It does look like it would fit well with the opacity and grain loading changes we want to put with the PM 2.5 adoption in 2008. I can save a copy of our conversation into my PM changes folder and let Uri know, but am concerned that this will be forgotten unless Cory does something about it.

-----Original Message-----
From: JACOBS Patty
Sent: Monday, October 29, 2007 3:25 PM
To: ARMITAGE Sarah
Subject: RE: Seemingly "conflicting" rules

Hi there,

Not to beat a dead horse, but some of these rules are so archaic and not relevant to what we do. Smoke spot is a surrogate for opacity. But if you look at our rule citation below, it references ASTM D2156-65, which is also referenced below, and is not applicable to our type of equipment - it is for home heating equipment, which we do not regulate. The relevant sections are in red font. Can we get rid of this??

340-208-0610

Particulate Matter Weight Standards

Except for equipment burning natural gas and liquefied petroleum gas, the maximum allowable emission of particulate matter from any fuel burning equipment:

(1) Is a function of maximum heat input as determined from Figure 1, except that from existing fuel burning equipment utilizing wood residue, it is 0.2 grain, and from new fuel burning equipment utilizing wood residue, it is 0.1 grain per standard cubic foot of exhaust gas, corrected to 12 percent carbon dioxide;

(2) Must not exceed Smoke Spot #2 for distillate fuel and #4 for residual fuel, measured by ASTM D2156-65, "Standard Method for Test for Smoke Density of the Flue Gases from Distillate Fuels".

ACTIVE STANDARD: ASTM D2156-94(2003) Standard Test Method for Smoke Density in Flue Gases from Burning Distillate Fuels

Developed by Subcommittee: D02.E0.01See Related Work by this Subcommittee
Adoptions: DOD Adopted; ANSI Approved
Book of Standards Volume: 05.01

1. Scope

1.1 This test method covers the evaluation of smoke density in the flue gases from burning distillate fuels. It is intended primarily for use with home heating equipment burning kerosine or heating oils. It can be used in the laboratory or in the field to compare fuels for clean burning or to compare heating equipment.

1.2 The values stated in SI units are to be regarded as the standard. The values in parentheses are provided for information only. Arbitrary and relative units are also used.

1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.

E97 Test Method for Directional Reflectance Factor, 45-deg 0-deg, of Opaque Specimens by Broad-Band Filter Reflectometry

Index Terms

heating oil; kerosine; smoke density; smoke spot number; ICS Number Code; 75.160.20

Patty Jacobs, P.E.
Oregon DEQ - Air Quality Program - NWR Office
2020 SW 4th Avenue, Suite 400
Portland, OR 97201
Office: 503-229-5425
Fax: 503-229-6945

-----Original Message-----
From: ARMITAGE Sarah
Sent: Monday, October 29, 2007 2:55 PM
To: JACOBS Patty
Subject: RE: Seemingly "conflicting" rules

We are trying to do some more updating along with the PM 2.5 adoption. Is smoke spot some kind of outdated particulate limit? If so, it might fit in.

If not, ask Cory who is collecting ideas for the next general rule improvement project.

-----Original Message-----
From: JACOBS Patty
Sent: Monday, October 29, 2007 2:30 PM
To: ARMITAGE Sarah
Subject: RE: Seemingly "conflicting" rules

OK Thanks.......for SPPIT 3?

Patty Jacobs, P.E.
Oregon DEQ - Air Quality Program - NWR Office
2020 SW 4th Avenue, Suite 400
Portland, OR 97201
Office: 503-229-5425
Fax: 503-229-6945

-----Original Message-----
From: ARMITAGE Sarah
Sent: Monday, October 29, 2007 1:50 PM
To: JACOBS Patty
Subject: RE: Seemingly "conflicting" rules

Patty,

So sorry to report that SPPIT did not touch 208-0610. First time I have heard of smoke spot and it does not sound like cutting edge.

Sarah

-----Original Message-----
From: JACOBS Patty
Sent: Monday, October 29, 2007 1:27 PM
To: ARMITAGE Sarah
Subject: RE: Seemingly "conflicting" rules

Hi there,

Another SPPIT2 question, see red font item below. Did rule 208-0610(2) change at all? The smoke spot thing need to go.........I hope it did. Thanks, Patty

Patty Jacobs, P.E.
Oregon DEQ - Air Quality Program - NWR Office
2020 SW 4th Avenue, Suite 400
Portland, OR 97201
Office: 503-229-5425
Fax: 503-229-6945

-----Original Message-----
From: ARMITAGE Sarah
Sent: Wednesday, October 17, 2007 12:45 PM
To: JACOBS Patty
Subject: RE: Seemingly "conflicting" rules

Ok - the rules will be effective when filed, which I hope to get done in the next few weeks.

-----Original Message-----
From: JACOBS Patty
Sent: Wednesday, October 17, 2007 12:44 PM
To: ARMITAGE Sarah; BAUMGARTNER Johnny; WIND Cory Ann
Subject: RE: Seemingly "conflicting" rules

Thanks.......then I shall delete this condition (#40) from the Title V Permit renewal for the PGE Beaver/ Port Westward plants. PJ

Patty Jacobs, P.E.
Oregon DEQ - Air Quality Program - NWR Office
2020 SW 4th Avenue, Suite 400
Portland, OR 97201
Office: 503-229-5425
Fax: 503-229-6945

-----Original Message-----
From: ARMITAGE Sarah
Sent: Wednesday, October 17, 2007 12:10 PM
To: BAUMGARTNER Johnny; WIND Cory Ann
Cc: JACOBS Patty
Subject: RE: Seemingly "conflicting" rules

Hey, good news I hope - that is if Patty was not needing to use the old gas tank rule.

Last night while cramming for the SPPIT2 EQC adoption, I realized that we are repealing the conflicting language. George in all his wisdom proposed to delete that section you refer to as part of SPPIT2. And the EQC just adopted SPPIT2 changes this morning. (Yay.) I have attached a rule excerpt with adopted deletions shown in redline.

-----Original Message-----
From: BAUMGARTNER Johnny
Sent: Friday, October 12, 2007 11:56 AM
To: ARMITAGE Sarah; WIND Cory Ann
Cc: BAUMGARTNER Johnny
Subject: Seemingly "conflicting" rules

Patty Jacobs found this rule and it seems to conflict with other rules I have been using.

OAR 340-208-0560(3) states that:

"Gasoline tanks with a capacity of 500 gallons or more that were installed after January 1, 1970 must be equipped with a submersible filling device or other vapor emission control systems."

OAR 340-232-0070(2)(a) EXEMPTS gasoline tanks with capacity of 1500 gallons or less from having submerged fill and vapor recovery requirements.

Am I missing something here?

Johnny