When should we use the new language described in this guidance? Answer: The new language should be used when you are processing any installation or operating permit where we originally used the <10 exemption. This includes permits for new or modified sources, chapter 31 or administrative modification or any renewal permit. Should DO/Laa staff go back and reissue permits where the <10 exemption was used? Answer: DO/Laa staff should make these changes whenever the permit comes up for revision. At this point DAPC has not decided to search for all past permits issued with the <10 exemption in order to separately revise the permits. Other than renewal or modified permits, Ohio EPA does not currently believe that the Court’s order requires the reissuance of permits where the <10 exemption was used. Can we still use the approach to avoid BAT by putting in the restrictions that keep emissions to below 10 tons per year? Answer: No, the avoiding of BAT approach can no longer be used because under the current court decision, no new or modified sources can avoid the applicability of BAT. Based on this guidance, it was intension, especially as stated in question #10, that permits would no longer be issued without BAT for emissions less that 10 tons per year. Should the September 2006 guidance be used with no BAT or should the subsequent July 2, 2010 guidance overrule the earlier guidance and BAT be set? LAA IT Issues 8 Erica Engel-Ishida F5 replacement research continues could be higher expense – On-boarding/Off-boarding Procedures coming –
When should we use the new language described in this guidance? Answer: The new language should be used when you are processing any installation or operating permit where we originally used the <10 exemption. This includes permits for new or modified sources, chapter 31 or administrative modification or any renewal permit. Should DO/Laa staff go back and reissue permits where the <10 exemption was used? Answer: DO/Laa staff should make these changes whenever the permit comes up for revision. At this point DAPC has not decided to search for all past permits issued with the <10 exemption in order to separately revise the permits. Other than renewal or modified permits, Ohio EPA does not currently believe that the Court’s order requires the reissuance of permits where the <10 exemption was used. Can we still use the approach to avoid BAT by putting in the restrictions that keep emissions to below 10 tons per year? Answer: No, the avoiding of BAT approach can no longer be used because under the current court decision, no new or modified sources can avoid the applicability of BAT. Based on this guidance, it was intension, especially as stated in question #10, that permits would no longer be issued without BAT for emissions less that 10 tons per year. Should the September 2006 guidance be used with no BAT or should the subsequent July 2, 2010 guidance overrule the earlier guidance and BAT be set? 8 LAA IT Issues F5 replacement research continues – could be higher expense On-boarding/Off-boarding – Procedures coming Erica Engel-Ishida
APL%20Agenda%2009222015.docx