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28.3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
DATE: April 8, 1980
SUBJECT: New Source Review Requirements for Lead
FROM: Richard G. Rhoads, Director, Control Programs Development Division
(MD-15)
TO: Director, Air and Hazardous Materials Division, Regions I-X
Recently, several Regions have requested guidance regarding new source
review requirements for lead SIPs.
The "Supplementary Guidelines for Lead Implementation Plans" contains a
brief outline of general SIP requirements. This outline discusses those
portions of 40 CFR 51 regulations "Requirements for Preparation, Adoption,
and Submittal of Implementation Plans" that were not revised to account for
the lead standard, but which are still applicable to the lead SIPs.
Specifically, the requirements of CFR 51.18 Review of New Sources and
Modifications must be satisfied for lead SIPs.
Existing permitting regulations adopted in accordance with Section
51.18 may be applicable to lead depending on the specific exemptions
included in the State's general permitting regulation. In general, the NSR
requirement for lead SIPs may be satisfied by simply revising existing
permit regulations to eliminate any exemption of sources that have the
potential to emit five tons/year or more of lead.
The source size limit is based on the definition of a point source of
lead which is five tons/year actual emissions of lead. The rationale for
this limit is based on an analysis contained in the "Supplementary
Guidelines for Lead Implementation Plans," pages 73-77. Briefly, this
rationale indicates that sources which emit five tons/year of lead have the
potential to violate the ambient standard for lead.
If you have any questions regarding new source review in lead SIPs,
contact Susan Jackson (629-5365) of my staff.
cc: Chief, Air Branch, Regions I-X
Mike James, OGC
Ed Reich, DSSE |
