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From: Wayne Pferdehirt (
Date: Mon May 06 1996 - 15:12:57 CDT

Forwarded from Dale Ziege, WI DNR:

Date: Mon, 6 May 1996 13:41 CDT From: (Dale
Ziege) Message-Id: <> To: Subject: Questions on 12 month averaging
X-VMS-To: smtp%""

The Wisconsin Air Program has been following the Federal present
policy memo on practical enforceability this since it was written
around 7 years ago in June of 1989. Previous federal policy, going
back at least past to 1985 and probably into the early 1980's also did
not recognize limits extending beyond 30 days.

Also, in your first question, you imply that limit can be on
EMISSIONS. That is generally not the case. The federal policy states
that the limits must be on raw material use, production rate or hours
of operation. It will recognize limits on emissions ONLY in specific
exceptions. Another thing to note is that it states that the limits
shall be MONTHLY at most, and only in "rare" circumstances can you go
to 12 month rolling averages. Bearing these things in mind I will try
to answer your questions.

1) Yes we have been been using monthly and 12- month rolling limits
(mostly on material usage) in our operation permit program. These
limits are put in only when requested by the facility when they decide
that they wish to limit their own Potential To Emit for whatever
reason they may have to want this. If they do not want to restrict
their Potential To Emit, they are not required to take such limits.

2) Yes the facilities are required to keep monthly records if they
want to restrict their federal Potential To Emit. Records need to
account for all emissions at the facility. Fugitives and
insignificant units need to be accounted for in some manner, although
not necessarily through monthly records.

3) Smaller units can be excluded if it can be shown that their
emissions could not possibly put the facility over whatever limit on
Potential To Emit that they requested be included in their permit.
This needs to be determined on a case-by-case basis, considering the
maximum potential emissions from the "smaller" units, and how close
the emissions from the "larger" emission units come to the Potential
To Emit limit that the facility chooses.

4) This can be done, but cannot be done generically. It would need
to be done on a case-by-case basis considering factors mentioned in
the answer to 3).

5) I can't answer this one. Only the facilities know the adjustments
that they've had to make. I do know that some have developed PC based
tracking systems that they use for this. I don't know if they would
have developed similar systems on their own so they could better track
their raw material use.

If you have any questions you can call me at (608)266-0113. Dale

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