Permitting & Enforcement Committee Meeting September 8, 2009
Permitting and Enforcement Committee FINAL
When: September 8, 2009
9:30 a.m. - 1:00 p.m.
Where: Central Office, Columbus
Conference Room C
Facilitator: Jim Braun, Co-Chair
Minutes: Ed Fasko
Time / Topic / Lead /Involvement / Actions Needed /
9:30
10:00 / Enforcement update
New items? / Orlemann / General update.
10:00
10:30 / New Source Review
New items?
Rocket Docket: 330 Appeals to resolve by December
Portable Wood Grinder
House Grinders / Hopkins
Hopkins
NEDO
NEDO / General update.
Update on progress.
Create exemption policy? See below.
Need follow-up from last meeting.
10:30
11:00 / Permit Issuance and Data Management
New items?
File Review Work Group / Ahern
RAPCA / General update.
Update on progress.
11:00
11:15 / Break / everyone / Relax & Stretch
11:15
11:45 / Terms and Conditions and Policy Distribution
New items? / Suttman / General update.
11:45
12:00 / Engineering Guide Revisions
#6 - PTI for Coal to Oil Conversion / Cleveland / Misty to revisit the changes for this guide.
#18 - SO2 Compliance Determination Methods for Boilers / Toledo / Draft almost ready for review. Check that SO2 SIP rules have been approved.
#20 - Determination of Compliance with Visible Emission Limitations for Stack Source / Akron / update on progress
#21 – BAT Requirements for New Fugitive Dust Emission Sources in Non-Appendix A Areas / Cleveland / JB working with Jim O. to make final revisions.
#22 – Acceptability of Manual Covers for Small Open Top Vapor Degreasers and Definition of “Enclosed Design” Degreaser / Cleveland / Version 2 comments due September 1, 2009. Comments received, JB making changes.
#23 - Determination of Significant Figures for TSP Emission Limitations / SEDO / Comments received and making revisions.
#24 - Application of Fugitive Dust Requirements to Affected Facilities / Toledo / update on progress
#25 - Determination of Source Nos. and Permit/Variance Fees for Fugitive Dust Sources / Cleveland / Comment period ended July 14. Jim O. will discuss with Tom Kalman.
#26 - Inclusion of Weight of Water in the Weight of "Refuse" Charged for Incinerators / NEDO / update on progress
#29 - Applicability of the PTI Rules to Increases in Capacity of a Derated Boiler / CDO / update on progress
#30 – Discontinuation of the Use of Control Measures for Fugitive Dust Sources in Non-Appendix A Areas / Cleveland / Comments due by September 1, 2009. No comments received. JB will finalize with Jim O..
#31 – Grouping Determinations for Similar Process Units Subject to Figure II / Cleveland / Comments due by September 14, 2009.
#32 – Variances from the Visible Emission Requirements / Cleveland / Comments due by October 1, 2009.
#34 - Conditions for Issuance of PTI/PTO for an Inactive Source / RAPCA / STARS2 webex discussion with Erica – need to define “shutdown”.
#35 – Consideration of External and Internal Floating Roof Storage Tanks for Registration Status / Cleveland / Comments due by October 14, 2009.
#36 – Criteria for Determining Whether Fuel Burning Equipment are Either Physically or Operationally United / Cleveland / Comments due by November 1, 2009.
#44 - Permit Issuance Policy for Relocation of Portable/Mobile Facilities / NEDO / More changes needed per STARS2, working with Erica on changes. Meeting held on July 14.
#53 - Interpretation of Open Burning Standards / Dewulf / JO / LB / Rule was appealed with hearing in February 2007.
#70 - Guidance on Evaluating Emissions of Toxic Air Pollution Compounds when Processing Permit-to-Install (PTI) Applications. / Hopkins / Hopkins review comments.
#72 - Guidance on when it is appropriate for the regulated community to group emissions unit IDs for certain emissions reporting purposes. / Erica / Jim O. / nearly done, Mike A. review modifications, discuss with Jim O.
#74 – Stack testing for PM2.5 / Hall / FR for PM2.5 effective. Need to address test protocol for condensables and the Hopkins NSR guidance.
#XX – Crushers NSPS Subpart OOO / Hopkins / Hopkins review comments and address recent changes to subpart OOO.
#77 – Amended 21-07 applicability / Orlemann/Braun / Finalized on August 24.
12:00
12:15 / General Permit & Permit By Rule development
Create new GPs and PBRs
Crematories - Cleveland / Need to resolve mercury modeling.
Generators - NEDO / Working with Cheryl.
Tub Grinders - CDO / Provide status update.
Aggregate Processing – CO / Provide status update.
12:15
12:30 / New items? / All / New items to discuss?
Pending Action Items suggested by P&E Committee / Date Action Completed
1. Post most recent template Director=s letters on intranet. / ??
2. Post most recent audit disclosure exemption letter on intranet. / ??
3. Suttman to prepare landfill guidance document. Need to address e-mail from USEPA regarding authority to allow changes. / ??
4. Orlemann to revise EAR form to remove duplicate information. / ??
Parking Lot Items:
1. Multiple emissions units controlled by a common control device. There is a small possibility that these permitting concepts might be used for the BAT rules under SB 265 or they could be used to develop pollutant specific limitations in the OAC rules.
Next meeting: November 10, 2009
-----Original Message-----
From: Ed Fasko [mailto:
Sent: Wednesday, September 02, 2009 8:49 AM
To: Braun, Jim
Subject: Fwd: Discuss Gibney's grinder at 9/8 P&E meeting?
Jim -
I know it is late, but could you add this on? Also, we need a follow-up on the house grinding issue and the exemption that Ward and Buchan disagreed on...
> Rick Carleski 9/1/2009 12:30 PM >
Hi Ed.
OCAPP staff have been discussing the "no permit needed" letter dated August 17, 2009 that NEDO sent to Beau Gibney at TRC for their portable wood grinder. I want to thank you and your staff for working with Adrienne on this. We encounter these and similar units often and it is an important issue for us. We would like to request a more formal DAPC policy statement on the exemption status of such portable diesel-fired machines.
As we understand it, the reason Gibney's grinder does not need a permit is based on a combination reasons: 1) the diesel engine, by itself, is an exempt non-road engine per OAC 3745-31-03(A)(1)(pp), 2) the PM emissions from the grinder portion are de minimis, and 3) the source is portable and moves around frequently.
Would you be willing to discuss these issues at the next P&E meeting on September 8? This would tie into the follow-up from Canton LAA's house debris grinder discussion on permitting we had at the last meeting.
Please let me know what you think. Jim Braun requested any agenda revisions by the end of today, but I'm sure he'll add it to the agenda if you ask later.
Thanks.
Rick Carleski, Supervisor
Office of Compliance Assistance and Pollution Prevention Ohio EPA
page2of3