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OAR Box 1802 

Prepped by Charmelle Mathews 

Document Number: 

81) IV-E-75 

Docket Number: 

A-90-37 

Printed 11/4/200811:58:00 AM Sheet 81 of 117 
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>0-37 

IV-E-75 

Meeting date: 5-23-01 

Attendees: 

Chuck Turner, VADEQ (clturner@deq.state.va.us) 

Makeba Morris, EPA. Region III 

Donna Weiss, EPA, Region III 

Lynn Hutchinson, EPA 

Milton Robinson, EPA 

Charles Howland, EPA, Region III, 

Chris Menen, EPA, Region III 

Neil Bigioni, EPA, Region III 

Marie Holman, EPA, Region III 

Sharon Baxter. VADEQ (skbaxter@deq.state.va.us) 

Monica Gibson, EPA 

Ted Cochin, EPA 

Meeting Summary: 

The EPA held a teleconference with representatives of the Department of Environmental Quality for the 

State of Virginia (VADEQ) to discuss their potential submission of an ECOS project dealing with New 

Source Review. The EPA believes that VADEQ's potential ECOS project is very similar in concept to the 

Clean Unit Exclusion that EPA intends to finalize as part of its NSR reform efforts. The purpose of this 

meeting was to discuss the current Agency thinking on the Clean Unit Exclusion so that the VADEQ could 

decide whether they wish to pursue a New Source Review ECOS proposal. 
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Meeting date: 5-23-01 

Attendees: 

Chuck Turner, VADEQ (clturner@deq.state.va.us) 

Makeba Morris, EPA, Region III 

Donna Weiss, EPA, Region III 

Lynn Hutchinson, EPA 

Milton Robinson, EPA 

Charles Howland, EPA, Region III, 

Chris Menen, EPA, Region III 

Neil Bigioni, EPA, Region III 

Marie Holman, EPA, Region III 

Sharon Baxter, VADEQ (skbaxter@deq.state.va.us) 

Monica Gibson, EPA 

Ted Cochin, EPA 

Meeting Summary: 

The EPA held a teleconference with representatives of the Department of Environmental Quality for the State 

of Virginia (VADEQ) to discuss their potential submission of an ECOS project dealing with New Source 

Review. The EPA believes that VADEQ's potential ECOS project is very similar in concept to the Clean Unit 

Exclusion that EPA intends to finalize as part of its NSR reform efforts. The purpose of this meeting was to 

discuss the current Agency thinking on the Clean Unit Exclusion so that the VADEQ could decide whether 

they wish to pursue a New Source Review ECOS proposal. 
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Do Not Cite or Quote - Not Final Agency Position 

Clean Unit Fact Sheet 

There would be a two step process for determining if a unit is clean. 

First, the unit would go through the appropriate major source (or minor) 

NSR process (BACT/LAER, ambient impacts analysis, Class I impacts). 

Then, the outcome would be compared to other sources in the RBLC. 

- For a unit in an attainment area to be deemed clean, it must be within 90% if the best BACT 

for a similar soruce in the RBLC. 

- For a unit in a nonattainment area to be deemed clean, it must be at least as stringent as the 

best LAER limit for a similar source in the RBLC. 

A unit going through minor NSR review could qualify for as clean unit if 

the minor NSR program has a technology review component and ambient 

impact analysis, and assures no impact on AQRVs. 

The exclusion would be effective for 10 years from issuance of the NSR 

permit. (Regardless of when the unit is actually deemed clean.) After 10 

years, the unit could undergo a new clean unit analysis with a new ambient 

impacts analysis and re-qualify for the exclusion, if appropriate. 

The exclusion would not apply if the unit increases is maximum hourly 

emissions rate (using the NSPS test) or intends to operate above its 

permitted allowable emission rate due to a physical or operational change. 

Thus, although we call this an "exclusion" it is functionally equivalent to 

changing the applicability test from a current maximum hourly to future 

maximum hourly emission calculation. 

The exclusion would expire if the unit does not begin construction within 

18 months after the NSR permit is issued. The unit would have to go 

through the process again to re-qualify for the new exclusion. 

The request for a clean unit exclusion must undergo public review through 

either the major NSR or Title V permit process. 

The issue as to whether the "clean unit" exclusion should apply when 

BACT/LAER is determined to be no control is still being discussed within 

the Agency. 
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Do Not Cite or Quote - Not Final Agency Position 

CLEAN UNIT TEST WORKSHEET 

(1) Calculate the PTE in tons per year ofthe unit with the current controls. 

(2) Calculate the PTE in tons per year ofthe unit without the current controls. 

(3) Calculate the PTE in tons per year ofthe unit with the "best controls". 

(4) Subtract line (1) from line (2) 

(5) Subtract line (3) from line (2) 

(6) Divide line (4) by line (5) and multiply by 100 % 

Check one of the following: 

The number on line (6) is 90% or greater, the unit qualifies as a "clean unit" 

The number on line (6) is less than 90%, the unit does not qualify. 

CLEAN UNIT TEST - EXAMPLE CALCULATION 1 (in tons per year) 

(1) Calculate the potential to emit ofthe unit with the current controls. 190 

(2) Calculate the potential to emit ofthe unit without the current controls. 1000 

(3) Calculate the potential to emit ofthe unit with the "best controls"*. 100 

(4) Subtract line (1) from line (2) 810 

(5) Subtract line (3) from line (2) 900 

(6) Divide line (4) by line (5) and multiply by 100 90 % 

Check one of the following: 

The number on line (6) is 90% or greater, the unit qualifies as a "clean unit" X 

The number on line (6) is less than 90%, the unit does not qualify. _ 
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BS^Fjrj Do Not Cite or Quote - Not Final Agency Position 

CLEAN UNIT TEST - EXAMPLE CALCULATION 2 (in tons per year) 

(1) Calculate the potential to emit ofthe unit with the current controls. 300 

(2) Calculate the potential to emit ofthe unit without the current controls. 1000 

(3) Calculate the potential to emit ofthe unit with the "best controls"*. 100 

(4) Subtract line (1) from line (2) 700 

(5) Subtract line (3) from line (2) 900 

(6) Divide line (4) by line (5) and multiply by 100 78 % 

Check one of the following: 

The number on line (6) is 90% or greater, the unit qualifies as a "clean unit" 

The number on line (6) is less than 90%, the unit does not qualify. X