Minutes of the ARB/CAPCOA/Industry
                     Title III Subcommittee Meeting
                            January 24, 1996

Purpose of the Meeting:

     The purpose of this meeting was to address issues related to Title III of 
     the federal Clean Air Act Amendments.

Attendees:     (see attached)

1.   Meeting Protocol

     This was the second CAPCOA Title III Subcommittee Meeting that has 
     devoted an afternoon to topics of interest to industry.  The ARB put the 
     agenda together.  Industry representatives need to bring items for the 
     agenda to the attention of Dan Donohoue at (916) 322-8277.  The ARB will 
     mail copies of the minutes from the meeting to each attendee and make 
     them available on the ARBIS.  The mailing list for this meeting was 
     developed from the ARB/CAPCOA/Industry task force.  If other names need 
     to be added to the mailing list, contact Dan Donohoue.   

2.   Report on Action Items from November 29, 1995 Meeting

     A.   Section 112(r) - The U.S. EPA s report on district responsibilities 
     under the accidental release prevention program if the Office of 
     Emergency Services receives delegation for the program

     B.   The ARB reported on the development of a concept paper on broad 
     program approval.  (See item 5 below)

3.   Briefing on Title V Activities Toward Consolidation of Permit 
     Requirements

     A draft version of Title V White Paper II is being circulated among 
     STAPPA/ALAPCO members.  Comments are due by the end of February.  Release 
     of the White Paper II for general review is anticipated in February.  
     The White Paper II should provide assistance in streamlining
     conflicting or duplicative requirements.

Issues:
þ    Sources can streamline and use the most stringent emission limitations
þ    Methods to streamline approval process
þ    Unclear how much help it will provide for 112 sources
þ    Must take straight delegation of NESHAP to use White Paper II 
     streamlining
þ    Qualifying criteria - how will this be implemented?

 4.  Coordinated Development of NESHAP Implementation/Compliance Material

     The subcommittee discussed the need for outreach and compliance 
     assistance material. Industry reported that API has conducted a one-day 
     workshop on the Gasoline Distribution MACT.  This workshop addressed 
     federal issues.  It did not have California-specific information. 
     API has also sponsored informational workshops on the HON, Petroleum 
     Refineries, and Marine Vessels MACTs.

Issues:  

þ    Should we pay API to come and do workshops instead of developing our own?
þ    Should we use API s information and tailor it for California?

5.   Broad Program Approval Concepts

     ARB presented an initial concept paper on integration of the state and 
     federal air toxic programs through a broad program approval mechanism.  
     The idea would be to establish a pilot program that would allow 
     California to meet the requirements of the emissions standards 
     established by the federal air toxics program using the existing 
     California air pollution control program.  The concept paper stresses 
     achieving at least the same emission reductions as the NESHAP, but 
     allowing flexibility for districts to tailor monitoring, recordkeeping, 
     and local reporting requirement needs.   
     
     Radian is preparing for WSPA a comparison of the Petroleum Refinery MACT 
     and the Gasoline Distribution MACT with applicable district VOC rules.  
     The purpose is to determine if requesting equivalency for the district 
     VOC rules is a viable option.

ACTION ITEM:

    WSPA will review Board Program Approval concept paper and provide initial 
     reaction to the ARB by the end of February.


6.   Section 112 Implementation Workshop Report

     ARB reported that a draft of the Section 112 Implementation Workshop 
     reports will be sent to the industry representatives that were co-leads 
     of a breakout session or a panel member. After incorporation of comments 
     from the districts and industry, a final report will be sent to all
     workshop participants.

ACTION ITEM:

    Review and comment on draft Section 112 Implementation Report by 
     February 23, 1996.

7.   Next Meeting Date and Location

The next CAPCOA Title III Subcommittee will meet at the ARB office in 
Sacramento and the video conference room at the Air Resources Board in 
El Monte.  The date for the next meeting is March 21, 1996.