From: Vrooman Gary L
Sent: Fri Aug 10 15:07:57 2012
To: FULLER Brian
Subject: RE: CT Rules Mobile Units
Importance: Normal
Hi Brian,
I’ll try and take a look at this early next week.
Gary
From: FULLER Brian [mailto:FULLER.Brian@deq.state.or.us]
Sent: Friday, August 10, 2012 2:10 PM
To: VROOMAN Gary L
Subject: CT Rules Mobile Units
Hi Gary,
We plan to get your review of the Conversion Technology rules sometime after the 16th. In the meantime though if you have time to look at a couple sections prior to the 16th that would be helpful.
A potential CT scenario is mobile pyrolysis unit that takes woody debris to make “biochar” (http://en.wikipedia.org/wiki/Biochar). The USFS has been researching this as a way to enhance soil health and manage slash. The CT unit would be portable and move from location to location.
The program has historically operated that our solid waste permits are site or location specific. (If a facility were to move, they could not take their existing permit with them. They’d need to apply for a new permit.) As a way to address mobile CT units we added some language to the CT rules on mobile units. This was modeled after Air Quality’s General ACDP permit for rock crushers (http://www.deq.state.or.us/aq/permit/acdp/general/AQGP-008.pdf).
Relevant AQ permit language:
1.4 Relation to local land use laws
| This permit is not valid in Lane County, or at any location where the operation of the permittee’s processes, activities, and insignificant activities would be in violation of any local land use or zoning laws. For operation in Lane County, contact Lane Regional Air Pollution Authority for any necessary permits at (541) 736-1056. It is the permittee’s sole responsibility to obtain local land use approvals as, or where, applicable before operating this facility at any location. |
7.4 Portable Plants - Relocation Notice
| If the facility is portable, the permittee must not install or operate the facility or any portion of the facility at any new site without first providing written notice to the Permit Coordinator in the appropriate regional office. The written notice must include the date of the proposed move, approximate dates of operation, a detailed map showing access to the new site, and a description of the air pollution controls and procedures to be installed, operated, and practiced at the new site. Additional permits may be required if the permittee operates individual components of the facility at more than one site at a time. |
The question is can the solid waste program issue a permit for a mobile facility? Is the what we have proposed in the rules “OK”? Do you see another way to make this happen? The main concern over ability is how it relates to land use approval. Currently 340-093-0070 (3)(b) requires a LUCS to be submitted (to make the permit application complete). We’ve modified this in regards to the mobile facility. The idea is that once a SW permit is issued the operator would need to get a LUCS from the local government prior to operating at a new location. The LUCS would not be submitted to DEQ but rather be obtained by the operator prior to operating at the new location. I suppose a twist could be to get a valid LUCS for the initial location and then require a LUCS to be obtained/on file for any subsequent locations. We are trying to avoid having to issue a new permit every time the operation moves (provided it’s doing essentially the same activity).
I’ve attached what I think are the relevant rules and here is a link to the proposed CT rules:
Give me a call if this isn’t clear.
Brian Fuller
Manager - Hazardous and Solid Waste Programs
Oregon DEQ - Western Region
541-687-7327 - Office
541-501-3349 - Mobile
*****CONFIDENTIALITY NOTICE*****
This e-mail may contain information that is privileged, confidential, or otherwise exempt from disclosure under applicable law. If you are not the addressee or it appears from the context or otherwise that you have received this e-mail in error, please advise me immediately by reply e-mail, keep the contents confidential, and immediately delete the message and any attachments from your system.
************************************