p.1 

OAR Box 1837 

Prepped by Keeia Richards 

Document Number: 

172) IV-C-12 

Docket Number: 

A-84-33 

Printed 11/14/2008 3:48:11 PM Sheet 172 of 238 
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IMTEI) STATES EN MH ON MENTAL PROTECT!* >N AGENCY /4 ~ tf ^"3 3 

UA.-HINCTON, DC. 20460 

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AIR AND HADiMlOV 

David C. O'Neal 

Designated Assistant Secretary 

Land and Minerals Management 

Department of the Interior 

18th and C Streets, NW 

Washington, D.C. 20240 

Dear Mr. O'Neal: 

\ 

I E EDW B ^ 

U l NOV I 41989 

On October 26, 1984, the Environmental Protection Agency 

(EPA) took action under the Clean Air Act proposing to add 

surface coal mines (SCM's) to the list of source categories for 

which fugitive emissions are included in determining whether a 

source is considered major under EPA's regulations to prevent 

significant deterioration in clean air areas (49 FR 43211). 

Should this proposed listing be made final, then new and modified 

SCM's would, in certain circumstances, be required to apply for 

prevention of significant deterioration (PSD) permits, use best 

available control technology to limit air pollution emissions, 

and conply with other PSD provisions. 

The Department of the Inte 

comments to EPA regarding this 

nearing final action on this pr 

elapsed since proposal, the cha 

management at your agency, we a 

the views outlined in the comme 

Due to a November 16, 1989 dead 

litigation, we request that any 

later than 10 days from the dat 

rior provided the attached 

rulemaking proposal. The EFA is 

oposal. Given the time that has 

nge in administration and the new 

re interested in knowing whether 

nts still represent your position 

line for final action imposed by 

response be returned to us no 

e of this letter. 

One of the alternatives previously discussed with your 

agency in connection with EPA's rulemaking proposal, which is 

still under active consideration, is to list fugitive emissions 

from SCM's, such that new SCM's that may adversely affect air 

quality near areas of special, natural significance would be 

required to obtain a PSD permit. This option would be designed 

to prevent air quality degradation near Class I PSD areas and 

would potentially only affect SCM's likely to impact these areas 

(e.g., SCM's within 50 kilometers of National Parks and 

Wilderness areas). As you evaluate the position taken by your 

agency, please let us know if the concerns previously expressed 

by your agency regarding EPA's proposal would be alleviated by 

this option. 

PA A:;*; fh)' 'Jj-c 
P.3 

Thank you for your continuing interest and participation in 

this matter. If your staff members have any questions, they may 

call Lydia Wegman of my staff at (FTS) 382-7400. We would 

appreciate your written response within 10 days. 

Sincerely, 

(berg 

Assistant Administrator 

Office of Air and Radiation 

Enclosure 
P.4 

Duplicate Letters Sent To: 

Department of Interior: 

David C. O'Neal 

Designated Assistant Secretary 

Land and Minerals Management 

18th and C Streets, NW 

Washington, DC 20240 

(202) 343-5676 

Note: Position is vacant at present. Will likely be filled within 2-3 weeks. 

Department of Interior: 

Constance B. Harriman 

Assistant Secretary 

Fish, Wildlife and Parks 

18th and C Streets, NW 

Washington, DC 20240 

(202) 343-4416 

Department of Energy: 

Peter N. Brush 

Assistant Secretary 

Environment, Safety and Health 

1000 Independence Avenue, SW 

Washington, DC 20585 

(202) 586-6151 

Department of Agriculture: 

F. Dale Robertson 

Chief, Forest Service 

14th and Independence Avenue, SW 

Washington, DC 20250 

---> Mailing Address: P. O. Box 96090 

Washington, DC 20090-6090 

(202) 447-6661 

Department of Commerce: 

Wendell L. Willkie, II 

General Counsel 

14th and Constitution Avenue, NW 

Washington, DC 20230 

(202) 377-4772