Permitting & Enforcement Committee MeetingSeptember 13, 2011
Permitting and Enforcement CommitteeFINAL
When: September13, 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?
Scheduled maintenance request process / Kalman/Paulian
Paulian / General discussion.
Need to clear up some confusion, possibly create policy.
10:00
10:30 / Permitting
Update on renewal project
General Permit development project
Proposed Potential to Emit Guidance
Temporary activities – permit needed? / Hopkins
Hopkins
CDO
OCAPP / General update.
General update.
Legal is currently reviewing - will redistribute for further comment.
See note below.
10:30
11:00 / Permit Issuance and Data Management
New items?
Generating Certain NOVs / Ahern
Engel-Ishida / General update.
Should the PIER unit increase/decrease or continue generating certain NOVs? See note below.
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.
#69 – Guidance on Air Dispersion Modeling / VanderWielen / Provide comments to Sarah by mid-August. Want to finalize by October. Might merge with EG 70.
#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. Need volunteers to resume work on this guide.
#XX – Non-road Engines / SEDO / update on progress
#XX – Emission unit ID designations / Ben Cirker / Tom Kalman reviewing as of 7/12/11.
#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 modelingSeptember 2010.
Tub Grinders - CDO / Draft terms distributed – comments due April 20, 2011.
Anaerobic Digesters / Jenny Avellana preparing GP.
Miscellaneous Metal / Cheryl working on changes for Chapter 17 and GACT (HHHHHH).
Compression Ignition RICE / Revised and issued Draft – public comment through June 24, 2011.
12:15
12:30 / Training
New training items? / All / Any new training on the horizon?
12:30
12:45 / New items
New items? / All / Any new topics to discuss?
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: November 8, 2011
OCAPP – permitting of temporary sources
From: Carleski, Rick [mailto:
Sent: Tuesday, September 06, 2011 12:36 PM
To: Braun, Jim
Cc: Carleski, Rick; Carney, Jim; Korenewych, Pam; LaFavre, Adrienne; Nabors, Ron; Pellegrino, Jim; Sowry, Dan; Witte, Ralph
Subject: RE: P&E Meeting Draft Agenda -requested item
OCAPP would like to request this be added to the 9/13 P&E agenda, possibly during the Permitting Section update:
- The recent draft GP for oil & gas drilling sites contained a write-up that described all air pollution sources to be covered under the proposed GP. That summary also contained statements that air permits were not needed for some activities because they were temporary.
OCAPP frequently encounters temporary sources such as the painting/blasting of outdoor structures, concrete cutting, portable wood chippers, construction roadway fugitive dust, etc. These things are not outright exempt in 31-03, nor always able to meet de minimis thresholds. OCAPP would like clearer guidance from DAPC on this issue.
PIER – continue generating certain NOVs
From: Engel-Ishida, Erica [mailto:
Sent: Thursday, August 11, 2011 1:35 PM
To: Braun, Jim
Cc: Ahern, Mike; Thomas, Elisa; Paulian, John; Kalman, Tom
Subject: P&E Topic
I have a topic to add to the agenda for the next P&E meeting. Should the PIER Unit Increase/Decrease or continue generating certain NOVs?
Historically our unit generated the NOV’s for FER/EIS submission and Title V applications because we had the ability to query the populations more easily. Now these are features in Stars2 available to all users. Should our unit continue this practice or pass that responsibility on to the DO/LAA where other NOV generation resides?If we keep it, what about Title V Compliance Certifications? Should we do those too?
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