Summary of Key Items from Permit Workgroup May/2006 Meeting

(June 9, 2006)

In an attempt to make the permit workgroup activities more useful to everyone, I have condensed the 05/25/06 meeting down to "five key items" as shown below. Please note that the Draft Minutes have NOT been completed (WiRO). Christy - please let us know if there are any other key issues to bring to the attention of the group:

1. There was agreement that a "Permit Writer Users Workgroup" is needed to address permit writer issues with participation by each regional office. Bob Kennedy will be taking the lead in establishing the date of the first meeting. Each region is expected to have at least one participant.

2. There are several pending requests by concrete batch facilities to use "alternative" controls, involving water spray devices, rather than a filter system to control loadout emissions. Gary Saunders will work with Water Quality in Raleigh Central to establish the history and concerns with respect to runoff from water spray systems. He will report back to the workgroup on the appropriate criteria for reviewing and accepting alternative control systems.

3. Some of the Title V permits will be re-opened for cases involving a recent "last MACT" to add a permit condition specifying that the "last MACT toxics demo" process was completed or needs further action.

4. It was agreed that all regions should be using the same permits approach in handling facilities with only emergency generators. Tom McKinney will draft language to update the guidance on this issue.

5. Jim Roller made a presentation to group regarding modeling for quarries. (Let me know if you would like a copy.) MRO will be preparing a permit for a quarry that replaced a primary crusher but needs additional time (after installing) to conduct the required modeling.