mech3.txt

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     Office of Air Quality, Permitting & Enforcement Division

               Mechanical Section Policy Memorandum

                 

Date:     February 15, 1994                            No.: 3

From:     Mike Gould

Approved by:  Gary Wallin

Subject:  Standard Exemptions Included in Permits

                  

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