"
Flynn,
Amy
E."
<
Amy_
E._
Flynn@
omb.
eop.
gov>
01/
21/
2005
11:
53
AM
To
Jeff
Herring/
RTP/
USEPA/
US@
EPA
cc
bcc
Subject
FW:
SBA
Advocacy
Comments
ANPRM
­
Potentially
Inadequate
Monitoring
Jeff­

Attached
are
comments
from
SBA
Advocacy
on
the
ANPRM.
Please
note,
the
comments
were
initially
sent
in
late
September,
but
do
not
appear
to
have
been
addressed
in
the
latest
draft.
I
would
like
to
discuss
these
comments
on
Monday,
if
possible.

­
Amy
aflynn@
omb.
eop.
gov
(
202)
395­
7345
­­­­­
Original
Message­­­­­
From:
Fraas,
Arthur
G.
[
mailto:
Arthur_
G._
Fraas@
omb.
eop.
gov]
Sent:
Tuesday,
September
28,
2004
2:
55
PM
To:
harnett.
bill@
epa.
gov
Cc:
kevin.
bromberg@
sba.
gov
Subject:
FW:
SBA
Advocacy
Comments
ANPRM
­
Air
Permits
Inadequacy
After
the
list
of
potential
monitoring
inadequacies
from
the
draft
ANPRM
(
see
p.
13­
14),
I
would
prefer
to
supplement
this
text
with
some
discussion
that
will
inform
the
comments.
For
example,
I
believe
there
are
several,
if
not
many
post­
2000
MACT
rules,
where
PM
limits
were
adopted,
but
only
COMs
or
BLDs
are
required.
In
contrast,
the
question
above
about
the
inadequacy
of
monitoring
opacity
alone
implicitly
assumes
that
these
are
inadequate
as
a
category.
This
is
not
what
EPA
found
in
recent
rulemakings.
Therefore,
these
questions
call
into
doubt
rules
which
EPA
has
already
found
adequate
in
post­
Title
V
rulemakings,
as
well
as
rules
for
which
EPA
has
not
made
any
recent
judgments.
EPA
should
review
recent
preambles
and
explain
the
basis
for
its
determinations
for
some
of
the
more
important
questions
above.
Then,
EPA
could
solicit
advice
about
the
wisdom
of
its
more
current
approaches,
and
contrast
them,
if
relevant,
with
earlier
practices.

I
would
suggest
that
EPA
summarize
some
of
the
more
recent
rulemakings
where
monitoring
determinations
were
made,
and
show
why
EPA
determined
that
monitoring
was
adequate.
It
could
compare
monitoring
under
an
NSPS
and
monitoring
under
a
MACT
for
the
same
industry,
and
discuss
whether
any
improvements
were
made
under
the
MACT.
The
public
could
be
asked
to
explain
why
the
MACT
monitoring
requirements
should
not
be
applied
now
to
the
NSPS.

As
another
example,
setting
ranges
for
certain
parameters
may
not
be
feasible
or
advisable.
Those
parameters
can
often
be
established
only
after
a
given
plant
is
operational.
Not
all
work
practices
may
warrant
recording
because
these
are
established
work
place
procedures
that
also
address
worker
safety
that
are
always
followed,
or
they
are
not
an
important
part
of
reducing
emissions
in
a
given
setting.
There
is
no
discussion
of
these
or
any
issues
regarding
the
potential
inadequacies.

Instead
of
asking
the
question
"
Are
there
other
patterns
of
potential
monitoring
inadequacies
in
Federal
rules"
after
the
list,
it
should
be:
"
Explain
where
in
any
of
the
categories
above,
the
monitoring
was
inadequate,
and
what
type
of
monitoring
should
address
the
inadequacy"?
and
then,
"
Explain
any
other
potential
monitoring
inadequacies
in
Federal
rules."

There
also
is
no
discussion
of
whether
the
stringency
of
the
rule
is
affected
by
changes
in
the
monitoring
requirements,
including
a
revision
of
the
monitoring
frequency.
The
discussion
should
reiterate
that
EPA
does
not
have
the
authority
to
revise
the
stringency
of
a
standard
by
revising
the
monitoring
requirements.
There
is
also
no
discussion
about
the
accuracy
of
using
surrogates,
such
as
opacity
monitoring
for
PM.
At
a
minimum,
EPA
should
consider
making
available
in
the
docket
information
about
the
accuracy
of
surrogates.
