May 16, 1995




MEMORANDUM

SUBJECT:  Title V Permitting for Nonmajor Sources in
          Recent Section 112 Maximum Achievable Control           
          Technology (MACT) Standards

FROM:     John S. Seitz, Director
          Office of Air Quality Planning and Standards

TO:       Addressees

     The purpose of this memo is to inform you of recent
developments regarding deferral and exemptions of the Title V
Part 70 permit requirements for nonmajor sources included in the
recently promulgated MACT standards.  

     Recently, staff from State and local implementing agencies
and from the EPA met at Brown Summit, North Carolina, to discuss
among other topics, concerns regarding permitting of nonmajor
sources required in some recently promulgated MACT standards. 
Together, the representatives from the various agencies
considered the advantages and disadvantages of permitting, timing
considerations, and alternative approaches.  Based on these
discussions, we believe we now better understand the burden to
the States of trying to permit the area sources at the same time
the States are focusing on major sources.  We also better
understand, based on these discussions and discussions with
industry representatives, the extent to which area sources, in
particular, need information, clarity, and guidance to obtain
Title V Part 70 permits.  We had already publicized our intention
to allow deferral of Part 70 permits for nonmajor drycleaning and
halogenated solvent cleaning sources.  Based on recent
discussions, we now plan to also propose to allow deferral of
permit acquisition for nonmajor sources of chromium
electroplaters and ethylene oxide commercial sterilizers.  A
Federal Register notice is being prepared to propose these
deferrals.  The notice will specify the dates when permits must
be acquired; the time will be approximately 5 years from now. 
Assuming these proposals are finalized, this means that the
requirement to obtain permits will be deferred for all nonmajor
sources for which we currently have Section 112 final rules.  It
should be noted that we also plan to propose to exempt 
entirely from the requirement to obtain a permit decorative
chrome platers and chromium anodizers controlling emissions with 


fume suppressants.  Of course, all sources would still be
required to meet the requirements of the Section 112 standards
with or without a permit.

     Please use the above information as guidance in planning
permitting programs and responding to questions from regulated
sources about the timing for Title V permit requirements.  I
greatly appreciate the input from the participants at Brown-
Summit and I will make sure that we follow up on the actions
described here and get the Federal Register proposal out soon. 
If you have any questions,  Mr. Dave Beck is the contact person. 
He can be reached at (919) 541-5421.  I trust this information
will be helpful to you. 

Addressees:

     Director, Air, Pesticides and Toxics
       Management Division, Regions I and IV
     Director, Air and Waste Management Division, Region II
     Director, Air, Radiation and Toxics Division, Region III
     Director, Air and Radiation Division, Regions V
     Director, Air, Pesticides and Toxics Division, Region VI
     Director, Air and Toxics Division, Regions VII, VIII, IX, X
     Bill Becker, STAPPA/ALAPCO
     Don Theiler, STAPPA/ALAPCO
     Bruce Jordan, ESD
     Bob Kellam, ITPID

bcc: Lalit Banker, ESD
     Dave Beck, ESD
     Steve Hitte, ITPID
     Joanna Swanson, ITPID
     Group Leaders, ESD      

OAQPS:ESD:OCG:LBANKER/thweatt:NCM:X5420:5/02/95