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January 1, 1978 Resumption of Operation of a Portland General Electric Plant 23.9
THE TEXT YOU ARE VIEWING IS A COMPUTER-GENERATED OR RETYPED VERSION OF A PAPER PHOTOCOPY OF THE ORIGINAL. ALTHOUGH CONSIDERABLE EFFORT HAS BEEN EXPENDED TO QUALITY ASSURE THE CONVERSION, IT MAY CONTAIN TYPOGRAPHICAL ERRORS. TO OBTAIN A LEGAL COPY OF THE ORIGINAL DOCUMENT, AS IT CURRENTLY EXISTS, THE READER SHOULD CONTACT THE OFFICE THAT ORIGINATED THE CORRESPONDENCE OR PROVIDED THE RESPONSE. 23.9 Mail Stop 514 January 1, 1978 E.J. Weathersbee Re: Portland General Electric Dear Mr. Weathersbee: This letter is in response to your letter of December 1 and Mr. Patterson's letter of November 21 addressed to Mr. Gaulding. A resumption of operation at this Portland General Electric plant would make it a new source subject to PSD (prevention of significant deterioration) and offset regulations. The fact that this major stationary source once had a permit to operate does not exempt it from those requirements. The purpose of the stringent new source review requirements is to assure that sources not factored into the State Implementation Plan strategy will not interfere with attainment and maintenance of any ambient standard or contribute to a significant deterioration of air quality. This source was explicitly excluded from that strategy. Its temporary permit was conditioned on the fact that it would discontinue operation by mid-1975 when the ambient standards were to be attained. The fact that the State's strategy for attainment of standards postulated no emissions from this source means that resumption of operation would automatically increase the amount of emissions above that which is allowed by the Implementation Plan. The discretionary authority referred to in section 129(a)(3) of the August 7, 1977 Clean Air Act Amendments (Congressional Record, August 3, 1977, H8526) can not be used to exempt this source from the offset procedure. You ask whether the impact of intermittent operation would be permissible. The source has the burden of demonstrating that:
The source should call Ms. Dolores Cooper of my staff if it has any questions about how it would make those demonstrations. Actual air quality on January 1, 1975 is used as the baseline for determining whether a major new source will contribute to significant deterioration. The fact that this source was operating at that time means that subsequent shutdown of the source increased the amount of new growth allowable in the area. However, a source that is shut down can not reserve that growth potential for itself. Applications for construction or modification under that program are considered in the order that applications are received. If you have any further questions, please call Mr. John Bookston, an attorney on my staff at (206) 442-1275. Sincerely, /s/ MR.Reed Lloyd A. Reed cc: Norm Edmisten, EPA bcc: Rich Biondi, DSSE |