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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

68) ll-C-26 

Docket Number: 

A-90-37 

Printed 11/4/200810:22:19 AM Sheet 68 of 147 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

Apri l 19, 1994 

Mr. Barry Garelick 

Environmental Regulations 

Solar Turbines Incorporated 

Post Office Box 85376 

San Diego, California 92186-5376 

Dear Mr. Garelick: 

BJJJJJL 

APR 2 51994 

EPA A1BDOCKET, 

This is in response to your April 7, 1994 letter 

regarding the March 30, 1994 draft Innovative Control Technology 

and Pollution Prevention Subgroup recommendations. Your letter 

addressed the examples of possible currently-demonstrated 

pollution prevention best available control technology (BACT) and 

lowest achievable emission rate (LAER) projects provided in the 

Subgroup's draft recommendations. In addition, you requested 

that the Environmental Protection Agency (EPA) review your 

interpretation of the Subgroup's recommendations. 

You indicated that since dry low oxides of nitrogen (NOx) 

combustion technology was not included in the examples, a 

decision had been made that it would therefore not qualify as a 

pollution prevention process. I do not believe that the omission 

of a particular process from the Subgroup's recommendations 

(i.e., dry low NO, combustion technology) should be interpreted 

as a decision that, since it has not been included in the 

Subgroup's list of pollution prevention type processes, it could 

never qualify as pollution prevention process. Rather, it is fay 

understanding that the examples of currently-demonstrated 

pollution prevention BACT and LAER projects listed in the 

Subgroup's recommendations are for the purpose of providing 

illustrative examples, and do not represent a definitive list of 

pollution prevention processes. 

In regards to your request for an Agency response to your 

interpretation of the Subgroup's recommendations, the EPA is 

currently evaluating the various recommendations to come out of 

each of the. Subcommittee's Subgroups. This is an ongoing and 

evolving process. Consequently, it would be premature at this 

time to provide an Agency position on the issue you have raised. 

Your comments, however, will be taken into consideration as EPA 
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prepares its rulemaking on new source review (NSR) reform. The 

rulemaking, currently scheduled for proposal in early 1995, will 

contain a full discussion of EPA's views on all the 

recommendations to come out of the NSR Reform Subcommittee's 

deliberations. We also plan on discussing the draft of the 

proposed rule with the Subcommittee prior to proposal in the 

Federal Register. 

As you may be aware, Larry Elmore of my staff has the 

lead on NSR reform pertaining to the permitting of pollution 

prevention and innovative technologies. If you have any 

additional questions, please feel free to contact him at 

(919) ;541-5433. 

David[ Solomon, Chief 

New Source Review Section 

Permits Programs Branch 

cc: M. Barr, Pillsbury, Madison & Sutro 

D. Aldorfer, General Motors 

B. Bankoff, Siemens Corporation