Permitting & Enforcement Committee MeetingMay 10, 2011
Permitting and Enforcement CommitteeFINAL
When: May 10, 2011
9:30 a.m. - 1:00 p.m.
Where:Central Office, Columbus
Conference Room C
Facilitator:Jim Braun, Co-Chair
Minutes:Jenny Avellana
Time / Topic / Lead /Involvement / Actions Needed
9:30
10:00 / Enforcement
New items?
Violations / Paulian/Kalman
Paulian / General update.
Discuss the Form of Action.
10:00
10:30 / Permitting
New items?
SOB form possible improvements
NAICS codes for PTIO backlog
Renewal permits terms and conditions
Proposed Potential to Emit Guidance
Boiler MACT
PTIO backlog project – streamline permit process
BAT flow diagram
PBR for portable crusher screener
Reissue Title V if new rule applies before Final? / Hopkins
Hall/Martz
Hall
Hall
CDO
Smith
SEDO/Canton
SEDO
Toledo
Braun / General update
Addressing CAM – see message below.
Need volunteers per message below.
Modify terms from previous PTI?
Revise based on Hopkins comments and redistribute for further comment.
Discussion of new rules.
General discussion.
SEDO has flow diagram to share.
See question below.
Reissue Draft, PPP, or PP?
10:30
11:00 / Permit Issuance and Data Management
New items?
Title V training manual workgroup
Public records request tool
STARS2 glitch – problem with task assignment
PER overdue notices in STARS2
STARS2 Permit Tracker / Ahern
Ahern
Ahern
Braun
Akron
Dzienis / General update.
Status update.
Status update.
Need to fix – appears to use default.
Do the DO/LAAs need to take action?
See below. Carryover from last meeting. Provide suggested changes to Mike Ahern.
11:00
11:15 / Break / everyone / Relax & Stretch
11:15
11:30 / New Rules and SIP Update
New items? / Paul Braun / General update.
11:30
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 / Discuss Toledo draft revisions provided on March 30, 2011.
#20 - Determination of Compliance with Visible Emission Limitations for Stack Source / Akron / update on progress
#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
#26 - Inclusion of Weight of Water in the Weight of "Refuse" Charged for Incinerators / NEDO / Submit comments by 2/15/10. No comments received.
#29 - Applicability of the PTI Rules to Increases in Capacity of a Derated Boiler / CDO / update on progress
#34 - Conditions for Issuance of PTI/PTO for an Inactive Source / RAPCA / STARS2 webex discussion with Erica – need to define “shutdown”.
#53 - Interpretation of Open Burning Standards / DeWulf / Burkleca / 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.
#74 – Stack testing for PM2.5 / Hall / FR for PM2.5 effective. Need to address test protocol for condensables and the Hopkins NSR guidance.
#79 – ERC Banking Tracking SOP / Avellana / Final guide ready for discussion.
#XX – Non-road Engines / SEDO / update on progress
#XX – Emission unit ID designations / Ben Cirker / Submit comments by end of October.
#XX – Crushers NSPS Subpart OOO / Hopkins / Hopkins review comments and address recent changes to subpart OOO.
12:00
12:15 / General Permit & Permit By Rule development
Create new GPs and PBRs
Crematories - Cleveland / Sarah VanderWielen to work on mercury modeling September 2010.
Tub Grinders - CDO / Draft terms distributed – comments due April 20, 2011.
Shingles Grinders - RAPCA / GP or PBR needed? Not needed as there are only a few of these grinders.
Anaerobic Digesters / Jenny Avellana preparing GP.
Miscellaneous Metal / Cheryl working on changes for Chapter 17 and GACT (HHHHHH).
Compression Ignition RICE / Drafted for the aggregate industry but available to all per Cheryl.
Aggregate Processing – CO / Public noticed between 9/3 and 9/6 in different newspapers. Comment period ends 10/6.
12:15
12:30 / Training
Training for Engineering Guide 44 / Engel-Ishida / Erica working on training in Columbus.
12:30
12:45 / New items
Proposed stack test guidance / Braun / Issue as informal guidance or make into a comprehensive Engineering Guide?
Pending Action Items suggested by P&E Committee / Date Action Completed
1. File review work group. / Per 11/9/10 meeting, the Legal Division wants to revisit and possibly develop a centralized system for tracking file review requests.
Next meeting: July 12, 2011
STARS2 Permit Tracker
From: Mike Ahern [mailto:
Sent: Wednesday, March 02, 2011 8:21 AM
Subject: Draft list of activities tracked outside of STARS2
Hello,
At the last P&E meeting we discussed that it is about the right time to take a look at the systems the DO/laas have maintained outside of STARS2 to track permit application review/permit development. Most of these systems pre-dated STARS2 and were the innovative results of addressing shortcomings in tracking capabilities in STARS and PTIs2000. We discussed in the P&E that it would be helpful to reduce the need to maintain separate systems if the needs of each offices' separate tracking information can be met via adding STARS2 functionality. I had asked for descriptions of the information and needs each office currently tracks outside of STARS2 so that we can try, over time, to address the needs form within STARS2 and to see if there are similar needs from office to office.
Attached is a raw list of the feedback I have received so far. I have contacted a couple of folks to get a better understanding of a couple of items. However, attached is what we will take a look at next week at the P&E meeting.
Please feel free to send me additional information by Friday of this week and I will get the information incorporated into the attached document.
Thanks everyone for your work and interest in this project. We will work diligently to meet you needs.
Sincerely,
Mike Ahern
Permit Issuance and Data Management Section
ATTACHMENT: SEE FILE “STARS2_requests from Ahern 3 2 2011”
Toledo Question
From: Pittman, Dan [mailto:
Sent: Friday, April 29, 2011 4:14 PM
Subject: P&E Question
TES recently received a PBR Notification for a Portable 150HP Crusher /Screener for a new facility.
The PBR was issued. The PBR Notification did not require information on the diesel engine portable generator.
Questions: Are we suppose to issue a permit for the diesel engine in these units? Can the PBR Notification be revised to include questions similar to the draft Tub Grinder General Permit Qualifying Criteria? Or, is it the intent to include the “unit – including the crusher and screen with the power plant “ as the only PBR emission unit identified as F00# ?
If this subject has already been discussed and comments issued, please provide the citation for review.
Thanks,
Dan Pittman
Toledo Environmental Services Division
Hall Items
From: Andrew Hall [mailto:
Sent: Wednesday, May 04, 2011 1:12 PM
Subject: Re: P&E Draft Agenda
1. SOB Form and Possible Improvements: Lynne Martz, to discuss ideas for identifying on the SOB whether CAM was evaluated for controlled, non-insignificant emissions units [this might be something the Title V training group has considered? If so then an update on where this group is at should be a part of this discussion]
2. DO/Laa involvement/volunteers needed to develop process/get correct NAICS codes assigned for the PTIO Backlog Reduction project.
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