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October 17, 1989 Ambient Air 6.29
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.
6.29
MEMORANDUM SUBJECT: Ambient Air
FROM: Robert D. Bauman, Chief
TO: Gerald Fontenot, Chief My staff and I have discussed the ambient air case outlined in the August 24, 1989 memorandum from Jim Yarbrough of your staff to Doug Grano of my staff. Specifically, Region VI and the Texas Air Control Board propose that prevention of significant deterioration (PSD) modeling for Mitsubishi Industries can discount the contribution of a background source to the predicted concentration as follows:
This situation is similar to a case raised to OAQPS's attention in 1987 by Region V. Guidance on this case was provided by OAQPS to Region V in a memorandum dated April 30, 1987 (attached). That guidance is consistent with your proposed approach and, therefore, we agree with your position. However, the State should be advised that, when modeling Mitsubishi, all receptors off Mitsubishi property are in ambient air and that the ambient air policy does not allow sources to excessively pollute their neighbors. Note that a background source could, in the future, change their operation and make portions of their property accessible to the public. Care should be taken to avoid situations that could result in undue exposure to excessive concentrations and which could result in adverse public health impacts. In response to your position on issuance of the permit where Mitsubishi makes a significant contribution to predicted violations of either the national ambient air quality standards (NAAQS) or PSD increments, policy contained in the July 5, 1988 memorandum from OAQPS to Region 3 should be
applied (attached). For a new or existing NAAQS violation, the permit may be granted under specific conditions. However, for any increment violation for which the proposed source has a significant impact, the permit should not be approved unless the increment violation is corrected prior to operation of the proposed source. If you have any questions regarding this memorandum, please call Doug Grano at FTS-629-5255. Attachments
cc: Air Branch Chief, Regions IV, VII-X
bcc: John Calcagni |