04/03/13 Meeting with EPA

Paul Koprowski, Justin Spenillo, Dave Bray, Donna Deneen, Julie Vergeront, Katie McClintock, Mark Fisher, Phil Allen, Jill Inahara

 

200 – Actual emissions – is this term used in other than 214, 220 and 222? Catchall definition and then 214 and 220. If used elsewhere, can point to that division.

Major source to 100 tpy, backsliding? For PM10 that existed in 1990 SIP. Any control measure in effect prior to 1990 that is currently in the SIP for the NAA. Remaining PM10 maintenance areas and Salem ozone.

Approval of very first Oregon PSEL program when EPA argued over all equivalency, major source thresholds were tighter than minimum requirement. Lose our ability in equivalency argument regulating smaller sources than federal.

202 – 1-hour standards need to be adopted before they can approve NSR/PSD changes. This would eliminate a hassle. Make SIP approval easier. EPA obligated to determine all NAAQS protected. If we don’t have all NAAQA adopted, creates problem. In this rule or ahead of this rule.

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214

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