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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

59) ll-F-6 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:47AM Sheet 59 of 86 
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A-90-19 

ll-F-6 

Attached are materials distributed by the EPA at a meeting 

with OMB on August 6, 1992. Below is a list of attendees. 

EPA 

Daphne McMurrer 

Bruce Jordan 

Lydia Wegman 

Andrew Otis 

Patricia Embrey 

Mamie Miller 

OMB 

Tim Hunt 

Troy Hillier 

Rick Belzer 

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l . 

EPA-OMB Meeting on HON Emissions Averaging 

o Cost Savings from Emissions Averaging 

OMB's Issues 

Averaging Period 

Banking Credits 

Control Efficiency Ratings for RCTs 

Averaging Across Source Categories 

o Industry's Issue 

Baseline for Determining Credits 

o States' Issues 

Interpollutant Trades 

Averaging within New Sources 

Need for a Discount Factor 
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OMB's Issues 

Averaging Period 

- Draft has a quarterly averaging period, rolled monthly. 

Reasons for selecting Quarterly/Monthly combo: 

1) Administrative penalties system; 

2) Potential for fluctuations in HAP emissions; and 

3) Ability to ascertain the source's compliance status 

frequently. 

Industry concerned that the Quarterly/Monthly combo 

limits their ability to respond to: 

1) Maintenance needs; and 

2) Unanticipated changes in production rates. 

These are the only concerns industry has raised 

about the Quarterly/Monthly combo. 

Industry has suggested annual compliance, with: 

1) quarterly reporting; and 

2) quarterly emissions allowances. 

States support Quarterly/Monthly combo. 

Banking Credits 

Draft has no banking provisions. 

Banking provisions inconsistent with technology based 

approach of NESHAP 

NESHAP have no cap 

Production changes and growth allowed 

New emission points have a "birth right" of 

residual emissions 

Banking traditionally used to provide emission 

allowances for growth under a cap system 

In effect, banking provisions simply extend the 

compliance period in a system without a cap. 

Other reasons for not including banking provisions in HON 

Administratively more complex 

Risk implications 

Enforcement difficulties 

Industry agrees that banking provisions are difficult to 

implement. 

States concerned about implementation difficulties, even 

without banking. 
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OMB's Issues (cont) 

Control Efficiency Ratings for RCTs 

Draft assigns a control efficiency rating to the 

Reference Control Technologies (RCTs). 

Draft also establishes a system for having a higher 

"nominal" efficiency assigned 

Devices must be different from the RCT 

120 days to determine if info is sufficient 

120 days to act 

Decision published in Federal Register 

Reasons for using control efficiency ratings: 

1) HON is a national standard, requirements must be 

achievable in a variety of situations; 

2) Consistency in assigning credits and debits; 

3) Avoids windfalls of emissions allowances; and 

4) Implementation and enforcement simplicity. 

Industry generally supportive of control efficiency 

ratings 

- Acknowledge that the ratings ease accounting 

Some concern about influence on incentives for 

"fine-tuning" operation of RCTs, but emissions 

estimation techniques may not support 

quantification of "fine-tuning" 

Averaging Across Source Categories 

Draft does not allow averaging across source categories 

Averaging across source categories would violate the 

"floor" provisions of the 1990 amendments