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Please see www.epa.gov/nsr for the latest information on EPA's New Source Review program.
Seasonal Afterburner Policy, Applicability of Part D New Source Review Requirements


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22.5

                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                Office of Air Quality Planning and Standards
                Research Triangle Park, North Carolina  27711

                                 JUN 28 1985

MEMORANDUM
----------

SUBJECT:  Seasonal Afterburner Policy, Applicability of Part D New Source
          Review Requirements

FROM:     Robert D. Bauman, Chief
          Standards Implementation Branch, CPDD (MD-15)

TO:       William S. Baker, Chief
          Air Programs Branch, Region II

     This is in response to your memorandum dated March 8, 1985, in which
you requested guidance on whether emissions increases associated with the
winter shutdown of VOC control equipment must be reviewed for applicability
for new source review (NSR).  Your proposal would allow sources which have
historically been using the EPA Seasonal Afterburner Policy to exempt the
increases in emissions for NSR applicability.  All other sources are
prohibited from exempting any emissions from the applicability requirements. 
These sources include any sources which deviate from the EPA Seasonal
Afterburner Policy, existing sources which although able to use the EPA
Seasonal Afterburner Policy have not chosen to apply it, and all new sources
of air pollution.  I support your proposal except for one minor change.  All
sources in existence before the date of this memo, which have not previously
requested an exemption under the EPA Seasonal Afterburner Policy should not
be required to evaluate the associated increase in emissions for NSR
applicability if the exemption is processed as a SIP revision.

     This policy position has been agreed on by Office of General Counsel
and Regulatory Reform staffs which should avoid any further revisions in the
near term.  The attached outline summarizes the relationship between the EPA
Seasonal Afterburner Policy and NSR.

Attachment

cc:  M. Levin
     W. Petersen
     D. Tyler    

          THE RELATIONSHIP BETWEEN THE SEASONAL AFTERBURNER POLICY
                            AND NSR APPLICABILITY

1.   Sources which have historically been using the EPA Seasonal Afterburner
Policy will not be required to evaluate the associated increase in emissions
for NSR applicability.

2.   Sources in existence as of the date of this memo, which have not
previously requested an exemption under the EPA Seasonal Afterburner Policy,
will not be required to evaluate the associated increase in emissions for
NSR applicability if the exemption is processed as a SIP revision.

3.   New sources which request the use of the EPA Seasonal Afterburner
Policy must be reviewed accordingly:

     a.  Evaluate the associated increase in emissions when calculating
potential emissions for applicability purposes.

     b.  If the request results in a source being classified as a new major
source or major modification, then require:

         i. Offsets for all emissions on a tons-per-year basis,
        ii. Statewide compliance, and
       iii. LAER, which may include seasonal shutdown of afterburners if the
State determines this shutdown meets standard industry practices for the use
of afterburners.

4.   Any other State exemption which allows increases in VOC's during the
wintertime which deviate from the EPA Seasonal Afterburner Policy (e.g., for
boilers using oil) will be required to evaluate the associated increase in
emissions as discussed in (3) above.

Notebook Entries: 2.20; 5.20
Seasonal Afterburner Policy, Applicability of Part D New Source Review Requirements

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