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Date: Fri May 03 1996 - 14:36:46 CDT

In regards to the questions posed by Duncan Fowler and forwarded by Deb
Kramer, the following is true in Minnesota to the best of my knowledge:

1. Minnesota is basing their operating permits on a 12-month rolling average
emission limit.

2. Minnesota facilities with an air operating permit are required to
maintain records on every emission unit (including fugitive) at least
monthly. Only those activities meeting the definition of "insignificant
activities" need not be monitored for air emissions.

3. Minnesota is in attainment for Ozone, therefore, facilities that have the
potential to emit less than 100 tons per year of VOC are not required to
obtain an air emissions permit. Consequently, most printing companies are
not required to obtain an air permit and do not have to maintain a 12-month
rolling average in order to prove to an agency inspector that they do not
need an air permit.

4. In Minnesota, facilities whose actual emissions are less than 50% of the
permitting threshold (50 tons per year of VOC) receive a registration permit.
 A registration permit requires a 12-month rolling average of actual VOC
emissions be maintained in order to demonstrate compliance with their air
permit. The 12-month rolling average is based on the chemicals purchased,
the VOC content of those chemicals, and the VOC emission rates of those
chemicals. The only assumption that is allowed is that all chemicals that
are purchased in a month are also used in that month. Of course in reality,
this doesn't happen but to simplify the calculations, the assumption is that
if its' bought in May, it's used in May.

5. The only adjustment Minnesota facilities have made to comply with their
air permits is to esablish an accurate monthly chemical purchasing tracking
system in order to account for their monthly chemical purchases.

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