P.1 

OAR Box 1790 

Prepped by Keeia Richards 

Document Number: 

207) ll-E-3 

Docket Number: 

A-90-37 

Printed 10/31/2008 12:43:16 PM Sheet 207 of 250 
P.2 

II 

J**"** . 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

Jul y 10, 1989 

MEMORANDUM 

SUBJECT: Meeting wit h Offic e of Management and Blidget (OMB) 

on Draf t Top-Down Best Availabl e Cftcf :ro[l Technology 

(BACT) Paper and PMlfJ IncrerfeJtjts J Kyy 

FROM: Edward J . Lillis , Chief ~TA l/\ 

Noncriteria Pollutant Programs Branch 

TO: John Calcagni, Director/ 

Air Quality Management/Division 

UU L 

995 

* EPA AIR DOCKET 

On June 20, we met with OMB to discuss the draft top-down BACT paper and 

the PM1Q increments package. Attendees are listed in Attachment 1. 

Too-Down BACT 

Most of the time was spent answering questions on the overall top-down 

BACT procedure and why the Environmental Protection Agency (EPA) is now 

requiring the top-down approach. They seemed to suggest that increased 

emphasis on a bottom-up approach would be preferential but did not state that 

position as such. They questioned whether the Clean Air Act (CAA) allowed EPA 

by policy [versus by rule] to tell a permit applicant (versus a State or local 

agency) what must be considered in a BACT analysis. They also asked about the 

level of documentation required of a source. We pointed out that it was no 

more than had always been expected of an applicant since the original BACT 

guidance was developed in the late 1970's. We agreed to send OMB a copy of 

the 1980 Prevention of Significant Deterioration (PSD) Workshop Manual that 

provides examples of the types of data the applicant must present. 

After responding to a number of these general questions and concerns, 

Nick Garcia indicated that OMB believed this policy was significant enough to 

warrant formal OMB review. I indicated that since it expanded on a policy 

that has been in effect for 1 1/2 years, and which does not change any 

existing rule, that we questioned whether OMB's review was necessary. I 

recommended to Mr. Garcia that his management seek formal review of this paper 

if they wanted to do so. 

PM} Q Increment Package 

The discussion on the PMjg increment package was very limited. Their 

primary request was for an explanation of why we recommended the "equivalent" 

approach versus the "percent national ambient air quality standard" approach 
P.3 

for selecting PMj0 increments. Once explained, OMB representatives did not 

appear to disagree with the rationale. They did point out that since PMI Q 

increments are in the CAA Amendments, which are due to be announced shortly by 

the Administrator, that they felt EPA's PM-^Q increments package should be 

delayed until the CAA Amendments are announced, and that they (i.e., the 

increments) should be consistent with the Administration's CAA Amendments 

(which they currently are). The indication was that OMB would hold the 

package until the Amendments were announced, which, at that time, was 

anticipated by Friday, June 23. 

I asked Mr. Garcia if, in the future, we could handle reviews of 

regulatory packages by teleconference call, particularly the PMjQ-type 

discussion that was completed in about 10 minutes or so. We learned that OMB 

apparently has limited teleconference capabilities but, if EPA initiates the 

call, conference calls may be an acceptable alternative in some situations. 

Mr. Garcia also suggested that he would be interested in a trip to EPA 

(Research Triangle Park) to discuss various packages; however, travel dollars 

are tight for the remainder of this fiscal year. I recommend that we pursue 

asking Mr. Garcia to visit with us next fiscal year. 

Attachment 

cc: D. 

T. 

G. 

D. 

R. 

s. 

G. 

D. 

D. 

Skie 

Eagles 

Foote 

Novello 

Campbell 

Hitte 

McCutchen 

deRoeck 

Solomon 
P.4 

ATTACHMENT 

EPA Attendees 

Tom Eagles 

Douglas Skie 

Greg Foote 

David Novello 

Ed Lillis 

Gary McCutchen 

Dan deRoeck 

David Solomon 

OMB Attendees 

Nicholas Garcia 

Richard Belzer