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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

i/fpe) II-D-31 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:01 AM Sheet 96 of 132 
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M*D-3 / 

Date sent: Mon, 18 May 1998 09:25:07 -0400 

From: "Wang DL (Don)" <wangdl@ucarb.com> 

To: SHEDD.STEVE@EPAMAIL.EPA.GOV 

Copies to: liukf@ucarb.com, soicejr@ucarb.com 

Subject: RE: OLD MACT Applicability -Reply 

Steve: 

Re: facilities that have not applied for a synthetic minor but plan to , ---^, 

do so, I think whether the source needs to fill out the ICR form ~"~~* 

depends on how confident they feel about procuring the synthetic minor 

permit. 

As an example, I would feel relatively confident in getting approval / , I" 

if the control/monitoring proposal were already proven or that 7 / 

reliability/accuracy were easily shown (KISS principle). / 

/ '~— ; 

The above would depend on the experience and creative tendencies .of 

the State Permitting Authority and its EPA Regional Office 

counterpart, which the source would be aware of. 

I would leave it up to the individual source. They know the 

consequences of not filling out an ICR form when they should have, and 

would be in the best position to assess the risk that they are taking 

and wish to take. 

This is my opinion. I'm sure that the other members in our our Band of 

Merry Men would have interesting ideas on the subject. Don > 

> From: STEVE SHEDD[SMTP:SHEDD.STEVE@epamail.epa.gov] > 

Sent: Friday, May 15, 1998 4:31 PM > To: Wang DL (Don) > Cc: 

bhaneke@rtp.pes.com; glaflam@rtp.pes.com > Subject: OLD MACT 

Applicability -Reply > > «Message : OLD MACT Applicability» > Don, > 

> I think you are correct if they are true or synthetic minors. If > 

they have not received their synthetic status and they are above > 

5/12.5 criteria, then we need to discuss and figure out what we can > 

do. If a facility is nearly finished the process and has submitted a 

> complete application on getting that synthetic status is one thing. 

> However, for those having just started the process and have no clue 

as > to the outcome or possibility of receiving synthetic minor status 

then > this is a different case. How do we distinguish? Is the 

facility > willing to take a risk? What do you think? > > Please get 

Greg LaFlam - 1 - Mon, 18 May 199812:10:23 
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back to me on any thoughts you have! > > Steve > > > > Stephen Shedd > 

U.S. EPA > Office of Air Quality Planning and Standards > Research 

Triangle Park, NC 27711 > voice: (919) 541-5397 > fax: (919) 541-0246 

> E-mail: shedd.steve@epa.gov > > > » "Wang DL (Don)" 

<wangdl@ucarb.com> 05/15/98 02:58pm > » > Steve: > Got some more 

questions. > > I have facilities that make only one type of product. 

They have been > determined to be either true minors or are expected 

to receive > synthetic > minor status. > > Do they have to fill out 

the OLD MACT ICR's if they trigger the ICR > applicability 

determination (based on actual) but not the major source > definition 

for MACT's? If so, why? > > Thxs in advance. Don > > > 

Greg LaFlam - 2 -- Mon, 18 May 199812:10:23 

Z 
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Date sent: Fri, 15 May 1998 16:31:15 -0400 

From: STEVE SHEDD <SHEDD.STEVE@epamail.epa.gov> 

Subject: OLD MACT Applicability -Reply 

To: wangdl@ucarb.com 

Copies to: bhaneke@rtp.pes.com, glaflam@rtp.pes.com 

Don, 

I think you are correct if they are true or synthetic minors. If 

they have not received their synthetic status and they 

are above 5/12.5 criteria, then we need to discuss and figure out what 

we can do. If a facility is nearly finished the process and has 

submitted a complete application on getting that synthetic status is 

one thing. However, for those having just started the process and 

have no clue as to the outcome or possibility of receiving synthetic 

minor status then this is a different case. How do we distinguish? 

Is the facility willing to take a risk? What do you think? 

Please get back to me on any thoughts you have! 

Steve 

Stephen Shedd 

U.S. EPA 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

voice: (919) 541-5397 

fax:(919)541-0246 

E-mail: shedd.steve@epa.gpv 

> » "Wang DL (Don)" <wangdl@ucarb.com> 05/15/98 02:58pm » > 

Steve: 

Got some more questions. 

I have facilities that make only one type of product. They have been 

determined to be either true minors or are expected to receive 

synthetic minor status. 

Do they have to fill out the OLD MACT ICR's if they trigger the ICR 

Greg LaFlam - 1 - Mon, 18 May 1998 08:32:29 

3 
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applicability determination (based on actual) but not the major source 

definition for MACT's? If so, why? 

Thxs in advance. Don 

Greg LaFlam - 2 - Mon, 18 May 1998 08:32:29