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Note: EPA no longer updates this information, but it may be useful as a reference or resource.

Please see www.epa.gov/nsr for the latest information on EPA's New Source Review program.

September 10, 1986 Remand of June 3, 1986 North County Resource Recovery Associates PSD permit in San Marcos, California. 8.13

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8.13

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IX
215 Fremont Street
San Francisco, Ca. 94105
September 10, 1986

Mr. R.J. Sommerville
Air Pollution Control Officer
San Diego County Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123

Dear Mr. Sommerville:

This is a follow-up to our June 27, 1986 letter to you regarding the June 3, 1986 remand of the North County Resource Recovery Associates PSD permit in San Marcos, California.

It is the initial opinion of EPA that PSD permits should not be issued to new sources by any permitting agency unless the project's proposed BACT represents the greatest degree of control currently achievable for unregulated pollutants emitted by that category of source. EPA suggests the following:

  • If the project's proposed BACT does not consider the control of unregulated pollutants, then the PSD permit should be placed on hold pending guidance from EPA Headquarters on the implementation of the remand decision.

  • If the project's proposed BACT considers the control of unregulated pollutants, then permitting can proceed provided a condition is added to the PSD permit as suggested in the attachment. This condition may be deleted from the affected permit at a future date when all issues related to the remand have been addressed by the applicant and the permitting agency.
-2-

Further guidance regarding this matter will be forthcoming. If you have any questions, please call Wayne Blackard, Chief of our New Source Section, at (415) 974-8249.

Sincerely,

David P. Howekamp
Director
Air Management Division

Enclosure

Suggested Permit Condition
--------------------------

Control of Unregulated Pollutants
---------------------------------

Should additional guidance relating to the June 3, 1986 PSD remand, applicable to this permitting action, be developed, (company name) shall provide to (agency name) any such analysis, data or demonstration of compliance with other requirements within the time required by such guidance.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

JUN 27 1986

Mr. David J. Minedew
Director
Washoe County Air Pollution Control District
1001 E. Ninth
Reno, NV 89520

Dear Mr. Minedew,

On June 3, 1986, the Administrator issued a remand of the North County Resource Recovery Associates PSD Permit to the Region 9 office. On June 24, all Regional offices of EPA were notified by the Office of General Counsel that the decision embodied in this remand should, at a minimum, be applied to all PSD applications currently in process (i.e. at least those projects that have not yet received a final permit). This requirement also applies to PSD programs delegated to State or local agencies.

Guidance on how to implement this decision should be forthcoming from EPA headquarters in approximately two weeks. Since BACT determinations for all permits are potentially impacted, you are requested to not issue any proposed or final permit until this guidance is provided to your agency.

Please call me if you have any questions.

Sincerely,

ORIGINAL
SIGNED BY:

David Howekamp
Director
Air Management Division

[A] Mr. James K. Ikeda "Mr. Ikeda"
Deputy Director for Environmental Health
Hawaii Department of Health Environmental Protection and Health
Services Division
P. O. Box 3378
Honolulu, HI 96801

[A] Mr. David J. Minedew "Mr. Minedew"
Director, Washoe County Air Pollution Control District
1001 E. Ninth
Reno, NV 89520

[A] Mr. Richard B. Booth "Mr. Booth"
Air Pollution Control District
Shasta County Air Pollution Control District
1855 Placer Street
Redding, CA 96001

[A] Lawrence Hart, M.D., M.P.H. "Dr. Hart"
Air Pollution Control Officer
Santa Barbara County Air Pollution Control District
315 Camino del Remedio
Santa Barbara, CA 93110

[A] Mr. R. J. Sommerville "Mr. Sommerville"
Air Pollution Control Officer
San Diego County Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123

[A] Mr. Donald R. Rowe "Mr. Rowe"
Air Pollution Control Officer
Fresno County Air Pollution Control District
1220 Fulton Mall
Fresno, CA 93721

[A] Mr. Milton Feldstein (Mr. Feldstein)
Air Pollution Control Officer
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109

[A] Mr. Lowell Shifley "Mr. Shifley"
Air Quality Officer
Nevada Department of Conservation and Natural Resources
Division of Environmental Protection
201 South Fall Street
Carson City, NV 89710


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