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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

140) IV-C-54 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:24 AM Sheet 140 of 142 
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#X - 0-H> 3 A-90-37 

IV-C-54 

^ ^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

s J2L ^ WASHINGTON, D.C. 20460 

HAY 1 7 2002 

OFFICE OF 

AIR AND RADIATION 

Mr. Douglas C. Shumway 

Mitsubishi Cement Corporation 

5808 State Highway 18 

Lucerne Valley, CA 92356-9691 

Dear Mr. Shumway: 

Thank you for your letter of March 21,2002, to Administrator Whitman in which you 

express support for several ideas that the Environmental Protection Agency is currently 

considering to improve the new source review (NSR) program. Administrator Whitman and I 

are committed to the air quality benefits provided by the NSR program, but we believe that the 

program can and should be improved. We are examining several ideas for improving the 

program to provide more regulatory flexibility and certainty, while creating incentives for 

industrial facilities to achieve environmental results. 

Thank you also for voicing your support for some of the options we are currently 

considering. I have noted your support for plantwide applicability limits, for the "actual-tofuture-actuar method for calculating emissions increases, and for cost thresholds and sector 

specific guidance for determining what constitutes "routine maintenance." I have also asked that 

your letter be included with other public comments in the docket for the NSR improvement 

rulemaking. We expect to announce the results of this effort later this year. 

Again, thank you for your letter. I appreciate the opportunity to be of service, and trust 

that the information provided is helpful to you. 

Sincerely, 

ffrey R. Hblmstead 

Assistant Administrator 

Internet Address (URL) • http://www.epa.gov 

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STATUS: 

Controlled Correspondence For 

OFFICE OF AIR AND RADIATION 

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PRIG. DUE PATE: 04/16/2002 . . 

MGRFA CORR 141 MAJOR CORR-GOVERNOR'S READING FII-E - ASSIGNED \V ' <s 

PENDING CORRES. DATE: 

RECEIVED DATE: 

ASSIGNED DATE: 

CLOSED DATE: 

03/21/2002 

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FROM: 

ORG: 

SALUTATION: 

CONSTrrUENT; 

TO: 

TO ORG: 

SUBJECT: 

ASSIGNED: 

SHUMWAY DOUGLAS C 

MITSUBISHI CEMENT CORPORATION 

ADMINISTRATOR 

EPA 

SUPPORT CHANGES TO NEW SOURCE REVIEW PROGRAM 

OFFICE OF AB. QUALITY PLANNING AND STANDARDS 

•'V 

COPIES OF INCOMING PROVIDED TO: AO -CAROLINE PETTI 

SIGNATURE: ASSISTANT ADMINISTRATOR 

OAR COMMENTS: 

AX INSTRUCTIONS: PREPARE REPLY FOR THE ASSISTANT ADMINISTRATOR'S SIGNATURE. 

SEND COPY OF REPLY TO OEX. 

GOVERNOR'S READING FILE. READ BY CHRISTINE TODD WHITMAN. 

ORIGINAL ASSIGNED TO: JEFF HOLMSTEAD 

OAR INSTRUCTIONS: ;;;; PREPARE REPLY FOR TIDE ASSISTANT ADMINISTRATOR'S 

SIGNATURE. 

|Ua d 

Assigned 

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Date Assigned 

04/06/2002 

Code/Status Date Completed by 

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OFFICE OF THE EXECUTIVE SECRETARIAT 

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CONTROL NO: AX-02034B1 PRIG. DUE DATE: 04/18/2002 

FILE CODE; MGRFA CORR 141 MAJOR CORR-GOVERNOR'S READING FILE • 

ASSIGNED BY CTW 

STATUS: 

FROM: 

ORG: 

SALUTATION: 

CONSTITUENT: 

TO: 

TO ORG: 

SUBJECT: 

PENDING CORRES. DATE: 03/21/2002 

RECEIVED DATE: 04/02/2002 

ASSIGNED DATE: 04/04/2002 

CLOSED DATE: 

SHUMWAY DOUGLAS C 

MITSUBISHI CEMENT CORPORATION 

ADMINISTRATOR 

EPA 

SUPPORT CHANGES TO NEW SOURCE REVIEW PROGRAM 

ASSIGNED: AIR &c RADIATION 

COPIES OF INCOMING PROVIDED TO: AO-CAROLINE PETTI 

SIGNATURE: 

INSTx 

COMMENTS: 

IMS: 

IMT: 

ASSISTANT ADMINISTRATOR 

PREPARE REPLY FOR THE ASSISTANT ADMINISTRATOR'S SIGNATURE. 

SEND COPY OF REPLY TO OEX. 

GOVERNOR'S READING FILE- READ BY CHRISTINE TODD WHITMAN. 

ORIGINAL ASSIGNED Ta JEPF HOLMSTEAD 

SCV 

SHARON VANMETER/DC/USEPA/US 

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Assigned 

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Date Assigned 

04/03/2002 

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MITSUBISHI CEMENT CORPORATION 

CUSHENBURY PLANT. 5808 STATE HIGHWAY 18, LUCERNE VALLEY, CA 92356-9691 TELEPHONE (700) 248-7373 

March 21,2002 

Honorable Christine Todd Whitman 

Administrator 

U.S. Errvirorimental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

RECEIVED 

APR - 2 2002 

EXEC. SECRETARIAT 

Dear Ms. Whitman, 

Mitsubishi Cement Corporation supports the proposed changes to the existing NSR 

program. 

While the objectives of the initial drafters of the NSR program were well intentioned, 

history has proven that the program's objectives are not being met under its current 

structure. All too often, facility operators in our industry ekctto forego manufacturing 

process changes and improvements out of concern that they will trigger NSR review. In 

a perverse way, the program - established to foster implementation of state-of-the-art 

technologies—often imposes a chilling effect on projects that could enhance 

environmental protection, 

A few key changes would go a long way towards improving the program without 

sacrificing protection of human health and the environment. Specifically, Mitsubishi 

Cement would support plant-wide applicability limits, cost thresholds to facilitate 

distinctions between major modifications and routine maintenance, sector-specific 

maintenance guidance, and extension of the Wisconsin Electric Power Company criteria 

to all industries. 

Thank you for considering our comments. 

Sincerely, 

Douglas C. Shumway 

Environmental Manager 

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