This document compares Ohio general air permits and site-specific air permits. It discusses that a general permit provides standardized requirements and a quicker approval process, while a site-specific permit allows more flexibility but a longer approval time. It outlines the permit application and qualification processes and provides examples of source categories that can receive general permits. It recommends considering a general permit for sources that need quick approval or meet the general criteria, while a site-specific permit is better for more complex sources where timing is not critical. Facilities may start with a general permit and later transition it to a site-specific permit for expansions.
Ohio General Air Permit vs. Site-Specific Permit: Which is Better for Your Facility
1. Ohio
GeneralAir
Permit vs.
Site-Specific
Permit
Andrew D. Shroads, QEP
614.887.7227 • ashroads@scainc.com
PO Box 1276
Westerville, OH 43086
While every effort has been made to ensure the accuracy of this information, SC&A is not
responsible for any errors or omissions. This information is not a substitute for professional
environmental consulting services. If legal services are required, consult with legal counsel.
2. Why is in air permit so important?
An air permit is the best tool for regulating air pollution
• Customized emissions limits for each source
• Summary of applicable state and Federal regulations
• Source-specific monitoring, testing, recordkeeping,
operational, and reporting requirements
• Audits and enforcement on how well you follow your permit
• Basis for air pollution fees
2
Early Permit Writers in the Wild
3. Who needs an air permit?
Unless specifically exempted, all sources of air pollution need
an Ohio Environmental Protection Agency (EPA) air permit.
1. De minimis Exemption:
◦ Ohio Administrative Code (OAC) Rule 3745-15-05
◦ Actual or potential emissions ≤10 pounds/day
2. Categorical Exemption:
◦ OAC Rule 3745-31-03(B)
◦ Certain boilers, tanks, grinding, emergency engines, heat
treating, composting, printing, and other operations
3. Permit-by-Rule:
◦ OAC Rule 3745-31-03(C)
◦ Permit is written in regulation so no application required
◦ Generators, molding, auto-body refinishing, gas stations
3
4. Types ofAir Permits
Permit-by-rule
• Permit written into Ohio air regulation
State (Natural Minor) Permit
• Air permit with no major source requirements
• Includes General Permits
Synthetic Minor Permit
• Air permit with additional restrictions (e.g. operating hours,
control equipment) to exempt major source requirements
Title V (Major) Permit
• Federally-reviewed, major air permit
• Includes General Permits
New Source Review Permit
• Federally-reviewed, major air permit with significant
restrictions to reduce air emissions
4
5. General Permit Categories
• Aggregate Processing
• Boilers
• Diesel Engines
• Biomass Digesters
• Drycleaning Operations
• Mineral Extraction
• Miscellaneous Metal Parts and Products Coating Lines
• Natural Gas Compressor Stations
• Oil & Gas Well-site Production Operations
• Paved & Unpaved Roadways / Parking Areas
• Ready Mix Concrete Batch Plants
• Storage Piles
• Agricultural Waste Tub Grinder
From: www.epa.ohio.gov/dapc/genpermit/genpermits.aspx
5
6. Air Permit Comparison
General Permit
6
• Simpler, source-specific
application
• Specific list of operations
• Qualifying criteria
• Generalized requirements
• Grouped sources
• Quicker processing time
• Requirements available
for review online
• Same fee as site-specific
permit
• Title V / state minor only
• No NSR general permits
Site-Specific Permit
• More complex,
generalized application
• Any air pollution source
• No qualifying criteria
• Specific requirements
• Specific sources
• Slower processing time
• Permit writer may allow
review of draft permit
• Same fee as general
permit
• Any permit type
7. Whichisbetterforyou?
7
General Permit (Quick)
• Need the permit quickly
• Satisfy qualifying criteria
• Facility-wide air emissions are unimportant
◦ No Title V or New Source Review (NSR), or concerns
◦ Simple NESHAP requirements
Site-Specific Permit (Flexible)
• Permit processing time unimportant
• Do not satisfy general permit qualifying criteria
• Facility-wide air emissions are important
◦ Synthetic minor restrictions
◦ Title V, NSR, or NESHAP facilities
8. Choosing Both
Changing a general permit to a site-specific permit
• Good option for facility expansions or modifications
• Quick initial permit to begin onsite operations sooner
• Original general permit requirements incorporated into a
new site-specific permit
◦ Cannot change (relax) general permit requirements
• Can be more expensive
◦ Cost for two permit applications and permit fees
◦ Cost the same if modification or expansion
Changing from a site-specific permit to a general permit
• Allowed only if the source is being modified or expanded
• Cannot be used if general permit is less restrictive
8