Joanna
Swanson/
RTP/
USEPA/
US
07/
06/
2005
05:
35
PM
To
Amy_
E._
Flynn@
omb.
eop.
gov
cc
John
Silvasi/
RTP/
USEPA/
US@
EPA,
Janet
McDonald/
RTP/
USEPA/
US@
EPA
Subject
Fw:
Question
about
Title
V
discussion
in
the
8­
hr
O
NAAQS
Implementation
Rule
(
phase
2)

Amy,

Based
on
our
conversation
yesterday,
my
understanding
is
that
you
wanted
me
to
consider
including
in
the
title
V
q's
a
a's
in
the
phase
II
package
an
explanation
of
how
the
PSD/
NSR
thresholds
had
changed
and
how
this
had
impacted
sources
coming
into
title
V
permitting.

As
we
discussed,
there
are
areas
which
go
from
being
classified
as
attainment
under
the
1­
hour
standard
to
being
considered
nonattainment
under
the
8­
hour
standard.
For
example,
the
Charlotte,
NC
area
was
designated
as
attainm
under
the
1­
hour
standard,
but
is
now
classified
as
moderate
nonattainment
under
the
8­
hour
standard.
As
a
result,
th
major
source
threshold
for
this
area
went
from
being
250
tpy
under
PSD
to
100
tpy
under
nonattainment
NSR.
The
title
major
source
threshold
remained
the
same
at
100
tpy.

In
fact,
in
no
case
under
the
phase
II
rule
does
the
change
in
major
source
threshold
under
PSD/
NSR
for
an
area
caus
source
to
become
subject
to
title
V
permitting
earlier
than
it
otherwise
would
have.
This
is
because
title
V
major
source
thresholds
are
always
lower
than
or
equal
to
PSD/
NSR
thresholds.
More
specifically,
PSD
thresholds
(
attainment
area
are
either
250
tpy
or
100
tpy
(
for
certain
designated
source
categories).
The
title
V
threshold
in
attainment
areas
on
the
other
hand
is
always
100
tpy.
In
nonattainment
areas,
the
major
source
thresholds
are
the
same
for
nonattainment
NS
and
title
V.

As
a
result,
although
a
source
can
trigger
the
requirement
to
apply
for
a
title
V
permit
due
to
its
actual
or
potential
emissions,
being
required
to
obtain
a
part
C
or
D
permit,
etc.,
the
requirement
to
obtain
a
part
C
or
D
permit
is
not
goin
hasten
when
a
source
will
be
required
to
apply
for
a
title
V
permit.
Is
this
something
you
would
like
to
have
explained
in
the
title
V
q's
and
a's?

Please
let
me
know
if
you
would
like
to
discuss
the
above.

Thanks
very
much,
Joanna
919­
541­
5282
­­­­­
Forwarded
by
Joanna
Swanson/
RTP/
USEPA/
US
on
07/
06/
2005
04:
33
PM
­­­­­

Joanna
Swanson/
RTP/
USEPA/
US
07/
05/
2005
10:
41
AM
To
Amy_
E._
Flynn@
omb.
eop.
gov
cc
John
Silvasi/
RTP/
USEPA/
US@
EPA,
Janet
McDonald/
RTP/
USEPA/
US@
EPA
Subject
Re:
Question
about
Title
V
discussion
in
the
8­
hr
O
NAAQS
Implementation
Rule
(
phase
2)

Amy,

I
agree
with
John's
statement
below.
A
good
example
of
the
attainment
designation
changing,
but
the
title
V
major
sou
threshold
remaining
the
same
can
be
seen
relative
to
the
Charlotte,
NC
area.
This
area
has
gone
from
attainment
und
the
1­
hour
standard
to
moderate
nonattainment
under
the
8­
hour
standard,
but
the
title
V
major
source
threshold
of
100
tpy
remains
the
same.
This
is
not
the
case
for
PSD/
NSR,
however,
as
the
major
source
threshold
of
250
tpy
drops
to
1
tpy
for
this
area
under
that
program.

Given
that
the
above
can
be
confusing,
I
suggest
that
we
edit
the
last
sentence
in
this
q
and
a
on
page
414
so
that
it
reads
as
follows:
"
This
is
because
the
current
8­
hour
classifications
do
not
result
in
a
lowering
of
the
title
V
major
sourc
threshold
for
any
area."
(
Given
that
we
are
now
past
June
15,
2005,
I
may
need
to
revise
the
q
and
a
a
little
more
to
reflect
that
only
the
8­
hour
classifications
are
in
effect.)

In
any
case,
thanks
for
the
comment,
Amy.
You
raise
a
good
point.

Joanna
Joanna
C.
Swanson
Operating
Permits
Group,
OAQPS
919­
541­
5282
John
Silvasi/
RTP/
USEPA/
US
07/
01/
2005
10:
27
AM
To
Amy_
E._
Flynn@
omb.
eop.
gov
cc
Joanna
Swanson/
RTP/
USEPA/
US@
EPA
Subject
Question
about
Title
V
discussion
in
the
8­
hr
O3
NAAQS
Implementation
Rule
(
phase
2)
Hi,
Amy,

One
of
OMB's
faxed
comments
on
p.
414
of
the
2/
6/
05
version
was
"
What
about
sources
in
new
8­
hr
NA
areas?"

I
checked
with
Joanna
Swanson,
my
Title
V
point
of
contact.
She
indicated
that
the
Title
V
major
source
threshold
for
areas
in
new
8­
hour
nonattainment
areas
(
since
none
are
above
a
moderate
classification)
would
remain
the
same
as
when
they
were
attainment
areas
under
the
1­
hour
standard,
namely
100
tons/
year.

(
Joanna,
please
feel
free
to
elaborate,
but
that's
the
gist
of
what
I
gathered
from
our
recent
conversation.)

John
J.
Silvasi
Environmental
Engineer
Ozone
Policy
and
Strategies
Group
(
C539­
02)
Office
of
Air
Quality
Planning
and
Standards
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
919­
541­
5666
(
v);
919­
541­
0824
(
fax)
silvasi.
john@
epa.
gov
