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From: Debra Kramer (
Date: Thu May 02 1996 - 15:32:00 CDT

I received this from the Small Business Ombudsman listserv - if any one has
comments about this please reply to the Printreg listserv. I would like to
have an opportunity to learn from responses to these questions. I will
forward the responses on to Duncan.


Deb Kramer

From: Duncan C. Fowler
To: kramer
Subject: Questions RE:12 MONTH ROLLING AVERAGE
Date: Thursday, May 02, 1996 1:40PM

I have received a request to get answers to the following questions. The
agency involved asked that I not ID them in the question as per the earlier
note I passed arround.

Please forward responses to me and I will forward your responses on to the
person that made the query. And if there are several of interest, I will
forward them on to the group.


Dunc Fowler

It seems to me that the US EPA has taken a position that operating permits
with an annual emission limit are practically unenforceable.

1) Is your state basing your operating permits on a 12 month rolling period
emission limit?

2) Are facilities with operating permits in your state required to maintain
records on every emission unit (including fugitive and insignificant
emission units) at least monthly?

3) Are smaller emission units exempt from such 12 month rolling record
keeping? If so, what threshold is used to decide which emission units must
have 12 month rolling records and which have less frequent monitoring?

4) How does a facility with a 12 month rolling period based emission limit
determine compliance with its operating permit if monitoring for some
emission units is less than monthly? What assumptions are they authorized
to use?

5) If your facilities previously used purchase records for determining
compliance with annual limits, what adjustments have they had to make to
generate more frequent monthly records?

Debra Kramer
3333 W. Arthington
Chicago, IL 60624

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