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Technology Transfer Network - OAR Policy and Guidance

OAR Policy and Guidance Metarecord

Document Title/Subject:
Radionuclide NESHAP and Title V
Related Documents:
Signed by: John Seitz and Margo Oge

Signature Date: September 20, 1994

Kirt Cox, Information Transfer and Program Integration Division, OAQPS



Regulatory Authority:
Title 5
Information Transfer and Program Integration Division (OAQPS)
Submitted By:
Document Type:
Policy & Guidance Memos
EPA Document Number:

Federal Register:
Subject Category:
National Emission Standards for Hazardous Air Pollutants
This is a memo from John Seitz and Margo Oge of EPA's Office of Air and Radiation outlining some relationships between the NESHAP for radionuclides and the Title V program. Permitting authorities (PAs) are encouraged to obtain delegation of all NESHAP, including the radionuclide NESHAP. EPA recognizes that few PA's have yet developed the technical expertise to independently implement the radionuclide requirements due to the strong Federal role in this area, so PA's are urged to develop State-EPA implementation agreements to obtain training and other support in implementing the program. States are free to use whichever combination of their personnel they feel is appropriate for doing this; the activities do not have to be in the air program. Because there is not yet a definition of "major" for radionuclide sources, no source would be a major ยง112 source solely due to its radionuclide emissions. However, some units subject to a radionuclide NESHAP are part of a source that is major for othe r reasons and, therefore, subject to Title V. The Title V permit would address all applicable requirements for every emissions unit at the source, including the radionuclide NESHAP. Therefore, for a Part 70 program to be approved, the PA must demonstrate that no legal impediment exists to issuing Part 70 permits that ensure compliance with radionuclide NESHAP and final action must be taken on all initial Part 70 permit applications, including sources subject to the radionuclide NESHAP, within 3 years from the effective date of the program.
(13 pages)

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