P.1 

OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

64) ll-C-22 

Docket Number: 

A-90-37 

Printed 11/4/200810:22:19 AM Sheet 64 of 147 
P.2 

^CT-i^-li"' 3 1?:1B FROM EPfl OfiR OflQPS SSCD TO 919195415509 P.01/03 

A-^o-37 

H'C'2-2, 

!;i#(-

FAX TO: Jeffrey Muffet. 3M 

Mike Nash, 3M 

Mike Sandusky, MPCA 

Rachel Rineheart, Region v 

Ron Van Mersbergen, Region V 

FROM: Clara Poffenberger, SSCD, OAQPS, EPA 

Bill Tyndall, OPAR, EPA 

Bill Lamason, AQMD, OAQPS, EPA 

Mark Kataoka, OGC, EPA 

SUBJECT: EPA calls to discuss plantwide emission limits 

Attached is are draft discussion questions. 

As we have discussed with you, EPA is currently undertaking 

a review of the NSR program called "NSR Reform." We are exploring 

different approaches for applicability of NSR to modifications. 

One approach has been called the "plantwide applicability limit." 

We understand that although this approach may be new to the 

federal NSR program, you have some experience related to 

implementing and applying this approach. We appreciate the time 

you take to meet with and to provide any relevant materials to 

assist us in developing an understanding of the effectiveness of 

such an approach. 

The attached questions are a revised version of questions we 

asked Oregon representatives. We.will be focussing on the 

experience from the 3M, St. Paul Tape Division permit, and would 

like to discuss problems and successes as well as ways to improve 

such permits. We also want to discuss hypothetical changes to the 

approach and purpose of such a permit to explore issues arising 

from the NSR reform options for applicability. 

If you have any questions, please call Clara Poffenberger at 

(703) 308-8709 or Bill Lamason at (919) 541-5374. 
P.3 

V ..T-4 "* \ • 

iY^l b hKUI'l trH UHK uHura M^ U I U 2 i. 3 .!._?;_>-»._:_. D o 3 r . oi ' o.. 

Draft 

Use of Plantwide Emission Limits 

for New Source Review Applicability 

Discussion Questions 

Scope of the Program 

• What do you think about the plantwide emissions limits 

becoming available to all facilities? Are there types of sources 

or types of emission units that should be excluded? 

What pollutants should be covered? Should the program 

cover only criteria pollutants or should toxics and other 

pollutants be covered? 

• Should fugitive emissions be counted in the limit? 

would they be measured and monitored? 

How 

What should be the basis for the emission? What about 

actuals? What about it being periodically reviewed? Under what 

conditions could the source or the permitting authority change the 

emissions cap? 

• Is there any special process associated with issuing a 

plantwide emission limit permit? What are the public 

participation requirements? What is the process for changes to 

the emissions cap or other changes to permit or within the 

emissions limit? 

Flexibility of Permit 

• What flexibility at the facility is provided by the 

permit? What can be done under this permit that could not be done 

under a traditional permit? 

• Are there limits on the types of internal plant changes 

and internal emissions trading allowed under the permit? What 

treatment is given for alternative operating scenarios? 

• How are unit-specific limits (such as BACT, LAER, NSPS, 

or RACT) reflected in the permit? 

Compliance and Enforcement 

How. is the emissions limit implemented? What conditions 

are placed on the source to show compliance with the limit? Are 

emission limits placed on individual units or groups of units? 

• What are the consequences of exceeding the cap? 
P.4 

r_GCT-2?-1993 1? :

1 9 FRum EPft OflR OflQPS SSCD lU VLiL-som^ii)-? ;, ^ r. tio'tJj' 

A..rGeneral 

• What are the successes of the 3M permit? What hasn't worked? 

How will the new Clean Air Act operating permits program 

(title V) and the new toxics program (§112) impact the plantwide 

emissions cap program? Will you incorporate the operating permits 

program or the toxic program into the plantwide emissions cap 

approach?