p.l 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

63) ll-F-10 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:48 AM Sheet 63 of 86 
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A-90-19 

ll-F-10 

Attached are materials distributed by the EPA at a meeting 

with OMB on September 10, 1992. Below is a list of attendees. 

EPA 

Daphne McMurrer 

Bruce Jordan 

Lydia Wegman 

Andrew Otis 

Patricia Embrey 

Rich Biondi 

Elliott Gilberg 

OMB 

Tim Hunt 

Troy Hillier 

Rick Belzer 

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EPA - OMB HON Meeting 

September 10, 1992 

Purpose: Follow-up discussion of Emissions Averaging Issues 

Averaging Across Source Categories: 

Considering legal implications and defensibility of: 

Source defined with Fenseline option 

Source grows with each new MACT option 

Exploring technical and administrative implications of 

switching to this approach for source definitions 

Possible to quantify VOC's, gaseous streams and 

particulates for trading? 

Timing and scope of residual risk analyses? 

Some States may do multiple permits for one 

facility; Allow trades across permits? 

Averaging Period 

Considering industry suggestion of an annual compliance 

period, with: 

1) quarterly reporting; and 

2) quarterly emissions allowances. 

Quarterly emissions allowance (Mini-cap) could be set by 

value of actual credits generated for the quarter (i.e. 

Mini-cap = value of credits + (0.25 * value of credits)) 

Banking Credits 

Considering need for banking in HON 

Banking inconsistent with technology based NESHAP 

NESHAP have no cap; changes and growth allowed 

Significant unanticipated emissions will 

probably be covered by upset/malfunction 

provisions 

Considering if banking is defensible 

Can we show that banking will not result in higher 

emissions? 

To make this showing, may have to limit how banked 

credits can be generated or used. 

Concerned about impact of banking on statute of 

limitations for HON enforcement 
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EPA - OMB HON Meeting 

September 10, 1992 

Control Efficiency Ratings for RCTs 

Considering allowing a revised system for assigning 

"nominal" efficiency ratings 

Relaxed requirements for devices to be used in 1 or 

a few sites 

Allows use of RCT at higher efficiencies, with 

monitoring requirements to ensure consistent 

assignment of credits and debits better 

Potential Optional RCE System 

- Technology is different than 

the RCT, or 

- The RCT is being used 

differently* 

RCT not used significantly 

differently 

BROADLY APPUCABLE 

Federal EPA review as described 

in draft HON proposal 

Never - if RCT could get a higher 

efficiency in many applications, 

that efficiency would be assigned 

initially 

USE IN 1 OR A FEW SITES 

Permit authority review as part 

of the averaging plan 

Federal review of the plans for 

performance testing the debit 

generator and monitoring the 

point that will be over-controlled 

with the higher efficiency RCT 

Must set clear minimum criteria for "different use" 

Baseline for Determining Credits 

Policy in draft HON partially based on technical 

difficulties determining how much credit to give on some 

points that have already been controlled 

Considering allowing credit for 33/50 controls 

Considering allowing credit for controls put in place 

since 11/15/90 

In either case, permitting authority would have to have 

sufficient data to assign credit values