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2018 Adoption Updates Proposed Revision: Questions & Answers

Note: These questions and answers pertain to the 2018 Adoption and SIP Updates Proposed Revisions. The information was current at the time of posting, but may be outdated after the adoption of regulations.

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Why is ADEC updating adoptions by reference?
ADEC is adopting updated federal regulations so that applicable requirements are included in permits.
Where can I find the updated adoption by reference documents?
The current and proposed updated adoption by reference documents can be found at: 18 AAC 50 Reference Materials
18 AAC 50.030--What is the purpose of adopting the Emissions from Worker Housing Letter? What’s driving the inclusion of the letter in the regulations? Can there be a suggestion to limit the inclusion of the requirements to a specific geographic location or the total number of workers’ houses included? Will facilities with PAELs have to do additional air monitoring or calculations for emissions to show that they wouldn’t be subject to additional permitting requirements?
The letter was issued to resolve inconsistencies with how EPA policy was being implemented. Because it is used as guidance for writing permits, the Department of Law requires that we adopt it by reference into 18 AAC 50. The policy must be applied consistently statewide. PAELs do not have to do modeling.
18 AAC 50.230(d)(2)(D)--Some facilities in very remote locations where internet access is not reliable may not being able to electronically submit required reports; would mail submission would still be acceptable in such cases?
The Department acknowledges that some locations may have difficulty with internet access and is willing to consider revising the regulations to allow for mail submission with approval.
18 AAC 50.311, ammonia emissions "significant" level in nonattainment areas--how will this interact with PM2.5 nonattainment calculations in the SIP development? Will it affect Department’s request for information and modeling?
EPA requires states to set a level for ammonia as a precursor for PM2.5 for nonattainment areas. Alaska has no facilities with that level of ammonia emission, so it shouldn’t be an issue.
Standard Condition I Emission Fees—New language: “For non-major stationary sources that only need a permit because they have an emission unit subject to EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) or New Source Performance Standards (NSPS), only the emissions from the emissions unit subject to the NESHAP and/or NSPS standards are counted as assessable emissions.” With the adoption of 40 C.F.R. 60, Subpart OOOOa, would the Department start to consider including fugitive emissions in the calculation??
The proposed revisions to SPC I does not change how the Department accounts for assessable emissions. For non-major stationary sources that only need a permit because they have an emission unit (affected facility) subject to NSPS or NESHAPs, only emissions from the affected facilities under the subpart (including fugitive) are included in assessable emissions calculations. Subpart OOOOa does not require an operating permit for non-major stationary sources.

Additional information:

FAQs Regarding the Department's Adoption of EPA's 2016 Revision to the Guideline on Air Quality Models (PDF)

The department will aggregate its response to substantially similar questions and make the questions and responses available on this page.  The department may, but is not required to, answer written questions received after the February 23, 2018, deadline for submitting questions.

Alternately, you may submit questions to Rebecca Smith at

Documents for the proposed regulation changes may be found at: 2018 Adoption Updates Proposal Webpage