Office of Air Quality, Permitting & Enforcement Division Mechanical Section Policy Memorandum þÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍ Date: February 15, 1994 No.: 3 From: Mike Gould Approved by: Gary Wallin Subject: Standard Exemptions Included in Permits þÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍ Policy: If a permit, amendment or renewal has an administrative complete date that is prior to the effective date of the newest revision of Regulation VI, Rule 116.116(c),(i.e., August 16, 1993), then any claimed standard exemption does not have to be included in the maximum allowable emission rates table (MAERT). This does not preclude the engineer from entering the exempted information on the MAERT or within the special provisions if so desired. However, in order to speedup the reduction in the backlog, another deficiency letter requesting additional emissions information on exempted processes may be counter productive. Additionally, when the permit is amended or renewed in the future, the exempted portion will need to be included in the MAERT. Background: Chemical Dynamics submitted an amendment application December 11, 1991 and was determined to be administratively complete on December 17, 1991. During the technical review, the company subsequently claimed fourteen different standard exemptions covering different processes. The application has not been determined to be technically complete and continues to be under review. Since special provisions and a MAERT are not being drafted, would the new Regulation VI policy on standard exemptions (page 13, paragraph 116.116[c]) be applicable? The answer is no. Necessary Action: none Revised 4-20-94 cc: All Mechanical Section