Permitting & Enforcement Committee Meeting November 18, 2014
Permitting and Enforcement CommitteeDRAFT
When: November 18, 2014 Answer Place ID: 2140
9:30 a.m. – 11:30 p.m.
Where:Central Office, Columbus
6th Floor - Conference Room A “Autumn Room”
Facilitator:Mike Hopkins, Sean Vadas
Minutes:Jenny Avellana
Time / Topic / Lead /Involvement / Actions Needed
9:30
9:35 / Introductions / All / Brief introductions.
9:35
10:00 / Compliance & Enforcement
New items?
EG #52 – Criteria for Requiring the Use of Continuous Emission Monitors
40 CFR 60, Appendix F – Procedure 3 / Paulian/Bergman/Kavalec
John Paulian
Todd Brown / General discussion.
Should this Engineering Guide go into revision?(carryover from previous meeting)
New COM QA Procedures.
10:00
10:30 / Permitting
New items?
Engineering Guide #16
Permit Fees / Mike Hopkins
Mike Hopkins
NEDO / General discussion.
Testing Frequency.
NEDO to identify which permit categories need to have permit fees clarified. Note: EG25 contains guidance for calculating fees for fugitive sources. (carryover from previous meeting)
10:30
10:40 /
Short Break, If Needed.
/ All10:40
11:00 / General Permit & Permit-By-Rule Development
Create new GPs and PBRs / Crematories GP- Cleveland / Problems meeting the mercury TLV under assumed conditions. SIP/Modeling section looking to see what restrictions may be needed (stack height/fenceline distance).
Roadways and Parking Areas / PBR for >24k – 70k VMT roadways.
Changes to be proposed in the Chapter 31 revisions.
Compressor Stations GP #14 / Cheryl – GP sent out to several facilities for review. Misty is now the contact on this.
Miscellaneous Metal Parts GP / Comments being addressed on the draft terms.
11:00
11:15 / Engineering Guide Revisions
#6 - PTI for Coal to Oil Conversion / Misty Parsons / reviewing guide
#18 - SO2 Compliance Determination Methods for Boilers / Toledo / Returned to Toledo to address Mike’s comments – 7/25/14
#23 - Determination of Significant Figures for TSP Emission Limitations / SEDO / Comments received and making revisions.
#29 - Applicability of the PTI Rules to Increases in Capacity of a Derated Boiler / CDO / update on progress
#42 - Definition of BAT for New Sources / NWDO / Beginning initial review
#44 - Permit Issuance Policy for Relocation of Portable/Mobile Facilities / CO/SEDO / Erica and Sarah Harter working on changes. – On Holduntil rules/forms changed.
#45 - Calculation of "Potential to Emit" for Surface Coating Lines / Canton / Draft revisions distributed for review 9/9/13. Comments until 10/11/13. Reviewing comments then will resend draft.
#46 - Determination of Cost-Effectiveness for BAT and RACM Evaluations / NWDO / Beginning initial review
#48 - VOC Compliance Determinations for Coating Lines / Canton / update on progress – reviewing guide– Draft expected by end of January
#51 - Number of Sampling Runs to be Witnessed by Agency Observers / RAPCA / Issued Final 9/12/14
#53 - Interpretation of Open Burning Standards / Paul Braun / Update on progress – reviewing guide.
#58 - Definition of “Facility” for Ohio Title V Permit Program / Drew Bergman / Beginning draft revisions due to recent court decisions
#70 - Guidance on Evaluating Emissions of Toxic Air Pollution Compounds when Processing Permit-to-Install (PTI) Applications. / Mike Hopkins / Mike Hopkins to review comments.
#74 – Stack testing for PM2.5 / Andrew Hall / On hold until asphalt plant testing issues are resolved.
#78 – MSW Landfill Higher Operating Values and Alternative Timeline Requests / NEDO / Revising approval procedure. (This is also a DSIWM Document)
#80 – Methods for Calculating PTE / CDO / Final recommendation submitted to Mike Hopkins on 7/24/2014. May need to re-evaluate it based on recent BAT guidance.
#82 – Ultra Low Sulfur Diesel Fuel Permitting / NWDO/CDO / Issued final 9/18/14, reissued to correct permit term language 10/1/14
#83 – Asphalt Testing Production Rates / Todd Brown/Alan / Draft out for review. Comments until 11/2/12. –> On hold until asphalt plant testing issues are resolved.
#84 – Non-road Engines / SEDO / update on progress
#86 – 31-05 Rule Citations / Mike Hopkins / Comments until 9/26/14.
#87 – <10 tons/year BAT Exemption / Mike Hopkins / Comments until 9/26/14.
11:15
11:30 / New items
Any new items to discuss? / All / New items to discuss?
Pending Action Items / Date Action Completed
Revisions to EAC Form #3862 for engines / Draft out, comments to Sarah Harteruntil 1/31/14.
Revisions to permit application & instructions / Mike Hopkins to review previous work done (in 2012?) on revisions and decide the priority of this work.
Next meeting: January 13, 2015
2015 – Meeting Schedule
January 13, 2015
March 10, 2015
May 12, 2015
July 14, 2015
September 15, 2015 (3rd Tuesday due to Labor Day holiday during 2nd week)
November 10, 2015 (Veterans Day is the 11th, but doesn’t seem to be a problem)
Added Topics:
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