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October 10, 1985 Questions and Answers on Implementing the Revised Stack Height Regulation 6.34

A number of questions/answers are presented for clarifying the revised stack height regulations for Clarification of interpretation of the regulation, SIP requirements and modeling analyses are presented. Interpretation of the regulation issues include: 1) Criteria to use with respect to grandfathering dates; 2) The source definition to use when determining whether tie-ins to grandfathered stacks should be permitted or prohibited; 3) definition of a "facility"; 4) How to determine GEP stack height for pollutants; 5) Determining "reliance" on the 2.5H formula; and 6) specification of structure that should not be represented by the formula. SIP requirement issues include when to state a compliance averaging time in SIP revisions for SO2 emission limits and stack height regulation requirements for States. Modeling analyses issues include: 1) Restrictions/prohibitions against raising/replacing stacks; 2) The status of flares; 3) Fluid modeling clarification; and 4) Clarification of modeling parameters for analyses.
Notebook Entries: 15.13; 3.39; 8.52

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