Response from the Ohio EPA

I sent an email to the part of the Ohio EPA that is responsible for our section of Ohio. Here is the response.

tl;dr: They are the air regulatory agency for Cincinnati, and if we emit less that 10 pounds per day we qualify for an exception.

Hi Andrew

Thank you for contacting the Office of Compliance Assistance and Pollution Prevention.

It is possible that you may need an air permit (called a permit to install and operate - PTIO) for the dust from cyclone if it is vented outside. Or it may be possible that the dust/emissions from the cyclone are what we call “de minimis” which would mean that your cyclone would be exempt from permitting requirements. Either way you should either need to assess if you are de minimis and/or if you need a permit. If you need a permit, you can apply for this permit and it would be issued by your local air agency, the Southwest Ohio Air Quality Agency (SWOAQA) - they are the air regulatory agency for Cincinnati.

Here is a fact sheet on air permits. Here is a fact sheet which explains the Air permit exemptions (including de minimis). You may qualify for de minimis if you emit less than 10 lbs/day of particulate matter/dust. De minimis is calculated based on maximum capacity of working 24 hrs/day. If you claim de minimis based on actual emissions, you must keep records onsite to document actual daily emissions from the source. You do not need to notify Ohio EPA or SWOAQA if you claim a de minimis exemption.

What is “maker space”? As a small business/non-profit I would be able to assist you in determining if you meet the de minimis exemption and/or if you need a permit. I would need to gather additional information from you about your operation.

Please let me know if you would like me to assist you with this or if you have any other questions.

My management has asked for customer service feedback. Please complete our 2-minute customer service survey and let my management know how I’m doing. Thank you!

Best!

Amber

Amber Hicks

Ohio EPA, OCAPP

937-285-6439

Got another email from Amber at the EPA.

tl;dr: We further qualify for a permanent exception since our cyclone is moving 1350 CFM, which is well under the 4000 CFM restriction.

Hi Andrew

Wow that is really cool! What a great program/concept.

I have some more information for you to think about.

There is a permanent exemption in the air rules for wood working operations to not obtain an air permit as long as they meet the following criteria:

  1. Operations are controlled by a fabric filter, scrubber or mist collector that is designed to not emit more than 0.03 grams of particulate per dry standard cubic foot of exhaust gas (rating of filter)

  2. A blower which blows less than 4000 cubic feet per minute volume

  3. The emissions are vented inside.

If you meet all of these criteria you would be permanently exempt for having to obtain an air permit.

Another option would be if your control equipment was integral to process. For example if there was an interlock that would not allow the equipment in your shop to run without also having the cyclone on. So essentially anytime any equipment is being operated the cyclone is on as well. This would be a “one switch” type of thing where when equipment is operated the cyclone automatically comes on as well. Under this scenario the control equipment is integral to the process and we could calculate any emissions from your shop including the control equipment which would then probably ensure that your shop would meet the de minimis exemption of less than 10 lbs. per day of dust emissions (vented outside) and thus not require a permit.

Let me know if you have any questions.

My management has asked for customer service feedback. Please complete our 2-minute customer service survey and let my management know how I’m doing. Thank you!

Best,

Amber

Amber Hicks

Ohio EPA, OCAPP

937-285-6439

I don't think we get close to 10lbs per day in the large stuff let alone the small stuff.

Awesome man! I never meant to come across as on the attack at ya I just remembered every area has a whole bunch of what ifs to jump through to a final answer. I’m still thinking a possible downpipe in the future might be nice to take that dusty smell out of the air or stay away from complaints come nice weather with the cars possibly.

It would also give us a good idea and containment if we did do a small spray booth. Plus given the amount of water based industrial paints for auto spray guns now for large jobs we cut cut down on fumes. Seeing we have the kiln as well I’d love to put in the option of powder coating as well :slight_smile: talk about doing top quality metal finishes down there :slight_smile: I think cerakote might be getting a little pricey lol.

Awesome man! I never meant to come across as on the attack at ya I just remembered every area has a whole bunch of what ifs to jump through to a final answer.

You’re fine, I did post the original thread because I was looking for problems, and wanted somebody to check my work.

I’m still thinking a possible downpipe in the future might be nice to take that dusty smell out of the air or stay away from complaints come nice weather with the cars possibly.

I agreed, but to be honest, I’m not motivated enough to make it a priority. I might change my mind if I notice we’re starting to get a noticable accumulation of dust outback.

It would also give us a good idea and containment if we did do a small spray booth.

I think it’s a similar issue. Honestly the EPA web site didn’t really seem to care what we were putting into the air, so Brad’s hypothetical nuclear fuel rod particles seems to be just as fine as something far less harmful. I think a spray booth has far more possibilities for causing problems, since paint is designed to stick to stuff, burns, and has VOCs. :wink:

Yeah the paint booth is a challenge depending on what your using. I got to work on the vent system out at cincy state for the spray booth in the hanger. We would have to come up with the paint types and thinning agents used on them. The newer water based stuff you can wear a 3m dust mask if wanted only because the thinning agent is water. Some of those can be very tricky to spray large objects without sagging or runs. It is slick though. I dono if we have a water supply outside but to build a oil/water separator system to pull things out better would be slick.

I’m curious if you’re aware of any cheap explosion proof fans. If this becomes a permanent installation we need to give this some serious thought. Generally they seem to hit a grand or two.

I’ve got an airbrush at home I use with water based acrylics, but I still make sure to always wear a mask. You’re correct that it’s “non toxic”, and the solvents aren’t an issue, but since paint is design to stick to things I can’t see anything good happening when I inhale even “non-toxic” paints.

It is often suggested that the fan problem be solved by separating the fan from the motor.
The fan is run by a belt.
This way the fan sits in the paint/solvent stream, but the motor is outside the duct completely
as the overspray is sucked in from the booth, and blown out the window at the other end of the duct.

(at least the overspray that’s not caught by the filter on the spray side of the fan.)

Correct John, that’s one way to make an explosion proof fan. I’ve seen a few that design and a few others, but I haven’t see any that aren’t in the $1K+ range. Maybe I’ll turn up something as I look further. Generally when you googling an explosion proof fan, the results seem slanted towards “Serious Industry” where they want you to call for a quote and the like. :slight_smile:

Sorry, what I meant was, one can find a motor and find the fan blades in two separate garage sales, then rig up the assembly oneself.

Also, here’s a simple lightweight boot (not sure how big a fan it takes, without blowing away!).

http://www.finewoodworking.com/2007/11/01/make-a-simple-spray-booth

build-a-spray-booth.jpg

FWIW, this is the fan used in the above jpg.

https://www.grainger.com/product/DAYTON-Propeller-3GTG4?searchBar=true&searchQuery=3gtg4

The price is listed at $!72.

Here’s a brief note on flammability (or inflammability ; ) ) calculations and situations:

http://www.finewoodworking.com/2012/10/25/spraying-solvents-risk-versus-reality

Good idea on cobbling something together, you’re correct about getting a blade, then attaching it to a motor. Any ideas on where to get a motor cheap? Ones I’ve seen usually run another $50-100 or more.

This is the final response from the Ohio EPA, with the calculations necessary to determine that we meet de minimis. If we’re ever audited we’ll be required to present these calculations to show we’re not in violation. Finally this covers everything, not just the woodshop.

I’ll be adding this file to the Dust Collection entry in the wiki as well.

Cincinnati.makerspace.calculations2.3.17.docx (35 KB)

Nooooo… not everything. This is the air portion, the solid waste is a different story. They are different divisions I think. Water too.

But… the key cut off is “conditionally exempt small quantity generator” (If I recall)… and the key provision being less than 800 pounds of hazardous waste a year, and the household hazardous waste exemption not applying because a 503c nonprofit is not a family household most times.

800 lbs seems generous, but it adds up fast. Best thing? the new pressure treated lumber might be non regulated instead of hazardous… that weight might trip up calculations.

Sorry, you’re correct, this is air pollution for the entire hive, and not just the cyclone/woodshop which I originally contacted them about. Which includes the metal shop and it’s welding, and potentially any finishing/painting we might do, with the caveat they expect us to contact them again if we install a paint booth.

Outside of your suggested water filter for dust, or Brad’s illusory nuclear fuel rods, I’m not sure how we would get in trouble with water or solid waste. Maybe if we got serious about making beer? Like 10s of gallons each weekend?

well, water (aka beer) is 8 lb.s / gal. , so don’t make too much!

Okay… it goes like this. (quick version, air, water, and solid waste departments are very unexpectedly separate beasts)

What do you do with hazardous wastes generated when you are a business, and not a homeowner, but not big enough of a fry to warrant an epa id number. Technically? Mercury bulbs, and lead waste from electronic components are not supposed to be dumpsterized. Lead waste in particular may need a certificate of disposal…

Sure maybe it is not a problem now… but it could be later. If people are talking a paint booth, what happens when there are cans of paint abandoned? If it is not latex, it cannot be hardened and discarded. That’s part of why the provision for if you add paint booth then contact again. A violation in containerization and disposal of the solvents is an air issue and a hazardous materials issue. (Open containers are considered treatment by evaporation and thus penalized monetarily). What happens as the hive grows? It adds up more quickly than is easily realized. And what about etching chemicals? Sewering of acids and bases went out of style long ago. Yup, likely gotta save that stuff up. Just one drum at 45 gallons at the weight of water is 360lbs… and that is about half the budget. Sure… nowhere near 45 gallons a year. But once those jars start adding up? People forget to label? Then you have unknown hazardous waste… and that sucks. Cause the pro guys are likely gonna bring a specialist and at least another laborer in supplied air to test each unknown by characteristic, and it will cost.

Far better to figure out the disposal before 800lbs accumulate and ya gotta hire the pro disposal guys… because it is the kind board of directors people that will be on the hook for any civil or criminal penalty.

Side note: Egads… there are still web pages up recommending sewering… The Ferric Chloride carries away copper which precipitates when neutralized… which will kill invertebrates in open waters, and given the age of the building, it is far more likely the sewer goes to storm sewer, which used to also be sanitary sewer… they even had the same nomenclature SS… which likely goes right to the river… where we would like invertebrates. Save our invertebrates eh? Or… if it goes to the treatment plant, then the sewage sludge gets taken to the country, and used as fertilizer… which makes our food. It’s the slugs or the peeps… If you flush.

Brad just posted that there are motors sitting unused in the Hive.

Okay… it goes like this. (quick version, air, water, and solid waste departments are very unexpectedly separate beasts)

What do you do with hazardous wastes generated when you are a business, and not a homeowner, but not big enough of a fry to warrant an epa id number. Technically? Mercury bulbs, and lead waste from electronic components are not supposed to be dumpsterized. Lead waste in particular may need a certificate of disposal…

Sure maybe it is not a problem now… but it could be later. If people are talking a paint booth, what happens when there are cans of paint abandoned? If it is not latex, it cannot be hardened and discarded. That’s part of why the provision for if you add paint booth then contact again. A violation in containerization and disposal of the solvents is an air issue and a hazardous materials issue. (Open containers are considered treatment by evaporation and thus penalized monetarily). What happens as the hive grows? It adds up more quickly than is easily realized.

Interesting. It’s already a bit of an issue, we have an entire fire cabinet full of half used spray cans and various wood stains and treatments. What’s the correct way to dispose of them? Can we take them to one of the Hamilton County disposal areas?

And what about etching chemicals? Sewering of acids and bases went out of style long ago.

I think we can just not allow people to etch, for that reason.

@John2pt0 - Good point, I’ll have to pick through them next time I’m down.