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Not All Air Emission Sources Require Air Permits

Does your business use materials or conduct activities that can release air pollutants? These are called air emission sources and many businesses have them. Common examples include surface coating and painting, material handling activities and operating fuel-burning equipment such as boilers and heaters.

For more help identifying air emission sources, see Ohio EPA’s Does My Small Business Need an Air Permit fact sheet. Once your business has identified your air emission sources, the next question is “Do I need an air permit for each air emission source at my facility?” Not necessarily. If an air emission source meets certain criteria it may be exempt from air permitting.

Currently, there are three different scenarios in which an air emission source could be exempt from air permitting:

  1. The source is exempt under Ohio EPA’s air regulations — Ohio EPA has determined that certain types of equipment and industrial activities which typically have lower air pollutant emissions do not require air permits. These activities and equipment are identified in the air pollution rules as being exempt from air permitting and include equipment such as small boilers and detergent-based parts washers and activities such as abrasive blasting and grinding. In some cases the source must meet certain criteria (such as specific horsepower, storage capacity, etc.) to qualify for the permanent exemption. You are not required to notify Ohio EPA if you have a source that is permanently exempt, however notification often helps future/new air inspectors understand your exemption status. If the exempt source is portable, the portable source notification requirements still apply.
  2. The source qualifies for a Permit-by-Rule (PBR) —Specific low-emitting sources qualify for an air permit exemption known as Permit-by-Rule or PBR. The PBR exempts the air emission source from the formal paperwork permitting process, however still requires that the source meet certain emission and operating conditions. Currently, there are 11 specific types of equipment and/or industrial operations that can qualify for a PBR, including auto body refinishing shops, small crushing and screening plants and small natural gas-fired boilers and heaters.
    To determine if your source qualifies for a PBR, begin by reviewing the list of sources covered under Permit-by-Rule. If your source appears to qualify, review the qualifying criteria, terms and conditions associated with the PBR. For each air emission source that qualifies, you must complete the PBR notification form and submit it to Ohio EPA or your local air agency. While the PBR exempts a source from the administrative air permitting process, monitoring, recordkeeping and reporting requirements still apply. You may find Ohio EPA’s PBR fact sheet helpful.
  3. The source has low emissions and is de minimis — In most cases, if an air emission source emits less than 10 pounds per day of particulate matter, sulfur dioxide, nitrogen oxides, organic compounds, carbon monoxide, lead or any other air contaminant and less than one ton per year of hazardous air pollutants (HAPs); then it is considered de minimis and does not require an air permit. However, there are some exceptions to this exemption.
    If you think that you have a low-emitting source that may be exempt from air permitting, you can calculate your air emissions and determine if they are less than 10 pounds per day. Then, review the list of conditions in the de minimis rule and ensure that your facility is allowed to use the de minimis exemption even if your emissions are less than 10 pounds per day. If you have a qualifying source and would like to claim the de minimis exemption, you are not required to notify the Ohio EPA or your local air agency; however the Ohio EPA district office or local air agency can review your de minimis calculations to ensure that your source qualifies. It is important to note that you must keep records demonstrating that your actual emissions do not exceed the de minimis thresholds.

For more information on air permit exemptions see Ohio EPA’s Air Permit Exemptions fact sheet or contact your Ohio EPA district office or local air agency. Small businesses can also contact the Office of Compliance Assistance and Pollution Prevention (OCAPP) at (614) 644-3469 or (800) 329-7518 for free help. OCAPP is a non-regulatory office within Ohio EPA that helps small businesses understand and comply with environmental requirements.

Tips to Evaluate if Your Air Emission Source Requires an Air Permit

  • Start by identifying all sources of air pollution at your facility.
  • Determine whether any of these sources are permanently exempt.
  • Determine whether any sources qualify for a PBR.
  • Calculate emissions to determine if any source is de minimis.

Note: an air permit is required for any air emission source that is not exempt. Need help? Contact OCAPP for technical assistance.