OAR Box 1793 

Prepped by Keeia Richards 

p.1 

Document Number: 

21) ll-F-63 

Docket Number: 

A-90-37 

Printed 11/3/2008 11:31:54 AM Sheet 21 of 45 
P.2 

10/27/95 09:40 S202 2084620 WASO NR/AQ NPS 1^1001/003 

United States Department of the Interior 

/I-96-37 

IN Kt* u HCFE* TO: 

NATIONAL PARK SERVICE 

P.O. BOX 37127 

WASHINGTON, o.c 20013-7127 

DATE •• JbJAU 

NUMBER OF PASES TO FOLLOMi &• 

TO. pcuA"^ S£**~**_ ? W djf2*e& t>L.h-^ <?. i 

FR0H: KQJHL A Ai« tKI s 

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SUBJECT: vusR 

HAVE ANY PROBLEMS UITH THIS FAX OR 

PLEASE CALL THE INDIVIDUAL FRON HHON YOU ARE RECEIVING THE FAX. 

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BLACKMELL. LAUREN 202-208-

CONNINS. BILL 202-208-

DENNIS, JOHN 202-208-

DiSALVO, CAROL 202-219-

EADY, COLLETTE 202-208-

JOMSTUN, 6ARY 202-208-

KLIUINSKI, SHARON 202-208-

NAUCIN, KAREN 202-219-

4912 NCCLELLAND. LINDSAY 

4631 NILLER, ABBY 

5193 OLHELL, PEG6Y 

8936 PECK, OEBBY 

4640 SHAFER, CRA16 

5886 UAUCER, BILL 

4639 UATKINS. tflLMA 

3384 UILSON, RITA 

202-208-4958 

202-208-4650 

202-219-8933 

202-208-4624 

202-219-8934 

202-219-3386 

202-208-4913 

202-208-3884 
P.3 

j.u/27/a o Utf.-iU 'Oti*)i aiWO aatOZU ItASU INK/ AM W S ©002/003 

KEY ISSUES AND STATUS AS OF 10/26/95 

1. De minimus or significance levels for AQRVs 

EPA and DOI have reached agreement on compromise lan<miumj EPA 

to add in edits discussed today 

2. Definition of "adverse impact" 

EPA and DOI have reached agreement on compromise languittM; EPA 

to add in edits discussed today, including deleting last p^^ance 

on p. 166. One additional clarifying sentence is #^gge5tad 

regarding HAPs that are constituents of criteria pollutants; (insert 

for p. 165), EPA OGC (Mark) has approved from legal standpoint. 

3. Linkage at notice stage 

EPA and DOI have reached agreement on compromise langWMM; EPA 

to add in edits discussed today ("potential") 

4. Definition of AQRVs 

EPA and DOI have reached agreement on compromise lang-pBjM (pp. 

165, 193; EPA to add in edits discussed today (make clfcfcp that 

adverse impact for all AQRVs not new) 

5. "Deference" to FLMs (proposals from OMB to delete thif?) 

EPA and DOI are still discussing language. An additiignal 

compromise version was FAXed for EPA consideration this afteje$pon. 

(see Molly's proposed insert) 

6. 50 km cutoff for considering Class II area impacts 

EPA and DOI are still discussing language. DOI pVfMses 

(again) to delete footnote 68 referring to the cutoff, or, 

alternatively, to clarify that the cutoff is only relevant to 

Gaussian models (not long-range transport) and only relevant to 

Class II area analysis. 

7. Limitation of pollutants considered for adverse impact to 

criteria pollutants 

EPA and DOI are still discussing language. DOI (NPS) pip($.p<5sed 

inserts were discussed in concept vith EPA OGC (Mark) this evening, 

and are approved from legal standpoint. Inserts still need EPA 

policy approval. 

4*. 

8. Other wording changes previously suggested by DOI fay e&arity 

of legal, technical and policy considerations. 

EPA and DOI have reached agreement on compromise language 

(pages throughout Class I section of preamble and on regulation 

with regard to criteria for rejecting adverse impact); EPA to add 

in edits discussed today. 

#*'•> 2 

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10/27/95 09:41 ©20 2 208 4620 WASO NR/AQ NPS B.003/003 

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PROPOSED NSR INSERT FOR PREAMBLE P. 60 (6/29/95 D 

"ADVERSELY IMPACT AQRVS." 

The potential adverse impact to AQRVs may be due oijgjl ] |f|ore 

Hazardous Air Pollutants (HAPs) that are constituents of WJftHiria 

pollutants. For example, increases in mercury and J>§Milium 

should be considered. FLMs have expressed concerns about 1$BY#* and 

other pollutants, and should be consulted by permitting ^fc&ofrities 

when deciding whether a particular proposed applicability- exclusion 

might impact AQRVs. 

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PROPOSED INS.ERT FOR PAGE 61, AFTER END OF FIRST PARA. (NOtEl EPA 

STAFF AGREED TO CONSIDER THIS BEFORE, BUT WE HAVE RECEIVES NO :jjfe 

DEFINITIVE RESPONSE): U 

Of course, as in all decisions pertaining to adverse impacts on 

AQRVs, it is expected that the permitting authority would consult 

with the FLM of potentially affected Class I area*.- J5uch 

consultation will help enable FLMs to carry out their afflVtyfttive 

responsibility under the Act to protect AQRVs. 

PROPOSED INSERT FOR P. 165 (DAN'S 10/25 VERSION), AFTER FJJMf REDLINED PARAGRAPH ENDS: 

?r, « 

In determining whether emissions from a proposed eo^tff .tfould 

present an adverse impact, any pollutants that are const4fcu*n£s of 

criteria pollutants should be considered. W& 

[Mark K. says this is consistent w/EPA policy/legal infcer£« and J^.v:^ 

expressed in a memo.] ?&*': ?.? 

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