P.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

14|) IV-C-U 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:24 AM Sheet 141 of 142 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

June 24, 1994 

P.2 

? r 

I 

Mr. Ernie Rosenberg 

Occidental Petroleum 

1747 Pennsylvania Avenue, NW .'. " - ^ • ~ .' -' 

Washington, DC 20006 ~ / 

Dear Mr. Rosenberg: 

As discussed and agreed at the March 1994 New Source Review 

(NSR) Reform Subcommittee meeting, the next Subcommittee meeting 

is scheduled to be held on July 19-20, 1994. The primary focus 

of this meeting will be an opportunity for the Subcommittee to 

respond to a staff draft of the NSR reform rulemaking package. 

As part of her continuing commitment to have the NSR reform rule 

move swiftly through the rulemaking process, Mary Nichols, 

Assistant Administrator for Air and Radiation, is planning to 

attend to hear the Subcommittee's comments on this package. 

Since the last Subcommittee meeting, Agency staff have been 

diligently working on draft preamble and regulatory language that 

addresses the numerous issues identified and deliberated upon by 

the Subcommittee. As originally scheduled, the draft rulemaking 

package was to be mailed to the Subcommittee members by June 15, 

1994. However, due to a number of factors, development of the 

draft rulemaking package has taken longer than anticipated and 

will not be mailed until early July. I recognize that the 

postponed mailout shortens your review period but hope that you 

will be able to focus your attention on the package during the 

2-week period preceding the meeting. Of course, you will not be 

limited to your oral comments at the meeting. We intend to 

accept your written comments on this draft package until 

August 31, 1994. 

To facilitate distribution of the rulemaking package, we are 

planning to mail you a 3.5 inch high-density DOS-formatted 

computer disc containing WordPerfect 5.1 files. This will 

greatly expedite the distribution of the material and should also 

provide you with increased flexibility to search and comment on 

the package. However, if you prefer to receive a hard copy of 
P.3 

1 

-.Vthe rulemaking package instead of a computer disc, please contact 

Larry Elmore at (919) 541-5433 as soon as possible. Also, please 

contact Larry if you fail to receive the draft rulemaking 

package, either the disc or hard copy, by 1 week before the 

Subcommittee meeting. 

In response to previous requests by Subcommittee members and 

to facilitate participation of Agency personnel, we will be 

holding the July 1994 NSR Reform Subcommittee meeting in the 

Washington, DC area. This meeting will be held at the Hyatt 

Regency Crystal City, 2799 Jefferson Davis Highway, Arlington, 

Virginia (telephone (703) 418-1234, telefax (703) 418-1289). A 

meeting agenda will be included with the rulemaking package. 

As always, I very much appreciate your continued 

participation in the NSR reform process. If you have any 

questions, please do not hesitate to contact me at (919) 541-5504 

or David Solomon at (919) 541-5375. I look forward to seeing you 

in July. 

Sincerely, 

/s/ 

Lydia N. Wegraan 

Deputy Director 

Office of Air Quality Planning 

and Standards 

OAQPS:AQMD:PPB:NSRS:L.Elmore/C.Bradsher(541-5433/MU)6/23/94. 

File = a:\JULY94\LETTER.2 

IDENTICAL LETTERS SENT TO: (See attached list) 

bcc: S. Hitte 

E. Lillis 

D. Solomon 

L. Elmore 

NSR Section 

B. Polkowsky 

B. Blaszczak 

C. Poffenberger 

C. Knopes 

B. Tyndall 

M. Kataoka 

V. Patton 

L. Hamjian 

E. Glen 

M. Spinks 

G. Worley 

R. Van Mersbergen 

D. Bray 
P.4 

_ _ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I \<9s*%j 1 Office of Air Quality Planning and Standards 

\ ^eCmC *' Research Triangle Park, North Carolina 27711 

\ PRO^° 

JUL 111994 

NOTE 

TO: New Source Review (NSR) Reform Subcommittee Members and 

Participating Federal Officials 

In preparation for the July 19-20, 1994 meeting of the NSR 

Reform Subcommittee, attached for your review is an initial staff 

working draft of a proposal to amend the NSR regulations based 

largely on the discussions and suggestions of the Clean Air Act 

Advisory Committee (CAAAC) NSR Reform Subcommittee. Also 

attached is a tentative agenda for the meeting. 

At the last Subcommittee meeting, Mary Nichols, Assistant 

Administrator for Air and Radiation, Environmental Protection 

Agency (EPA), discussed a schedule in which EPA would complete a 

NSR Reform proposal package in early 1995, with a final rule 

one year later. As you well know, this is a very ambitious 

schedule, and the EPA staff involved have been diligently working 

to ensure that a rule is promulgated consistent with this 

schedule and to have a draft proposal package in time for the 

July meeting. Due to the short lead time and the number and 

complexity of the issues being addressed, the attached document 

has not been reviewed by any level of EPA management and has 

undergone only limited internal staff review. Consequently, it 

does not, nor should it be construed to, represent an official 

EPA position on any of the views or positions contained within. 

In addition, please note that the proposed regulatory 

language has not yet been fully developed and, therefore, may not 

completely reflect the policy positions set out in the preamble. 

However, the attached draft rulemaking package and, in 

particular, the portions of the draft preamble addressing EPA's 

proposed policies should provide an ample basis for further 

discussion and comment. 

Also attached for your review is a concept paper which 

directly relates to many of the Class I area issues that have 

been presented to, and discussed by, the Subcommittee. The paper 

describes an innovative regional approach for implementing the 

prevention of significant deterioration requirements for 
P.5 

1 -

- ~4 

protecting Class I areas, which is being developed by the 

Interagency Work Group on Air Quality Modeling. During the 

meeting, the Interagency Work Group's proposal will be discussed 

as a possible alternative for incorporation into the NSR Reform 

effort. 

In addition to written and oral comments presented at the 

meeting, written comments on the draft rulemaking proposal and 

the concept paper will be accepted until August 31, 1994. To 

maintain the ambitious rulemaking schedule for NSR Reform, late 

comments may not be fully considered in the development of the 

final proposal. Comments should be sent to me at Mail Drop 15, 

U.S. EPA, Research Triangle Park, NC 27711. 

The draft rulemaking proposal is contained on the enclosed 

high-density DOS formatted diskette in the form of WordPerfect" 

5.1 files. This was done to expedite the receipt of the material 

and should provide the reviewer with an enhanced ability to 

search and rearrange text when making suggested changes. The 

diskette contains the following four files: 

PREAM.DRF Draft preamble. 

51165.DRF Draft changes to nonattainment NSR regulations. 

51166.DRF Draft changes to PSD regulations. 

5221A.DRF Draft plantwide applicability PSD rules (only). 

If you have difficulty accessing these files, prefer a printed 

copy of the rulemaking package, or have any questions about the 

upcoming meeting and agenda, please feel free to contact me at 

(919) 541-5375 or Larry Elmore of my staff at (919) 541-5433. 

Thank you again for your continued participation in, and 

support of, the NSR Reform effort. We look forward to working 

with you at the upcoming Subcommittee meeting. 

Davi/d Solomon 

Chief 

New Source Review Section 

3 Attachments 

cc: L. Wegman 

S. Shaver 

E. Lillis 

NSR Contacts 
P.6 

/Mo-^ 

New Source Review Reform Subcommittee Meeting" 

July 19-20, 1994 \ 

Hyatt Regency, Crystal City, VA tt zs Revised Agenda I \ 'w**" \ 

Tuesday, July 19, 1994 

9:00 am Opening remarks, review of agenda, and adjustments to the program. 

- Remarks by Lydia Wegman, Subcommittee Co-chair and 

Deputy Director, Office of Air Quality Planning and Standards, US EPA. 

9:15 am Presentation and discussion of EPA staff draft revisions to Best Available Control 

Technology (BACT) and Lowest Achievable Emission Rate (LAER) requirements. 

- Presented by Dennis Crumpler, New Source Review Section, US EPA. 

10:30 am Break. 

'10:45 am Presentation and discussion of EPA staff draft provisions concerning use of 

undemonstrated control and pollution prevention technologies as BACT or to achieve 

LAER. 

- Presented by Larry Elmore, New Source Review Section, US EPA. 

12:00 pm Opportunity for public comment. 

12:15 pm Lunch. 

1:30 pm Presentation and discussion of EPA staff draft revisions to PSD Class I area requirements. 

- Presented by Dan deRoeck, New Source Review Section, US EPA. 

2:45 pm Break. 

3:00 pm Presentation and discussion of existing source subgroup deliberations. 

- Presented by Chris Shaver, Environmental Defense Fund, 

and Chuck Knauss, Swidler and Berlin. 

4:00 pm Presentation and discussion of the Interagency Workgroup on Air Quality Modeling 

concept paper on modeling and PSD increment tracking. 

- Presented by Marcia Spink, Region III, US EPA. 

5:15 pm Opportunity for public comment. 

5:30 pm End of day's session. 
P.7 

NSR Reform Subcommittee Meeting -- July 19-20, 1994 

Preliminary Agenda (continued) 

Wednesday, July 20, 1994 

8:45 am Opening of day's session and adjustments to the schedule. 

- Remarks by Patrick Raher, Subcommittee Co-chair and Hogan and Hartson, 

and by Mary Nichols, Assistant Administrator for Air and Radiation, US EPA. 

9:00 am Presentation and discussion of EPA staff draft provisions concerning NSR applicability 

(general overview and the clean unit applicability test). 

- Presented by William Lamason, New Source Review Section, US EPA. 

10:15 am Break. 

10:30 am Continued presentation and discussion of EPA staff draft provisions concerning NSR 

applicability. 

11:45 am Discussion of next steps in the NSR Reform process. 

12:00 am Opportunity for public comment. 

12:15pm End of meeting. 
P.8 

A -? o- 37 

NEW SOURCE REVIEW SUBCOMMITTEE MEETING 

INVITED PARTICIPANTS 

(Alphabetical Listing) 

July 19-20, 1994 -UL:Z£ 

David Aldorfer 

General Motors 

Argonaut A-205-H 

485 W. Milwaukee 

Detroit, MI 48202 

(313) 556-7850 

(313). 556-7683 fax 

Praveen Amar 

NESCAUM 

129 Portland Street 

Boston, MA 02173 

(617)367-8540 

(617) 742-9162 fax 

Barbara Bankoff 

Siemens Corporation 

701 Pennsylvania Ave 

Suite 720 

Washington, DC 20004 

(202) 434-4810 

(202) 347-4015 fax 

Michael Barr 

Pillsbury, Madison & Sutro 

National Association of Manufacturers 

225 Bush Street 

San Francisco, CA 94104 

(415) 983-1151 

(415) 477-4751 fax 

Bob Beasley 

Virginia Dept of Environmental Quality 

4900 Cox Road 

Glen Allen, VA 23060 

(804) 527-5174 

(804) 527-5141 fax 

| EPA AIR DOCKET 

William Becker ~ ——. —-

STAPPA/ALAPCO 

444 N Capitol Street NW, Suite 307 

Washington DC 20001 

(202) 624-7864 

(202) 624-7863 fax 

David Bradley 

Washington Department of Ecology 

P.O. Box 47600 

300 Desmond Drive 

Olympia, WA 98504-7600 

(206) 407-6989 fax 

David Bray 

U.S. EPA - Region X 

1200 Sixth Avenue 

Seattle, WA 98101 

(206) 553-4253 

(206) 553-0110 fax 

William Bumpers 

Howery & Simon 

1299 Pennsylvania Avenue 

Washington, DC 20004 

(202) 383-7160 

(202) 383-6610 fax 

John Bunyak 

National Park Service 

P.O. Box 25287 

12795 West Alameda Pkwy 

Lakewood, CO 80228 

(303) 969-2072 

(303) 967-2822 fax 

July IS, 1994 
P.9 

Mark Carney 

U.S. Generating Company/EGA 

7500 Old Georgetown Road 

Bethesda, MD 20814 

(301)718-6899 

(301) 718-6901 fax 

David Carr 

Southern Environmental Law Center 

201 West Main Street, Suite 14 

Charlottesville, VA 22901 

(804) 977-4090 

(804) 977-1483 fax 

Dennis Crumpler 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-0871 

(919) 541-5509 fax 

Dan deRoeck 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-5593 

Larry Elmore 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-5433 

(919) 541-5509 

Larry Feldcamp 

Baker & Botts 

One Shell Plaza 

910 Louisiana 

Houston, TX 77002 

(713) 229-1573 

(713) 229-1522 fax 

Andrea Bear Field 

Hunton and Williams 

2000 Pennsylvania Avenue, NW 

Suite 9000 

Washington, DC 20006 

(202) 955-1558 

(202) 778-2201 fax 

Rich Fisher 

USDA Forest Service 

Rocky Mountain Station 

240 W. Prospect Road 

Fort Collins, CO 80526 

(303) 498-1232 

(303) 498-1010 fax 

Greg Foote (LE-132A) 

U.S. EPA - OGC 

401 M Street SW 

Washington, DC 20460 

(202) 260-7620 

(202) 260-0586 fax 

Eileen Glen 

U.S. EPA - Region JJI 

841 Chestnut Bldg 

Philadelphia, PA 19107 

(215) 597-9800 

(215) 597-3156 fax 

Lynn Hamjian 

U.S. EPA - Region I 

John F. Kennedy Federal Building 

One Congress Street 

Boston, MA 02203 

David Hawkins 

Natural Resources Defense Council 

1350 New York Avenue, NW 

Suite 300 

Washington, DC 20005 

(202) 783-7800 

(202) 783-5917 fax 

July 15, 1994 
P.10 

Jacqueline Bogard 

Intel Corporation 

145 S. 79th Street 

Chandler, AZ 85226-4799 

(602) 554-3621 

(602) 554-3556 fax 

Mark Kataoka (2344) 

USEPA-OGC 

401 M Street SW 

Washington, DC 20460 

(202) 260-2090 

(202) 260-4149 fax 

Chuck Knauss 

Swidler & Berlin 

3000 K Street, NW 

Suite 300 

Washington, DC 20007 

(202) 424-7644 

(202) 424-7643 fax 

Chris Knopes (2126) 

USEPA - OPPE 

401 M Street SW 

Washington, DC 20460 

(202) 260-6921 

(202) 260-0512 fax 

Bill Lamason 

U.S. Environmental Protection Agency 

Office of Air Quality 

Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-5374 

(919) 541-5509 

Karen Malkin 

U.S. DOI-M1B 

National Park Service 

1849 C Street NW, Rm 3229 

Washington DC 20240 

(202)208-4911 

(202) 208-4620 fax 

Vivian Mclntire 

Eastman Chemical Company 

Eastman Road FANB-4 

Kingsport, TN 37662 

(615) 229-3045 

(615) 229-4864 fax 

Ray Menebroker 

California Air Resources Board 

2020 L Street 

Sacramento, CA 95812 

(916) 322-6026 

(916) 445-5023 fax 

Tom Micai 

NJDEPE - NESCAUM 

401 East State Street 

P.O. Box CN027 

Trenton, NJ 08625 

(609) 633-8248 

(609) 633-8236 fax 

Bruce Miller 

U.S. EPA - Region TV 

345 Courtland Street NE 

Atlanta, GA 30365 

(404) 347-3043 

(404) 347-3059 fax 

Bill Lewis 

Morgan, Lewis & Bockius 

1800 M Street, NW 

Washington, DC 20036 

(202) 467-7145 

(202) 467-7176 fax 

Mary Nichols 

Assistant Administrator, Office of 

Air & Radiation 

U.S. Environmental Protection Agency 

401 M Street, SW 

Washington, DC 20460 

July 15, 1994 
P.11 

Robert Nordhaus 

Department of Energy - GC-1 

1000 Independence Avenue, SW 

Washington, DC 20585 

(202) 586-1499 fax 

Bemie Paul 

Eli Lilly and Company 

Lilly Corporate Center 

Drop Code 1134 

Indianapolis, IN 46285 

(317) 276-3753 

(317) 277-1680 fax 

Patrick Raher 

Hogan & Hartson 

555 13th Street, NW 

Washington, DC 20004 

(202) 637-5682 

(202) 637-5910 fax 

Leslie Ritts 

Chadbourne and Parke 

1101 Vermont Avenue, Suite 900 

Washington, DC 20005 

(202) 962-4559 

(202) 289-3002 fax 

John A. Paul 

RAPCA 

451 W. Third Street 

Dayton, OH 45422 

(513) 225-4435 

(513) 225-3486 fax 

Vickie Patton 

USEPA-OGC 

401 M Street SW 

Washington, DC 20460 

(202) 260-7727 

(202) 260-0586 fax 

Bill Pedersen 

Shaw, Pittman, Potts & Trowbridge 

2300 N Street, NW 

Washington, DC 20037-1128 

(202) 663-8852 

(202) 663-8007 fax 

Clara Poffenberger (6306W) 

U.S. EPA - SSCD 

2805 Jefferson Davis Hwy 

Arlington, VA 22202 

(703) 308-8709 

(703) 308-8739 fax 

Ernie Rosenberg 

Occidental Petroleum 

1747 Pennsylvania Ave NW 

Washington, DC 20006 

(202) 857-3051 

(202) 857-3030 fax 

John Ruscigno 

Oregon Dept of Environmental Quality 

811 SW 6th Avenue 11th Floor 

Portland, OR 97204 

(503) 229-6480 

(503) 229-5675 fax 

Mike Sewell 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-0873 

(919) 541- 5509 fax 

Chris Shaver 

Environmental Defense Fund 

1405 Arapahoe Avenue 

Boulder, CO 80302 

(303) 440-4901 

(303) 440-8052 fax 

July 15, 1994 
P.12 

Sally Shaver 

U.S. Environmental Protection Agency 

Office of Air Quality 

Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

(919) 541-5551 

David Solomon 

U.S. Environmental Protection Agency 

Office of Air Quality 

Planning & Standards 

MD-15 

Research Triangle Park, NC 27711 

Lydia Wegman 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-10 

Research Triangle Park, NC 27711 

(919) 541-5506 

Christopher Wolz 

Office of Management & Budget 

New Executive Office Bldg - Room 3019 

725 17th Street, NW 

Washington, DC 20503 

(202) 395-5870 

(202) 395-5167 fax 

(919) 541-5375 

Marcia Spink 

U.S. EPA - Region HI 

841 Chestnut Street 

Philadelphia, PA 19107 

(215)597-9800 

(215) 597-3156 fax 

Richard Zbur 

Latham & Watkins 

633 W. 5th Street 

Los Angeles, CA 90071-2005 

(213) 485-1234 

(213) 891-8763 fax 

Donald Theiler 

Wisconsin Department of 

Natural Resources 

Bureau of Air Management 

P.O. Box 7921 

101 South Webster 

Madison, Wl 53703 

(608) 266-0603 

(608) 267-0560 fax 

John Trout 

Air Pollution Control District 

of Jefferson County 

850 Barrett Avenue 

Louisville, KY 40204-1745 

(502) 574-5306 fax 

BUI Tyndall (6103) 

USEPA-OPAR 

401 M Street SW 

Washington, DC 20460 

(202) 260-6499 

(202) 260-9766 fax 

July 15, 1994 
P.13 

A-HQ-V? 

New Source Review Reform Subcommittee MembefsT^ — 

and Invited Federal Agency Representatives / 

July 19-20, 1994 

Industry 

1. Ernie Rosenberg 

2. Michael Barr 

3. Vivian Mclntire 

4. Leslie Ritts 

5. David Aldorfer 

6. Bill Pedersen 

7. Bill Lewis 

8. Andrea Bear Field 

9. Mark Carney 

10. Pat Raher 

11. Jacqueline Bogard 

12. Bernie Paul 

13. Barbara Bankoff 

14. Chuck Knauss 

15. Larry Feldcamp 

16. William Bumpers 

17. Richard Zbur 

Representing ~"~""~—-—y^^^Cv/.-

Occidental Petroleum/Chemical Manufacturers Association 

PiUsbury, Madison & Sutro/National Association of 

Manufacturers 

Eastman Chemical Company 

Chadbourne & Parke/NEDA-CARP 

General Motors 

Shaw, Pittman, Potts & Trowbridge/CouncU for Clean Air 

Implementation 

Morgan, Lewis & Bockius 

Hunton & Williams/Utility Air Regulatory Group 

Electric Generation Association 

Hogan & Hartson 

Intel Corporation 

Eli Lilly 

Siemens 

Swidler & Berlin/Pharmaceutical Manufacturers Association 

Baker & Botts 

Hower & Simon 

Latham & Watkins 
P.M 

Environmental Organizations 

18. David Hawkins 

19. Chris Shaver 

20. David Carr 

Representing 

Natural Resources Defense CouncU 

Environmental Defense Fund 

Southern Environmental Law Center 

State/local Agencies 

21. Praveen Amar 

22. John Paul 

23. William Becker 

24. Bob Beasley 

25. Donald Thieler 

26. David Bradley 

27. John Ruscigno 

28. Tom Micai 

29. Ray Menebroker 

30. John Trout 

Representing 

Northeast States for Cobmined Air Use Management 

Montgomery County, Ohio, Regional Air Pollution Agency 

(NSR Committee Chairperson for ALAPCO) 

STAPPA/ALAPCO 

Virginia Department of Air Pollution Control 

Wisconsin Department of Natural Resources 

Washington Department of Ecology 

Oregon Department of Environmental Quatity 

New Jersey Department of Environmental 

Protection & Energy 

California Air Resources Board 

Jefferson County Air Pollution Control District, Kentucky 

Federal Agencies 

31. Rich Fisher 

32. Karen Malkin 

33. John Bunyak 

34. Robert Nordhaus 

35. Christopher Wolz 

Representing 

USDA Forest Service 

National Park Service 

National Park Service 

Department of Energy 

Office of Management and Budget 
P.15 

EPA 

36. Mary Nichols 

37. Lydia Wegman 

38. SaUy Shaver 

39. David Solomon 

40. BUI Lamason 

41. Larry Elmore 

42. Dan deRoeck 

43. Dennis Crumpler 

44. Clara Poffenberger 

45. Christopher Knopes 

46. BUI Tyndall 

47. Mark Kataoka 

48. Vickie Patton 

49. Greg Foote 

50. Lynn Hamjian 

51. Eileen Glen 

52. Marcia Spink 

53. Bruce Miller 

54. Dave Bray 

Representing 

Office of Air and Radiation 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Air Quality Planning & Standards 

Office of Enforcement and Compliance 

Office of Policy, Planning, and Evaluation 

Office of Policy Analysis & Review 

Office of General Counsel 

Office of General Counsel 

Office of General Counsel 

Region I 

Region III 

Region III 

Region IV 

Region X 
P.16 

A its - 3 7 

ISSUES ASSOCIATED 

WITH THE 

IMPLEMENTATION OF A CLASS I PROGRAM 

by 

Al Cimorelli 

Region III 

TJ.S. Environmental Protection Agency 

Patrick Hanrahan 

STAPPA/ALAPCO Representative1 

John S. Irwin2 

Office of Air Quality Planning and standards 

U. S. Environmental Protection Agency 

4l,2@ 

EPA AIR DOCKET 

Federal and State modelers have struggled with the issues 

related to Class I area analyses and have found their resolutions 

to be elusive. Currently the consensus opinion is that the Class 

I program is fundamentally different from other air programs 

(such as, Class II and State Implementation Plans (SIP's)). 

Unfortunately, the Federal Agencies have attempted to implement 

the assessment of Class I impacts as if the assessment is similar 

to that associated with Class II and SIP impacts. This has lead 

to a significant mis-match between the analysis process and the 

inherent needs of the Class I program. 

The Class II program reguires that analyses be performed 

within a domain on the order of 50 kms or less and centered on 

the source (the domain changes from permit to permit). Given the 

small domain, Class II analyses lend themselves to individual 

state implementation. Class I analyses, on the other hand, are 

centered on specific land areas. Therefore, the modeling domain 

does not change from permit to permit. Furthermore, these 

analyses involve a modeling domain on the order of hundreds of 

kms, thus reguiring multi-state coordination. Additionally, 

Class I area analyses for AQRVs may require estimating the 

deposition of secondary pollutants and their impact on 

visibility. Finally, the affirmative responsibilities of the 

1 State and Territorial Air Pollution Administrators / 

Association of Local Air Pollution Control Officials 

(STAPPA/ALPCO). Mr. Hanrahan is with the State of Oregon, 

Debarment of Environmental Quality. 

2 The author is on assignment from the Atmospheric Sciences 

Modeling Division, Air Resources Laboratory, National Oceanic 

Atmospheric Administration, U. S. Department of Commerce. 
FLM's significantly adds to the coordination difficulties 

inherent in the program. 

To address the coordination between Federal Agencies of 

modeling techniques involving long-range transport, the 

Interagency Workgroup for Air Quality Models (IWAQM) was formed. 

The membership of IWAQM includes participants from the National 

Park Service, the Forest Service, and the Fish and Wildlife 

Service. IWAQM has concluded that unless a centralized regional 

program is adopted, severe implementational problems will be " 

unavoidable. 

We recommend that Class I program implementation be 

accomplished on a Class I area (or cluster of Class I areas) 

basis, not permit-by-permit as is the case for the Class II 

program.. The cornerstone of this approach is an up-front 

comprehensive increment and AQRV analysis of the area. We 

envision this "initialization" study to be accomplished outside 

the context of a permit application. An up-front study is 

preferred since many of the decisions which need to be made (e.g. 

inventory, AQRVs criteria, etc.) are specific to the Class I 

area not the applicant's source. Further, it avoids having these 

decisions colored by the negotiations which occur for a single 

source. If desired, the "initialization" can involve technical 

experts from private and public groups. Finally (and perhaps 

most importantly), it provides future applicants with up-front 

information needed for planning and assurance of what is expect 

for the given situation. 

In large part, the emissions inventory and meteorological 

data which are developed during the initializing process remain 

fixed in subsequent analyses. Therefore, once "initialization" 

is complete, each additional new source need only determine its 

additive contribution; as such, increment and AQRVs are directly 

tracked. This approach has the benefit of removing the burden, 

from each applicant, of developing an emissions inventory 

specific for their application; although, updates may be 

necessary to account for changes in actual emissions from other 

sources. Within this approach, provisions can be made for 

updating the initial analysis under certain circumstances. For 

instance, a re-initialization analyses could result from any one 

of the following: 1) periodic State audit as contemplated by the 

PSD regulations, 2) by choice of the permit applicant, or 3) as 

the science changes. Once the system is "re-initialized", new 

meteorological data and grids may result. 

The following provides a summary of the major implementation 

issues that must be addressed if a successful Class I program is 

to develop. With the possible exception of the resource 

question, we believe that the recommended approach provides a 

framework for the resolution of these issues. 
P.18 

NEED FOR COORDINATION: Any effective Class I area program will 

need to provide for the coordination and management of interstate 

data bases (meteorological and source emissions) and interstate 

emission reductions. 

Regional groups consisting of EPA, the States, the FLM's and 

public and private technical groups could form to provide the 

needed coordination and management. These groups could be 

considered on a Class I area specific basis. For a program which 

operates permit-by-permit these groups would need to operate as 

standing committees. However, the recommended regional approach 

would only require such groups to form for the purpose of 

"initialization". 

INCREMENT TRACKING: The permit-by-permit approach presents many 

obstacles that make direct increment tracking very difficult, if 

not impossible. Variations in scope and degree of refinement of 

analyses among permits presents the major obstacles. Because each 

applicant's analysis can be so different (eg. screening vs. 

refined analyses), each analysis must reconsider all previous 

work. The need to deal with actual emissions, including area and 

minor sources, present other obstacles. In the West, large open 

burning area sources such as forest slash burning may consume 

significant increment. 

Although it is not feasible to track increment in a permitby-permit program, what can and should be done is to track the 

increment consuming inventory of sources. With such an inventory 

a properly conducted study could then define the amount of 

increment that has been consumed. 

The inefficiencies present in the permit-by-permit approach 

are substantially mitigated by the regional approach. With the 

recommended regional approach increment tracking is automatic; no 

additional analysis or special systems are needed to track 

increment. 

EMISSIONS: Keeping track of emissions on a regional basis will 

require data base management beyond what is presently done. In a 

permit-by-permit program -regional data base management becomes 

quite complex. For this type of program two possibilities exist 

for developing the needed inventories. First the applicant could 

be required to collect the data from all involved states, regions 

and the FLMs; this is how the present system operates. Second 

coordinated central archive could be developed from which the 

applicant could derive the information. Of course, this would 

require a single agency to accept the responsibility for 

coordinating and maintaining the information. We have 

recommended adopting the second option if a permit-by-permit 

approach is used. 
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However, the need for developing such an elaborate system 

would be obviate with the regional approach. Comprehensive 

inventories are developed during the "initilization" phase of the 

regional approach. 

METEOROLOGY, TOPOGRAPHY, AND LAND USE DATA: The IWAQM Phase I 

demonstration project has shown that significant resources are 

required to process meteorological, topographic and land use 

data. It is IWAQM's opinion that the resource requirements are 

severe enough to possibly preclude using the IWAQM recommended 

approach if a full analysis is required for each permit. A 

significant advantage of the regional approach is that the 

resource intense data processing occurs only during 

"initialization" and any subsequent "re-initialization". Unless 

an approach is used which is similar, to the regional approach in 

this regard, implementation of the IWAQM recommendations will be 

severely limited. 

RESOURCE NEEDS: Full implementation of a regional approach will 

require additional resources. For the group charged with 

performing the analyses and maintaining the data bases, upgraded 

computer hardware will certainly be needed. Additionally, this 

could require an increase in staff and training of existing 

staff. 

OFFSET PROGRAM: When an analysis indicates that all available 

increment has been consumed or a Class I area is expected to be 

adversely impacted by a new source, permitting can usually 

proceed through some form of offsetting. In general, an offset 

program can take one of two forms: (1) Emissions Based: reduce 

emissions at an existing plant by some percentage of the new 

source's emissions, generally greater than one for one. This 

approach is independent of the impact of the emissions. (2) 

Impact or Effects Based: reduce emissions at an existing plant by 

an amount that offsets the adverse impact predicted from the new 

plant. 

To insure that the offsetting emissions will provide a 

benefit that protects the Class I area resources, we suggest an 

impact based program be considered. Only if the proposed 

offsetting emission are simulated using atmospheric transport and 

dispersion models can one assure the consequences of the proposed 

offsets. 

ADVERSE IMPACT THRESHOLDS: From a practical point of view, a new 

source permitting program should include a relatively simple way 

of screening out those sources whose impacts are insignificant. 

A means to accomplish this would be to establish significance 

criteria against which the individual impacts from the new source 

could be judged. This is especially important in a Class I 

program since full increment or AQRV analyses are resource 
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intensive. For the Class I increments, EPA is presently working 

to establish significance criteria. 

Developing significance criteria for AQRVs is a more 

difficult issue. AQRVs are, by definition, Class I area 

specific. Therefore, determining what incremental impact is 

significant may need to be done for each area individually. 

However, there is a need to find an approach which avoids having • 

an applicant perform an analysis without knowing what will be 

considered a problem. A possibility could be for the FLM's to 

quantitatively define AQRV significance criteria on a 

case-by-case basis at a time early in the permitting process and 

prior to the performance of any modeling. 

It is envisioned that, with a regional approach, such 

criteria would be developed at the time of "initilization". 

INVENTORY DOMAIN: A controversial issue related to Class I 

analyses is the development of the emissions inventory. Given 

the small size of the increments, impact from distant sources can 

be important. 

There seems to be a consensus among modelers that developing 

objective criteria for selecting which source should be 

explicitly modeled is inherently problematic. 

With the regional approach, there will not be a need to 

establish objective criteria. The needed inventories will be 

developed area-by-area, through the cooperation of the states, 

regions and FLMs, at the time of the "initilization" process. 

For subsequent permits, only small changes to the source 

inventory are expected. As these changes are made, the 

inventory, which is specific for a given Class I area, will . 

evolve naturally with each permit or periodic state audit.