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OAR Box 1802 

Prepped by Charmelle Mathews 

Document Number: 

62) IV-E-56 

Docket Number: 

A-90-37 

Printed 11/4/2008 11:57:59 AM Sheet 62 of 117 
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131- E- S(p Meeting Summary 

Conference call with David Hawkins, NRDC on May 4,2000 

Attendees: David Hawkins, Karen Blanchard, Anna Wood, Carol Holmes, Dennis Crumpler, 

Lynn Hutchinson, Tom Driscoll, Bill Harnett 

Purpose ofthe call: To discuss the Clean Unit concept as described in the attachment, and to 

discuss options for limiting netting, and for addressing industry's concerns about debottlenecking 

and linking issues. 

After Tom Driscoll provided a summary ofthe attached paper describing the Clean Unit 

concept, David Hawkins provided feedback on the concept. He had major concerns that the 

Clean Unit concept as described would not necessarily be better for the environment than the 

current program. He suggested that to test the concept we might make an assumption that the 

program began in 1990 and then examine what BACT would be today. We would then compare 

the technologies that would have been clean in 1990 and see how they differ from what we 

would determine to be clean today. He indicated a concern that if low NOX burners were 

determined to be clean in 1990, and they had a 30 year lifetime, then if a modification were made 

today, we would miss the extra reductions we would get from the addition of SCR which has 

evolved as a clean technology during the last decade. Further, he did not believe that this 

concept would be a "carrot" to get industry who does not currently meet the definition of clean to 

apply controls now, but instead, they would wait until they needed or wanted to make a change. 

He thought the concept might be more acceptable if a safeguard were built in to ensure that when 

a modification is made that the "clean technology" is within X% (perhaps 5-10%) of what BACT 

would be at the time ofthe change. 

He said that the only way this concept could work is if there are no plaintiffs, and before 

this would be acceptable to the environmental community, the safeguard he spoke about would 

need to be added. Other concerns included the level of control that would be determined to be 

clean, and the time and resources it would take for EPA to develop the list of clean technologies, 

which, after citing the recent court decision on periodic monitoring, he indicated the need for a 

rulemaking exercise for this effort. If we pursue this, he urged OAQPS to work with the Office 

of Reinvention to ensure that the concept of pollution prevention is not discouraged by the 

emphasis on add-on controls, and suggested that the definition of clean be tied to a performance 

based metric. 

Next we asked for David Hawkins' feedback on ways to limit netting since this was an 

issue raised by STAPPA/ALAPCO as being very important. He suggested that EPA consider the 

dual source definition which EPA had adopted years ago, and also reducing the contemporaneous 

period of time, perhaps by the use ofthe project net approach. Lastly, we described the 

industry's concerns about debottlenecking and linking and gave several kinds of situations as 

illustrations as to where industry indicated that they did not believe they should be caught by the 

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NSR net. He noted that it appeared to him that industry wanted to use creditable decreases for 

netting purposes but not creditable increases. He did not seem totally opposed to the notion put 

forth by an ALAPCO member that emissions units be exempted which are not physically 

changed, are subject to enforceable permit conditions, and have been subject to an ambient air 

quality impacts analysis. He cautioned that the environmental community would be examining 

the whole NSR Reform package before coming to any conclusions as to whether and the extent 

to which they could support it.