The document outlines the Ohio EPA's air pollution control program, detailing its structure, compliance strategies, permit processes, and the challenges it faces, particularly regarding new ozone standards and the Clean Power Plan. It emphasizes the agency's commitment to efficiency, consistency, and transparency while providing various online services to facilitate compliance for businesses. Additionally, it highlights successes in the oil and gas sector, including swift permit issuances, and the agency's proactive stance in addressing emerging air quality issues.

1. Ohio EPA, Air Pollution Control
Updates

2. Topics
 Permit and Compliance Improvements – What does
this mean for you?
 Compliance Strategies for Business – Making things
easy
 Emerging Air issues including Ozone, Clean Power
Plan, etc.

3. Ohio EPA’s
Air Pollution Control Program
 5 Regional (District) Offices; 9 Local Air Agencies;
Central Office; Field Office
 180 Employees across the state plus Local Air Agencies
 +72,000 sources at over 14,000 regulated facilities
 2,000 Air permits issued annually
 +290 Ambient air monitors
 We are efficient and lean!

4. Ohio Air Pollution Control Offices

5. Ohio EPA’s
Air Pollution Control Program
• District Offices
• Permits, Inspections,
• Communication, problem solving
• Central Office
• State Implementation Planning
• Permit review and issuance
• Modeling
• Legal and Policy Issues

6. What drives us?
• Consistency - statewide
• Efficiency - permit and compliance programs to
facilitate compliance of regulated community
• Prioritization – recognizing top priorities and
focusing our efforts accordingly

7. Permit Process: Making it Easy
• Online application preparation and tracking
• Pre-application meeting to begin process
• Periodic status calls and/or meetings with
specialists
• Review of permit before issuance– No surprises!
• Changes happen – we adapt quickly!

8. Permit Process: What to Expect
• Recommend early pre-meeting
• Review of application within 14 days
• Deadline driven
• Highly experienced with PSD & Synthetic Minor
permits
• 85% of new permits written within 90 days in
past 2 yrs

9. Success Story: Oil/Gas Expansion
 Worked closely with Oil and Gas industry
 Held multiple conference calls with interested parties
 Conducted webinars
 Guidance:
 General Permit developed for well sites
 General Permit developed for compressor stations
 Developed multiple guidance documents
 Information packets and guidance docs to industry

10. Success Story: Oil/Gas Expansion
 Since development began, we have issued:
 500+ permits for well-site installations
(average issuance – 15 days)
 280 permits for mid-stream
(compressor stations, gas clean-up)
 40 permits for gas processing for oil/gas expansion
(separation, fractionation, stabilization facilities)
 Still expanding!

11. Available Online Services
 eBusiness Center
 Air Services
 Electronic Payments
 Other Division Applications
 Customer Support Center
 Permit Wizard
 FAQ
 Training

12. What can you do in Air Services?
Create & Submit
 Permit Applications
 Emissions Reports
 Permit Related Reporting
 Compliance
 Emissions Tests
 CEM/CERMS/COMS
 Facility Data Updates
 Portable Source Relocation
View History & Maintain Data
 Permit tracking
 View submission history
 View correspondence

13. Designed for Ease of Use
 Designed to avoid duplicate data entry
 Access to facility application and reporting history
 Access to Word version of current permits
 Ability to copy from previous reports or applications
within facility

14. Compliance and Enforcement
 Our Goal is Compliance
 We strive to be fair, equitable, transparent and timely.
 Inspector Rotation
 Discuss findings of inspections during the visit.
 Minimize surprises and opportunity to address issues
quickly. (many times before we leave)
 Memorialize how problems should be addressed
across the state. (via internal improvements)

15. Practical Advise
 Preparing staff for inspections
 Obvious stuff (permits, monitoring, recordkeeping,
reports, testing, etc.)
 Inspections: Ask about inspector’s operational
knowledge and tailor conversation. Walk the plant
process start to finish
 Big Bang Theory vs CSI vs Colombo
 Human element
 Build trust and a relationship
 Honesty, integrity, no double-speak, clearly answer
questions and find information quickly.

16. Current Challenges
 Federal Activity
 Ozone
 NAAQS
 Startup Shutdown Malfunction SIP Call
 Interstate Transport
 Clean Power Plan
 Doing More with Less…

18.  Photo of Republic Steel, Cleveland from
Cleveland State University, Dept. of History,
Teaching and Learning Cleveland

19. Ohio’s Attainment Challenges
 The entire state is attainment for nitrogen dioxide,
and carbon monoxide.
 Isolated nonattainment areas for SO2, lead and PM
2.5
 New Ozone Standard

23.  U.S. EPA adopted ozone standard in 2008 – 0.075
ppm eight-hour average
 Cincinnati, Cleveland, Columbus designated
nonattainment
 Attainment date - 2014 – Cincinnati and Columbus met
standard – Ohio EPA requested/one year extension for
Cleveland – met standard in 2015
Ozone NAAQS

25. 0
10
20
30
40
50
60
70
80
90
100
110
120
1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013
ppb
Ohio Average
One Year 8-Hour Averages
Average LLS-30 LLS-20

26.  U.S. EPA proposed a range from 0.065 ppm – 0.070
ppm
 Ohio EPA filed comments – data supports keeping
standard 0.075 ppm
 On October 1, 2015, U.S. EPA adopted a standard
of 0.070 ppm for both primary and secondary
standard
U.S. EPA Revised Ozone Standard

27. October 1, 2015 U.S. adopts new standards
October 1, 2016 States submit recommendations
for nonattainment areas
October 1, 2017 U.S. EPA finalizes nonattainment
October 1, 2019 Infrastructure SIPs due
October 1, 2020 Attainment date for marginal
nonattainment areas (expect all Ohio
areas to be marginal)
Timeline for Completion – Revised
Ozone Standard (cont’d)

28. Clean Power Plan aka 111(d)
 Carbon emissions from existing coal and natural gas fired
electricity generators
 U.S. EPA proposes plan that requires 32% reduction in
emissions of CO2
 111(d) is a stationary source rule
 Coal based control technology not practical
 Parasitic load penalty alone of almost 30%
 Only way to reduce emissions is to reduce coal usage
 Energy Sector rule
 More renewable energy sources
 Maximize existing natural gas plants

29. Interi
m
Step 3
Interim
Step 2
Interim
Step 1
2030
Goal
CPPFinalRule
InitialStateSubmission
FinalPlanSubmission
Clean
Energy
Incentive
Program
2-year
delay
Clean Power Plan Timeline

30. Key Questions and Challenges
 How to analyze Compliance Pathways efficiently?
 Mass vs Rate?
 Trade-Ready plan?
 How do we minimize CPP impact on electricity costs
to end users?
 How do we assure continued reliable service to the
state?
 How do we minimize the unpredictability in the
marketplace and provide certainty for future
investment and development?

31.  Legal Challenges
 Methodical analysis
 Collaborate very closely with Ohio Public Utilities
Commission
 Not an Island (awareness of other states)
 Extension request due Sept 2016
 Outreach and Engagement Plan
 Remain mindful of challenges and not rush to
any decisions.
Ohio’s CPP next steps

32.  Questions or concerns?
Adam Ward
Assistant Chief
Ohio Environmental Protection Agency
Division of Air Pollution Control
w 614.728.3784
c 614.546.9163
adam.ward@epa.ohio.gov