From: Melissa Payne/RTP/USEPA/US                                        
                                                                   

To: "Dave Darling" <ddarling@paint.org>                                 
                                                                 

Date: 08/07/2009 11:23 AM                                               
                                                                   

Subject: RE: Reconstruction                                             
                                                                      

Dave,

I just looked at the Chemical Manufacturing Area Source rule and we can
most likely do something like what they have, i.e.

(1)  An affected source is existing if you commenced construction or
reconstruction of the affected source before (add date).

(2)  An affected source is new if you commenced construction or 

reconstruction of the affected source on or after (add same date).

I'll check with General Council on the dates and language.

I hope this is helpful,

Melissa

Melissa Payne

Regulatory Development and Policy Analysis Group Office of Air Quality
Planning and Standards U.S. Environmental Protection Agency

919.541.3609

From: "Dave Darling" <ddarling@paint.org>                               
                                                                   

To: Melissa Payne/RTP/USEPA/US@EPA                                      
                                                                 Date:
08/07/2009 11:05 AM                                                     
                                                             

Subject: RE: Reconstruction                                             
                                                                      

Melissa  - any word on the reconstruction question?

thanks

David

From: Payne.Melissa@epamail.epa.gov
[mailto:Payne.Melissa@epamail.epa.gov]

Sent: Wednesday, July 29, 2009 2:06 PM

To: Dave Darling

Subject: Re: Reconstruction

David,

There is no reconstruction definition in the proposal; let me look into
this and get back to you in a couple of days.

Thanks,

Melissa

Melissa Payne

Regulatory Development and Policy Analysis Group Office of Air Quality
Planning and Standards U.S. Environmental Protection Agency

919.541.3609

                                                                        

                                                                        

to: Melissa Payne 07/29/2009 01:59 PM 

Melissa - question - a facility is considering adding a couple tanks and
worried about the compliance date since as proposed - new and
reconstructed sources would have to comply by the date of publication of
the final rule in the Federal Register or upon startup of the facility,
whichever is later as opposed to 2 years for existing.

Is there a definition for reconstruction? The MACT standards had a
modification definition having to do with capital expenditures, etc.?

I'm hoping that over the next two years or so facilities can make minor
modifications with falling into the new source trap suggestions?

David

