P.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

127) IV-C-41 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:24 AM Sheet 127 of 142 
P.2 

Karen Blanchard 

06/16/2000 01:29 PAA 

A-90-3 ^ 

tDC-C- V/ 

To: gosulliv@sso.org, wosulliv@dep.state.nj.us, paulja@rapca.org, 

pmr@dc2.hhlaw.com 

cc: chknauss@swidlaw.com, Bill Harnett/RTP/USEPA/US@EPA, Anna 

Wood/DC/USEPA/US@EPA. Dennis 

Crumpler/RTP/USEPA/US@EPA. Pam Smith/RTP/USEPA/US@EPA, 

dhawkins@nrdc.org 

Subject: Comment requested on 2 Cap PAL approach 

K 

Attached is a summary of a pa'2cap.wp p^L approach submitted to us by an environmental group 

for consideration. Would you please look this over and let us know your thoughts. You may have 

seen or heard about this already, but we have no documented comments on it. Do you think that you 

could get your thoughts to us in the next week or so? 

•: -. Tl ' ' f^T^'l 

EPA AIR DOCKET 
ENVIRONMENTAL GROUPS TWO- CAP PAL APPROACH ....Pai2caP.wpd...4/i 2/000 

Issues 

One PAL Option 

One PAL, Two Caps 

BACT/LAER on Existing Units 

Environmental Groups Position 

There is only one type of PAL, one tiiat is based on BACT-performance*. Sources do not 

select between an actuals or allowables based PAL. *LAER-performance is required for 

nonattainment pollutants 

Two caps operate togetiier to provide headroom for well-controlled increases in facility 

operations but would not allow facilities to use reduced operation rates to continue reliance on 

poorly-controlled units. 

1) Annual Actuals Cap - an annual emissions cap equal to BACT-performance rates time 

actual annual operating levels. This assures mat in any year actual emissions will be not 

greater than if BACT was on all units greater man a small deminimis level. 

2) Major NSR Applicability Cap - an annual major NSR applicability cap equal to BACTperformance rates times full capacity operation levels. (Full capacity at me time the PAL was 

established). Major NSR does not apply to modifications provided emissions remain below 

me major NSR applicability cap. 

Units greater man a small deminimis level must meet BACT. 

- Units significant and greater comply with BACT unit-by-unit. 

- Units between deminimis and below significant levels may use a performance based 

compliance approach across units as long as operation-weighted total equals BACT 

performance. 

Facilities witfi units emitting at greater than BACT-performance must meet a compliance 

schedule to bring large units to BACT and smaller units to aggregate BACT-performance 

within a 5 to 10 year period. (The five year compliance period would apply to facilities where 

me majority of emitting units are already amortized). 
IP 

Adding New Units Under PAL 

Performance Based Option for 

BACT/LAER Compliance 

BACT/LAER Periodic 

Adjustment 

Periodic PAL Level Adjustment 

Partial PAL 

Expanding PAL 

All new units get BACT (except very small "deminimis" units) 

Allowed for units between deminimis and significant 

BACT-performance targets reviewed at least every 10 years with new compliance timetables 

established to achieve revised performance targets. 

Under the two cap approach no adjustment for unused capacity is required. 

Not included. Approach is plantwide. 

Capacity-expansion projects that could not be achieved witiiin the major NSR applicability cap 

would go through traditional major NSR.