### RE: Clarification letters regarding 20.2.72 NMAC Singleton,Kerwin, NMENV to: Ashley Mohr 10/18/2012 12:23 PM

Cc: "Bates, Rita, NMENV", "Cooke, Gail, NMENV" , "Weaver, Lany,

NMENV"

From: "Singleton,Kerwin, NMENV" <Kerwin.Singleton@state.nm.us>

To: Ashley Mohr/R6/USEPA/US@EPA

Cc: "Bates, Rita, NMENV" <Rita .Bates@state.nm.us>, "Cooke, Gail, NMENV" <gail.cooke@state.nm.us>, "Weaver, Lany, NMENV" <lany.weaver@state.nm.us>
History: This message has been replied to and forwarded.

1 attachment



### Ashley, Attached is the spreadsheet identifying all active sources in the Tempo AQB dataset. In the interest of time, I have not reviewed all 17763 entries, but you should be aware that a single entry may represent a number of identical sources (e.g., an owner/operator may include 75 identical portable compressors under a single Notice of Intent). For the purposes of your review, let us use 17763 as the number of active sources plus the estimated 2000 sources exempt under Part 72 for a total of 19763 sources under NMED’s jurisdiction. T he exempt sources comprise approximatel y 10% of this total. If we were to account for the multiple sources in Tempo, it is safe to say that the exempt sources are less than 10% of the total number of sources in the system.

Should you require additional information, please do not hesitate to contact me.

Regards,
Kerwin

From: Mohr. A shley@epamail.epa.gov [mailto:Mohr. A shley@epamail.epa.gov] Sent: Wednesday, October 17, 2012 11:19 A M To: Singleton,Kerwin, NMENV Subject: RE: Clarification letters regarding 20.2.72 NMAC

Thanks so much for the update. I really appreciate your quick response!

Ashley

_ _________________________________ Ashley N.Q. Mohr Environmental Scientist Air Permits Section (6PD-R) U.S. Environmental Protection Agency
1445 Ross Avenue Dallas, TX 75202 (214) 665-7289FAX (214) 665-6762 mohr.ashley@epa.gov

From: "Singleton,Kerwin, NMENV" < Kerwin.Singleton@state.nm.us >

To: A shley Mohr/R6/USEPA/US@EPA

Date: 10/17/2012 09:51 A M

Subject: RE: Clarification letters regarding 20.2.72 NMAC

Ashley, I received a preliminary data set late yesterday, but it needs to be refined to limit the query to the AQB files only. I should have something later today.

Kerwin

From: A shley Mohr [ mailto:Mohr. A shley@epamail.epa.gov ] Sent: Tuesday, October 16, 2012 2:46 PM To: Singleton,Kerwin, NMENV Subject: RE: Clarification letters regarding 20.2.72 NMAC

Kerwin,

Thanks again for your assistance. Once you have spoken with your IT contact and have an idea of the time frame required to get this data, could you let me know? My response to management on this question is time sensitive so I would like to provide an estimated time frame to them as soon as possible. Just so you are aware of my time frame, a response providing the total number of active units in comparison to the exempted sources number by the end of this week would be ideal.

Thanks again!

Ashley

_ _________________________________ Ashley N.Q. Mohr Environmental Scientist Air Permits Section (6PD-R) U.S. Environmental Protection Agency
1445 Ross Avenue Dallas, TX 75202 (214) 665-7289 FAX (214) 665-6762 mohr.ashley@epa.gov

From: "Singleton,Kerwin, NMENV" < Kerwin.Singleton@state.nm.us >

To: A shley Mohr/R6/USEPA/US@EPA
Cc: A bi Vijayan/R6/USEPA/US@EPA, "Cooke, Gail, NMENV" < gail.cooke@state.nm.us >, "Weaver, Lany, NMENV" <lany.weave r @state.nm.us >, "Bates, Rita, NMENV" < Rita.Bates@state.nm.us >

Date: 10/16/2012 03:26 PM

Subject: RE: Clarification letters regarding 20.2.72 NMAC

Ashley,
T he 2000 estimated units was determined from the spreadsheet I forwarded to you on 09/25/12. As indicated in the SI

_ DESCRIPTION column, one TEMPO entry may cover multiple
units. T hat list covered all active units in TEMPO as o f 09/13/12. If this requires additional explanation, please let me know.

T hanks,

Kerwin

From: A shley Mohr [ mailto:Mohr. A shley@epamail.epa.gov ] Sent: Tuesday, October 16, 2012 1:59 PM To: Singleton,Kerwin, NMENV
Cc: A bi Vi j ayan; Cooke, Gail, NMENV; Weaver, Lany, NMENV; Bates, Rita, NMENV Subject: RE: Clarification letters regarding 20.2.72 NMAC

Kerwin,

Can NMED supply a total number of currently active units based on the NMED TEMPO permitting database? We would like to understand how the "2,000 active units that may have been subject to exemptions" under Part 72, Section 202 compares with the total number of currently active units in New

Mexico.

Thanks in advance for your help. Let me know if you have any questions regarding my request.

Ashley

_ _________________________________ Ashley N.Q. Mohr Environmental Scientist Air Permits Section (6PD-R) U.S. Environmental Protection Agency
1445 Ross Avenue Dallas, TX 75202 (214) 665-7289 FAX (214) 665-6762 mohr.ashley@epa.gov

From: "Singleton,Kerwin, NMENV" < Kerwin.Singleton@state.nm.us >

To: A shley Mohr/R6/USEPA/US@EPA
Cc: "Weaver, Lany, NMENV" < lany.weave r @state.nm.us >, "Bates, Rita, NMENV" < Rita.Bates@state.nm.us >, "Cooke, Gail,

NMENV" < gail.cooke@state.nm.us >, A bi Vijayan/R6/USEPA/US@EPADate: 09/25/2012 10:52 A M

Subject: RE: Clarification letters regarding 20.2.72 NMAC

Ashley,

T he subject item breakdown is as follows:

 22 Backup/Standby

 30 Emergency

 493 Exempt

 397 Insignificant A copy of the data pull is attached to this email. Should you require further clarification, please

do not hesitate to contact me. Regards, 

### Kerwin C. Singleton Manager, Control Strategies
A ir Quality Bureau

505.476.4350 505.476.4375 (FAX)

1301 Siler Road - Bldg B

Santa Fe, NM 87507-3113


# 
Please consider the environment before printing this e-mail.

From: A shley Mohr [ mailto:Mohr. A shley@epamail.epa.gov ] Sent: Tuesday, September 25, 2012 9:21 A M To: Singleton,Kerwin, NMENV Cc: Weaver, Lany, NMENV; Bates, Rita, NMENV; Cooke, Gail, NMENV; A bi Vi j ayan Subject: Re: Clarification letters regarding 20.2.72 NMAC

Kerwin,

You were listed as the staff contact on the Part 72 clarification letter regarding permit exemptions, so I am reaching out to you regarding a follow-up question I had after reviewing the letter.

Based on my understanding of the letter, the "excess of 2,000 active individual units" accounts for the multiple units included in the total of 942 subject items for the 4 different categories referenced in the letter (Backup/Standby, Emergency, Exempt, Insignificant). Do you have information regarding the number of individual active units for each of the 4 categories. I am trying to get an idea of how many of the 2,000 active individual units did claim an exemption. I assume that those sources in the Exempt category in the database would reflect this information. I understand that this would not include allsources that utilized an exemption under Section 202, since all exemptions do not require notification under the provisions of Part 72 in addition to any sources that may not have been entered into the

database.

Thanks in advance for your help. Feel free to give me a call if you have any questions.

Ashley

_ _________________________________ Ashley N.Q. Mohr Environmental Scientist Air Permits Section (6PD-R) U.S. Environmental Protection Agency
1445 Ross Avenue Dallas, TX 75202 (214) 665-7289 FAX (214) 665-6762 mohr.ashley@epa.gov

From: "Weaver, Lany, NMENV" < lany.weave r @state.nm.us >

To: Thomas Diggs/R6/USEPA/US@EPA, Jeffrey Robinson/R6/USEPA/US@EPA, A shley Mohr/R6/USEPA/US@EPA
Cc: "Bates, Rita, NMENV" < Rita.Bates@state.nm.us >, "Singleton,Kerwin, NMENV" < Kerwin.Singleton@state.nm.us >, "Goodyear, Richard, NMENV" < richard.goodyear@state.nm.us >, "Cooke, Gail, NMENV" < gail.cooke@state.nm.us >

Date: 09/19/2012 05:37 PM

Subject: Clarification letters regarding 20.2.72 NMAC

Please find attached 2 letters providing additional information about submittals of revisions to 20.2.72 NMAC

– Construction Permits. One provides a clarification of the intent of Section 220 (General Construction Permits to

not apply to PSD sources), and the other provides information (to the extent available) about the exemptions
provisions in Section 202

. The hard copies of the letters will be sent to Tom Diggs.

If you have additional questions, please contact Rita Bates or Kerwin Singleton.

Lany Weaver

N ew Mexico Environment Departmen t Air Quality Bureau (505) 476-4322[attachment "Clarification

_ of

_ 20.2.72.220

_ N MAC.pdf" deleted by Ashley Mohr/R6/USEPA/US] [attachment "Exemptions

_ under

_ 20.2.72.202

_ N MAC.pdf" deleted by Ashley Mohr/R6/USEPA/US] [attachment "13 SEPTEMBER 2012 TICKET T11290 3rd RESULTS.xls" deleted by Ashley Mohr/R6/USEPA/US]