One of the major changes under EPA’s so-called New Source Review (NSR) Reform rules promulgated in 2002 was the use of “actual to projected future actual” emissions for determining if a source modification is “major,” thus triggering Prevention of Significant Deterioration (PSD) or nonattainment area (NAA) requirements such as offsets. One of the requirements under the NSR Reform rules was that for a source modification that escaped PSD or NAA requirements based on the source’s projection of future actual emissions, the source was required to keep records for 5 years (10 years in certain cases) of their emission increases if there was a “reasonable possibility” that the PSD/NAA thresholds could be exceeded. As a result of a court remand, EPA proposed on March 8, 2007 criteria for determining the “reasonable possibility” standard. EPA’s preferred option was a “percentage increase trigger” that would require recordkeeping if the projected increase exceeds 50 percent of the significant increase triggers for a major modification. In a separate rulemaking, EPA established this as an interim interpretation in NA areas governed by EPA rules under 40 CFR Part 51, Appendix S. For more information, refer to the Federal Register notice or contact Kent Berry at 1-800-229-5299.
In December 2006 President Bush signed a bill into law allowing greater flexibility in using Leaking Underground Storage Tank (LUST) Trust Fund money to protect ground water. The new law, Public Law 109-433, permits LUST funds to be used to implement changes made in the Energy Policy Act of 2005. This Act relates to tank inspections, operator training, cleanup of MTBE, and other related provisions. The hope is that this new law will free up some of this money for states to use to address leaking tanks.
Ohio EPA has revised the format of their annual Title V compliance certifications. The revised approach continues to require full certification. However, the revised format does not require identification of each permit term and condition within the form. Instead, the completed form highlights all instances of intermittent compliance during the compliance certification period. The new Title V compliance certification form released by OEPA can be accessed via their website at http://www.epa.state.oh.us/dapc. Use of this new form is optional for calendar year 2006 (due April 2007) but will be required for calendar year 2007 (due April 2008).
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