P.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

94) IV-C-8 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:22 AM Sheet 94 of 142 
P.2 

& S^m\ 

-ft 

y % A-10-37 

£ A ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 7 0 - C " 8 

| ^[g ^ | RESEARCH TRIANGLE PARK. NC 27711 

%wa*& 

April 5, 1999 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Mr. Mark Wygonik 

Flexible Packaging Association 

1090 Vermont Ave., N.W., Suite 500 

Washington, D.C. 20005-4960 

Dear Mr. Wygonik: 

This is in response to your March 30,1999 letter to John Seitz that requests a meeting 

with him and appropriate staff later this month to discuss pending reform of the New Source 

Review (NSR) program. We very much appreciate the work that your members have done to 

develop What you believe to be reasonable and rational changes to the NSR program. 

The work you describe sounds interesting. You mentioned that your idea would be to 

suggest changes that would result in lower emissions, increased permit efficiency, increased 

operational flexibility, reduced reporting burden on State agencies, and increased consistency in 

definitions and interpretations, and leave a system that encourages manufacturing operations to 

reduce pollution before it is generated. Once you have a work product that does these things, 

please send it to us for our review. Pending our review, we will determine whether a meeting 

makes sense, given all of our busy schedules. 

As you know, in the February 2-3 meeting, we asked that by February 28 stakeholders 

provide written proposals that addressed some of the key issues identified on February 2-3. To 

date, we have received only one written product. The EPA is willing to review any work product 

that you develop that reflects a way of dealing with applicability issues that will help us as we 

finalize our NSR Reform rulemaking effort. 

Because of EPA's interest in moving forward on NSR Reform, we have resumed work to 

produce a final rulemaking, based largely on the 1996 proposal, the 1998 notice of availability, 

and the ensuing comments on each. We plan to promulgate the rule around the end of 

December 1999 which would have us completing a draft of the Federal Register package around 

June 1999. If a work product can be produced in a timely manner relative to our schedule, we 

will take due consideration of it in promulgating the final rule. This means that you should 

provide such information to us by May 21,1999 so that we can stay on track with our schedule. 

Recycled/Recyclable .Printed with Vegetable OD Based Inks on 100% Recycled Paper (40% Postconsumer) 
r 

^ P.3 

« V "f -IP""'1 > " ' 

I want to thank you for your work on this issue. I look forward to reviewing your 

altemative approach t@ NSR that would help us to bring the NSR Reform effort to closure. 

Please contact Karen !lanG%aQ?d at (919) 54|l-5503 regarding whether a meeting to discuss your 

completed work product should be sehedulid. 

Sincerely, 

William Harnett 

Acting Director 

Information Transfer and Program 

Integration Division 

2, 
P.4 

. 81/14/_195 :23:57 2028423B41 FLEXIBLE PKG ASSN PAGE 02 

.' / ' 

/ 

Flexible Packaging Association 

March 30,1999 

Mr. John Seitz 

MD-10 

US EPA Mailroom 

Research Triangle Park, NC 27711 

Dear Mr. Seitz: 

The Flexible Packaging Association requests a meeting with you and the appropriate US 

EPA staff, to discuss pending reform of the New Source Review program. We request a 

' four-hour meeting on April 19,20 or 21. 

Our members have worked diligently since the February 2 & 3 Washington, DC, 

Stakeholders meeting, to develop what we believe arc reasonable and rational changes to 

the NSR program. These changes would result in lower emission, increased permit 

efficiency, increased operational flexibility, reduced reporting burden on state agencies, 

increased consistency in definitions and interpretations and leave a system that 

encourages manufacturing operations to reduce pollution before it is generated. 

We would like to bring a small group of environmental managers from several FPA 

companies to discuss the merits of these suggestions. We would also like to bring a few 

of our Corporate CEO's to help the discussions address real world facilities. We would 

like to meet at EPA's offices in Research Triangle Park. 

During presentations at FPA's 1999 Environmental Summit, Dennis Crumpler and Bruce 

Jordan encouraged FPA to get involved in the regulatory development process and we 

have. After our presentation made during the February 2 & 3 Stakeholders meeting, FPA 

became concerned with some of the suggested reforms forwarded by large industry 

sectors and with the misconceptions held by EPA regarding the effects of NSR on 

flexible packaging manufacturing. In particular, FPA is concerned that EPA's emphasis 

on big business will result in reforms that contain little consideration for the constraints 

of small business. 

( sourceU. reduction 

1090 Vermont Ave.. N.W., Suite 500, Washington. D.C. 20005-4960 

(202)842-3880, Fax (202) 842-3841, e-mail: fifa@flexpack.org 

3 
P.5 

•— '"'fW ¥ W "f "If-W !"! r 

01/14/1995 23:57 2028423141 FLEXIBLE PKG ASSN EAGE *»03 

? * 

March 30,1999 

Page 2 

FPA believes our request for a meeting lis important. We have committed our industry's 

environmental mariagernent experts and) our industiy's corporate leadership to this 

meeting. We request the participation c|f David Solomon, Dennis Crumpler and Tom 

Curran and we encourage the participation of Bruce Buckhcit and others from the Office 

of Enforcement and Compliance Assurance. 

In order for our participants to make travel arrangement, we would appreciate a response 

as soon as is possible. 

We await your response. 

\ 

Sincerely, 

Mark Wygonikf(j 

Director - Technology &. Regulatory Af&irs 

CC: 

Tom Curran 

MD-10 

US EPA Mailroom 

Research Triangle Park, NC 27711 

Dennis Crumpler 

MD-12 

US EPA Mailroom 

Research Triangle PMc. NC 27711 

4-