Air Permitting Process for Metal Finishers

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Basic overview of the air permitting process for metal coating/finishing facilities.

Basic overview of the air permitting process for metal coating/finishing facilities.

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  • 1. Air Permitting Process Presented for: Metal Finishers 1
  • 2. Do I need a permit?• New regulated sources of air pollution must obtain an initial Permit to Install and Operate (PTIO) from Ohio EPA before constructing a new emissions unit.• Even if the emissions unit was constructed years ago, the first step is always to apply for an initial PTIO.Note: PTIO is valid for 10 years. 2
  • 3. Application Submittal1. Facility discusses situation with District Office/Local Air Agency (DO/LAA) and Office of Compliance Assistance and Pollution Prevention (OCAPP)2. Facility prepares PTIO application – Completed PTIO application bearing an original signature by a responsible official – Emissions Activity Category (EAC) form – MSDS – Emissions calculations – Process flow diagram• Note: There is no fee to apply for a PTIO. 3
  • 4. Application Review1. DO/LAA reviews information in application – Issues completeness determination – There may be a request for additional or clarifying technical information.2. DO/LAA performs a site visit3. DO/LAA prepares a permit recommendation4. Proposed terms shared with facility5. Recommendation submitted to Ohio EPA Central Office 4
  • 5. Permit Issuance1. Final permit or denial issued by Ohio EPA Central Office.2. PTIO permit and invoice sent to facility when permit has been issued. – Invoice based on the amount of emissions and type of emissions unit. 5
  • 6. What next?1. Facility reads and complies with permit2. Apply for renewal PTIO before expiration.Note: Ohio EPA personnelmay conduct a sitevisit/inspection at anytime. This can beunannounced. 6
  • 7. Permit Content• Emission limitation and/or control requirements• Operational restrictions• Monitoring and/or recordkeeping requirements• Reporting requirements – PTIO annual PER• Testing requirements• Miscellaneous requirements 7
  • 8. Possible Applicable Regulations• Code of Federal Regulations (CFR): – 40 CFR Part 63 Subpart N – 40 CFR Part 63 Subpart WWWWWW (6W) –• Ohio Administrative Code (OAC): – OAC Rule 3745-17-07(A)(1) = visible PE from stack – OAC Rule 3745-17-07(B)(1) = visible fugitive dust – 8
  • 9. 40 CFR Part 63 Subpart N• Applies to: – Hard chromium electroplating – Decorative chromium electroplating – Chromium anodizing• Factors to consider: – Type of control equipment – Requires Operation and Maintenance (O & M) plan – Several required notifications 9
  • 10. 40 CFR Part 63 Subpart 6W• Rule covers area source plating and polishing processes that use/emit: – Cadmium – Chromium – Lead – Manganese – Nickel 10
  • 11. 40 CFR Part 63 Subpart 6W cont.• Subpart 6W does NOT apply to: – Sources subject to Subpart N (Cr electroplating) – Processes using metals other than Cd, Cr, Pb, Mn, and Ni or processes using these metals at very low concentrations – Tanks used for R&D or educational purposes – Thermal spraying to repair surfaces – Dry mechanical polishing prior to plating 11
  • 12. How do I Apply for Permits?• Apply online at Ohio EPA Air Services:• Download application forms from Ohio EPA:• Contact Office of Compliance Assistance and Pollution Prevention (OCAPP)• Contact District Office/Local Air Agency 12
  • 13. Need Assistance?• Ohio EPA’s Office of Compliance Assistance and Pollution Prevention (OCAPP) – Small business – Free – Info is not shared with Ohio EPA inspection or enforcement staff – (800) 329-7518 – (614) 644-3469 – Website: 13
  • 14. Air Permit DO/LAA Contact Information for Northeast OhioCleveland Division of Air Quality Ohio EPA Northeast District Office75 Erieview Plaza, Suite 200 2110 East Aurora RoadCleveland, OH 44114 Twinsburg, OH 44087216-664-2297 (voice) 330-963-1200(voice)216-420-8047 (fax) 330-487-0769 (fax)Akron Regional AQMD Canton Div. of Air Pollution Control146 South High Street, Room 904 420 Market Avenue, NorthAkron, OH 44308 Canton, OH 44702330-375-2480 (voice) 330-489-3385 (voice)330-375-2402 (fax) 330-489-3335 (fax) Complete DO/LAA list found at: 14