Permitting & Enforcement Committee MeetingMay 11, 2010
Permitting and Enforcement CommitteeFINAL
When: May11, 2010
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 update
New items?
Possibly Revise EAR Form. / Orlemann
Orlemann / General update.
Follow up from March meeting.
10:00
10:30 / New Source Review
New items?
Proposed Potential to Emit Guidance
SCC codes in permit document
Area source MACT & GACT / Hopkins
CDO
Hall
RAPCA / General update
Revise based on comments received.
Should SCC code be included in permit?
See information below.
How to address? See information below.
10:30
11:00 / Permit Issuance and Data Management
New items?
File Review Work Group
Title V Renewal guidance
Title V Technical Incompleteness
Title V Preliminary Incompleteness / Ahern
Ahern
Ahern
Ahern
Ahern / General update.
Comments received?
Comments received?
Final distributed on March 31, 2010.
Further discussion on guidance?
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 / 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
#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 / Version 2 sent to Jim O. 1/5/10.
#26 - Inclusion of Weight of Water in the Weight of "Refuse" Charged for Incinerators / NEDO / Draft revisions distributed 1/8/10. Submit comments by 2/15/10.
#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”.
#37 – Whether or Not Product Separation/Recovery Equipment Constitute Control Equipment / Cleveland / Two comments received by 2/12/10. Jim O. reviewing comments for final determination.
#44 - Permit Issuance Policy for Relocation of Portable/Mobile Facilities / NEDO / FINAL April 14, 2010.
#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.
#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.
12:00
12:15 / General Permit & Permit By Rule development
Create new GPs and PBRs
Crematories - Cleveland / Sarah VanderWielen to review mercury modeling November 2009.
Generators - NEDO / Working with Cheryl.
Tub Grinders - CDO / Provide status update.
Aggregate Processing – CO / Cheryl almost done with G.P. as of 11/10/09.
12:15
12:30 / New items
Title V training manual / Braun / CO/DO/LAAs create one training manual that can be used by everyone?
Pending Action Items suggested by P&E Committee / Date Action Completed
1. Suttman to prepare landfill guidance document. Need to address e-mail from USEPA regarding authority to allow changes. / Per 1/12/10 meeting, received comments on draft guidance and working with Solid Waste to finalize.
2. Orlemann to revise EAR form to remove duplicate information. / Per March 2010 meeting, Jim O. to discuss with his staff to see if changes are needed.
Next meeting: July13, 2010
From: Erica Engel-Ishida [mailto:
Sent: Monday, April 26, 2010 12:17 PM
To: 'Carl Safreed'; Braun, Jim; Andrew Hall
Cc:danaleman; Jim Orlemann; Mike Ahern; Mike Hopkins
Subject: RE: SCC code question for crematories
Hi All,
It is possible to have the SCC(s) designated in the facility profile appear in the EU specific terms. We would have to pay for the change to Stars2. It would be in Section C at the start of each the EUnear the EU ID and description.
Considerations:
- Is this only something for the PTI/Title V PTO or PTIOs as well?
- Not all EUs have SCC's listed in the profile at this time. If we add SCC's to the permit does this make it a required field for the DO/LAA to enter if it has not yet been supplied?is it OK if it is blank?
- For groups of EUs, would you want the SCC(s) listed for each individual EU?
Let me know if you need more info.
Erica
> On 4/23/2010 at 3:29 PM, Andrew Hall wrote:
The only thing I can add to the discussion at this point is what Dan suggested to me when we met last week - the suggestion that Ohio air permits (at the emissions unit level) specify SCC codes on the actual permit document. (I seem to recall that other States have done so on their Title V permits). Erica could likely speak as to the capability of STARS2 fordoing that. IfSCC codes on permit documents isa possibility then I suggest it be added as a topic for P&E (my sense being that this could turn into a rather involved project).
Andrew
> "Braun, Jim" <> 4/23/2010 2:52 PM >
Carl,
While I agree that there should be more consistency with the SCC codes, I can see where people can end up using a different code based on the search criteria that they use to find the code. If someone searches just for incineration they might not finda codespecific to cremation. Unfortunately, that's the way the system is currently working it appears. One way tohandle that would be to identify acommon emissions unit thatis processed regularly, note the different SCC codes available for that unit, and then identify the correct code to use. This would need to be handled by Central Office or USEPA though in order to ensure that people are notified accordingly of which code to use.
From:Clinefelter, Christopher [mailto:
Sent: Friday, May 07, 2010 11:20 AM
To: Braun, Jim
Cc:Canan, Jefferis; Marsee, Jenny
Subject: RE: P&E Meeting Draft Agenda
Jim,
Questions for the P&E meeting.
1)What is the latest on the state’s plan to address the various area source MACTs/GACTs? It’s our understanding that some of these are being cited as applicable rules in permits. Is that the expectation? If so, is it acceptable to cite the applicable rule by reference or put an “applicability statement” on the Facility Side? What is the expectation here if there is a compliance issue? Can the state/DOs/LAAs pursue enforcement, if the state hasn’t accepted delegation for the program?
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