Under the current rule, Ohio EPA requires a facility to conduct air quality modeling when the potential emissions of a covered air toxic exceed one ton per year. This threshold is easily exceeded because it is based on potential emissions. The modeling can get expensive and can delay the issuance of an air permit.
The comments requested Ohio EPA to adopt a more streamlined approach that would require the agency to develop a spreadsheet that a facility can use to input their actual material consumption and other data so that it calculates the emissions and estimated exposure levels that would occur at the property border. If the concentration of chemical is below the exposure limit, then the facility would not have to take any further action. If the concentration of the chemical is greater than exposure limit, then the facility would have to model the emissions to determine the exposure concentration.