive Research. Various permit terms and conditions apply to the operation of these sources. Associated reporting requirements require recordkeeping and reporting of various data relevant to these sources.
The permit lists each emergency generator larger than 50 hp. These units are permitted under what is designated a “permit by rule” which has limited recordkeeping requirements.
The permit lists other, relatively minor, sources of emissions. These sources have been inventoried and are listed in the permit. These sources include numerous boilers smaller than 10 mmBtu/hr, a number of storage tanks, miscellaneous printing equipment and maintenance facilities. Though not having explicit permit terms and conditions, these sources need to be in compliance with applicable regulations.
U.S. EPA rules applicable to these sources include Boiler MACT and RICE MACT.
The permit limits potential emissions from the larger sources on campus. Recordkeeping related to the operation of these sources provides verification that these facilities are in compliance with the applicable permit limits. EHS personnel will periodically request this information from the appropriate department. Emissions are calculated and reported to Ohio EPA on a periodic basis. This reporting verifies compliance and provides the basis for OEPA to compute emissions fees for the facility.
Emissions are estimated for the smaller sources including the emergency generators. These emissions have to be reported to Ohio EPA only when the emissions from an individual source exceed one ton per year. Refined estimates will be calculaed whenever necessary.
.......... U.S. EPA
.......... Clean Air Act, 1970; Clean Air Act Amendments, 1990
.......... Boiler MACT, 2013; RICE MACT, 2013
.......... Ohio EPA
.......... Ohio Administrative Code (OAC-3745)