Attachment 1 

Ohio Air Monitoring Network 2007-2008 
Ohio Air Monitoring Network 207-2008 

As required by 40 CFR 58.10 Ohio EPA is providing an annual monitoring network plan for public review and comments. After a 30 

day comment period Ohio EPA will submit this plan with comments to the US EPA Region V Regional Administrator. The Ohio Air 

Monitoring Network as it exists as of August 15,2007 is included in the accompanying table. 

The plan for Ohio's Air Monitoring Network for 2007-2008 is to make relatively few changes to the air monitoring network overall. 

There will be a few site/instrument reductions for sulfur dioxide, carbon monoxide, nitrogen dioxide and fine particulate matter or 

PM 10. These changes were determined as prudent to make because of historical data that shows certain sites and areas have been in 

compliance with and lower than the National Ambient Air Quality standards for several years. 

For the portion of the network that measures very fine particulate matter or PM2.5, Ohio EPA expects to continue with rnoni toring or 

sampling at the existing PM2.5 Federal Reference Methd sites much as they existed at the beginning of 2007. For the monitors that 

measure ozone concentrations those instruments and sites will also remain most1 y unchanged. 

Slight changes to the network wcur each year that are unplanned. There are changes that occur because of events such as building or 

roof maintenance, construction, change of ownership of the site or other changes at the site that require moving the instruments. Some 

changes that are planned my include adding additional sites for special studies or for areas of complaints for some new or proposed 

facility. 

The Federal requirements for monitoring for sulfur dioxide, nitrogen dioxide and carbon monoxide air pollutants were changed in late 

2006 to no longer quire minimum numbers of monitors for those parameters. The National Ambient Air Quality Standards or 

NAAQS still exist for those parameters and Ohio will still maintain sites and monitors for those air pollutants. There will be some 

reductions in numbers of sites and monitors for those pollutants but a monitoring effort will still be maintained. 

All site and parameter changes are made in consultation with and approval of the US EPA Regional air monitoring staff. 

Ohio EPA follows the Federal general guidance for air monitoring that is to monitor in areas of 1) expected high concentrations, 2) 

areas of high population density, 3) areas with significant sources 4) general background concentration sites and 5) areas of regional 

transport of a pollutant. Not all air pollutants or areas of the state may have sites for all of these categories. 
An important consideration of all air monitoring projects and sites is that funding resources be available to operate and maintain the 

sites and equipment, provide for sample analysis, data collection and reporting. 

As of the time of publication of this list Ohio EPA plans to discontinue monitoring at locations as shown in the table at: 

4 sulfur dioxide sites 

1 carbon monoxide site 

1 nitrogen dioxide site 

6 fine particulate matter or PMlO sites 

2 very fine particulate matter or PM2.5 sites 

1 ozone site 

5 TSP for metals or lead sites 

Ohio EPA plans to move sites and instruments for: 

3 PM2.5 sites 

2 PM2.5 chemical speciation sites 

1 PMlO site 

1 TSP-metals site 

Ohio EPA plans to add sites for: 

1 combined PM2.5, ozone, sulfur dioxide and TSP-metals site 

1 continuous PMlO site 

1 continuous PM2.5 site with FRM 

All of the plans are subject to approval by US EPA. 
For questions about the Ohio Air Monitonng Network please contact: 

Gary Engler at 6 14-644-3623 or Randy Hock at 6 14-644-36 19. 

Comments about the Ohio Air Monitoring Network may be emailed to: 

Fax number 614-644-3681 

Address: 

Ohio EPA 

Air Monitoring Section 

Division of Air Pollution Control 

50 West Town St. 

Columbus, OH 43215 
Ohio Air Monitoring Network - 2007-2008 

dway, Akr monoxide 

ioxide . 

red 

ed Fluores . . 
I U.V. Photometric I Continuous I Highest conc. I Urbm 





- 

39-083-0002 

39689-0005 

40.309722 

40.025833 

Not in a MSA 

Knox Co. 

Fire Station , Centerburg 

Columbus MSA 

Licking Co. -- Heath School, Heah 

Columbus MSA 

Madison Co. 

-82.69 1944 

-82.432778 

ZZ%%FMadisonSchool,randofiypOzoneOzone 

Ozone 

- 

U.V. Photometric 

U.V. Phtometric 

U.V. Photometric 

Conti'nuous 

Continuous 

Continuous 

Populs~m - 

- - 

Population 

Population 

Urban 

Urban 

Urban 

- - 
Wheeling WV-OH MSA 

;eq. FRM 

rEOM 
Meigs Co. 

39- 105-0005 Veterans Hospital, Pomeroy 39.037778 -82.045556 Sulfur dioxide Pulsed Fluorescence Contin~cn~ls Population -- Urban - 

39-1 15-000Q 

Not in a MSA 

Morgan Co. 

St. Rt. 83, Hackney Schml 

Not in a MSA 

Tuscarawas Co. 

39.63422 1 -81.670038 Sulfur dioxid ~ulsed~~.~orescence Continuous ~ourGnen led Urban 
AQS is the Air Quality System maintained by US EPA for air quality data. In the AQS ID# the first 2 digits refer to the state. 39 is Ohio. The next 3 

digits are the county within Ohio. The last 4 digits designate a specific sire within the county. 

All PM2.5 Seq. FRM sites are comparable to the PM2.5 NAAQS. 

All Ozone sites are comparable to the NAAQS. 

All sulfur dioxide, carbon monoxide and nitrogen dioxide sites are comparable to the NAAQS. 

PM is Particulate Matter. PMlO means particulate matter of 10 microns in diameter or smaller. A micron is one millionth of a meter. 

Ph42.5 is particulate matter 2.5 millionths of a meter in diameter or smaller. PMlO is fine particulate matter and PM2.5 is very fine particulate matter. 

MSG indicates a Metropolitan Statistical Area. 

Monitoring instruments used for comparing to the National Ambient Air Quality Standards are designated as Federal Reference Methcds (F;RM) or 

Equivalent Methods. 

PM2.5 Seq. FRM are samplers that sample for PM2.5 can hold multiple samples for Seauentia1 sampling and are Federal Reference Methods m). 

Colocated or colo indicates a site with duplicate samplers for Quality Assurance purposes. Data is statistically compared from the two samplers for the 

same days. Duplicate samplers may sample at a T in 6 day schedule m even a 1 in 12 day schedule. 

Chem. Speciation sites are sites and samplers that collect PM2.5 samples that are analyzed for the chemical speciation make-up of the PM2.5 particulate 

matter. 

U.V. Photometric indicates ultra-violet photometric, a method of detection for ozone concentrations. 

U.V. fluorescence indicates ultm-violet fluorescence, a method of detection for sulfur dioxide concentrations. 

VOCs are Volatile Organic Compounds. The methd of collecting and analyzing whole air samples for VOCs is in Ohio is TO-14a. The collection 

utilizes a stainless steel canister for subsequent analysis by gas chromatograph -mass spectrometer. There are approximately 72 compounds scanned for 

in the analysis. 
TSP - metals is the method of collecting Total Suspended Earticulate by drawing an air sample through a filter media that is then analyzed at a laboratory 

for airborne metals including lead. arsenic. cadmium. chromium, nickel, zinc, manganese and beryllium and sometimes particulate mercury. Analysis is 

by ICP or Xnductivel y Coupled Plasma Emission Spectroscopy or Graphic Furnace Atomic Absorption. 

BAM indicates a Beta Attenuation Monitor, a mthod of detection for fine particulates. 

TEOM indicates a Tapered Element Oscillating Microbalance, a method of detection for fine particulates. 

SIP is State Implementation Plan that details how the state will implement controls that will bring the area into attainment status for a particular National 

Ambient Air Quality Standard. Chemical speciation sampling and analysis for PM2.5 aids helps to determine what control measures and plans will best 

control fine particulates. 

Ohio Air Monitoring Agencies 

The following list of organizations perform ambient air quality sampling in Ohio within specific areas of ihe state: 

Akron Regional Air Quality Management District 

146 South High St. 

Akron, Ohio 44308 

(330) 375-2480 

Mdna, Portage, Summit counties 

-- - -- 

Air PolIution Controf bvision 

Canton City Health Department 

420 Market Ave. North 

Canton, Ohio 44702-1544 

(330) 489-3385 

Stark County 

City of Toledo 

Division of Environmental Services 

348 South Erie St. 

Toledo, Ohio 43604 

(419) 936-30 15 

Lucas County 

Mahoning-Trumbul l APC Agency 

345 Oak Hill Ave. 

Youngstown, Ohio 44502 

(330) 743-3333 

Mahoning, Trumbull counties 

- - 
- Department of Environmental Services Ohio EPA 

Air Quality Programs Central District Office 

250 William Howard Taft Rd. 50 West Town St. 

Cincinnati, Ohio 452 19-2660 Columbus, Ohio 43604 

(51 3) 946-7777 (614) 728-3778 

Hamilton, Butler, Warren, Clermont counties 

Department of Public Health & Welfare Ohio EPA 

Division of the Environment Southeast District Office 

1925 St. Clair Ave. 2195 Front St. 

Cleveland, Ohio 441 14 Logan, Ohio 43138 

(216) 664-2324 (740) 385-8501 

- Cuyahoga County 

Regional Air Pollution Control Agency Ohio EPA 

Montgomery County Health Department Northeast District Office 

117 South Main St. 21 10 Aurora Rd. 

P.O. Box 972 Twinsburg, Ohio 44087 

Dayton, Ohio 45422-1280 (330) 425-9171 

(937) 225-4435 

Lake County Health Depament 

Air Pollution Control 

33 Mi11 St. 

Painesvile, Ohio 44077 

(440) 350-2543 

Lake, Geauga counties 

Air Pollution Unit 

Portsmouth City Health Department 

605 Washington Smt 

Portsmouth, Ohio 45662 

(740) 353-5156 

Brown, Adams, Scioto, Lawrence counties 

Ohio EPA 

Northwest District Office 

347 North Dunbridge Rd. 

Bowling Green, Ohio 43402 

(419) 352-8461 

Ohio EPA 

Southwest District Office 

401 East fifth St. 

Dayton, Ohio 45402-29 1 1 

(937) 285-6357 
Ozone 2008 
Carbon Monoxide 2008 
Nitrogen Dioxide 2008 
Lead Sites 2008 
Sulfur Dioxide 2008 
PM-10 Sites 2008 
PM-2.5 2008 Federal Reference Method 
PM-2.5 2007 Continuous Sites 
PM-2.5 2008 Speciation 


Highlights from 2006 

Objectives for 2006, and the Status of 

Compliance with Each 

Summary of Environmental Improvements 

Summaries of Statistics: 

Part I: Overall Program Statistics 

Part II: Field Office Statistics Part Ill: AGO Statistics 

Part IV: Penalty Statistics 
96.7% compliance rate at the end of the year for 1610 High Priority Facilities 

(i.e., Title V, FESOP, and synthetic minor PTI facilities) (an HPF is 

considered to be in compliance if there are no emission violations) 

1 10 cases resolved (including 2 TRI and 2 1 12(r) cases) 

40 cases resolved with Findings and Orders (unilateral F&Os were issued 

for one case [i.e., Lanxess Corporation], but they did not completely 

resolve the case) 

50 referrals to the Attorney General's Office (record high number of 

( - referrals) 

19 cases resolved by the Attorney General's Office (including 9 Consent 

Orders) 

107 new cases 

79 cases pending at the end of the year within the DAPC Enforcement 

Committee (lowest number of pending cases since 1989) 

93 cases pending at the end of the year at the Attorney General's Office 

(record high number of cases pending) 
$ 634,230 USEPA 

The total &r civil penalties assessed in Ohio since 1984 equal $94,981,273. 

The following total emission reductions resulted (or will result) from the 

enforcement cases resolved through F&Os and Consent Orders: CO - 2.7 TPY; 

particulates - 11 3 TPY; VOCIOC - 160 TPY; NOx - 41 9 TPY; and SO2 - 8,332 

TPY. 

The following major enforcement cases were resolved by the Ohio EPA or the 

Ohio EPNAGO with large civil penalties, i.e., equal to or greater than $100,000: 

Advanced Organics, Inc.1Kalmbach Ingredients, Inc. $ 

Cargill Incorporated $ Kokosing Materials, Inc. $ National Lime & Stone Company, Bucyrus Plant $ 

National Lime & Stone Company, Carey Plant $ 

Cognis CorporationICognis Oleochemicals, LLC $ Clymer Acquisition, Inc. $ 

The Timken Company $ 
1. Resolve 90 or more EC cases during CY 2006, and of the 90, use F&Os to 

resolve 50 or more of the cases. 

110 cases were resolved during the CY, and 40 of those cases were 

resolved with F&Os. 

2. By 12/31, reduce the backlog of EC cases such that there are no cases 

(including verified complaints) that have been on the docket for over 21 

months (from the date the Enforcement Action Request is received by the 

Central Office). 

At the beginning of CY 2006, there were 48 cases on the EC docket that 

had to be resolved to meet this goal. At the end of CY 2006,2 cases 

remained on the EC docket that were older than 21 months. 

3. Develop each new case received during the CY in a timely manner. 

("Develop" = prepare a DWL, draft F&Os, or a referral to the AGO.) 

This is an ongoing effort of the DAPC. 

4. Maintain an overall compliance percentage for High Priority Facilities of 95% 

or greater, considering only emission violation enforcement cases. 

The compliance percentage at the end of the year was 96.7%. 

5. For each enforcement case resolved with F&Os or a Consent Order, 

calculate, if possible, the environmental improvement associated with each settlement. 

This was calculated for each of the cases resolved during the CY where 

there was an environmental improvement. 
12/31/09; and a SCR 

and wet gas scrubber will 

be installed at the fluid 

catalytic cracking unit by 

12/31/09. (The estimated 

emission reductions are expected to occur by 

12/31/09 with the abovementioned new control 

equipment and after a 

planned increase in refinery production.) 

OSI Sealants, Inc. 04/27/06 

3M Medina 1 1/28/06 

CleanHarbors 1211 4106 

PPM, LLC 

F&Os VOC 0.035 TPY Implemented better 

tracking of production 

and emissions from batch mixers. 

F&Os VOC 7.9 TPY Discontinued use of 

catalytic incinerator serving emissions unit 

KOOl and vented VOC 

emissions to existing regenerative thermal 

oxidizer serving KO05 

(continuous paper or film 

web coating line). 

Overall VOC emission 

control efficiency for 

KOOl increased from 

73.2% to 87.7%. 

F&Os VOC 22.4 TPY Rebuilt the carbon 

adsorption unit serving emissions units L004, 

L005, L006, and P003, 

reducing VOC emissions by 17.0 tons per year. 

Also, 5.4 tons per year of 

VOC emissions were 

eliminated from the 

operation of emissions 

unit LOO1 through 

quarterly monitoring of 

VOC emissions and 

shutting down the unit for 

the remainder of the year 

when its annual cap is 

reached. ' 

Page - 1 - 
Cognis 12/29/06 Corporation1 

Cognis 

Oleochemicals, LLC 

reconfigured by installing 

a new conveyor system 

from the primary crusher 

in the quarry pit through 

an underground culvert under County Road 16 to 

a surge pile at the 

processing plant. Wet suppression of fugitive dust will be used as 

needed. (This project is 

a Supplemental 

Environmental Project.) 

VOC 128.5 TPY Replacement of 

catalyst and ceramic 

filters in both catalytic 

oxidizers serving 

emissions units POI0 and 

PO17 (ozonolysis 

processes I and 11), 

cleaning of partially clogged filters and catalyst, capping of scrubber vents to 

eliminate leaks while 

inactive, repair of preheater block, and 

operation of each 

scrubber and catalytic 

oxidizer in series. 

PE 57.7 TPY For emissions units B027 

and 6028, replacement 

of all bags in the 

baghouse with new, heavier duty bags and 

replacement of a leaking 

bypass valve. 

Page - 2 - 
The program resulted in the following emissions reductions in 2006: 

PM 535.4 Ibs 

CO 5,451.0 Ibs 

HC (VOC) 2.852.9 Ibs 

Total 8,839.3 Ibs = 4.42 TPY 

SUMMARY TABLE: ENVIRONMENTAL IMPROVEMENTS RESULTING 

FROM AIR ENFORCEMENT SETTLEMENTS DURING 2006 

POLLUTANT TOTAL REDUCTIONS* 

Particulates 113 TPY 

VOC 160 TPY 

419 TPY 

8,332 TPY 

CO 2.7 TPY 

TOTAL 9,027 TPY *rounded numbers 

Page - 3 - 
Summaries of Statistics 
Part I: Overall Program Statistics 
CALENDARYEAR 

NUMBER OF CASES REFERRED TO THE AGO 

DURING 1997 THRU 2006 

1998 2000 2002 2004 2006 

CALENDARYEAR 
CALENDAR YEAR 

SUMMARY OF CASES RESOLVED 

DURING 1997 THRU 2006 

CALENDAR YEAR 
CALENDAR YEAR 

NUMBER OF CASES PENDING 

AT THE END OF 1997 THRU 2006 

2000 2002 2004 2006 

CALENDARYEAR 
Compliance & Enforcement Tracking Application 

Compliance Status of Ohio's High Priority Facilities as of December 31,2006 

Totals 1610 53 7 1 3.3% 4.4% 96.7% 92.3% 

01 

02 

03 

04 

05 

06 

07 

08 

13 

14 

15 

16 

* To count the number of active HPF enforcement actions for DAPC, the following parameters must be met: 

1. Facility is an HPF facility 

2. Facility is not Shut Down 

3. The enforcement ID includes at least 1 formal action 

4. The enforcement ID does not include any of the following actions: 

05 (Final Compliance Without Enforcement) EW (Withdrawal of Enforcement Action) 66 (State Findings and Orders) 

05 (Final Compliance After Enforcement) DY (Change Lead to USEPA) 68 (Local Findings and Orders) 

X2 (State Court Order Filed) 

Dlstrict ORce Local Air Authority (DOILAA) 

Ohio EPA (Central District Office) 

Ohio EPA (Northeast District Office) 

Ohio EPA (Northwest District Ofnce) 

Toledo Environmental Control 

Ohio EPA (Southwest District Office) 

Ohlo EPA (Southeast District Offlce) 

PortsmouUl City Health Department 

Regional Air Pollution Control Agency 

Cleveland Local Air Agency 

Hamilton County Dept of Environmental Servlce 

Canton City Health Department 

Akron Regional Air Quality Management District 

Total "Imber Of 

HPFs 

163 

232 

285 

58 

43 

185 

20 

117 

124 

222 

81 

100 

Total number of 

HPFs 

E~nisslons 

Violations 

1 

8 

15 

2 

0 

8 

0 

2 

4 

10 

1 

2 

Total number of 

HPFs with 

Ad~ninistralive 

Violatlons Only 

2 

7 

12 

2 

2 

32 

1 

1 

5 

4 

1 

2 

Percentage of 

I-IPFs with 

Emissions 

Violations 

0.6 

3.4 

5.3 

3.4 

0 

4.3 

0 

1.7 

3.2 

4.5 

1.6 

2.0 

Percentage of 

HPFs with 

Admlnislralive 

Violations Only 

1.2 

3.0 

4.2 

3.4 

4.7 

17.3 

5.0 

0.9 

4.0 

1.8 

1.6 

2.0 

Overall 

Compliance 

Percentage lor 

all HPFs with 

tnissions 

Violations Only 

99.4 

96.6 

94.7 

96.6 

100.0 

95.7 

100.0 

98.3 

96.8 

95.5 

98.4 

98.0 

overail 

Pe'"e'ltage 'Or 

all HPFs 

Violatior's 

98.2 

93.6 

90.5 

93.2 

95.3 

78.4 

95.0 

97.4 

92.8 

93.7 

96.8 

96.0 
Part II: Field Office Statistics 

(The following two graphs do not include the partial-role local air agencies, viz., the 

Lake County General Health District and the Mahoning-Trumbull Air Pollution 

Control Agency. 

During 2004,2005, and 2006, the Lake County General Health District was involved 

in the resolution of 3,4, and 0 enforcement cases, respectively. 

During 2004,2005, and 2006, the Mahoning-Trumbull Air Pollution Control Agency 

was involved in the resolution of 6, 7, and 9 enforcement cases, respectively.) 
PORTS 1 

L p 8NwD0 SEDO F J ELEVE L 

HAMCO 3 

AKRON 

CAN 0 

I3 

NUMBER OF CASES 

SUMMARY OF TOTAL CASES RESOLVED BY 

FIELD OFFICE FOR 2004,2005, AND 2006 

CAN HAMCO SEDO RAPCA CDO TDPC 

FIELD OFFICE 
Part Ill: AGO Statistics 
AIR ENFORCEMENT CASES RESOLVED BY 

THE OEPAIAGO DURING 1997 THRU 2006 

V1 

19 

5 

P! W rn 

5 z 

1 I I I 

1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 

CALENDAR YEAR 
Part IV: Penalty Statistics 
CALENDAR Y 

TOTAL ClVlL PENALTIE! rSSESSED BY THE 

OHlO EPA DURING 1997 THRU 2006 
YEAR 

TOTAL VIL PENALTIES ASSESSED BY THE 

OHlO EPAlAGO DURING 1997 THRU 2006 

=. 

e 2.12 2.01 3- 

1.56 3 

W a =! ' 2 

0. 

1997 1998 1999 2000 2001 2002 2003 2004 2005 ' 2( 

CALENDAR YEAR 
CALENDARYEAR 

TOTAL CIVIL . 'ENALTIES ASSESSED IN - - 

DURING 1997 THRU 2006 
ASSESSED 

RUNNING 

IN 

TOTALS 

OHIO DURING 

OF CIVIL 

1997 

PENALTIES 

THRU 

7 

2006 I 

p

y

g 

, 

p

implementing the Ohio Right-to-Know Program, in which we are partners with the 

State Emergency Response Commission (SERC), the Local Emergency Planning 

Agencies (LEPCs) and the Ohio Emergency Management Agencies (OEMA). 

This budget request includes funding level of $54,168,744 in FY2008 and 

$54,675,923 in FY2009 for Ohio EPA, the LAAs, OEMA and the LEPCs. The 

following table represents the total amount of funding requested by DAPC. 

Fund 

678 (TRI) 

5BY (Mobile Sources) 

602 (Mobile Sources) 

4T3 (Title V) 

542 (1 1 2(r)) 

4K2 (Asbestos, PTI, non-Title V, FESOP fees) 

592 (Anti-tampering) 

696 (Penalty) 679 (SERC) 357 (Grant) 

DAPC 5BC 

LAA 5BC 

Total Continuation Funding 

Expansion Funding 4T3 Expansion Funding 5BY Expansion Funding 4K2 

Total Expansion Funding Total Funding Requested 

FY2008 Requested 

funding level 

$210,622 

$14,620,241 

$250,000 

$1 6,872,927 

$146,188 

$3,178,062 

$9,707 

$750,000 

$2,628,647 $6,823,949 $4,493,675 $1,731,984 

$51,716,002.00 

$1,743,118 

$196,865 

$512,759 

$2,452,742.00 

$54,168,744.00 

FY2009 Requested 

funding level 

$21 0,622 

$14,620,241 

$250,000 

$1 6,854,174 

$146,188 

$3,178,062 

$9,707 

$750,000 

$2,628,647 $6,823,949 $4,493,675 

$1,731,984 

$51,697,249.00 

$1,652,604 

$437,574 $888,496 

$2,978,674.00 

$54,675,923.00 
p

main focus of the air program. The success of the program will be whether 

the air in every Ohio county meets the safe levels established by U.S. EPA. To meet this goal, DAPC creates plans to implement the requirements of the 

Clean Air Act and other programs adopted by U.S. EPA, which limit 

emissions of air pollution, and operates an air quality monitoring network that 

provides DAPC with the information to determine whether the NAAQS are 

being achieved and whether public health and welfare is being protected. 

Air Toxics - Air toxic compounds are emissions that cause a public health 

concern because these chemicals have the potential to cause cancer or 

other detrimental health impacts. In the 1990 Clean Air Act Amendments, an 

increased emphasis was placed on air toxics, the evaluation of risk and 

additional control requirements to reduce risk. Over the past few years, we 

have seen increase requests to evaluate possible effects of air toxics. DAPC 

continues to maintain a program to monitor air toxics in our cities, as well as 

respond to special requests for localized air toxic studies. Other DAPC 

programs that assist with air toxic control include the Toxic Release Inventory 

Program and the Risk Management Planning Program. 

Air Emission Authorization and Evaluation - DAPC regulates more than 

75,000 individual sources of air pollution at 13,000 facilities. DAPC strives 

to provide for the processing of all permit actions on a timely basis. Because 

facilities must obtain a Permit-to-Install (PTI) prior to installing a new source 

of air pollution, DAPC continually strives to improve the timeliness of the PTI 

permitting program. Facilities with smaller sources of air pollution are 

covered by the state Permit-to-Operate (PTO) program. Facilities with sources that have the potential to be classified as a major source of air 

pollution, but accept additional restrictions that limit their emissions, are 

subject to the Federally Enforceable State Operating permit (FESOP) 

program. Approximately 700 facilities are required to obtain Title V permits. 

Facilities with major sources of air pollution are subject to Title V permitting, 

which is a federally mandated permit program created under Title V of the 

Clean Air Act Amendments of 1990. Finally, DAPC is planning to implement 
y 

Due to the industrialized nature of Ohio, there is a significant resource 

burden associated with this activity. DAPC also strives to operate a fair and 

efficient enforcement program to resolve violations when they are identified. 

DAPC has developed goals for the timely evaluation and resolution of 

violations of air pollution control rules. 

Mobile Sources Control - DAPC oversees the contractor-operated emissions 

inspection program, known as E-Check, for vehicles in the ClevelandIAkron, 

area. The goal of the program is to encourage motorists to routinely maintain 

the emission control equipment on their vehicles, thereby reducing the 

release of pollutants that lead to the formation of ozone. This contract for the 

E-Check program expires December 31,2007. Right-to-Know - DAPC administers the Right-to-Know Program or Chemical 

Inventory Reporting Program under which facilities file reports summarizing 

the locations and quantities of hazardous chemicals stored on-site. These 

reports are used for emergency planning activities, which Ohio EPA 

coordinates with OEMA, the SERC and 87 LEPCs. 

CURRENT SITUATION Ohio EPA has developed a strategic plan for the operation of DAPC in the future. 

The strategic planning process creates goals to ensure the long-term success of the 

program. The goals include healthy air, timely issuance of permits, increased 

compliance, and enhanced services provided to all customers of DAPC. The 

following summarizes these goals and the progress toward achieving them in the 

current biennium. 

Attaininq the NAAQS 

DAPC's goal is to attain and maintain the existing national air quality standards in all 

of Ohio's counties. One strategy to achieve this goal is maintain the attainment standard of Ohio's counties with the NAAQS with the standards which were 

implemented prior to 2004, and to continue to implement the control programs 
Air Monitorinq 

DAPC's goal is to operate a comprehensive air quality monitoring network that (a) 

provides timely monitoring data, (b) ensures that 100% of the monitors meet the 

U.S. EPA standards for data capture and accuracy, and (c) verifies data when 

violations are measured and assesses whether the readings were accurate. DAPC 

currently operates one of the most extensive monitoring systems in the country. 

DAPC is currently operating one of the country's most extensive air pollution monitoring networks comprised of 245 ambient air monitors, including 49 ozone 

monitors. 

Air Toxics The Clean Air Act Amendments of 1990 placed an increased emphasis on riskbased regulations. DAPC has witnessed an increased emphasis on toxics and the 

characterization of risk. DAPC must develop improved air toxics information 

(monitoring network and inventory) to support quantitative evaluation, 

characterization and tracking risk-based indicators and implement programs to 

lower air toxics. DAPC conducts toxics monitoring, and also participates U.S. 

EPA's homeland security initiative to monitor for the use of biological weapons 

throughout Ohio. 

Compliance/Enforcement 

DAPC operates a comprehensive compliance-monitoring program, which consists 

of site visits, and technical reviews of compliance records submitted by permitting 

facilities. DAPC strives to implement a compliance program that effectively 

evaluates the regulated community's compliance with the regulations that were 

adopted to protect air quality. At least 95% of the high priority facilities are to be in 

substantial compliance. The current compliance rate is approximately 97%. In addition, DAPC strives to operate an efficient enforcement program to resolve 

violations within two years. By the end of 2005, we resolved 110 enforcement 

cases, 65 of which were resolved through the use of Findings & Orders, and 

assessed $1,220,194 in civil penalties during the CY. [These numbers do not 

include settlements at the Attorney General's Office.] 
Title V permits within the time frame approved by U.S. EPA, and (b) issuing all 

Permits-to-Install as expeditiously as possible. The division issued more than 95% 

of the PTls within the statutory 180-day time line. During 2005, over 55% of the 

PTls were issued within 45 days. During 2005, almost 70% of the PTls were issued 

within 60 days. 

E-Check 

It is DAPC's goal to operate the E-Check program in a manner that provides an 

accurate test by achieving a 95% passing rate for equipment calibration verification and provides a high quality (90%) of customer service, including short wait times, 

courteous staff at test stations, customer hotlines, as determined by customer survey cards or independent surveys. 

Technical Assistance/Outreach 

DAPC strives to continually improve DAPC's information technology by improving public access to DAPC technical resources, including regulations, technical 

guidance and environmental data. 

DAPC CHALLENGES 

Ozone and Fine Particulate State Implementation Plan (SIP! Development and 

Implementation In June 2004, U.S. EPA's designation of non-attainment counties for the 8-hour 

ozone standard became effective. The implementation of the new ozone standard and the associated non-attainment designations significantly increased DAPC's 

workload, as U.S. EPA designated 33 of Ohio's counties, including every major 

urban area in the state, as non-attainment. In addition, in April 2005, U.S. EPA 

finalized the nonattainment designations for the fine particulate or PM2.5 standard. 

Thirty-one counties in Ohio were designated nonattainment. Once the 

designations were finalized by U.S. EPA, Ohio EPA was required to develop, adopt, and implement the needed emissions reduction regulations for both stationary and 

mobile sources as needed to improve air quality to meet the standards within three 

years from the effective date of the designations. The implementation of the new 
Twenty-seven counties in Ohio remain designated nonattainment for PM2.5. (Thirtyone counties were originally designated as non-attainment for PM2.5, and U.S. EPA 

dropped four counties because monitoring data demonstrated that the counties 

attained the standard.) The attainment demonstrations and State lmplementation 

Plans (SIPS) are due in April 2008 (PM2.5) and June 2007 (ozone). In addition, 

U.S. EPA is likely to adopt more stringent standards for both ozone and fine 

particulates. The establishment of new standards will result in new non-attainment 

areas and additional work for Ohio EPA, as new attainment demonstrations and 

SIPS will be required. 

Implementation of other Federal Proqram 

Regional Haze - Ohio EPA continues its development of a program to address 

regional haze, as required by U.S. EPA. Haze is caused when sunlight encounters 

small pollution particles in the air. Under the 1999 regional haze rule, states are 

required to set periodic goals for improving visibility in the 156 federal Class I areas 

in the country, and develop implementation plans to reduce emissions from large 

sources that are contributing to haze in national parks. These plans must contain 

enforceable measures and strategies for reducing visibility-impairing pollution and are due in December 2007. 

Ohio EPA is also working with several Midwestern states to conduct the technical 

analysis to identify contributing sources to regional haze. At a minimum, Ohio EPA 

will be required to adopt rules that represent Best Available Retrofit Technology 

(BART) for a select group of sources by the federal deadline of December 2007. 

After the adoption of BART rules, there will need to be a continuing effort on the part 

of the state to examine ways to eliminate man-made impacts on visibility to the 

national parks. 

Mercury Rules - U.S. EPA adopted a rule to permanently cap and reduce mercury 

emissions from power plants in the United States. U.S. EPA's rules allow for alternatives for controlling emissions of mercury from utilities, which included the 

installation of controls and establishing "standards of performance" limiting mercury 

emissions from new and existing utilities. This regulation creates a market based 

"cap-and trade" program that reduces nationwide utility emissions of mercury in two 
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facilities must be reviewed and also, there will be entirely new "Plant-wide 

Applicability Limit permits" under the Permit to Install rules to be developed and 

issued. 

Clean Air Interstate Rule - On March 10, 2005, U.S. EPA issued the "Clean Air 

Interstate Rule" (CAIR) designed to dramatically reduce and permanently cap 

emissions of sulfur dioxide (S02), and nitrogen oxides (NOx) from electric utilities. 

These rules set the baseline or minimum amount of controls that must be adopted 

to reduce the impact of the interstate transport of emissions to an acceptable level. 

Ohio EPA is required to adopt rules consistent with the federal rules by March 2007. 

Following the submission of the plan, Ohio EPA must work with Ohio facilities to 

implement these requirements. Without resources to maintain our existing staff, 

DAPC will not be able to complete the activities associated with the CAIR rules, 

including providing for allocations of emissions. 

Transportation and General Conformitv 

"Transportation conformity" and "General Conformity" are processes mandated by 

the Clean Air Act that requires that emissions from transportation projects not 

contribute to air quality violations in the state. Each federally funded transportation 

project must uphold the SIP for the attainment and maintenance of the national 

ambient air quality standards (NAAQS). Any other Federal actions (actions that require federal support, federal licensing, federal permitting, or federal approval) 

must meet general conformity requirements and must not contribute to air quality 

violations in Ohio. These SIPS includes an emissions budget from all sources 

including motor vehicles. 

Transportation plans must be within the allowable emissions budget for motor 

vehicles as defined by the- SIP. Ohio EPA will prepare new mobile source 

emissions budgets for the major urban areas in Ohio as part of the ozone SIPS. 

Ohio EPA will review transportation plans and federal projects based on U.S. EPA's 

new regulations. If the conformity determination is not made, then the use of 

federal funds for transportation projects is restricted. 
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addition, Ohio EPA is restricted from imposing additional air quality monitoring 

requirements for an air contaminant source when a specific monitoring, recordkeeping, or reporting requirement is established for that source under applicable 

federal regulations or state rules unless agreed to by the owner or operator. 

Three major rulemaking initiative are required by SB 265: (1) the development of 

the list of toxic chemicals which we intend to regulate, but are not included in the list 

of HAPS identified in the Clean Air Act; (2) the identification of pre-construction 

activities which a facility may initiate prior to receiving a permit-to-install; and (3) the 

identification of source specific "best available technology." The rulemaking 

activities associated with the list of toxic chemicals and the identification of preconstruction activities are currently underway. However, the adoption of rule 

identifying best available technology requires a technical review of the pollution 

control options available for hundreds of types of sources of air emissions, and a: 

review of the efficiency and cost of each identified control. DAPC's existing staff is being directed to work on these activities, and any reduction in staffing will impact 

DAPC's ability to implement the changes required by S.B. 265. 

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Onaoinq Maintenance and Enhancements to the STARS Rebuild 

DAPC has contracted with UNICON International, Inc. to rebuild the current 

permitting system to create web-based permitting and reporting system. DAPC 

worked with ITS and DAS to prepare the request for proposal (RFP) for the system, 

and due to the high bids that DAPC received from the first RFP, the proposed 

system was scaled back to a system that included the critical features needed by 

DAPC, which would also produce bids that DAPC could afford. As we work with the 

contractor, we identify items that we wish we would have included in the 

specifications for the system. In addition, DAPC operates smaller computer 

programs, such as the compliance tracking system (CETA), which we would like to incorporate into the new system. DAPC is requesting spending authority of 

$1,800,000 ($900,000 in SFY2008 and $900,000 in SFY2009) which is available as 

part of our cash balance in the Title V fee and non-Title V accounts to pay for 

enhancements to the new system. 

E-Check - U.S. EPA has adopted a stringent standard for ozone, and the air quality 
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language adopted in HB 66, we believe we have authority to extend the contract 

beyond December 31,2007 where federally mandated. 

Ohio EPA worked with the General Assembly in preparation of the 2006-2007 

biennium budget to obtain approval of an extension to the contract to operate the ECheck program through a contract with Envirotest. A two-year extension was 

approved, and Ohio EPA entered into a contract to extend the program in the 

seven-county Cleveland-Akron area through December 31, 2007. The legislature 

proposed and approved the use of tobacco monies to fund the operation and 

administration of the program, and eliminated the $1 9.50 test fee. 

With the proposed continuation of the program, Ohio EPA is submitting the 

corresponding recommendation for funding to both pay for the contract to operate 

the program, and to maintain the existing staffing level of 9.8 FTEs in both our 

Central Office in Columbus and in the field offices in Cleveland and Akron. As is 

currently the case, Ohio EPA's administrative costs are included as part of the overall funding provided by the tobacco monies. As we negotiate the extended 

contract, our programmatic costs will continue to be included in that manner. The 

requested increase in spending authority includes the Ohio EPA staffing pay 

increase of 3.5% in FY2008 and 2009 and the estimated increase in costs for the 

extended contract, Ohio EPA assumed an increase in contractor costs of 3%. 

This proposal for expansion, along with the continuation level of funding proposal 

will provide for the operation of the E-Check program in Northeastern Ohio. 

Because the legislature eliminated the test fee associated with the program, Ohio EPA does not have another source of revenue to support the program. If the 

increase is ~oj approved, DAPC will be required to reduce: (I) staffing by 0.2 FTEs 

in FY2009, and (2) the testing services provided by Envirotest. Under reduced 

staffing levels, Ohio EPA will not be able to provide the minimum level of contractor 

oversight, including performance equipment audits to ensure the integrity of the 

program, and our ability to provide customer service, including responding to 

exemption and extension requests needed by the public, would be greatly reduced. 

The reduction in testing services provided by the contractor would result in 

increased wait times for the people required to have their cars tested. 
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failure to adopt an adequate plan will mean that the federal government withholds federal highway money against the entire state. The increase in spending authority 

for this fund, along with the requested increase in spending authority for the Title V 

fee fund will provide for continuation funding. In addition, U.S. EPA requires that 

states provide a continued level of funding to maintain eligibility for grant funding. If 

this spending authority is not approved, DAPC may not meet our continued eligibility 

level and, as a result, would receive a reduced grant award. 

Over the past few years, the ability to retain the same level of federal funding has 

become increasingly difficult. Any reduction in funding would result in less staffing 

and would reduce inspection and monitoring activities. 

SETTING PRIORITIES 

DAPC has carefully examined its goals and priorities while preparing this budget 

request. The programs that are emphasized are the programs that are: (1) required 

by federal law, and (2) those services which impact our stakeholders the most. 

Federally required programs include the implementation of the new ozone and particulate standard. Services which impact our stakeholders include the PTI program, in which the timeliness of the permit effects the facility's ability to install 

the air pollution source, and the air toxics program, in which DAPC has received an 

increasing number of requests for air toxics monitoring bases on health concerns of 

the communities. DAPC is de-emphasizing programs that have a low impact on 

stakeholders and do not impact the air quality. The renewal of state permits to 

operate and the compliance inspections of small sources have been given a lower 

priority over the inspection and permitting of larger sources. 

As mentioned above, Ohio EPA will have a significant challenge meeting additional 

Clean Air Act mandates over the course of the biennium. Without additional 

spending authority to use existing funds to maintain existing staff, the agency faces 

the real prospect of having federal sanctions levied against the State of Ohio for the 

first time. This will come in the form of entire metropolitan areas not having 

approved plans and, therefore, the federal government will not fund transportation 
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increase efficiency. These projects include the STARS rebuild, which incorporates 

all of DAPC's permitting programs. Significant financial resources and staff time are 

being devoted to the design of this system to ensure that the system is built 

efficiently, and the recent and planned improvements to the permitting programs, 

such as combined permits are incorporated into the system. 

Operational Changes 

DAPC has implemented many innovative changes to our program in the FY2006- 

2007. The changes were in the areas of improvements to information technology, 

permitting, and the E-Check Program. 

Improvements in Information Technolos~ 

DAPC recognizes that improved efficiency goes hand in hand with improved 

information technology. It is DAPC's goal to continually improve DAPC's information technology by improving public access to DAPC technical resources 

including regulations, technical guidance and environmental data. DAPC's efforts in 

, . the upcoming biennium will focus on improving and improving the information, 

which is available through the DAPC web page. 

The STARS rebuild began in FY06 and includes incorporating the PTI functions and 

PTO functions into a single system, thereby reducing duplication of effort by Ohio 

EPA and LAA staff. This new system will assist DAPC in the implementation of a 

process through which a combined PTI and PTO will be issued. DAPC created six process improvement teams, which recommended improvements to our business 

process, which were necessary prior the design of the new system. The STARS 

Rebuild contractor, UNICON, has been working on the project since February 6th. 

On April 3, 2006, they completed phase I of the project, a Project Plan for Phase 2. 

This project will continue in FY2008-2009. 

Improvements in Permitting 

As mentioned above, a process improvement team studied the efficiency of the 

DAPC permit process, and has recommended the implementation of a combined 

permit program, which combines the issuance of the PTI and the PTO. DAPC is 
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eliminating the backlog of state PTOs, which were assigned the lowest priority for 

permit issuance for DAPC, to allow for the implementation of the Title V program 

approximately nine years ago. This low priority has resulted in a significant backlog 

of permits. 

DAPC has worked with industry on the "Permit Process Efficiency Committee" and 

the committee has developed four categories of improvements to the permit system. 

PPEC is a collaborative effort between Ohio EPA, U.S. EPA and members of 

several business and trade associations. Participants include the Ohio Chamber of 

Commerce, Ohio Chemistry Technology Council, Ohio Manufacturers' Association, 

Ohio Petroleum Council, and National Federation of Independent Business - Ohio 

Chapter. The PPEC process has involved a detailed review of air permitting 

efficiency in Ohio, as well as discussion and development of achievable and 

measurable recommendations to improve permitting efficiency. These include permit-by-rule, increasing the permit exemption threshold, general permits and 

plant-wide applicability limits. DAPC has implemented these improvements to the 

permit process during the FY06-07 biennium, and will continue to implement these improvements in FY08-09. 

The General Permit program has been fully implemented. A general permit is the 

same as any permit to install or State permit to operate that DAPC issues except all 

the terms and conditions of the permit have been developed in advance. This is 

referred to as the "model general permit". A potential applicant can review the model general permit qualifying criteria and terms and conditions and then complete 

the application and sign the qualifying criteria document if they believe they qualify 

for that model general permit. DAPC will review the applicant's information to 

confirm they meet the qualifications and then issue the model general permit to the applicant. This review process is very quick (typically less than 45 days) because a 

case-by-case permit does not need to be developed. Thirty-three different model 

general permits are available covering boilers, dry cleaners, metal painting, 

concrete plants, roadways and storage piles. To date, sixty-eight general permits 

have been issued resulting in significant cost savings to the state. Overall, this has been a very successful program. 
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processing Permit by Rule applications, converted all application forms to word and 

implemented a system to accept electronic PTI applications, which improved the 

efficiency of the air permitting program by streamlining the permitting process while 

maintaining rigorous pollution control standards. Over 1000 emissions units are 

currently covered under a permit-by-rule. By obtaining these permits, permittees 

obtain permits very quickly (typically as soon as they submit the notification) and 

Ohio EPA's review work is reduced significantly. By any measure, this has been a 

very successful program. 

It was determined that the Plant-wide Applicability Limits (PAL) rules did not need to 

be developed because they were included in the federal NSR Reform rules. Ohio 

EPA incorporated the NSR Reform rules into Ohio rules. Ohio rules now allow 

companies to apply for and obtain a PAL. In addition, after extensive work with all 

interested parties on developing a rule to exempt small sources, this approach was 

abandoned. This work will not be done because SB 265 was passed instead. Ohio EPA also restructured our approach to major projects, including: (1) frequent 

meetings calls to identify problems; (2) concurrent central office/districtllocal office 

review. This resulted in successfully meeting company's timing expectations (eg., 

GM Lordstown Assembly Plant, DaimlerChrysler Toledo North Assembly Plant, 

Sunoco Toledo Refinery, Republic Engineered Products - canton melt shop 

flexibility project.) 

Ohio EPA incorporated U.S. EPA's NSR Reform rules into our program in late 2004. 

These rules implemented changes that allow sources more flexibility to respond to 

rapidly changing markets and to plan for future investments in pollution control and 

prevention technologies. They also provided greater regulatory certainty, 

administrative flexibility and permit streamlining, while ensuring the current level of environmental protection. Ohio EPA is currently operating under these new rules. 

The above changes to improve the efficiency of the permitting program have allow 

DAPC to direct permitting staff to high priority permitting projects, and has improved 

the overall timeliness of the permitting process. DAPC issued more than 95% of the 

PTls within the statutory 180-day time line. During 2005, over 55% of the PTls were 
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visible to the public. Nonetheless, they were successful regardless of the short time 

to accomplish it, since the contract was signed in December 2005, which extended the program to December 2007.