Permitting & Enforcement Committee Meeting July 14, 2009
Permitting and Enforcement Committee FINAL
When: July 14, 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?
Incineration of Used Pharmaceuticals
Mobile House Grinders
BAT Update
Permits Status / Hall for Hopkins
Hall
Hall
Hall
Hall / General update
See attached information.
See attached information.
Potential implementation/guidance.
Total of 212 NSR pending – good.
112 are on the Late Permits list – not so good.
10:30
11:00 / Permit Issuance and Data Management
New items?
Transfer of Ownership guidance document
Permit process survey form.
Public Information Requests – File Review / Ahern
Ahern
Ahern
Braun / General update.
Discuss any changes needed.
Develop web-based form – need input.
**High Priority – set up meeting to create proposed policy.
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 / Comments due by July 14, 2009.
#22 – Acceptability of Manual Covers for Small Open Top Vapor Degreasers and Definition of “Enclosed Design” Degreaser / Cleveland / Comments due by August 1, 2009.
#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 extended to July 14.
#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 August 15, 2009.
#31 – Grouping Determinations for Similar Process Units Subject to Figure II / Cleveland / Comments due by September 1, 2009.
#32 – Variances from the Visible Emission Requirements / Cleveland / Comments due by September 14, 2009.
#34 - Conditions for Issuance of PTI/PTO for an Inactive Source / RAPCA / update on progress
#35 – Consideration of External and Internal Floating Roof Storage Tanks for Registration Status / Cleveland / Comments due by October 1, 2009.
#36 – Criteria for Determining Whether Fuel Burning Equipment are Either Physically or Operationally United / Cleveland / Comments due by October 14, 2009.
#44 - Permit Issuance Policy for Relocation of Portable/Mobile Facilities / NEDO / More changes needed per STARS2, working with Erica on changes.
#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 changes.
#XX – Crushers NSPS Subpart OOO / Hopkins / Hopkins review comments and address recent changes to subpart OOO.
#XX – Amended 21-07 applicability / Orlemann/Braun / Only one comment received on version two. JO and JB working to finalize.
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: September 8, 2009
> Richard Fowler 7/2/2009 3:57 PM >
DSIWM Mobile House Grinders, Stark County:
On June 24, DSIWM-NEDO received a call from Dan Aleman, Canton Local Air Agency. Dan has a proposed project in the city of Canton involving the demolition of almost 3000 houses. The city of Canton has requested proposals for the demolition and disposal of the houses. The cheapest alternative is to grind the houses on-site with mobile grinding equipment and dispose at a landfill. It is NEDO's understanding that these are all older houses where asbestos, lead paint and other issues may be present. As a result NEDO has a number of concerns regarding air pollution and solid waste/CDD disposal issues:
1. The 700 HP grinder will generate significant dust. According to Canton LAA, they can no longer use BAT permit conditions so this activity can be permitted with limited restrictions.
2. It is the contractors desire to dispose of this material as CDD waste. NEDO indicated to Dan that any material which has gone through a grinder would be considered pulverized and therefore must be disposed of at a solid waste landfill.
NEDO will continue to work with Canton LAA on the solid waste issues. It is our understanding the Canton LAA is talking with DAPC regarding the air issues. Contact: Lynn Sowers, NEDO, DSIWM (ext. 1254) and Dave Dysle, NEDO, DSIWM (ext. 1286).
If they accidentally grind asbestos isn't it all contaminated? Asbestos concerns in neighborhoods? Environmental Justice lawsuit?
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