­­­­­
Forwarded
by
Pam
Long/
RTP/
USEPA/
US
on
10/
06/
2003
11:
28
AM
­­­­­
Bill
Harnett
08/
26/
2003
06:
56
AM
To:
Pam
Long/
RTP/
USEPA/
US@
EPA
cc:
Subject:
For
Docket
­­­­­
Forwarded
by
Bill
Harnett/
RTP/
USEPA/
US
on
08/
26/
2003
06:
56
AM
­­­­­
Bill
Harnett
08/
26/
2003
06:
55
AM
To:
Amy_
L._
Farrell@
omb.
eop.
gov
cc:
Bill
Wehrum/
DC/
USEPA/
US@
EPA
Subject:
Re:
this
thought
just
came
to
me
The
rule
and
language
are
fine.
If
a
process
unit
fails
the
emission
or
operational
limitation
then
they
do
a
case­
by­
case
review
to
see
if
the
activitiy
is
RMRR.
If
it
is
determined
that
the
it
is
not
RMRR
but
rather
a
physical
change
then
the
main
NSR
rule
apply
to
see
if
there
is
an
increase
in
emissions.
AS
we
have
done
nothing
to
change
that
test
it
will
apply
on
an
emission
unit
basis
as
required
under
the
rules.

Amy_
L._
Farrell@
omb.
eop.
gov
08/
26/
2003
12:
31
AM
To:
Bill
Harnett/
RTP/
USEPA/
US@
EPA,
Bill
Wehrum/
DC/
USEPA/
US@
EPA
cc:
Subject:
this
thought
just
came
to
me
CONTEXT:
Draft
rule
provision:
the
replacement
activity
shall
not
cause
the
process
unit
to
exceed
any
emission
limitation
or
operational
limitation
that
has
the
effect
of
constraining
emissions
that
applies
to
the
process
unit
and
that
is
legally
enforceable.

From
two
commenters:
Following
support
for
process
unit
definition.

"
However,
we
urge
EPA
to
make
clear
in
its
final
rule
that
this
"
process
unit"
definition
should
only
apply
for
purposes
of
determining
eligibility
for
the
"
equipment
replacement"
RMRR
exclusion.
The
"
process
unit"
definition
should
not
be
used
to
set
"
emission
unit"
boundaries
for
purposes
of
determining
when
an
emissions
increase
at
a
unit
triggers
an
NSR
analysis.
EPA's
rules
clearly
provide
that
such
an
analysis
can
only
consider
increases
at
an
individual
emissions
unit
within
a
process
unit.
Also,
if
NSR
should
be
triggered
for
any
emissions
unit
within
a
process
unit,
NSR
requirements
such
as
BACT
would
apply
ONLY
at
that
emissions
unit.
The
current
NSR
regulations
clearly
establish
this
restriction,
see
40
CFR
52.21(
j)(
3),
and
nothing
in
EPA's
proposal
indicates
any
intention
to
change
it."
QUESTION:
Does
the
rule
construction
in
any
way
cloud
the
established
boundary?
Do
we
need
premable
clarification?

amy
