p.1 

OAR Box 1802 

Prepped by Charmelle Mathews 

Document Number: 

18) IV-E-13 

Docket Number: 

A-90-37 

Printed 11/4/200811:57:59 AM Sheet 18 of 117 
July 21,1998 

MEMORANDUM 

JUL Z 8 

EPA MR DOCKET 

_P.2_. 

/ - 'in - 21 

2&:-E-)3 

SUBJECT: Summary- May 26,1998 Meeting between Industry Stakeholders and Office of 

Air Quality Planning and Standards Regarding the Promulgation of New Source 

Review Reform 

To: Air Docket A-90-37 

From: Dennis Crumpler, NSR Reform Team Leader, Integrated Implementation group, 

ITPID 

Attendees: 

Name 

Lydia Wegman 

Dennis Crumpler 

Dan deRoeck 

Maine Dewbury 

Michele Dubow 

Lynn Hutchinson 

Rob Kaufman 

Amy Lilly 

Bill Pederson 

Ellen Siegler 

David Solomon 

Karen Blanchard 

Organization 

EPA, OAQPS 

EPA, OAQPS 

EPA, OAQPS 

Proctor & Gamble 

EPA, OAQPS 

EPA, OAQPS 

American Forest & 

AAM 

Shaw, Pittman 

Paper Assoc. 

American Petroleum Institute 

EPA, OAQPS 

EPA, OAQPS 

Phone 

919-541-5504 

919-541-0871 

919-541-5593 

513-6344027 

919-541-3803 

919-541-5795 

202-463-2588 

703-505-7788 

202-663-8852 

202-682-8271 

919-541-5375 

919-541-5503 

Fax 

-2464 

-5509 

-5509 

-5481 

-5509 

-5509 

-2423 

-8817 

-8007 

-8033 

-5509 

-5509 

Bill Pederson started the meeting. He provided a handout of talking points which is attached. 

Discussion: 

• Industry raised concern over recent policy memorandum and letters regarding BACT on 

debottlenecked units at Westvaco Plants as being inconsistent with historic EPA policy. 

[It was agreed that discussion on this issue was outside the Reform rulemaking, thus was 

deferred to another occasion]. EPA indicated it would investigate the implications on the 

pollution control project exclusion that was proposed 

• Karen Blanchard asked for specific examples of FLM "unbridled discretion" in holdingup permits. 

• Discussed de minimis levels for Class 1 AQRV adverse impacts. EPA also asked for 

instances where inappropriate models had been required or used. 

• EPA reported DOI/USDA FS is developing list of most critical AQRVs and sensitive 

receptors via a new effort FLAG.. 

• Re-endorsed Allowable to Allowable - noting old unused capacity should not be allowed 

as basis for netting. 
P.3 

• EPA gave a description of Clean Unit test and asked for specific revisions to make it 

simpler 

• Industry representatives supported technology as a basis for applicability exclusion and 

also advocated that net-out units should get the clean-unit exclusion. 

• With respect to the proposed definition of actual emissions (based on 10-year look-back 

at capacity utilization) industry had no problem with normalizing for activity with 

exception of voluntary reductions. 

• We noted that Potential to emit limits as a basis become highly problematic if voluntary 

reductions are not made enforceable 

• Lydia Wegman recapped the schedule. 

• The Forest and Paper Products Association indicated the timing of the May 99 

promulgation is problematic because States need quick authorization in some cases to 

revise their SIPs to allow Pollution Control Projects. The MACT requirements for the 

pulp and paper industry will otherwise require sources to also get PSD permits which 

takes such along time that the sources could end up having to put on redundant control 

technologies for little or no environmental gain. — we discussed the notion of getting 

States to submit SIP revisions for parallel processing with the promulgation of NSR 

Reform, since the Pollution Control Project exclusion was one of elements that receive 

little disparaging comment. 

Attachment (Agenda) 
P.4 

Agenda for Meeting on New Source Review between EPA OAQPS and Industry 

Representatives 

May 26,1998 

I. Purpose of Meeting 

A. Express our views to EPA on key issues. 

B. Explore the possibilities of working with EPA on this very complex package. 

II. Issues 

A. BuckheU Memo dated March 18,1998 on BACT for debottlenecking projects 

1. Appears to be a reversal of EPA's long-established policy on debottlenecking. 

2. Implications for pollution control project exclusion. c?ff & f7fS£~ *-^- f^

r

 * 

3. Implications for pollution prevention. 

B. Class I - Clearly a basically contentious issue. But there are changes that we think 

would at least narrow the differences and improve the program as well. 

1. Set a de ininimis level below which there will be presumed to be no adverse 

AQRV impact. (The current regs have such a level - one miicrogram per cubic meter.) J8f2. Establish a definite set of models to be used for AQRV analysis, i/ 

3. EPA should itself define the pollution levels that have an adverse impact on 

visibility, and should use the existing definition of "adverse impact on visibility" in the final 

NSR rule. 

4. EPA should require FLMs to define by rule AQRVs other than visibility for 

each eligible area. 

C. Applicability 

1. General - Only a "potential to potential" approach is truly simple. Many steps 

toward such a simple system can be taken without even theoretically running the dangers EPA 

fears. 
P.5 

2. Pollution Control Project exclusion - AF&PA is discovering that some states 

are reluctant to grant a pep exclusion to "cluster" projects before the promulgation of a rule defining the exclusion. This is a part of the rule where we need action. In this regard 

a. We very much agree that emissions increases from pollution control projects 

should be accounted on a "potential to potential" basis. 

b. The exclusion should extend to new units that have a pollution control purpose, 

not just to modifications to existing units. As long as such new units fit the definition of pep, 

there is no reason to exclude them. They will not induce a source to operate more intensively, 

since pollution control projects do not make a "bottom line" contribution. By excluding new 

units EPA would create incentives for a source to put controls on individual units when a single 

stand-alone control unit would be more efficient. 

c. State and local requirements should be eligible for the exclusion as they have 

been since 1974. 

3.. The ten-year lookback 

a. We have always been for this and hope that EPA promugates it. 

b.. The point is to allow us to use any activity level that the source has reached in 

the past ten years. We agree that the activity level should be normalized to current emission rates 

to reflect todays state of emission control technology. 

c. As our comments discuss, EPA should be consistent here. If it adopts a ten year 

baseline for determining whether an individual unit has had an emissions increase, a ten year 

baseline for generating netting credits is required as well to avoid paradoxical results. 

39920041 /DOCSDCI