United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/4-87-007
May 1987
Air
vvEPA
Ambient Monitoring
Guidelines for
Prevention of
Significant
Deterioration (PSD)
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RA-450/4-87-007
../lay 1987
Ambient Monitoring Guidelines
for Prevention of Significant
Deterioration (PSD) \
by
Monitoring and Data Analysis Division
Office of Air Quality Planning and Standards
and
Environmental Monitoring Systems Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park NC 27711
U.S. Environment?! Protection Agency
Rpoio.i :J U'C'-ary (?{ I- ;>
77°VV?/;; '--'.' > ^'."'^'>, 12th Floor
Chicago, iL b(;u04-J-'JO
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FOREWORD
Many individuals were involved in the preparation of this document
and should be contacted if any questions arise in the application of the
guideline.
Subject Area
Ambient Air Quality
Monitoring
Meteorological
Monitoring
Quality Assurance
(Ambient Air
Quality)
PSD Policy and
Interpretation
of Regulations
Acceptable Methods
Non-Criteria
Pollutants
Contact
Stan Sleva
David Lutz
James Dicke
Larry Purdue
Jack Puzak
Gary McCutchen
Larry Purdue
Ken Rehme
Phone Number
(Area Code 919)
541-5652
541-5476
541-5682
541-2665
541-2106
541-5592
541-2665
541-2666
FTS Number
629-5652
629-5476
629-5682
629-2665
629-2106
629-5592
629-2665
629-2666
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DISCLAIMER
This report has been prepared by the Office of Air Quality Planning
and Standards and the Environmental Monitoring Systems Laboratory, U.S.
Environmental Protection Agency, and approved for publication. It has been
subject to the Agency's peer and administrative review, and it has been
approved for publication as an EPA document.
Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
111
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TABLE OF CONTENTS
Page
1. INTRODUCTION [[[ 1
2. GENERAL REQUIREMENTS AND CONSIDERATIONS ........................... 3
2.1 Monitoring Data Rationale ------------------------------------ 3
2.1.1 Criteria Pollutants - Preconstruction Phase ----------- 3
2.1.2 Criteria Pollutants - Postconstruction Phase ---------- 4
2.1.3 Noncriteria Pollutants - Preconstruction and
Postconstruction Phase -------------------------------- 5
2.2 Monitoring Objective and Data Uses --------------------------- 5
2.3 VOC and 03 Monitoring Requirements --------------------------- 5
2.4 Use of Representative Air Quality Data ----------------------- 6
2.4.1 Monitor Location -------------------------------------- 6
2.4.2 Data Quality ---------- ...... -------------------------- 8
2.4.3 Currentness of Data ------------------------------ ..... 9
2.4.4 Provisions for PMio and TSP in Transition Period
of 1987 PSD Amendments -------------------------------- 9
2.5 Duration of Monitoring --------------------------------------- 9
2.5.1 Normal Conditions ------------------------------------- 9
2.5.2 Transition Period for PMo and TSP -------------------- 10
2.5.2.1 Transition Within 10 Months After
Effective Date of PMiQ Amendments ------------- 10
2.5.2.2 Transition During 10-16 Months After
Effective Date of PMio Amendments ------------- 11
2.5.2.3 Transition During 16-24 Months After
Effective Date of PMiQ Amendments ------------- 12
2.5.2.4 Period Following 24 Months After Effective
Date of PM Amendments ----------------------- 12
2.6 Sampling Methods and Procedures ------------------------------ 13
2.7 Frequency of Sampling ---------------------------------------- 13
2.8 Monitoring Plan ---------------------------------------------- 14
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TABLE OF CONTENTS (Continued)
Page
3. NETWORK DESIGN AND PROBE SITING CRITERIA ........................ 17
3.1 Network Design ----------------------------------------------- 17
3.2 Number and Location of Monitors ------------------------------ 17
3.2.1 Preconstruction Phase --------------------------------- 17
3.2.2 Postconstruction Phase -------------------------------- 19
3.2.3 Special Concerns for Location of Monitors ------------- 19
3.3 Probe Siting Criteria ----------------------------------------- 19
3.3.1 Total Suspended Particulates (TSP) ........... - ...... --- 21
3.3.1.1 Vertical Placement ............................ 21
3.3.1.2 Spacing from Obstructions ------- ...... -------- 22
3.3.1.3 Spacing from Roads --------------- .......... 22
3.3.1.4 Other Considerations -------------------------- 24
3.3.2 PMo ......................................... - ......... 24
3.3.2.1 Vertical Placement -------------------- ..... 24
3.3.2.2 Spacing from Obstructions --------------------- 24
3.3.2.3 Spacing from Roads ---------------------------- 25
3.3.2.4 Other Considerations -------------------------- 25
3.3.3 Sulfur Dioxide (S02) ................................... 25
3.3.3.1 Horizontal and Vertical Probe Placement ------- 25
3.3.3.2 Spacing from Obstructions --------------------- 25
3.3.4 Carbon Monoxide (CO) ..... - ........................... 26
3.3.4.1 Horizontal and Vertical Probe Placement ------- 26
3.3.4.2 Spacing from Obstructions --------------------- 26
3.3.4.3 Spacing from Roads ---------------------------- 26
3.3.5 Ozone (03) ------ ........... - ......... - .............. 27
3.3.5.1 Vertical and Horizontal Probe Placement ------- 27
3.3.5.2 Spacing from Obstructions --------------------- 27
3.3.5.3 Spacing from Roads ---------------------------- 27
3.3.6 Nitrogen Dioxide (N0£) ..... - ........................ 28
3.3.6.1 Vertical and Horizontal Probe Placement ------- 28
3.3.6.2 Spacing from Obstructions --------------------- 28
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TABLE OF CONTENTS (Continued)
Page
3.3.7 Lead (Pb) 28
3.3.7.1 Vertical Placement 28
3.3.7.2 Spacing from Obstructions 29
3.3.7.3 Spacing from Roads 29
3.3.7.4 Other Considerations 29
3.3.8 Noncriteria Pollutants 29
3.3.8.1 Vertical Placement - 29
3.3.8.2 Spacing from Obstructions 30
3.3.8.3 Other Considerations - - 30
3.4 Probe Material and Pollutant Sample Residence Time 30
3.5 Summary of Probe Siting Requirements 31
4. QUALITY ASSURANCE FOR AIR QUALITY DATA 38
4.1 Quality Assurance for Criteria Air Pollutants 38
4.1.1 General Information 38
4.1.2 Quality Control Requirements 39
4.1.2.1 Organizational Requirements 39
4.1.2.2 Primary Guidance 39
4.1.2.3 Pollutant Standards - 40
4.1.2.4 Performance and System Audit Programs 40
4.1.3 Data Quality Assessment Requirements 40
4.1.3.1 Precision of Automated Methods 40
4.1.3.2 Accuracy of Automated Methods 41
4.1.3.3 Precision of Manual Methods 42
4.1.3.4 Accuracy of Manual Methods 42
4.1.4 Calculations for Automated Methods 43
4.1.4.1 Single Analyzer Precision 43
4.1.4.2 Single Analyzer Accuracy 44
4.1.5 Calculations for Manual Methods 45
4.1.5.1 Single Instrument Precision for TSP, Pb,
and PMio - 45
4.1.5.2 Single Instrument Accuracy for TSP and PMiQ 45
4.1.5.3 Single Instrument Sampling Accuracy for Pb 45
4.1.5.4 Single-Analysis-Day Accuracy for Pb 45
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TABLE OF CONTENTS (Continued)
Page
4.1.6 Organization Reporting Requirements 46
4.2 Quality Assurance for Noncriteria Air Pollutants 46
4.2.1 Selection of Method 46
4.2.2 Calibration 46
4.2.3 Data Validation - 47
4.2.4 Standard and Split Samples 47
5. METEOROLOGICAL MONITORING 48
5.1 Data Required 48
5.2 Exposure of Meteorological Instruments 49
6. METEOROLOGICAL INSTRUMENTATION 52
6.1 Specifications 52
6.1.1 Wind Systems (horizontal wind) 52
6.1.2 Wind Systems (vertical wind) 52
6.1.3 Wind Fluctuations 52
6.1.4 Vertical Temperature Difference 53
6.1.5 Temperature 53
6.1.6 Humidity 53
6.1.7 Radiation - Solar and Terrestrial 53
6.1.8 Mixing Height 53
6.1.9 Precipitation 54
6.1.10 Visibility 54
7. QUALITY ASSURANCE FOR METEOROLOGICAL DATA 55
8. DATA REPORTING 56
8.1 Air Quality Data Reporting 56
8.2 Meteorological Data Format and Reporting 56
APPENDIX A - PROCEDURES TO DETERMINE IF MONITORING DATA WILL BE
REQUIRED FOR A PSD APPLICATION
1. INTRODUCTION A-l
2. PSD PERMIT APPLICATION PROCEDURES A-l
2.1 Part 1 - Source Applicability Determination A-l
2.2 Part 2 - Pollutant Applicability Determination A-3
2.3 Part 3 - BACT Analysis A-5
2.4 Part 4 - Ambient Air Quality Analysis A-5
2.5 Part 5 - Source Impact Analysis A-7
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TABLE OF CONTENTS (Continued)
Page
2.6 Part 6 - Additional Impact Analysis A-7
2.7 Part 7 - File Complete PSD Application A-7
3. DECISIONS FOR MONITORING DATA REQUIREMENTS A-10
REFERENCES A-24
vm
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1. INTRODUCTION
The Clean Air Act Amendments of 1977, Part D, Prevention of Significant
Deterioration, require that certain new major stationary sources and major
modifications be subject to a preconstruction review which includes an
ambient air quality analysis. Furthermore, the Act requires that an analysis
be conducted in accordance with regulations promulgated by the EPA. In
this regard, the Agency promulgated PSD regulations [1] on June 19, 1978,
which included ambient monitoring requirements. Guidelines were published
in May 1978 [2] to discuss monitoring for PSD purposes. However, in response
to the June 18, 1979 preliminary Court Decision (Alabama Power Company v._
Costle, 13 ERC 1225), EPA proposed revised PSD regulations L3J on September
5, 1979. The final court decision was rendered December 14, 1979 [4],
Based on the public comments to the September 5, 1979 proposed PSD regulations
and the December 14, 1979 court decision, EPA promulgated new PSD regula-
tions on August 7, 1980. Some of the pertinent provisions of the 1980 PSD
regulations that affect PSD monitoring are discussed below:
(a) Potential to emit.
The PSD regulations retain the requirement that new major
stationary sources would be subject to a new source review on
the basis of potential to emit. However, the_..axinuaj[emission
potential of a source will be determined after the application
of air pollution controls rather than before controls as was
generally done under the 1978 regulations [1].
(b) De minimis cutoffs.
The PSD regulations will exempt on a pollutant specific basis
major modifications and new major stationary sources from all
monitoring requirements when emissions of a particular pollutant
are below a specific significant emission rate, unless the
source is near a Class I area. Also included are significant
air quality levels which may be used to exempt sources or
modifications from PSD monitoring when the air quality impacts
from the sources or modifications are below specified values.
(c) Noncriteria pollutants.
The 1978 PSD regulations [1] required monitoring only for those
pollutants for which national ambient air quality standards
exist. However, there are a number of pollutants for which
no ambient standards exist (noncriteria pollutants) but which
are regulated under new source performance standards and
national emission standards for hazardous pollutants. The
1980 regulations [5J require an ambient air quality analysis
for all regulated pollutants emitted in significant amounts.
This analysis will generally be based on modeling the impact
of the pollutants in lieu of collecting monitoring data.
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(d) Reconstruction monitoring.
A list of air quality concentrations is included in the PSD
regulations as criteria for generally exempting proposed sources
or modifications from collecting monitoring data. Basically,
monitoring data will be required if the existing air quality
and the impact of the proposed source or modification is equal
to or greater than these concentrations. In certain cases,
even though the air quality impact or background air quality
may be less than these concentrations, monitoring data may be
required if the proposed source or modification will impact a
Class I area, nonattainment area, or area where the PSD incre-
ment is violated.
(e) Postconstruction monitoring.
The PSD regulations include authority to require postconstruc-
tion monitoring. In general, EPA may require postconstruction
monitoring from large sources or sources whose impacts will
threaten standards or PSD increments. The permit granting
authority will make this decision on a case-by-case basis.
In 1987 [6] EPA promulgated revisions to the National Ambient Air
Quality Standards (NAAQS) for Particulate Matter. Also, revisions were
promulgated to revise the PSD regulations to account for the NAAQS changes.
The PM^g amendments will not require any new data gathering requirements be-
yond the 1980 PSD requirements for PSD applications submitted not later than
10 months after the effective date of the 1987 PSD amendments. New monitoring
requirements for PMjo will be phased in for PSD applications submitted greater
than 10 and and less than 24 months after the effective date of the 1987 PSD
amendments. In addition, all new monitoring requirements for PM^g will be in
effect 24 months after the effective date of the PSD amendments.
Because of the revisions to the PSD regulations, this guideline has been
modified to reflect such revisions. The purpose of this guideline is to
address those items or activities which are considered essential in conducting
an ambient air quality monitoring program. Guidance is given for designing a
PSD air quality monitoring network as well as the operational details such as
sampling procedures and methods, duration of sampling, quality assurance
procedures, etc. Guidance is also given for a meteorological monitoring
program as well as the specifications for meteorological instrumentation and
quality assurance procedures.
An appendix is included to show how the ambient air quality analysis
fits in the overall PSD requirements. Flow diagrams are presented to aid a
proposed source or modification in assessing if monitoring data may be
required.
General adherence to the guidance contained in this document should
ensure consistency in implementing the PSD monitoring regulations.
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2. GENERAL REQUIREMENTS AND CONSIDERATIONS
2.1 Monitoring Data Rationale
The court decision [4] has affirmed the Congressional intent in the
Clean Air Act as it relates to PSD monitoring requirements. The court
ruled that section 165(e)(l) of the Clean Air Act requires that an air
quality analysis be conducted for each pollutant subject to regulation
under the Act before a major stationary source or major modification could
construct. This analysis may be accomplished by the use of modeling and/or
monitoring the air quality. EPA has discretion in specifying the choice of
either monitoring or modeling, consistent with the provisions in section
165(e)(2). As will be discussed later, modeling will be used in most cases
for the analysis for the noncriteria pollutants.
The court ruled that section 165(e)(2) of the Clean Air Act requires
that continuous preconstruction air quality monitoring data must be collected
to determine whether emissions from a source will result in exceeding the
National Ambient Air Quality Standards (NAAQS). Further, the data could be
used to verify the accuracy of the modeling estimates since modeling will
be the principal mechanism to determine whether emissions from the proposed
source or modification will result in exceeding allowable increments. In
regard to monitoring requirements, the court stated that EPA had the authority
to exempt de mini mis situations.
Postconstruction monitoring data requirements are addressed in section
165(a)(7) of the Clean Air Act. Sources may have to conduct such monitoring
to determine the air quality effect its emissions may have on the area it
impacts. EPA has the discretion of requiring monitoring data and the court
stated that guidelines could be prepared to show the circumstances that may
require postconstruction monitoring data.
In view of the provisions of sections 165(e)(l), 165(e)(2), and 165(a)(7)
of the Clean Air Act, the de mini mis concept, and sections of the final PSD
regulations, Sections 2.1.T7 2.1.2 and 2.1.3 present the basic rationale
which generally will be followed to determine when monitoring data will or
will not be required. It should be noted that the subsequent use of "moni-
toring data" refers to either the use of existing representative air quality
data or monitoring the existing air quality.
Additional discussion and flow diagrams are presented in Appendix A of
this guideline which show various decision points leading to a determination
as to when monitoring data will or will not be required. Also, these
procedures indicate at what points a modeling analysis must be performed.
2.1.1 Criteria Pollutants - Preconstruction Phase
For the criteria pollutants (S02, CO, and N02) continuous air quality
monitoring data must, in general, be used to establish existing air quality
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concentrations in the vicinity of the proposed source or modification. For
VOC emissions, continuous ozone monitoring data must be used to establish
existing air quality concentrations in the vicinity of the proposed source
or modification. For PMjQ and lead, the 24-hour manual method will be used
to establish the existing air quality concentrations. However, no pre-
construction monitoring data will generally be required if the ambient
air quality concentration before construction is less than the significant
monitoring concentrations. (The significant monitoring concentrations for
each pollutant are shown in Table A-2 in the appendix to this guideline.)
To require monitoring data where the air quality concentration of a pollutant
is less than these values would be questionable because these low level
concentrations cannot reasonably be determined because of measurement
errors. These measurement errors may consist of errors in sample collection,
analytical measurement, calibration, and interferences.
Cases where the projected impact of the source or modification is less
than the significant monitoring concentrations would also generally be
exempt from preconstruction monitoring data, consistent with the de mini mis
concept. [40 CFR 51.24(1)(8) and 40 CFR 52.21(i)(8)].
The one exception to the de mini mis exemption occurs when a proposed
source or modification would adversely impact on a Class I area or would
pose a threat to the remaining allowable increment or NAAQS. For those
situations where the air quality concentration before construction is near
the significant monitoring concentration, and there are uncertainties
associated with this air quality situation, then preconstruction air quality
monitoring data may be required. These situations must be evaluated on a
case-by-case basis by the permit granting authority before a final decision
is made.
2.1.2 Criteria Pollutants - Postconstruction Phase
EPA has discretion in requiring postconstruction monitoring data
under section 165(a)(7) of the Clean Air Act and in general will not
require postconstruction monitoring data. However, to require air
quality monitoring data implies that the permit granting authority will
have valid reasons for the data and, in fact, will use the data after it
is collected. Generally, this will be applied to large sources or
sources whose impact will threaten the standards or PSD increments.
Examples of when a permit granting authority may require postconstruction
monitoring data may include:
a. NAAQS are threatened - The postconstruction air quality is
projected to be so close to the NAAQS that monitoring is needed to
certify attainment or to trigger appropriate SIP related actions if
nonattainment results.
b. Source impact is uncertain or unknown - Factors such as complex
terrain, fugitive emissions, and other uncertainties in source or emission
characteristics result in significant uncertainties about the projected
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impact of the source or modification. Postconstruction data is justified
as a permit condition on the basis that model refinement is necessary to
assess the impact of future sources of a similar type and configuration.
2.1.3 Noncriteria Pollutants - Preconstruction and Postconstruction Phase
Consistent with section 165(e)(l) of the Clean Air Act, EPA believes
that an analysis based on modeling of the impact of noncriteria pollutants
(including TSP) on the air quality should generally be used in lieu of
monitoring data. The permit granting authority, however, does have the
discretion of requiring preconstruction and postconstruction monitoring
data. Before a permit granting authority exercises its discretion in
requiring monitoring data, there should be an acceptable measurement method
approved by EPA (see Section 2.6) and the concentrations would generally be
equal to or greater than the significant monitoring concentrations (shown
in Table A-2 of the appendix).
A permit granting authority may require monitoring data in cases such
as (a) where a State or other jurisdiction has a standard for a noncriteria
pollutant and the emissions from the proposed source or modification pose a
threat to the standard, (b) where the reliability of emission data used as
input to modeling existing sources is highly questionable, especially for
the pollutants regulated under the national emission standards for hazardous
pollutants, and (c) where available models or complex terrain make it
difficult to estimate air quality or impact of the proposed source or
modification.
2.2 Monitoring Objective and Data Uses
The basic objective of PSD monitoring is to determine the effect
emissions from a source are having or may have on the air quality in any
area that may be affected by the emission. Principal uses of the data are
as follows:
(a) To establish background air quality concentrations in the vicinity
of the proposed source or modification. These background levels are important
in determining whether the air quality before or after construction are or
will be approaching or exceeding the NAAQS or PSD increment.
(b) To validate and refine models. The data will be helpful in
verifying the accuracy of the modeling estimates.
2.3 VOC and 03 Monitoring Requirements
The previous 0.24 ppm nonmethane organic compound (NMOC) standard,
which was used as a guide for developing State Implementation Plans to
attain the 63 ambient standard, has been rescinded. However, VOC emissions
are the precursors in the formation of ozone. Consequently, any new source
or modified existing source located in an unclassified or attainment area
for ozone that is equal to or greater than 100 tons per year of VOC emissions
will be required to monitor ozone. VOC monitoring will not be required.
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2.4 Use of Representative Air Quality Data
The use of existing representative air quality data was one of the
options discussed in Section 2.1 for monitoring data. In determining
whether the data are representative, three major items which need to be
considered are monitor location, quality of the data, and currentness of
the data.
2.4.1 Monitor Location
The existing monitoring data should be representative of three types
of areas: (1) the location(s) of maximum concentration increase from the
proposed source or modification, (2) the location(s) of the maximum air
pollutant concentration from existing sources, and (3) the location(s) of
the maximum impact area, i.e., where the maximum pollutant concentration
would hypothetically occur based on the combined effect of existing sources
and the proposed new source or modification. Basically, the locations and
size of the three types of areas are determined through the application of
air quality models. The areas of maximum concentration or maximum combined
impact vary in size and are influenced by factors such as the size and
relative distribution of ground level and elevated sources, the averaging
times of concern, and the distances between impact areas and contributing
sources.
In situations where there is no existing monitor in the modeled areas,
monitors located outside these three types of areas may or may not be used.
Each determination must be made on a case-by-case basis. In order to
clarify EPA's intent regarding the use of existing monitoring data, some
examples are included to demonstrate the overall intent.
(a) Case I - If the proposed source or modification will be constructed
in an area that is generally free from the impact of other point sources
and area sources associated with human activities, then monitoring data
from a "regional" site may be used as representative data. Such a site
could be out of the maximum impact area, but must be similar in nature to
the impact area. This site would be characteristic of air quality across a
broad region including that in which the proposed source or modification is
located. The intent of EPA is to limit the use of these "regional" sites
to relatively remote areas, and not to use them in areas of multisource
emissions or areas of complex terrain.
(b) Case II - If the proposed construction will be in an area of
multisource emissions and basically flat terrain, then the proposed source
or modification may propose the use of existing data at nearby monitoring
sites if either of the following criteria are met.
1. The existing monitor is within 10 km of the points of proposed
emissions, or
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2. The existing monitor is within or not farther than 1 km away
from either the area(s) of the maximum air pollutant concentration from
existing sources or the area(s) of the combined maximum impact from existing
and proposed sources.
If the existing monitor(s) meets either of the above two conditions,
the data could be used together with the model estimates to determine the
concentrations at all three types of areas discussed earlier in this section.
As an example of the first criterion, if an existing monitor is located
within 10 km from the points of proposed emissions but not within the
boundaries of the modeled areas of either of the three locations noted
above, the data could be used together with model estimates to determine the
concentrations at the three types of required area.
The next example applies to the second criterion. In evaluating the
adequacy of the location of existing monitors, the applicant must first,
through modeling, determine the significant ambient impact area of the
proposed source. In general, except for impact on Class I areas, the
application of air quality models for the purpose of determining significant
ambient impact would be limited to 50 km downwind of the source or to that
point where the concentration from the source falls below the levels shown
in Table A-3 of the Appendix. For Class I areas, a significant impact is
1 ug/nr (24-hr) for PM10 and S02. The applicant would then identify within
this significant impact area the area(s) of the maximum air pollutant con-
centration from existing sources and the area(s) of the combined maximum
impact from existing and proposed sources. The area(s) of estimated maximum
concentration from existing sources or the estimated maximum combined
impact area(s) are determined as follows: First, within the modeled signifi-
cant ambient impact area, estimate the point of maximum concentration from
existing sources, and the point of combined maximum impact (existing and
proposed source). Using these concentration values, determine the areas
enclosed by air quality concentration isopleths equal to or greater than
one half of the respective estimated maximum concentration. An existing
monitor located within or not farther than 1 km away from of any of these
areas can yield representative data.
The rationale for considering the use of existing data collected from
monitors satisfying the above criteria is that modelers have a reasonable
degree of confidence in the modeling results within the 10 km distance and
the maximum concentrations from most sources are likely to occur within
this distance. Generally, the modeling results in this flat terrain case
may under or over predict by a factor of two, and thus the actual maximum
impact from the source(s) could occur at points where the model predicts
one half of this impact. Data collected within or not farther than 1 km
from areas may be considered as representative.
(c) Case III - If the proposed construction will be in an area of
multisource emissions and in areas of complex terrain, aerodynamic downwash
complications, or land/water interface situations, existing data could only
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be used for PSD purposes if it were collected (1) at the modeled location(s)
of the maximum air pollution concentration from existing sources, (2) at
the location(s) of the maximum concentration increase from the proposed
construction, and (3) at the location(s) of the maximum impact area. If a
monitor is located at only one of the locations mentioned above and the
locations do not coincide, the source would have to monitor at the other
locations.
It must be emphasized that the permit granting authority may choose
not to accept data proposed under the cases discussed above. This may
occur because of additional factors, especially in Case II which were not
discussed but must be considered, such as uncertainties in data bases for
modeling and high estimates of existing air quality resulting in possible
threats to the applicable standards. Because of such situations, the
permit granting authority must review each proposal on a case-by-case basis
to determine if the use of existing data will be acceptable. It is important
for the proposed source or modification to meet with the permit granting
authority to discuss any proposed use of existing data. If the data are
not acceptable, then a monitoring program would have to be started to
collect the necessary data.
2.4.2 Data Quality
The monitoring data should be of similar quality as would be obtained
if the applicant monitored according to the PSD requirements. As a minimum,
this would mean:
1. The monitoring data were collected with continuous instrumentation.
No bubbler data should be included. See Section 2.7 for frequency
of particulate pollutant sampling.
2. The applicant should be able to produce records of the quality
control performed during the time period at which the data were
collected. Such quality control records should include calibration,
zero and span checks, and control checks. In addition, quality
control procedures should be a minimum specified in the instrument
manufacturer's operation and instruction manual.
3. Historical data that were gathered from monitors which were operated
in conformance with Appendix A or B of the Part 58 regulations [7]
would satisfy the quality assurance requirements.
4. The calibration and span gases (for CO, S02 and N02) should be
working standards certified by comparison to a National Bureau of
Standards gaseous Standard Reference Material.
5. The data recovery should be 80 percent of the data possible during
the information effort.
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2.4.3 Currentness of Data
The air quality monitoring data should be current. Generally, this
would mean for the preconstruction phase that the data must have been
collected in the 3-year period preceding the permit application, provided
the data are still representative of current conditions. When such data
are required, the noncriteria pollutant data must also have been collected
in the 3-year period preceding the permit application provided that an
acceptable measurement method was used. For the postconstruction phase,
the data must be collected after the source or modification becomes
operational .
2.4.4 Provisions for PMm and TSP in Transition Period of 1987
PSD Amendments
Section 2.5.2 discusses the use of existing representative air quality
data for PIQ and TSP during the phasing in of the 1987 PSD amendments for
parti cul ate matter. References are cited for using existing nonreference
and/or PM^ data where available, or TSP data. Existing representative air
quality data for PM^o collected more than 12 months after the effective date of
the 1987 PSD amendments must have been collected using reference or equivalent
method samplers.
2.5 Duration of Monitoring
2.5.1 Normal Conditions
If a source must monitor because representative air quality data are
not available for the preconstruction monitoring data requirement, then
monitoring generally must be conducted for at least 1 year prior to submis-
sion of the application to construct. Also, if a source decides to monitor
because representative air quality data are not available for the postcon-
struction monitoring data requirement, then monitoring must also be conducted
for at least 1 year after the source or modification becomes operational.
However, under some circumstances, less than 1 year of air quality data may
be acceptable for the preconstruction and postconstruction phases. This
will vary according to the pollutant being studied. For all pollutants,
less than a full year will be acceptable if the applicant demonstrates
through historical data or dispersion modeling that the data are obtained
during a time period when maximum air quality levels can be expected.
However, a minimum of 4 months of air quality data will be required. As
discussed in Section 2.1.3, monitoring for noncriteria pollutants will
generally not be required.
Special attention needs to be given to the duration of monitoring for
ozone. Ozone monitoring will still be required during the time period when
maximum ozone concentrations will be expected. Temperature is one of the
factors that affect ozone concentrations, and the maximum ozone concentrations
will generally occur during the warmest 4 months of the year, i.e., June-
September. However, historical monitoring data have shown that the maximum
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yearly ozone concentration for some areas may not occur from June-September.
Therefore, ozone monitoring will also be required for those months when
historical ozone data have shown that the yearly maximum ozone concentrations
have occurred during months other than the warmest 4 months of the year.
This requirement is in addition to monitoring during the warmest 4 months
of the year. If there is an interval of time between the warmest 4 months
of the year and month where historical monitoring data have shown that the
maximum yearly ozone concentration has occurred, then monitoring must also
be conducted during that interval. For example, suppose historical data
have shown the maximum yearly ozone concentration for at least 1 year
occurred in April. Also, suppose the warmest 4 months for that particular
area occurred June-September. In such cases, ozone monitoring would be
required for April (previous maximum concentration month), May (interval
month), and June-September (warmest 4 months).
Some situations may occur where a source owner or operator may not
operate a new source or modification at the rated capacity applied for in
the PSD permit. Generally, the postconstruction monitoring should not
begin until the source is operating at a rate equal to or greater than 50
percent of its design capacity. However, in no case should the postcon-
struction monitoring be started later than 2 years after the start-up of
the new source or modification.
If the permit granting authority has determined that less than 1 year
of monitoring data is permissible, the source must agree to use the maximum
values collected over this short period for comparison to all applicable
short-term standards, and the average value for the short period as the
equivalent of the annual standard.
It should also be noted that the above discussion of less than 1 year
of data pertains to air quality data, not meteorological data. When the air
quality impact must be determined using a dispersion model, the preferred
meteorological data base is at least 1 year of on-site data. Although less
than 1 year of data may be sufficient to determine the acceptability for a
model, once the model has been accepted, a full year of meteorological data
must be used in the PSD analysis.
2.5.2 Transition Period for PMm and TSP
The 1987 PSD regulatory changes for particulate matter [6] provide for
a transition period for phasing in the PM^g monitoring data requirements.
The term "monitoring data" was previously defined in Section 2.1 as the use
of existing representative air quality data or monitoring to determine the
existing air quality.
2.5.2.1 Transition Within 10 Months After Effective Date of PMm Amendments -
The first provision of the regulations concerning a transition period is in
section 52.21(i)(ll)(i) and relates to applications for a PSD permit submitted
not later than 10 months after the effective date of the 1987 PSD amendments.
During this 10-month period, the permit granting authority has the discretion
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of waiving the preconstruction monitoring data requirements for the ambient
air quality analysis discussed in Appendix A of this guideline. In all cases
no applicant would be required to initiate monitoring during this period.
However, the requirement to use existing air quality data would be discre-
tionary. The discretion would be based in part on the availability of
existing air quality data which could include total suspended particulate
matter data, PM^g data, as well as inhalable particulate matter (PMis) data.
The PM^5 data would be from samplers with inlets designed for a 5C percent
collective efficiency at 15 urn. The PM^5 data could be from dichotomous
samplers or high volume samplers with a size selective inlet of 15 urn.
(a) Comparing Representative Air Quality Data to PMjp NAAQS.
In situations where existing PMig and/or PM^s data are available, the data
may be used for describing the existing air quality levels for comparison
with the PMio NAAQS. Reference [8] describes procedures for estimating
ambient PM^g concentrations from PMi5 ambient air measurements. The PMi5 data
multiplied by a correction factor of 0.8 may be assumed to be equivalent to
PMig. Existing TSP data may only be used as a "one-for-one" substitute for
comparison to the Pl^g NAAQS.
Concerning the priorities for using existing air quality data, the
first preference is to use ambient PMig data. The second preference is
to use inhalable particulate (PM^) measurements obtained with a dichoto-
mous sampler or a size selective high volume sampler. The third preference
is to use total suspended parti culte (TSP) data. Also, combinations of
the above data may be used.
2.5.2.2 Transition During 10-16 Months After Effective Date of
Amendments^- The second provision of the regulations concerning a transition
period is in section 52.21(1 )(11)(11) and relates to applications for a
PSD permit submitted more than 10 months and no later than 16 months after
the effective date of the 1987 PSD amendments. If preconstruction monitoring
data are required in the ambient air quality analysis during this 10 to
16-month period, the applicant must use representative air quality data
or collect monitoring data.
(a) Comparing Preconstruction Air Quality Data to PMip NAAQS.
Existing representative PMig and/or PMis air quality data may be used
if available. The priorities and calculations for using these data
were described in Section 2.5.2.1. Existing TSP data cannot be used dur-
ing during this transition period.
If the applicant collects new PMig and/or PMis monitoring data, the
data should have been collected from the date 6 months after the effective
date of the 1987 PSD amendments to the time the PSD application becomes
otherwise complete. The preferences for PMig and PM^5 data were previously
discussed.
(b) Other Considerations and Explanations. As discussed in Section
2.5.1, less than the maximum amount of data (10 months in this case) moni-
toring data will be acceptable if the applicant demonstrates, through
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historical data or dispersion modeling, that the data would be obtained
during a time period when the maximum air quality can be expected. The
minimum of 4 months of air quality data would still be required. The
assumptions for the 10-month figure were derived by assuming that 5 months
are needed for instrument and equipment procurement, 1 month to install
the equipment, calibrate and ensure satisfactory operation, and a minimum
of 4 months of monitoring data. The upper range of 16 months after the
effective date for use of non-reference PM^g monitoring is based on the
assumption that within 11 months after the effective date, reference or
equivalent method samplers for PM^g would be designated by EPA ana would
be commercially available. Furthermore, 1 month would be needed to
install the equipment, calibrate, and ensure satisfactory operation, and
a minimum of 4 months would be needed for gathering monitoring data.
2.5.2.3 Transition During 16-24 Months After Effective Date of
Amendments - The third transition period provision of the amendments is
in section 52.21(m)(l)(vii ) and relates to applications for a PSD permit
submitted more than 16 months and not later than 24 months after the
effective date of the 1987 PSD amendments. If preconstruction monitoring
data are required in the ambient air quality analysis during this 16 to
24-month period, the applicant must use representative air quality data
or collect monitoring data.
(a) Comparing Preconstruction Air Quality Data to PM\n NAAQS.
If existing representative PMjg and/or PMis air quality data are available
they may be used. The priorities and calculations for using these data
were described in Section 2.5.2.1. Existing TSP data cannot be used
during this transition period. If no PMjg or PMis representative air
quality data are available, the applicant will have to collect monitoring
data using only reference or equivalent PM^o method samplers. The sampling
must be conducted for at least 12 months during the period from 12 months
after the effective date to the time when the application is completed,
except if the permit granting authority determines that a complete and
adequate analysis can be accomplished with monitoring data over a shorter
period (but in no case less than 4 months).
2*5.2.4 Period Following 24 Months After Effective Date of PMm Amendments -
For applications for a PSD permit submitted later than 24 months after
the effective date, the transition period would no longer be in effect.
If preconstruction monitoring data are required in the ambient air quality
analysis, the applicant must use representative air quality data or
collect monitoring data.
(a) Comparing Preconstruction Air Quality Data to PMm NAAQS. If
existing representative PM^g air quality data are available, they may be
used. However, existing PM^g representative air quality data collected
later than 24 months after the effective date of the 1987 PSD amendments
must have been collected using reference or equivalent PMig method sam-
plers. If no PM^o representative air quality data are available, the
applicant will have to collect monitoring data using only reference or
equivalent PMjg method samplers.
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2.6 Sampling Methods and Procedures
(a) Criteria pollutants.
All ambient air quality monitoring must be done with continuous
Reference or Equivalent Methods, with the exception of particulate matter
and lead for which continuous Reference or Equivalent Methods do not exist.
For particulate matter and lead, samples must be taken in accordance with
the Reference Method. The Reference Methods are described in 40 CFR 50.
A list of designated continuous Reference or Equivalent Methods can be
obtained by writing Environmental Monitoring Systems Laboratory, Department
E (MD-76), U.S. Environmental Protection Agency, Research Triangle Park,
NC 27711.
(b) PM^Q Transition for Non-reference Methods
As discussed in Section 2.5.2, non-reference monitors for
may be used for applications submitted not later than 16 months after the
effective date of the 1987 PSD amendments. These could include PM^g monitors
as well as inhalable particulate matter (PMjg) monitors. The PMi5 monitors
could be dichotomous monitors or high volume monitors with a size selective
inlet of 15 urn.
(c) Noncriteria pollutants.
For noncriteria pollutants, a list of acceptable measurement
methods is available upon request by writing Environmental Monitoring
Systems Laboratory, Quality Assurance Division (MD-77), U.S. Environmental
Protection Agency, Research Triangle Park, NC 27711. This list of accept-
able methods will be reviewed at least annually and are available from
the above address. Measurement methods considered candidates for the
noncriteria pollutant list should be brought to the attention of EPA at
the address given above.
2.7 Frequency of Sampling
For all gaseous pollutants and for all meteorological parameters,
continuous analyzers must be used. Thus, continuous sampling (over the
time period determined necessary) is required. For particulate pollu-
tants, except for PMjg, daily sampling (i.e., one sample every 24 hours)
is required except in areas where the applicant can demonstrate that signi-
ficant pollutant variability is not expected. In these situations, a
sampling schedule less frequent than every day would be permitted. However,
a minimum of one sample every 6 days will be required for these areas.
The sampling frequency would apply to both preconstruction and postcon-
struction monitoring.
The sampling frequency for PMjg samplers is determined by the
, or TSP concentrations relative to the PM^Q NAAQS. The philosophy is
to use existing data where possible to determine the PM^g sampling frequency.
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The frequencies discussed below are consistent with the Part 58 sampling
frequencies [6]. If PMjo data are available but not from the locations as
specified in Section 2.4.1, then modeling could be used in conjunction with
the data to estimate the PMjg concentrations in the appropriate sampling
area(s) to determine the PM^g sampling frequency. If these estimated concen-
trations were < 80 percent of the PMjg NAAQS, then a minimum of one sample
every 6 days would be required for PM^g monitors; for >j30 - <90 percent of
the PM^g NAAQS, a minimum of one sample every other day would be required;
and for ^90 percent of the PM^g NAAQS every day sampling would be required.
PM]^ data would be treated the same way except the data must be multiplied
by a correction factor of 0.8 to be equivalent to PMjg.
Reference [8] describes how TSP data may also be used to estimate the
probability of exceeding the PMig NAAQS in the appropriate sampling area(s)
for purposes of determining the PM^g sampling frequency. If the probabilities
are < .20 of the PM^g NAAQS, then a minimum of one sample every 6 days would
be required for PM^g monitors; for >_.20 - <.50 probabilities, a minimum of
one sample every other day would be required; and for >_.50 probabilities,
every day sampling would be required. These probability intervals are in
line with the percent of the NAAQS intervals specified when using PM^g data.
In those cases where no PM^g, PM^, or TSP data are available to
determine the PM^g sampling frequency, the PM^g expected concentrations
could be estimated by modeling. These estimated concentrations would be
used to calculate the percentage of the PM^g NAAQS and the resulting PM^g
sampling frequency as discussed above for the cases where PM^g data were
available.
2.8 Monitoring Plan
A monitoring plan prepared by the source should be submitted to and
approved by the permit granting authority before any PSD monitoring
begins. Note that approval of the monitoring plan before a monitoring
program is started is not a requirement. However, since the network
size and station locations are determined on a case-by-case basis, it
would be prudent for the owner or operator to seek review of the network
and the overall monitoring plan from the permit granting authority prior
to collecting data. This review could avoid delays in the processing of
the permit application and could also result in the elimination of any
unnecessary monitoring. Delays may result from insufficient, inadequate,
poor, or unknown quality data. Table 1 lists the types of information
that should be included in the monitoring plan.
2.9 Meteorological Parameters and Measurement Methods
Meteorological data will be required for input to dispersion models
used in analyzing the impact of the proposed new source or modification
on ambient air quality and the analyses of effects on soil, vegetation,
and visibility in the vicinity of the proposed source. In some cases,
representative data are available from sources such as the National
14
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Weather Service. However, in some situations, on-site data collection
will be required. The meteorological monitoring and instrumentation
considerations are discussed in Sections 5 and 6.
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TABLE 1. MINIMUM CONTENTS OF A MONITORING PLAN
I. SOURCE ENVIRONMENT DESCRIPTION (within 2 km of source)
o topographical description
o land-use description
o topographical map of source and environs (including location of
existing stationary sources, roadways, and monitoring sites)
o climatological description
o quarterly wind roses (from meteorological data collected at the
source or other representative meteorological data)
II. SAMPLING PROGRAM DESCRIPTION
o time period for which the pollutant(s) will be measured
o rationale for location of monitors (include modeling results and
analysis of existing soures in the area)
o rationale for joint utilization of monitoring network by other
PSD sources
III. MONITOR SITE DESCRIPTION
o Universal Transverse Mercator (UTM) coordinates
o height of sampler (air intake) above ground
o distance from obstructions and heights of obstructions
o distance from other sources (stationary and mobile)
o photographs of each site (five photos: one in each cardinal direc-
tion looking out from each existing sampler or where a future
sampler will be located, and one closeup of each existing sampler
or where a future sampler will be located. Ground cover should be
included in the closeup photograph.)
IV. MONITOR DESCRIPTION
o name of manufacturer
o description of calibration system to be used
o type of flow control and flow recorder
V. DATA REPORTING
o format of data submission
o frequency of data reporting
VI. QUALITY ASSURANCE PROGRAM
o calibration frequency
o independent audit program
o internal quality control procedures
o data precision and accuracy calculation procedures
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3. NETWORK DESIGN AND PROBE SITING CRITERIA
A source subject to PSD should proceed with designing a PSD monitoring
network only after going through the procedure in Appendix A to determine
if monitoring data will be required. To fulfill that requirement, a source
may use representative air quality data which was discussed in Section 2.4
or monitor. This section presents guidance to be used if an applicant
decides to monitor in lieu of using representative air quality data.
3.1 Network Design
The design of a network for criteria and noncriteria pollutants will
be affected by many factors, such as topography, climatology, population,
and existing emission sources. Therefore, the ultimate design of a network
for PSD purposes must be decided on a case-by-case basis by the permit
granting authority. Section 3.2 discusses the number and location of
monitors for a PSD network. Additional guidance on the general siting of
the monitors may be found in references 9-13 which discuss highest concen-
tration stations, isolated point sources, effects of topography, etc.
Probe siting criteria for the monitors are discussed in Section 3.3. The
guidelines presented here should be followed to the maximum extent practical
in developing the final PSD monitoring network.
3.2 Number and Location of Monitors
The number and location of monitoring sites will be determined on a
case-by-case basis by the source owner or operator and reviewed by the
permit granting authority. Consideration should be given to the effects of
existing sources, terrain, meteorological conditions, existence of fugitive
or reentrained dusts, averaging time for the pollutant, etc. Generally,
the number of monitors will be higher where the expected spatial variability
of the pollutant in the area(s) of study is higher.
3.2.1 Preconstruction Phase
Information obtained in the ambient air quality analysis in Appendix A
will be used to assist in determining the number and location of monitors
for the preconstruction phase. The air quality levels before construction
were determined by modeling or in conjunction with monitoring data. The
screening procedure (or more refined model) estimates were determined in
Appendix A.
The source should first use the screening procedure or refined model
estimates to determine the general location(s) for the maximum air quality
concentrations from the proposed source or modification. Secondly, the
source should determine by modeling techniques the general location(s) for
the maximum air quality levels from existing sources. Thirdly, the modeled
pollutant contribution of the proposed source or modification should be
analyzed in conjunction with the modeled results for existing sources to
determine the maximum impact area. Application of these models must be
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consistent with EPA's "Guideline on Air Quality Models" [14]. This would
provide sufficient information for the applicant to place a monitor at
(a) the location(s) of the maximum concentration increase expected from the
proposed source or modification, (b) the location(s) of the maximum air
pollutant concentration from existing sources of emissions, and (c) the
location(s) of the maximum impact area, i.e., where the maximum pollutant
concentration would hypothetically occur based on the combination effect of
existing sources and the proposed new source or modification. In some
cases, two or more of these locations may coincide and thereby reduce the
number of monitoring stations.
Monitoring should then be conducted in or as close to these areas as
possible (also see discussion in Section 3.2.3). Generally, one to four
sites would cover most situations in multisource settings. For remote
areas in which the permit granting authority has determined that there are
no significant existing sources, a minimum number of monitors would be
needed, i.e., one or probably two at the most. For new sources, in these
remote areas, as opposed to modifications, some concessions will be made on
the locations of these monitors. Since the maximum impact from these new
sources would be in remote areas, the monitors may be located, based on
convenience or accessibility, near the proposed new source rather than near
the maximum impact area since the existing air quality would be essentially
the same in both areas. However, the maximum impact area is still the
preferred location.
When industrial process fugitive particulate emissions are involved,
the applicant should locate a monitor at the proposed source site (also see
Section 3.2.3). If stack emissions are also involved, a downwind location
should also be selected. For fugitive hydrocarbon emissions, the applicant
should locate a monitor downwind of the source at the point of expected
maximum ozone concentration contribution. This location will be found
downwind during conditions that are most conducive to ozone formation, such
as temperature above 20°C (68°F) and high solar radiation intensity. For
hydrocarbon emissions from a stack, the applicant should also locate the
monitor in the area of expected maximum ozone concentration. For both
fugitive and stack emissions, the selection of areas of highest ozone concen-
trations will require wind speed and direction data for periods of photo-
chemical activity. Monitoring for ozone will only be necessary during the
seasons when high concentrations occur.
Since ozone is the result of a complex photochemical process, the rate
of movement across an area of the air mass containing precursors should be
considered. The distance from the proposed source to the monitor for an
urban situation should be about equal to the distance traveled by the air
moving for 5 to 7 hours at wind speeds occurring during periods of photo-
chemical activity. In an urban situation, ozone formation over the initial
few hours may be supressed by nitric oxide (NO) emissions. For a point
source, the NO interactions may be minimal, and the travel time to the
expected maximum ozone concentration may be 3 to 4 hours downwind. In
general, the downwind distance for the maximum ozone site should generally
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not be more than 15 to 20 miles from the source because a lower wind speed
(2-3 miles per hour) with less dilution would be a more critical case.
Additionally, the frequency that the wind would blow from the source over
the site diminishes with increasing distances.
3.2.2 Postconstruction Phase
As discussed above for preconstruction monitoring, appropriate dis-
persion modeling techniques are used to estimate the location of the air
quality impact of the new source or modification. Monitors should then be
placed at (a) the expected area of the maximum concentration from the new
source or modification, and (b) the maximum impact area(s), i.e., where the
maximum pollutant concentration will occur based on the combined effect of
existing sources and the new source or modification. It should be noted
that locations for these monitors may be different from those sites for the
preconstruction phase due to other new sources or modifications in the area
since the preconstruction monitoring.
Generally, two or three sites would be sufficient for most situations
in multisource areas. In remote areas where there are no significant
existing sources, one or two sites would be sufficient. These sites would
be placed at the locations indicated from the model results. The same
concerns discussed in Section 3.2.1 regarding industrial process fugitive
particulate emissions, fugitive hydrocarbon emissions, and ozone monitoring
would also be applicable for the postconstruction phase.
3.2.3 Special Concerns for Location of Monitors
For the preconstruction and postconstruction phases, modeling is used
to determine the general area where monitors would be located. Some of the
modeled locations may be within the confines of the source's boundary.
However, monitors should be placed in those locations satisfying the defini-
tion of ambient air. Ambient air is defined in 40 CFR 50.1(e) as "that
portion of the atmosphere, external to buildings, to which the general
public has access." Therefore, if the modeled locations are within an area
excluded from ambient air, the monitors should be located downwind at the
boundary of that area.
In some cases, it is simply not practical to place monitors at the
indicated modeled locations. Some examples may include over open bodies of
water, on rivers, swamps, cliffs, etc. The source and the permit granting
authority should determine on a case-by-case basis alternative locations.
3.3 Probe Siting Criteria
The desire for comparability in monitoring data requires adherence to
some consistent set of guidelines. Therefore, the probe siting criteria
discussed below must be followed to the maximum extent possible to ensure
uniform collection of air quality data that are comparable and compatible.
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Before proceeding with the discussion of pollutant specific probe siting
criteria, it is important to expand on the discussion in Section 3.2 of the
location of monitors. In particular, reference is made to two monitoring
objectives.
Case 1: Locating monitors to determine the maximum concentration
from the proposed source and/or existing sources.
t Case 2: Locating monitors to determine where the combined impact
of the proposed source and existing sources would be
expected to exhibit the highest concentrations.
For Case 1, the driving force for locating the siting area of the
monitor as well as the specific location of the probe or instrument shelter
is the objective of measuring the maximum impact from the proposed source.
Two Case 1 examples are given. Consider the first situation in which a
proposed source would be emitting pollutants from an elevated stack. Under
these circumstances, sufficient mixing generally occurs during the transport
of the emissions from the stack to the ground resulting in small vertical
gradients near ground level, thus, a wide range of probe heights, 3-15 meters
for gases and 2-15 meters for particulates is acceptable. For the same
objective (maximum concentration from proposed source), consider the second
example in which pollutants would be emitted from a ground level source.
In this case, the concentration gradient near the ground can be large,
thereby requiring a much tighter range of acceptable probe heights. For
ground level sources emitting pollutants with steep vertical concentration
gradients, efforts should be made to locate the inlet probe for gaseous
pollutant monitors as close to 3 meters (a reasonable practical represen-
tation of the breathing zone) as possible and for particulate monitors
using the hi-volume sampler 2 to 7 meters above ground level. The ration-
ale for the 3 meters is that for gaseous pollutant measurements, the inlet
probe can be adjusted for various heights even though the monitor is loca-
ted in a building or trailer. On the contrary, the 2-3 meter height for
the hi-volume sampler placement is not practical in certain areas. The 7
meter height allows for placement on a one story building and is reasonably
close to representing the breathing zone.
Turn now to the second monitoring objective, Case 2, which is locating
monitors to determine the maximum impact area taking into consideration the
proposed source as well as existing sources. The critical element to keep in
mind in locating a monitor to satisfy this objective is that the intent is
to maximize the combined effect. Thus, in one circumstance, the existing
source might contribute the largest impact. The importance of the above
discussion to the topic of probe siting criteria is that in attempting to
locate a monitor to achieve this objective, the placement of the probe or
instrument shelter can vary depending upon which source is the predominant
influence on the maximum impact area. As an extreme example, consider the
situation where a proposed elevated source would emit CO into an urban area
and have maximum combined CO impact coincident to an area adjacent to a
heavily traveled traffic corridor. It is known that traffic along corridors
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emit CO in fairly steep concentration gradients so the placement of the probe
to measure the areas of highest CO concentration can vary significantly with
probe height as well as distance from the corridor. In this example, the
traffic corridor has the major influence on the combined impact and therefore
controls the probe placement. As noted in the CO probe siting criteria in
Section 3.3.3 as well as Appendix E of the May 10, 1979 Federal Register
promulgation of the Ambient Air Monitoring Regulations [7_| and revised and
updated on March 19, 1986 [15], the required probe height in such microscale
cases is given as 3 +_ 1/2 meters while the distance of the probe from the
roadway would be between 2 and 10 meters.
As another example, consider the case where the same proposed CO source
would emit CO at elevated heights and have a combined maximum CO impact in an
urban area that is only slightly affected by CO emissions from a roadway.
The combined impact area in this case is far enough away from the two sources
to provide adequate mixing and only small vertical concentration gradients at
the impact area. In this case, the acceptable probe height would be in the
range of 3-15 meters.
It is recognized that there may be other situations occurring which
prevent the probe siting criteria from being followed. If so, the differences
must be thoroughly documented. This documentation should minimize future
questions about the data.
The desire for comparability in monitoring data requires adherence to
some consistent set of guidelines. Therefore, the probe siting criteria
discussed below must be followed to the maximum extent possible to ensure
uniform collection of air quality data that are comparable and compatible.
To achieve this goal, the specific siting criteria that are prefaced with a
"must" are defined as a requirement and exceptions must be approved by the
permit granting authority. However, siting criteria that are prefaced with
a "should" are defined as a goal to meet for consistency, but are not a
requirement.
3.3.1 Total Suspended Particulates (TSP)
Section 3.3.1 is applicable only for the following cases. PSD
applications submitted not later than 6 months after the effective date of
the 1987 PSD amendments would use this siting criteria when collecting TSP
monitoring data. Also, representative air quality data for TSP collected
not later than 6 months after the effective date of the 1987 PSD amendments
would use this siting criteria.
3.3.1.1 Vertical Placement - The most desirable height for a TSP monitor
is near the breathing zone. However, practical considerations such as
prevention of vandalism, security, accessibility, availability of electri-
city, etc., generally require that the sampler be elevated. Therefore, a
range of acceptable heights needs to be used. In addition, the type of
source, i.e., elevated or ground level, predominantly influencing the area
of impact must be considered when locating the monitor. For purposes of
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determining elevated source impact, the sampler air intake must be located
2-15 meters above ground level. The lower limit was based on a compromise
between ease of servicing the sampler and the desire to avoid reentrainment
from dusty surfaces. The upper limit represents a compromise between the
desire to have measurements which are most representative of population
exposures, and the considerations noted earlier. For ground level sources
with steep vertical concentration gradients, the air intake must be as close
to the breathing zone as practical.
3.3.1.2 Spacing from Obstructions - If the sampler is located on a roof or
other structure, then there must be a minimum of 2 meters separation from
walls, parapets, penthouses, etc. Furthermore, no furnace or incineration
flues should be nearby. The separation distance from flues is dependent on
the height of the flues, type of waste or fuel burned, and quality of the
fuel (ash content). For example, if the emissions from the chimney are the
result of natural gas combustion, no special precautions are necessary except
for the avoidance of obstructions, i.e., at least 2 meters separation. On
the other hand, if fuel oil, coal, or solid waste is burned and the stack is
sufficiently short so that the plume could reasonably be expected to impact
on the sampler intake a significant part of the time, other buildings/locations
in the area that are free from these types of sources should be considered
for sampling. Trees provide surfaces for particulate deposition and also
restrict airflow. Therefore, the sampler should be placed at least 20 meters
from the dripline of trees and must be 10 meters from the dripline when
trees act as an obstruction [15],
Obstacles such as buildings must also be avoided so that the distance
between obstacles and the sampler is at least twice the height that the
obstacle protrudes above the sampler. In addition, there must be unre-
stricted airflow in an arc of at least 270° around the sampler, and the
predominant direction for the season of greatest pollutant concentration
potential must be included in the 270° arc.
3.3.1.3 Spacing from Roads - A number of studies [16-23] support the
conclusion that particulate concentrations decrease with increasing height
of the monitor and distance from the road. Quite high concentrations have
been reported at monitors located at a low elevation close to heavily tra-
veled roads. Moreover, monitors located close to streets are within the
concentrated plume of particulate matter emitted and generated by vehicle
traffic. Therefore, ambient monitors for TSP should be located beyond the
concentrated particulate plume generated by traffic, and not so close that
the heavier reentrained roadway particles totally dominate the measured
ambient concentration.
An analysis of various monitoring studies [24] shows that a linear
relationship between sampler height and distance from roadways defines a
zone where the plume generated by traffic greater than approximately 3,000
vehicles per day is diminished. Figure 1 illustrates this relationship by
showing two zones where TSP monitors could be located. Zone A represents
locations which are recommended and Zone B represents locations which
22
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should be avoided in order to minimize undesirable roadway influences. Roads
with lower traffic (less than approximately 3,000 vehicles per day) are
generally not considered to be a major source or vehicularrelated pollutants,
and so as noted in Figure 1 do not preclude the use of monitors in Zone B for
those situations. However, note that for those cases where the traffic is
less than approximately 3,000 vehicles per day, the monitor must be located
greater than 5 meters from the edge of the nearest traffic lane and 2 to 15
meters above ground level.
In the case of elevated roadways where the monitor must be placed below
the level of the roadway, the monitor should be located no closer than approx-
imately 25 meters from the edge of the nearest traffic lane. This separation
distance applies for those situations where the road is elevated greater than
5 meters above the ground level, and applies to all traffic volumes.
3.3.1.4 Other Considerations - Stations should not be located in an unpaved
area unless there is vegetative ground cover year round so that the impact
of reentrained or fugitive dusts will be kept to a minimum. Additional
information on TSP probe siting may be found in reference 9.
3.3.2 PMin
3.3.2.1. Vertical Placement - Although there are limited studies on the
PMiQ concentration gradients around roadways or other ground level sources,
references 16, 17, 19, 25, and 26 show a distinct variation in the distribu-
tion of TSP and Pb levels near roadways. TSP, which is greatly affected by
gravity, has large concentration gradients, both horizontal and vertical,
immediately adjacent to roads. Pb, being predominantly submicron in size,
behaves more like a gas and does not exhibit steep vertical and horizontal
gradients as does TSP. PM^o» being intermediate in size between these two
extremes exhibits dispersion properties of both gas and settleable particu-
lates and does show vertical and horizontal gradients [27]. Similar to
monitoring for other pollutants, optimal placement of the sampler inlet for
PM^g monitoring should be at breathing height level. However, practical
factors such as prevention of vandalism, security, and safety precautions
must also be considered when siting a PMio monitor. Given these considera-
tions, the sampler inlet for ground level source monitoring must be 2-7
meters above ground level. For PM^o samplers, the acceptable range for
monitoring emissions from elevated sources is 2-15 meters above ground
level.
3.3.2.2 Spacing from Obstructions - If the sampler is located on a roof or
other structure, then there must be a minimum of 2 meters separation from
walls, parapets, penthouses, etc. No furnace or incineration flues should
be nearby. This separation distance from flues is dependent on the height
of the flues, type of waste or fuel burned, and quality of the fuel (ash
content). In the case of emissions from a chimney resulting from natural
gas combustion, the sampler should be placed, as a precautionary measure,
at least 5 meters from the chimney.
24
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On the other hand, if fuel oil, coal, or solid waste is burned and the
stack is sufficiently short so that the plume could reasonably be expected
to impact on the sampler intake a significant part of the time, other
buildings/locations in the area that are free from these types of sources
should be considered for sampling. Trees provide surfaces for particulate
deposition and also restrict airflow. Therefore, the sampler should be
placed at least 20 meters from the dripline of trees and must be 10 meters
from the dripline when trees act as an obstruction [15],
The sampler must also be located away from obstacles such as buildings,
so that the distance between obstacles and the sampler is at least twice
the height that the obstacle protrudes above the sampler. There must also
be unrestricted airflow in an arc of at least 270° around the sampler, and
the predominant wind direction for the season of greatest pollutant
concentration potential must be included in the 270° arc.
3.3.2.3 Spacing from Roads - For these situations where the emissions from
a proposed source would impact close to a roadway, the air intake for the
monitor must be located between 5-15 meters from the edge of the nearest
traffic lane. Monitors located in this area would thus measure the combined
impact from the proposed source and the roadway. The sampler air intake
must be 2-7 meters above ground level.
3.3.2.4 Other Considerations - Stations should not be located in an unpaved
area unless there is vegetative ground cover year round so that the impact
of reentrained or fugitive dusts will be kept to a minimum. Additional
information on PM^g siting may be found in reference 28.
3.3.3 Sulfur Dioxide (SO?)
3.3.3.1. Horizontal and Vertical Probe Placement - As with TSP monitoring,
the most desirable height for an SOg inlet probe is near the breathing
height. Various factors enumerated before may require that the inlet probe
be elevated, consideration must also be given to the type of source pre-
dominantly influencing the impact area. For elevated sources, the inlet
probe must be located 3 to 15 meters above ground level. For ground level
sources, locate as close to the breathing zone as possible. If the inlet
probe is located on the side of the building, then it should be located on
the windward side of the building relative to the prevailing winter wind
direction. The inlet probe must also be located more than 1 meter vertically
or horizontally away from any supporting structure and also away from
dirty, dusty areas.
3.3.3.2 Spacing from Obstructions - No furnace or incineration flues, or
other minor sources of S02 should be nearby. The separation distance is
dependent on the height of the flues, type of waste or fuel burned, and the
quality of the fuel (sulfur content). If the inlet probe is located on a
roof or other structure, it must be at least 1 meter from walls, parapets,
penthouses, etc.
25
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The inlet probe should be placed at least 20 meters from the drip-
line of trees and must be 10 meters from the dripline when trees act as
an obstruction [15]. Additionally, the probe must be located away from
obstacles and buildings. The distance between the obstacles and the inlet
probe must be at least twice the height that the obstacle protrudes above
the inlet probe. Airflow must also be unrestricted in an arc of at least
270° around the inlet probe, and the predominant direction for the season of
greatest pollutant concentration potential must be included in the 270°
arc. If the probe is located on the side of a building, 180° clearance is
required. Additional information on S02 probe siting criteria may be found
in reference 10.
3.3.4 Carbon Monoxide (CO)
3.3.4.1 Horizontal and Vertical Probe Placement - Because of the importance
of measuring population exposure to CO concentrations, optimum CO sampling
should be done at average breathing heights. However, practical factors
require that the inlet probe be higher. In general, for CO emitted at
elevated heights, the inlet probe for CO monitoring should be 3-15 meters
above ground level. For those situations where the emissions from a pro-
posed source would impact a street canyon or corridor type area in an urban
area, and the area is predominantly influenced by the traffic from the
street canyon or traffic corridor, the inlet probe should be positioned 3 +_
1/2 meters above ground level which coincides with the vertical probe
placement criteria for a street canyon/corridor type site [7]. The criteria
is more stringent than the 3 to 15 meter range specified earlier because CO
concentration gradients resulting from motor vehicles traveling along
street canyon or corridors are rather steep and show wide variations in CO
levels at different heights. The 3 meter height is a compromise between
breathing height representation and such factors as the prevention of
obstructions to pedestrians, vandalism, etc.
In addition to the vertical probe criteria, the inlet probe must also
be located more than 1 meter in the vertical or horizontal direction from
any supporting structure.
3.3.4.2 Spacing from Obstructions - Airflow must also be unrestricted in
an arc of at least 270° around the inlet probe, and the predominant direction
for the season of greatest pollutant concentration potential must be included
in the 270° arc. If the probe is located on the side of a building, 180°
clearance is required [7, 15]. Additionally, trees should not be located
between the major sources of CO and the sampler. The sampler must be at
least 10 meters form the dripline of a tree which is between the sampler
and the source if the tree extends at least 5 meters above the sampler [15].
3.3.4.3 Spacing from Roads - For those situations discussed above where
the emissions from a proposed source would impact a street canyon/corridor
type area, the inlet probe must be located at least 10 meters from an
intersection and preferably at a midblock location. The inlet probe must
also be placed 2-10 meters from the edge of the nearest traffic lane.
26
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Also no trees or shrubs should be located between the sampling inlet
probe and the road [15], Additional information on CO probe siting may be
found in reference 11.
3.3.5 Ozone
3.3.5.1 Vertical and Horizontal Probe Placement - The inlet probe for
ozone monitors should be as close as possible to the breathing zone. The
complicating factors discussed previously, however, require that the probe
be elevated. The height of the inlet probe must be located 3 to 15 meters
above ground level. The probe must also be located more than 1 meter
vertically or horizontally away from any supporting structure.
3.3.5.2 Spacing from Obstructions - The probe must be located away from
obstacles and buildings such that the distance between the obstacles and
the inlet probe is at least twice the height that the obstacle protrudes
above the sampler. The probe should also be located at least 20 meters
from the dripline of trees. Since the scavenging effect of trees is greater
for ozone than for some of the other pollutants, strong consideration should
be used in locating the inlet probe to avoid this effect. Therefore, the
sampler must be at least 10 meters from the dripline of trees that are
located between the source of the ozone precursors and the sampler along
the predominant summer daytime wind direction [15], Airflow must be un-
restricted in an arc of at least 270° around the inlet probe, and the pre-
dominant direction for the season of greatest pollutant concentration
potential must be included in the 270° arc. If the probe is located on the
side of a building, 180° clearance is required.
3.3.5.3 Spacing from Roads - It is important in the probe siting process
to minimize destructive interferences from sources of nitric oxide (NO)
since NO readily reacts with ozone. Regarding NO from motor vehicles,
Table 2 provides the required minimum separation distances between roadways
and ozone monitoring stations. These distances were based on recalculations
using the methodology in reference 12 and validated using more recent
ambient data collected near a major roadway. The minimum separation distance
must also be maintained between an ozone station and other similar volumes
of automotive traffic, such as parking lots. Additional information on
ozone probe siting criteria may be found in reference 12.
27
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Table 2. MINIMUM SEPARATION DISTANCE BETWEEN OZONE MONITORS
AND ROADWAYS (EDGE OF NEAREST TRAFFIC LANE)
Roadway Average Daily Traffic,Minimum Separation Distance Between
Vehicles Per Day Roadways and Monitors, Meters
< 10,000 >_ 10a
15,000 20
20,000 30
40,000 50
70,000 100
>UO,000 X250
aDistances should be interpolated based on traffic flow.
3.3.6 Nitrogen Dioxide (NO?)
3.3.6.1 Vertical and Horizontal Probe Placement - As discussed for previous
pollutants, the acceptable ranges for a monitor/probe inlet for monitoring
N02 emissions in an area principally influenced by an elevated source is
3-15 meters. For areas influenced primarily by a ground level source, the
height should be as close to 3 meters as possible. Regarding the distance
of the probe from the supporting structure, a vertical or horizontal distance
of 1 meter must be maintained.
3.3.6.2 Spacing from Obstructions - Buildings, trees, and other obstacles
can serve as scavengers of N02. In order to avoid this kind of interfer-
ence, the station must be located well away from such obstacles so that the
distance between obstacles and the inlet probe is at least twice the height
that the obstacle protrudes above the probe. Also, a probe inlet along a
vertical wall is undesirable because air moving along that wall may be
subject to possible removal mechanisms. Similarly, the inlet probe should
also be at least 20 meters from the dripline of trees and must be at least
10 meters from the dripline of trees which protrude above the height of
the probe by 5 of more meters [15]. There must be unrestricted airflow in an
arc of at least 270° around the inlet probe, and the predominant direction for
the season of greatest pollutant concentration potential must be included in
the 270° arc. If the probe is located on the side of the building, 180°
clearance is required. Additional information on N02 probe siting criteria
may be found in reference 12.
3.3.7 Lead (Pb)
3.3.7.1 Vertical Placement - Breathing height is the most desirable location
for the vertical placement of the Pb monitor. However, practical factors
previously mentioned require that the monitor be elevated. In elevating
the sampler, consideration must be given to ground level emissions (whether
they be stationary or mobile sources) with steep vertical concentration
gradients. Placing the shelter too high could result in measured values
28
-------
significantly lower than the level breathed by the general public. Accord-
ingly, the sampler for ground level source monitoring must be located 2 to
7 meters above ground level. In contrast, samplers to monitor for elevated
sources, as noted in previous discussion, are allowed a wider range of
heights for locating the sampler/inlet probe. For Pb samplers, the acceptable
range for monitoring emissions from elevated sources is 2-15 meters above
ground level.
3.3.7.2 Spacing from Obstructions - A minimum of 2 meters of separation
from walls, parapets, and penthouses is required for samplers located on a
roof or other structure. No furnace or incineration flues should be nearby.
The height of the flues and the type, quality, and quantity of waste or
fuel burned determine the separation distances from flues. For example, if
the emissions from the chimney have a high lead content and there is a high
probability that the plume would impact on the sampler during most of the
sampling period, then other buildings/locations in the area that are free
from the described sources should be chosen for the monitoring site. The
sampler should be placed at least 20 meters from the dripline of trees and
must be at least 10 meters from the dripline of trees when the tree(s) could
be classified as an obstruction [15], since trees absorb particles as well
as restrict airflow.
The sampler must be located away from obstacles such as buildings, so
that the distance between obstacles and the sampler is at least twice the
height that the obstacle protrudes above the sampler. There must also be
unrestricted airflow in an arc of at least 270° around the sampler, and the
predominant direction for the season of greatest pollution concentration
potential must be included in the 270° arc.
3.3.7.3 Spacing from Roads - For those situations discussed in Section
3.3.7.1 where the emissions from a proposed source would impact close to a
major roadway (greater than approximately 30,000 ADT), the air intake for
the monitor must be located within 15-30 meters from the edge of the nearest
traffic lane. Monitors located in this area would thus measure the combined
impact from the proposed source and the roadway. The sampler air intake
must be 2 to 7 meters above ground level.
3.3.7.4 Other Considerations - Stations should not be located in an unpaved
area unless there is vegetative ground cover year round so that the impact
of reentrained or fugitive dusts will be kept to a minimum. Additional
information on Pb siting criteria may be found in reference 13.
3.3.8 Noncriteria Pollutants
3.3.8.1 Vertical Placement - Similar to the discussion on criteria pollutants,
the most desirable height for monitors/inlet probes for noncriteria pollutants
is near the breathing zone. Again, practical factors require that the
monitor/ inlet probe be elevated. Furthermore, consideration must be given
to the type of source, i.e., elevated, ground level, stationary, or mobile.
As the case may be, for noncriteria particulate pollutant monitors, the
29
-------
following monitor/inlet probe ranges are acceptable: for impact areas pre-
dominantly influenced by elevated sources, 2-15 meters; for ground level
sources 2 to 7 meters. Regarding noncriteria gaseous pollutants, acceptable
heights are as follows: areas impacted primarily by elevated sources, 3-15
meters; areas affected principally by ground level sources, as close to 3
meters as possible.
3.3.8.2 Spacing from Obstructions - If the sampler/inlet probe is located
on a roof or other structure, then there must be a minimum of 2 meters
separation from walls, parapets, penthouses, etc. No furnace or inciner-
ation flues should be nearby. This separation distance from flues is
dependent on the height of the flues, type of waste or fuel burned, and
quality of the fuel. For example, if the emissions from the chimney contain
a high concentraton of the noncriteria pollutant that is being measured and
there is a high probability that the plume would impact the sampler/inlet
probe during most of the sampling period, then other buildings/locations
in the area that are free from the described sources should be chosen for
the monitoring site. The sampler/inlet probe should also be placed at
least 20 meters from the dripline of trees and must be at least 1C meters
from the dripline of tree(s) that could be classified as an obstruction [15].
The sampler/inlet probe must be located away from obstacles and buildings
such that the distance between the obstacles and the sampler/inlet probe
is at least twice the height that the obstacle protrudes above the sampler/
inlet probe. Airflow must be unrestricted in an arc of at least 270°
around the sampler/inlet probe, and the predominant direction for the
season of greatest pollutant concentration potential must be included in
the 270° arc. If the inlet probe is located on the side of a building,
180° clearance is required.
3.3.8.3 Other Considerations - Stations for measuring particulate non-
criteria pollutants should not be located in an unpaved area unless there
is vegetative ground cover year round so that the impact of reentrained or
fugitive dusts will be kept to a minimum.
3.4 Probe Material and Pollutant Sample Residence Time
For reactive gases, special probe material must be used. Studies
[29-33] have been conducted to determine the suitability of materials such
as polypropylene, polyethylene, polyvinylchloride, tygon, aluminum, brass,
stainless steel, copper, pyrex glass, and teflon for use as intake sampling
lines. Of the above materials, only pyrex glass and teflon have been found
to be acceptable for use as intake sampling lines for all the reactive
gaseous pollutants. Furthermore, EPA [34] has specified borosilicate glass
or FEP teflon as the only acceptable probe materials for delivering test
atmospheres in the determination of reference or equivalent methods.
Therefore, borosilicate glass, FEP teflon, or their equivalent must be used
for inlet probes.
30
-------
No matter how unreactive the sampling probe material is initially,
after a period of use, reactive participate matter is deposited on the
probe walls. Therefore, the time it takes the gas to transfer from the
probe inlet to the sampling device is also critical. Ozone in the presence
of NO will show significant losses even in the most inert probe material when
the residence time exceeds 20 seconds [35]. Other studies [36-37] indicate
that a 10-second or less residence time is easily achievable. Therefore,
sampling probes for reactive gas monitors must have a sampler residence
time less than 20 seconds.
3.5 Summary of Probe Siting Requirements
Table 3 presents a summary of the requirements for probe siting criteria
with respect to distances and heights. These criteria are specified for
consistency between pollutants and to allow the use of a single manifold
for monitoring more than one pollutant at a site.
31
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4. QUALITY ASSURANCE FOR AIR QUALITY DATA
On May 10, 1979, EPA promulgated quality assurance requirements for
PSD monitoring for $03, N02, 03, CO, and TSP. These quality assurance
requirements were revised and updated on March 19, 1986 [15]. These quality
assurance requirements are Appendix B of 40 CFR 58 (reference 7). Section
4.1 describes minimum quality assurance requirements for PSD monitoring for
all criteria air pollutants (S02, N02, 03, CO, TSP, Pb and PMio). Monitoring
organizations are required to meet quality assurance requirements of Appendix
B at the time the station is put into operation.
Currently, quality assurance for PSD monitoring for noncriteria air
pollutants are EPA recommendations only. EPA promulgated requirements are
not available for noncriteria air pollutants. Section 4.2 describes minimum
quality assurance recommendations for noncriteria air pollutants.
4.1 Quality Assurance for Criteria Air Pollutants
4.1.1 General Information
The following specifies the minimum quality assurance requirements of
an organization operating a network of PSD stations. These requirements
are regarded as the minimum necessary for the control and assessment of the
quality of the PSD ambient air monitoring data submitted to EPA. Organiza-
tions are encouraged to develop and implement quality assurance programs
more extensive than the minimum required or to continue such programs
where they already exist.
Quality assurance consists of two distinct and equally important
functions. One function is the assessment of the quality of the monitoring
data by estimating their precision and accuracy. The other function is the
control, and improvement, of the quality of the monitoring data by implemen-
tation of quality control policies, procedures, and corrective actions.
These two functions form a control loop; when the assessment function
indicates that the data quality is inadequate, the control effort must
be increased until the data quality is acceptable.
In order to provide uniformity in the assessment and reporting of data
quality, the assessment procedures are specified explicitly in Sections
4.1.3, 4.1.4, 4.1.5 and 4.1.6.
In contrast, the control and corrective action function encompasses a
variety of policies, procedures, specifications, standards, and corrective
measures which have varying effects on the resulting data quality. The
selection and degree of specific control measures and corrective actions
used depend on a number of factors such as the monitoring methods and
equipment used, field and laboratory conditions, the objectives of the
monitoring, the level of data quality needed, the expertise of personnel,
the cost of control procedures, pollutant concentration levels, etc.
38
-------
Accordingly, quality control requirements are specified in general terms,
in Section 4.1.2 to allow each organization to develop a quality control
system which is most effective for its own circumstances.
For purposes here, "organization" is defined as a source owner/operator,
a government agency, or their contractor which operates an ambient air
pollution monitoring network for PSD purposes.
4.1.2 Qua!ity Control Requirements
4.1.2.1 Organizational Requirements - Each organization must develop and
implement a quality control program consisting of policies, procedures,
specifications, standards and documentation necessary to:
(a) meet the monitoring objectives and quality assurance requirements
of the permit granting authority
(b) minimize loss of air quality data due to malfunctions or out-
of-control conditions,
The quality control program must be described in detail, suitably
documented, and approved by the permit granting authority.
4.1.2.2 Primary Guidance - Primary guidance for developing the quality
control program is contained in references 38 and 39, which also contain
many suggested procedures, checks, and control specifications. Section
2.0.9 of reference 39 describes the specific guidance for the development
of a quality control program for PSD automated analyzers and manual methods.
Many specific quality control checks and specifications for manual methods
are included in the respective reference methods described in 40 CFR 50, or
in the respective equivalent method descriptions available from EPA (see
Section 2.6). Similarly, quality control procedures related to specifically
designated reference and equivalent analyzers are contained in their respective
operation and instruction manuals. This guidance, and any other pertinent
information from appropriate sources, should be used by organizations in
developing their quality control programs.
As a minimum each quality control program must have operational
procedures for each of the following activities:
(a) selection of methods, analyzers, or samplers,
(b) installation of equipment,
(c) calibration,
(d) zero and span checks and adjustments of automated analyzers,
(e) control checks and their frequency,
(f) control limits for zero, span and other control checks, and
respective corrective actions when such limits are surpassed,
(g) calibration and zero/span checks for multiple range analyzers
(h) preventive and remedial maintenance
(i) recording and validating data
(j) documentation of quality control information.
39
-------
As previously mentioned, specific guidance for each activity listed
above that must be a part of an organization's quality control program is
described in Section 2.0.9 of reference 39.
4.1.2.3 Pollutant Standards - Gaseous standards (permeation tubes,
permeation devices or cylinders of compressed gas) used to obtain test
concentrations for CO, S02, and NOg must be working standards certified by
comparison to a National Bureau of Standards (NBS) gaseous Standard Reference
Material (SRM). A traceability protocol for certifying a working standard
by direct comparison to an NBS SRM is given in reference 40. Direct use of
an NBS SRM as a working standard is not prohibited but is discouraged
because of the limited supply and expense of NBS SRM's. When available,
gas manufacturers' cylinder gases Certified Reference Materials "CRM" may
be substituted for NBS SRM cylinder gases in establishing traceability.
Test concentrations for ozone must be obtained in accordance with the
UV photometric calibration procedure specified in Appendix 0 of 40 CFR 50,
or by means of an ozone transfer standard which has been certified. Consult
reference 41 for guidance on ozone transfer standards.
Flow measurements must be made by a flow measuring instrument which is
traceable to an authoritative volume or other standard.
4.1.2.4 Performance and System Audit Programs - The organization operating
a PSD monitoring network must participate in EPA's national performance
audit program. The permit granting authority, or EPA, may conduct system
audits of the ambient air monitoring programs of organizations operating
PSD networks. See Section 1.4.16 of reference 38 and Sections 2.0.11 and
2.0.12 of reference 39 for additional information about these programs.
Organizations should contact either the appropriate EPA Regional Quality
Control Coordinator or the Quality Assurance Division, EMSL/RTP, at the
address given in reference 40 for instructions for participation.
4.1.3 Data Quality Assessment Requirements
4.1.3.1 Precision of Automated Methods - A one-point precision check must
be carried out at least once every two weeks on each automated analyzer
used to measure S02, N02, 03, and CO. The precision check is made by
challenging the analyzer with a precision check gas of known concentration
between 0.008 and 0.10 ppm for S02, N02, and 03 analyzers, and between 8 and
10 ppm for CO analyzers. The standards from which precision check test con-
centrations are obtained must meet the specifications of section 4.1.2.3.
Except for certain CO analyzers described below, analyzers must operate in
their normal sampling mode during the precision check, and the test atmosphere
must pass through all filters, scrubbers, conditioners, and other components
used during normal ambient sampling and as much of the ambient air inlet
system as is practicable. If permitted by the associated operation or
instruction manual, a CO analyzer may be temporarily modified during the
precision check to reduce vent or purge flows, or the test atmosphere may
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enter the analyzer at a point other than the normal sample inlet, provided
that the analyzer's response is not likely to be altered by these deviations
from the normal operational mode.
If a precision check is made in conjunction with zero/span adjustment,
it must be made prior to such zero and span adjustments. The difference
between the actual concentration of the precision check gas and the concen-
tration indicated by the analyzer is used to assess the precision of the
monitoring data as described in Section 4.1.4.1. Report data only from
automated analyzers that are approved for use in the PSD network.
4.1.3.2 Accuracy of Automated Methods - Each sampling quarter audit each
analyzer that monitors for S02, N02, 03, or CO at least once. The audit is
made by challenging the analyzer with at least one audit gas of known
concentration from each of the following ranges which fall within the
measurement range of the analyzer being audited:
Concentration Range, ppm
Audit Point
S02, 03
NOg
CO
1
2
3
4
0.03 to 0.08
0.15 to 0.20
0.35 to 0.45
0.80 to 0.90
0.03 to 0.08
0.15 to 0.20
0.35 to 0.45
3 to 8
15 to 20
35 to 45
80 to 90
The standards from which audit gas test concentrations are obtained must
meet the specifications of Section 4.1.2.3. Working and transfer standards
and equipment used for auditing must be different from the standards and
equipment used for calibration and spanning. The auditing standards and
calibration standards may be referenced to the same NBS SRM or primary UV
photometer. The auditor must not be the operator/analyst who conducts the
routine monitoring, calibration, and analysis.
The audit shall be carried out by allowing the analyzer to analyze an
audit test atmosphere in the same manner as described for precision checks
in Section 4.1.3.1. The exception given in Section 4.1.3.1 for certain CO
analyzers does not apply for audits.
The difference between the actual concentration of the audit test gas
and the concentration indicated by the analyzer is used to assess the
accuracy of the monitoring data as described in Section 4.1.4.2. Report
data only from automated analyzers that are approved for use in the PSD
network.
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4.1.3.3 Precision of Manual Methods - (a) TSP and PMm Methods. For a given
organi zation's monitoring network, one sampling site must have col 1 ocated
samplers. A site with the highest expected 24-hour pollutant concentration
must be selected. The two samplers must be within 4 meters of each other
but at least 2 meters apart to preclude airflow interference. Calibration,
sampling, and analysis must be the same for both collocated samplers as well
as for all other samplers in the network. The collocated samplers must be
operated as a minimum every third day when continuous sampling is used.
When a less frequent sample schedule is used, the collocated samplers must
be operated at least once each week. For each pair of collocated samplers,
designate one sampler as the sampler which will be used to report air quality
for the site and designate the other as the duplicate sampler. The differences
in measured concentration ( g/m3) between the two collocated samplers are
used to calculate precision as described in Section 4.1.5.1.
(b) Pb Methods. The operation of collocated samplers at one sampling
site must be used to assess the precision of the reference or an equivalent
lead method. The procedure to be followed for lead methods is the same as
described in 4.1.3.3(a) for the TSP and PMio methods.
4.1.3.4 Accuracy of Manual Methods - (a) TSP and PMm Methods. Each
sampling quarter audit the flow rate of each sampler at least once. Audit the
flow at the normal flow rate, using a certified flow transfer standard (see
reference 39). The flow transfer standard used for the audit must not be
the same one used to calibrate the flow of the sampler being audited,
although both transfer standards may be referenced to the same primary flow
or volume standard. The difference between the audit flow measurement and
the flow indicated by the sampler's flow indicator is used to calculate
accuracy, as described in Section 4.1.5.2
Great care must be used in auditing high-volume samplers having flow
regulators because the introduction of resistance plates in the audit
device can cause abnormal flow patterns at the point of flow sensing. For
this reason, the orifice of the flow audit device should be used with a
normal glass fiber filter in place and without resistance plates in auditing
flow regulated high-volume samplers, or other steps should be taken to
assure that flow patterns are not perturbed at the point of flow sensing.
(b) Pb Methods. For the reference method (Appendix G of 40 CFR 50)
each sampling quarter audit the flow rate of each high-volume lead sampler
at least once. Audit the flow rate at one flow rate using a reference flow
device described in Section 2.2.8 of reference 39, or a similar flow transfer
standard. The device used for auditing must be different from the one used
to calibrate the flow of the high-volume sampler being audited. The auditing
device and the calibration device may both be referenced to the same primary
flow standard. With the audit device in place, operate the high-volume
sampler at its normal flow rate. The difference in flow rate (in m3/min)
between the audit flow measurement and the flow indicated by the sampler's
normal flow indicator are used to calculate accuracy as described in Section
4.1.5.3.
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Great care must be used in auditing high-volume sampler having flow
regulators because the introduction of resistance plates in the audit
device can cause abnormal flow patterns at the point of flow sensing. For
this reason, the orifice of the flow audit device should be used with a
normal glass fiber filter in place without resistance plates to audit flow
regulated high-volume samplers, or other steps should be taken to assure
that flow patterns are not perturbed at the point of flow sensing.
Each sampling quarter, audit the lead analysis using glass fiber
filter strips containing a known quantity of lead. Audit samples are
prepared by depositing a lead solution on 1.9 cm by 20.3 cm (3/4 inch by 8
inch) unexposed glass fiber filter strips and allowing to dry thoroughly.
The audit samples must be prepared using reagents different from those used
to calibrate the lead analytical equipment being audited. Prepare audit
samples in the following concentration ranges:
Equivalent Ambient
Range Cone, ug Pb/strip Cone, ug Pb/m^*
1 100 to 300 0.5 to 1.5
2 600 to 1000 3.0 to 5.0
*Equivalent ambient lead concentration in ug/nr* is based on sampling at 1.7
m-Vmin for 24 hours on 20.3 cm x 25.4 (8 inch x 10 inch) glass fiber filter.
Audit samples must be extracted using the same extraction procedure
used for exposed filters.
Analyze at least one audit sample in each of the two ranges each day
that samples are analyzed. The difference between the audit concentration
(in ug Pb/strip) and the analyst's measured concentration (in ug Pb/strip)
are used to calculate analysis accuracy as described in Section 4.1.5.4.
The accuracy of an equivalent method is assessed in the same manner as
the reference method. The flow auditing device and lead analysis audit
samples must be compatible with the specific requirements of the equivalent
method.
4.1.4 Calculations for Automated Methods
4.1.4.1 Single Analyzer Precision - Each organization, at the end of each
sampling quarter, shall calculate and report a precision probability interval
for each analyzer. Directions for calculations are given below and directions
for reporting are given in Section 4.1.6. If monitoring data are invalidated
during the period represented by a given precision check, the results of
that precision check shall be excluded from the calculations. Calculate
the percentage difference (dj) for each precision check using equation 1.
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Y - X
I-, - A-,
X 100
where: Y-j = analyzer's indicated concentration from the i-th precision
check,
X-j = known concentration of the test gas used for the i-th precision
check.
For each instrument, calculate the quarterly average (dj), equation 2, and
the standard deviation (Sj), equation 3.
(2)
dj
sj
n
= 1 z di
n
1=1
/
= / 1
"2 n o
S di - 1 ( E d^r
1-1 "n" 1-1
(3)
Where n is the number of precision checks on the instrument made during the
sampling quarter. For example, n should be 6 or 7 if span checks are made
bi-weekly during a quarter.
Calculate the 95 percent probability limits for precision using equations
4 and 5.
Upper 95 Percent Probability Limit = dj + 1.96 Sj (4)
Lower 95 Percent Probability Limit = dj - 1.96 Sj (5)
4.1.4.2 Single Analyzer Accuracy - Each organization, at the end of each
sampling quarter, shall calculate and report the percentage difference for
each audit concentration for each analyzer audited during the quarter.
Directions for calculations are given below (directions for reporting are
given in Section 4.1.6).
Calculate and report the percentage difference (d-j) for each audit
concentration using equation 1 where Y-j is the analyzer's indicated concen-
tration from the i-th audit check and X-j is the known concentration of the
audit gas used for the i-th audit check.
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4.1.5 Calculations for Manual Methods
4.1.5.1 Single Instrument Precision for TSP, Pb? and PMin» Estimates of
precision for ambient air quality participate measurements are calculated from
results obtained from collocated samplers as described in section 4.1.2.3.
At the end of each sampling quarter, calculate and report a precision
probability interval, using weekly results from the collocated samplers.
Directions for calculations are given below, and directions for reporting
are given in Section 4.1.6.
For the paired measurements obtained as described in sections 4.1.2.3(a)
and 4.1.2.3(6), calculate the percent difference (d-j) using equation la,
where Yj is the concentration of pollutant measured by the duplicate sampler,
and X-j is the concentration measured by the sampler reporting air quality for
the site. Calculate the quarterly average percent difference (dj), equation
2, standard deviation (Sj), equation 3, and upper and lower 95 percent
probability limts for precision (equations 6 and 7).
x 100
(la)
Upper 95 Percent Probability Limit - dj + 1.96 Sj/
Lower 95 Percent Probability Limit - dj - 1.96 Sj/
(6)
(7)
4.1.5.2 Single Instrument Accuracy for TSP and PMm - Each organization, at
the end of each sampling quarter, shall calculate and report the percentage
difference for each high-volume or PMjo sampler audited during the quarter.
Directions for calculation are given below and directions for reporting are
given in Section 4.1.6.
For the flow rate audit described in Section 4.1.3.4, let X-j represent
the known flow rate and Yi represent the indicated flow rate. Calculate the
percentage difference (d-j) using equation 1.
4.1.5.3 Single Instrument Sampling Accuracy for Pb - Each organization, at
the end of each sampling quarter, shall calculate and report the percentage
difference for each high-volume lead sampler audited during the quarter.
Directions for calculation are given in Section 4.1.5.2 and directions for
reporting are given in Section 4.1.6.
4.1.5.4 Single-Analysis-Day Accuracy for Pb - Each organization, at the
end of each sampling quarter, shall calculate and report the percentage
difference for each Pb analysis audit during the quarter. Directions for
calculations are given below and directions for reporting are given in
Section 4.1.6.
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For each analysis audit for Pb described in Section 4.1.3.4(b), let X-j
represent the known value of the audit sample and Y-j the indicated value of
Pb. Calculate the percentage difference (d-j) for each audit at each concen-
tration level using equation 1.
4.1.6 Organization Reporting Requirements
At the end of each sampling quarter, the organization must report
the following data assessment information: (a) for automated analyzers -
precision probability limits from Section 4.1.4.1 and percentage differences
from Section 4.1.4.2, and (b) for manual methods - precision probability
limits from Section 4.1.5.1 and percentage differences from Sections 4.1.5.2,
4.1.5.3 and 4.1.5.4. The precision and accuracy information for the entire
sampling quarter must be submitted with the air monitoring data. All data
used to calculate reported estimates of precision and accuracy including
span checks, collocated sampler and audit results must be made available to
the permit granting authority upon request.
4.2 Quality Assurance for Noncriteria Air Pollutants
At the present time, there are no EPA regulations on quality assurance
for PSD monitoring of noncriteria air pollutants. The following are EPA
recommendations for a minimum quality assurance program for noncriteria
pollutants.
4.2.1 Selection of Method
Selection of the measurement method for noncriteria air pollutants
is extremely important. A list of acceptable measurement methods for
noncriteria air pollutants is available and may be obtained by writing:
U.S. Environmental Protection Agency, Environmental Monitoring Systems
Laboratory, Quality Assurance Division (MD-77), Research Triangle Park,
North Carolina 27711. This list of acceptable methods will be revised at
least annually and be available from the above address. Measurement methods
considered candidates for the noncriteria pollutant list should be brought
to the attention of EPA at the address given above.
4.2.2 Calibration
Calibration procedures described in the acceptable methods should be
followed and a schedule for calibrations should be established. In addition,
flow measurement devices used to measure sampling rate should be calibrated
and a schedule established for recalibration. Calibration procedures for
several flow measurement devices (rotameter, critical orifice, mass flow
meter, and wet test meter) are described in Section 2.1.2 of reference 39.
All calibration procedures should be written and maintained up-to-date by a
document control system. A description of one document control system that
has been found to be effective is discussed in Section 1.4.1 of reference 38.
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4.2.3 Data Validation
Measurement data of poor quality may be worse than no data at all.
Therefore, the monitoring organization should establish data validation
procedures and implement these procedures to invalidate data of question-
able quality. Examples of data validation procedures for criteria pollu-
tants described in Section 2.0.9 of reference 39 may be useful as a guide
in establishing data validation procedures for noncriteria pollutants.
4.2.4 Standard and Split Samples
Where possible, standard samples containing the pollutant of interest
should be analyzed periodically during the analysis of collected samples.
This practice is useful in helping to determine if the analytical system is
in control. Splitting samples with another laboratory is quite useful in
determining if there are unidentified biases in the analytical system.
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5. METEOROLOGICAL MONITORING
5.1 Data Required
The preconstruction review of proposed major emitting facilities will
require the use of meteorological data. It is essential that such data be
representative of atmospheric dispersion conditions at the source and at
locations where the source may have a significant impact on air quality.
The representativeness of the data is dependent upon (a) the proximity of
the meteorological monitoring site to the area under consideration, (b) the
complexity of the topography of the area, (c) the exposure of the meteorolog-
ical sensors, and (d) the period of time during which the data are collected,
More guidance for determining representativeness is presented in reference
42.
A data base representative of the site should consist of at least the
following data:
a. hourly average wind speed and direction
b. hourly average atmospheric stability based on Pasquill stability
category or wind fluctuations (a ), or vertical temperature
gradient combined with wind speea
c. hourly surface temperature at standard height for climatological
comparisons and plume rise calculations
d. hourly precipitation amounts for climatological comparisons.
In addition, hourly average mixing heights may be necessary for the
air quality impact analysis. In most cases, this may be limited to an
extrapolation of twice-daily radiosonde measurements routinely collected by
the National Weather Service (NWS). Sections 5.2 and 6.1 contain specific
information on instrument exposure and specifications.
Requirements for additional instrumentation and data will depend upon
the availability of information needed to assess the effects of pollutant
emissions on ambient air quality, soils, vegetation, and visibility in the
vicinity of the proposed source. The type, quantity, and format of the
required meteorological data will also be influenced by the input require-
ments of the dispersion modeling techniques used in the air quality analysis
Any application of dispersion modeling must be consistent with the EPA
"Guideline on Air Quality Models" [14], The guideline makes specific
recommendations concerning air quality models and data bases. It also
specifies those situations for which models, data, and techniques other
than those recommended therein, may be applied.
Site-specific data are always preferable to data collected off-site.
The availability of site-specific meteorological data permits relatively
detailed meteorological analyses and subsequent improvement of dispersion
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model estimates. An important source of background information pertaining
to on-site meteorological instrumentation is contained in an EPA workshop
report [43], Off-site meteorological data may be used in lieu of site-
specific data only if it is agreed by source owner and permit granting
authority that the off-site data are reasonably representative of atmospheric
conditions in the area under consideration. The off-site meteorological
data can sometimes be derived from routine measurements by NWS stations.
The data are available as individual observations and in summarized form
from the National Climatic Data Center, Federal Building, Asheville, NC
28801. On the other hand, if the nearest source of off-site data is con-
siderably removed from the area under consideration, and especially if
there are significant terrain features, urban areas, or large bodies of
water nearby, it may be necessary that the required meteorological data be
site-specific.
In some cases, it will be necessary that data be collected at more
than one site in order to provide a reasonable representation of atmospheric
conditions over the entire area of concern. Atmospheric conditions may
vary considerably over the area. In some cases, (e.g., complex terrain) it
will not be feasible to adequately monitor the entire meteorological field
of concern. Then the only recourse is to site the stations in areas where
characteristic and significant airflow patterns are likely to be encountered.
In any event, one of the meteorological stations should be located so that
it represents atmospheric conditions in the immediate vicinity of the
source.
Although at least 1 year of meteorological data should be available, a
shorter period of record that conforms to the air quality monitoring period
of record discussed in Section 2.5 is acceptable when approved by the
permit granting authority. If more than 1 year of data is available, it is
recommended that such data be included in the analysis. Such a multiyear
data base allows for more comprehensive consideration of variations in
meteorological conditions that occur from year to year. A 5-year period of
record will usually yield an adequate meteorological data base for considering
such year-to-year variations.
In all cases, the meteorological data used must be of at least the
quality of data collected by the National Weather Service. Desired features
of instrumentation for collecting meteorological data are discussed in
Section 6.1.
5.2 Exposure of Meteorological Instruments
Measurements of most meteorological parameters are affected by the
exposure of the sensor. To obtain comparable observations at different
sites, the exposures must be similar. Also, the exposure should be such
that the measured parameters provide a good representation of pollutant
transport and dispersion within the area that the monitoring site is supposed
to represent. For example, if wind flow data over a fairly broad area are
desired, the wind sensors should be away from the immediate influence of
trees, buildings, steep slopes, ridges, cliffs, or hollows.
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The standard exposure of wind instruments over level open terrain is
10 meters above the ground. Open terrain is defined as an area where the
distance between the anemometer and any obstruction to the wind flow is at
least five times the height of the obstruction. Where a standard exposure
is unobtainable at this height, the anemometer should be installed at such
a height that its indications are reasonably unaffected by local obstructions
and represent as closely as possible what the wind at 10 meters would be in
the absence of the obstructions. Detailed guidance on assessing adverse
aerodynamic effects due to local obstructions is contained in reference 44.
In locating wind sensors in rough terrain or valley situations, it will be
necessary to determine if local effects such as channeling, slope and
valley winds, etc., are important, or whether the flow outside those zones
of influence is to be measured. If the analysis concerns emissions from a
tall stack, it may be desirable to avoid the local influences. On the
other hand, if pollution from low-level sources is the main concern, the
local influences may be important.
If the source emission point is substantially above the standard
10-meter level for wind measurements, additional wind measurements at the
height of the emission point and at plume height are desirable. Such
measurements are used to determine the wind regime in which the effluent
plume is transported away from the source. (The wind speed and direction
50 to 100 meters or more above the surface are often considerably different
than at the 10-meter level.) An instrumented tower is the most common
means of obtaining meteorological measurements at several elevations in the
lower part of the atmospheric boundary layer. For wind instruments mounted
on the side of a tower, precautions must be taken to ensure that the wind
measurements are not unduly influenced by the tower. Turbulence in the
immediate wake of a tower (even a latticetype tower) can be severe. Thus,
depending on the supporting structure, wind measuring equipment should be
mounted (e.g., on booms) at least two structure widths away from the structure,
and two systems mounted on opposite sides of the structure will sometimes
be necessary. A wind instrument mounted on top of a tower should be mounted
at least one tower width above the top. If there is no alternative to
mounting instruments on a stack, the increased turbulence problem [45],
must be explicitly resolved to the satisfaction of the permit granting
authority.
Atmospheric stability is another key factor in pollutant dispersion
downwind of a source. The stability category is a function of static
stability (related to temperature change with height), convective turbulence
(caused by heating of the air at ground level), and mechanical turbulence
(a function of wind speed and surface roughness). A procedure for estima-
ting stability category is given by Turner [46] which requires information
on solar elevation angle, cloud cover, ceiling height, and wind speed. The
hourly observations at NWS stations include cloud cover, ceiling height,
and wind speed. Alternative procedures for estimating stability category
may be applied if representative data are available. For example, stability
category estimates may be based upon horizontal wind direction fluctuations
[47], or vertical gradients of temperature and wind speed [48]. To obtain
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a representative reading of the air temperature, the temperature sensor
should be protected from thermal radiation from the sun, sky, earth, and
any surrounding objects, and must be adequately ventilated. Aspirated
radiation shields are designed to provide such protection. (Note that
ambient temperature data are also commonly required for plume rise estimates
used in dispersion model calculations.)
Mixing height is another parameter that can be important in some
cases. Mixing height is the distance above the ground to which relatively
free vertical mixing occurs in the atmosphere. For estimating long-term
average concentrations, it is adequate to use a representative annual
average mixing height [49], However, in many cases, and especially for
estimates of short-term concentrations, twice-daily or hourly mixing height
data are necessary. Such data can sometimes be derived [49] from represen-
tative surface temperatures and twice-daily upper air soundings collected
by selected NWS stations.
Precipitation collectors must be located so that obstructions do not
prevent the precipitation from falling into the collector opening or force
precipitation into the opening. Several collectors may be required for
adequate spatial resolution in complex topographic regimes.
Final rule making entitled "Visibility Protection for Federal Class I
Areas," was published in the Federal Register on December 2, 1980. The
regulations are applicable to 36 States listed in the action. Although
these States are not required to establish visibility monitoring networks,
they should consult with the Federal Land Managers to determine monitoring
needs. Paragraph 51.305 states that the SIP strategies "must take into
account current and anticipated visibility monitoring research, the avail-
ability of appropriate monitoring techniques and such guidance as is pro-
vided by the Agency." Visibility definitions, monitoring methods, modeling
considerations and impact assessment approaches are among the subjects of
three EPA reports: (1) "Protecting Visibility: An EPA Report to Congress"
[50], (2) "Interim Guidance for Visibility Monitoring" [51], and (3) "Work-
book for Estimating Visibility Impairment" [52]. Also, since publication
of the final rule, the.National Park Service has established a visibility
monitoring system. The States or permit granting authority should consider
these resources when handling visibility new source review questions.
Additional information and guidance on siting and exposure of
meteorological instruments is contained in reference 53.
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6. METEOROLOGICAL INSTRUMENTATION
6.1 Specifications
Meteorological instrumentation used for PSD monitoring must yield
reasonably accurate and precise data. Accuracies and allowable errors are
expressed in this section as absolute values for digital systems; errors in
analog systems may be 50 percent greater. For example, an allowable error
expressed as 5 percent means the recorded value should be within _+5 percent
of the true value for digital systems, and +7.5 percent for analog systems.
Records should be dated, and should be accurate to within 10 minutes. Wind
speed and direction (or vector components) should be recorded on a digital
data logging system at intervals not to exceed 60 seconds for a given
variable; data recorded on continuous strip recorders at intervals not
exceeding 60 seconds may be used as backup. These specifications apply to
the meteorological instruments used to gather the site specific data that
will accompany a PSD permit application. When the use of existing represen-
tative meteorological data is approved by the permit granting authority,
the instrumentation should meet, as a minimum, NWS standards [54-55].
6.1.1 Wind Systems (horizontal wind)
Wind direction and wind speed systems should exhibit a starting
threshold of less than 0.5 meter per second (m/s) wind speed (at 10 degrees
deflection for direction vanes). Wind speed systems should be accurate
above the starting threshold to within 0.25 m/s at speeds equal to or less
than 5 m/s. At higher speeds, the error should not exceed 5 percent of the
observed speed (maximum error not to exceed 2.5 m/s). The damping ratio of
the wind vane should be between 0.4 and 0.65 and the distance constant
should not exceed 5 m. Wind direction system errors should not exceed 5
degrees, including sensor orientation errors. Wind vane orientation
procedures should be documented.
6,1.2 Wind Systems (vertical wind)
In complex terrain, downwash of plumes due to significant terrain
relief may pose a problem. If such a problem potentially exists, it may be
necessary to measure the vertical component of the wind at the proposed
site, and as close as possible to stack height. The starting threshold for
the vertical wind speed component should be less than 0.25 m/s. Required
accuracy for the vertical wind speed component is as specified in Section
6.1.1 for horizontal speeds.
6.1.3 Wind Fluctuations
Determination of the on-site standard deviation of wind fluctuations,
or derived standard deviations of cross-plume concentrations may be necessary
if dispersion parameters are being developed for use at a specific site. Since
the analytical framework within which such wind fluctuations measurements/
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statistics are to be incorporated is expected to be unique or applied on a
case-by-case basis, approval by the permit granting authority is required
and no general requirements regarding specifications are outlined in this
guideline. Considerable care is required in the selection of wind instru-
ments and data logging systems, especially in the choice of sampling and
averaging times. Thus, response characteristics of wind sensors are
especially critical [56,57]. Owners or operators designing programs incor-
porating these capabilities should submit a statement from a qualified
consultant identifying the adequacy of such wind system(s) within the
context of the overall PSD ambient monitoring program.
6.1.4 Vertical Temperature Difference
Errors in measured temperature difference should not exceed 0.003
°C/m.
6.1.5 Temperature
Errors in temperatures should not exceed 0.5°C if fog formation,
icing, etc., due to water spray or water vapor emitted from the facility
may be a problem. Otherwise, errors should not exceed 1.0°C.
6.1.6 Humidity
Atmospheric humidity can be measured and expressed in several ways.
If the permit granting authority determines that a significant potential
exists for fog formation, icing, etc., due to effluents from the proposed
facility, error in the selected measurement technique should not exceed an
equivalent dewpoint temperature error of 0.5°C. Otherwise, errors in
equivalent dewpoint temperature should not exceed 1.5°C over a dewpoint
range of -30°C to +30°C.
6.1.7 Radiation - Solar and Terrestrial
The determination of Pasquill stability class may be based on whether
the solar radiation is termed strong, moderate, or slight. Stability class
can be determined from sun elevation and the presence, height, and amount
of clouds [46], or by using a pyranometer and/or net radiometer during the
daytime and a net radiometer at night. Such radiation-to-stability relation-
ships are expected to be site-specific, and the responsibility for demon-
strating their accuracy lies with the permit applicant. General accuracy
for pyranometers and net radiometers used in a PSD monitoring network is
expected to be +5 percent.
6.1.8 Mixing Height
Mixing height data may be derived from NWS upper air data. If
available data are determined to be inappropriate by the permit granting
authority, such data may be obtained on-site by the permit applicant [58]
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The instrument system to be used is not specified in this guideline, but
its precision and resolution should not exceed the limits associated with
NWS radiosonde systems [54,55].
6.1.9 Precipitation
A recording precipitation collector should have a resolution of 0.25
mm (0.01 inches) liquid precipitation per hour at precipitation rates up to
7.6 cm/hour. Accuracy should be within 10 percent of the recorded value. A
heated system should be used to assure proper measurement of frozen precipi-
tation. A suitable windscreen should be used.
6.1.10 Visibility
Visibility can be measured within 5 percent of true over visual
ranges of about 80 meters to 3 km with available transmissometers. Estimates
can be based upon very short path lengths using other types of equipment
such as nephelometers [59]. At this time, the combined use of a multi-
wavelength telephotometer, integrating nephelometer and particulate monitor,
together with color photography, should prove most helpful in documenting
baseline visibility related parameters. These as well as other components
of a visibility monitoring program, are discussed in reference 51. Reference
50 also contains much background information.
54
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7. QUALITY ASSURANCE FOR METEOROLOGICAL DATA
All equipment should receive an appropriate examination and calibration
prior to initial installation to assure the acquisition of the maximum
amount of usable data within the error limits specified herein. Inspection,
servicing, and calibration of equipment must be scheduled throughout the
measurement program at appropriate intervals to assure at least 90 percent
data retrieval for each variable measured at sites where continuous air
quality monitors are being operated. At remote sites, data retrieval for
measured variables should not fall below 80 percent. In addition, the
joint frequency for the recovery of wind and stability data should not fall
below 90 percent on an annual basis; missing data periods must not show
marked correlation with the various meteorological cycles.
Calibration of systems should be accomplished no less frequently than
once every 6 months. In corrosive or dusty areas, the interval should be
reduced to assure adequate and valid data acquisition.
If satisfactory calibration of a measuring system can be provided only
by the manufacturer or in special laboratories, such as wind-tunnel facilities,
arrangements should be made for such calibrations prior to acquisition of
the equipment. A parts inventory should be maintained at a readily accessible
location to minimize delays in restoring operations after system failures.
An independent meteorological audit (by other than one who conducts
the routine calibration and operation of the network) should be performed
to provide an on-site calibration of instruments as well as an evaluation
of (a) the network installation, (b) inspection, maintenance, and calibra-
tion procedures, and logging thereof, (c) data reduction procedures, including
spot checking of data, and (d) data logging and tabulation procedures. The
on-site visit (requiring as little as 1 day in many cases) should be made
within 60 days after the network is first in full operation, and a written
audit/evaluation should be provided to the owner. This report should be
retained by the owner. Any problems should be corrected and duly noted as
to action taken in an addendum to the audit report. A reproducible copy of
the audit report and the addendum should be furnished with the source
construction permit application.
Such independent meteorological audit-evaluations should be performed
about each 6 months. The last such inspection should be made no more than
30 days prior to the termination of the measurement program, and while the
measurement operation is in progress.
The 1983 publication "Quality Assurance Handbook for Air Pollution
Measurement Systems: Volume IV. Meteorological Measurements" [60] should
be consulted for more information. Major sections in this volume address
(1) quality assurance of the measurement process, (2) methods for judging
the suitability of sensor siting, and (3) meteorological data validation.
55
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8. DATA REPORTING
8.1 Air Quality Data Reporting
A summary of the air quality data, the raw air quality data, and the
quality assurance data discussed in Section 4.1.6 must be submitted to
the permit granting authority at the time of submittal of the PSD application.
There should be a prior agreement between the source and the permit granting
authority as to whether the raw data should be submitted in addition to a
summary of the data. Some sources may also desire to submit data periodically
to the permit granting authority for review to identify any problems in the
data as they occur. Note that this is not a requirement. The applicant
and the permit granting authority should have a prior agreement as to the
format and procedure for the data submission. The air quality data should
preferably be submitted in SAROAD format and in a machine readable form. A
printout of the contents of the tape or cards should also be included. All
raw data not previously submitted (i.e., calibration data, flow rates,
etc.) should be retained for 3 years and submitted upon request to the
permit granting authority.
For continuous analyzers, at least 80 percent of the individual hourly
values should be reported by the source in any sampling period. For manual
methods (TSP and particulate pollutants), 80 percent of the individual
24-hour values should be reported in any sampling period. This capture
rate is important because of the short duration of a PSD monitoring program.
In addition, there should not be a correlation between missing data periods
and expected highest concentrations.
8.2 Meteorological Data Format and Reporting
Because of the different data requirements for different types of
analyses that might be used to evaluate various facilities, there is no
fixed format that applies to all data sets. However, a generalization can
be made: all meteorological parameters must be collated in chronological
order and tabulated according the observation time, and be furnished to the
permit granting authority upon request. All meteorological variables that
have a SAROAD parameter code should be submitted in SAROAD format. All
units should be in the SI system (International System of Units) [61]. All
input data (in the format required by the analytical procedures selected)
used in, and all results of, the air quality analyses must be furnished to
the permit granting authority upon request.
56
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APPENDIX A
PROCEDURES TO DETERMINE IF MONITORING DATA WILL
BE REQUIRED FOR A PSD APPLICATION
-------
1. INTRODUCTION
This appendix has been included in this guideline to aid both the
reviewing authorities and the source applicants in determining if monitoring
data will or will not be required under PSD. The major considerations
leading to a monitoring data decision have been simplified for presentation
in this appendix. This discussion represents the Federal requirements and
the minimum State program requirements. It is important to identify the
reviewing authority, whether it be the local or State air pollution control
agency, or the Regional Office of EPA for the final requirements. For a
complete discussion on the complex PSD issues, the reader is referred to
the PSD regulations and the preamble discussion [5,6].
2. PSD PERMIT APPLICATION PROCEDURES
Figure A-l shows a simplified organizational overview of the proce-
dures to be followed in the preparation of a PSD permit application.
Figure A-l shows that these procedures are divided into seven parts. This
division is only for illustrative purposes within this appendix and is
intended only to separate the complex procedures into distinct subparts.
Within the Part 1-Source Applicability Determination, both candidate new
and modified major sources are reviewed to see if PSD review will apply.
The Part 2-Pollutant Applicability Determination shows those pollutants
emitted from subject sources that may or may not be exempted from further
analysis. The Part 3-BACT Analysis is to ensure the application of best
available control technology (BACT) on subject pollutants. Air quality
analysis covered in Part 4 includes both modeling and monitoring data
considerations for certain BACT pollutants. The Part 5-Source Impact
Analysis is to demonstrate that the proposed emissions would not cause or
contribute to a violation of any NAAQS or PSD increment. The Part 6-
Additional Impact Analysis is to ensure that the proposed emissions increases
would not impair visibility, or impact on soils and vegetation. Finally,
Part 7 represents the complete PSD application which transfers to the
permit granting authority the results of all the analysis from the first
six parts. Normally, the source applicant will supply all the information
including the BACT and air quality analyses to make the necessary determi-
nations. Each of these seven parts is discussed below in Sections 2.1-2.7.
Section 3 contains flow diagrams and discussion of the first four parts
that pertain to the decision whether monitoring data will or will not be
requi red.
2.1 Part 1 - Source Applicability Determination
The first step in the PSD program is to determine if a proposed new
or modified source is subject to the PSD regulations. The first test for
PSD applicability is that the proposed construction must involve a major
stationary source. Thus, the candidate construction must either be a
proposed new major stationary source or involve the modification of an
existing major stationary source. The criteria in determining whether
A-l
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Part 1 - Source Applicability Determination
\
Part 2 - Pollutant Applicability Determination
I
Part 3 - BACT Analysis
Part 4 - Ambient Air Quality Analysis
Part 5 - Source Impact Analysis
Part 6 - Additional Impact Analysis
Part 7 - Complete PSD Application
Figure A-1. Simplified procedures for the preparation of a PSO permit application.
A-2
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the affected source is sufficiently large (in terms of emissions) to be a
new major stationary source or major modification is based on consideration
of its potential to emit at rates exceeding certain threshold values.
Potential to emit is the capability at maximum design capacity to emit a
pollutant after the application of all required air pollution control
equipment, taking into account all federally enforceable requirements
restricting the type or amount of source operation. A major modification
is generally a physical change in or a change in the method of operation of
a major stationary source which would result in a significant net emissions
increase for any regulated pollutant. (There are several changes that are
exempted from being considered a major modification.) Also, the proposed
source or modification must locate in a PSD areaan area designated as
"attainment" or "unclassifiable." If the proposed source or modification
would meet certain tests and commence construction in a continuous fashion
at the proposed site within a reasonable time, a PSD permit under the
August 7, 1980 regulations would not be necessary. Lastly, there are
specific new sources and modifications that are exempted from PSD review.
All of the above considerations are explained in more detail in Section 3
of this appendix.
If it is determined that a new source or modification is subject to
the PSD regulations, then one must proceed to the Part 2-Pollutant
Applicability Determination in order to learn how the pollutant-specific
requirements of PSD may apply.
2.2 Part 2 - Pollutant Applicability Determination
If a source applicant has determined that a proposed new source or
modification would be subject to the PSD requirements, then the applicant
must assess whether the pollutants the project would emit are subject to
PSD. If a new major stationary source emits pollutants for which the area
it locates in is designated nonattainment, then the source is exempt from
PSD review for those pollutants. These sources must, however, meet the
applicable requirements of new source review (NSR) for each nonattainment
pollutant. If a major construction proposed for a PSD area involves only
changes for nonattainment pollutants, then the source is not subject to
PSD. These sources must meet the appropriate nonattainment NSR under the
SIP for the pollutant. Once the question of NSR jurisdiction is resolved,
then the PSD review applies to significant emissions increases of regulated
ai r pollutants.
Specific numerical cutoffs which define what emissions increases are
"significant" are shown in Table A-l. These emissions rates will be used
for pollutants to be emitted from a PSD source unless the new source or
modification is to be located within 10 km of a Class I area [1], For these
situations, the proposed source or modification must be prepared to demonstrate
that it would not have a significant impact with respect to a Class I area.
A Class I significant impact is defined as one microgram per cubic meter
(ug/m3 or more for a 24-hour average. Further details on how the significant
emission rates in Table A-l were derived may be found in the preamble
discussion of the PSD regulations [5].
A-3
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TABLE A-l. SIGNIFICANT EMISSIONS RATES
f < s - - -' ; '
Pollutant Emissions Rate (tons/year)
Carbon monoxide 100
Nitrogen oxides 40
Sulfur dioxide 40
Particulate Matter 25 (TSP)
Particulate Matter 15 (PMio)
Ozone (volatile organic compounds) 40
Lead 0.6
Asbestos 0.007
Beryllium 0.0004
Mercury 0.1
Vinyl chloride 1.0
Fluorides 3
Sulfuric acid mist 7
Total reduced sulfur (including H2S) 10
Reduced sulfur (including t^S) 10
Hydrogen sulfide 10
A-4
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If the emissions from a new source will be significant, or if the net
emissions increase from a proposed modification will be significant, then
one must proceed to the Part 3-BACT Analysis for these pollutants.
2.3 Part 3 - BACT Analysis
Any major stationary source or major modification subject to PSD must
conduct an analysis to ensure application of best available control technology
(BACT) for all applicable pollutants. During each analysis, which will be
done on a case-by-case basis, the reviewing authority will evaluate the
energy, environmental, economic, and other costs associated with each
alternative technology. The reviewing authority will then specify an
emissions limitation for the source that reflects the maximum degree of
reduction achievable with all these concerns in mind for each pollutant
regulated under the Act. In no event can an emission limitation be required
which would be less stringent than any applicable standard of performance
under 40 CFR Parts 60 and 61.
After the BACT determination, the source must then investigate the
need for each pollutant subject to BACT (BACT pollutant) to also undergo
the remaining analyses for this pollutant.
2.4 Part 4 - Ambient Air Quality Analysis
Each application by a PSD source or modification must contain an air
quality analysis for each BACT pollutant to demonstrate that its new pollutant
emissions would not violate either the applicable NAAQS or the applicable
PSD increment. This analysis ensures that the existing air quality is
better than that required by national standards and that baseline air
quality is not degraded beyond the applicable PSD increment. Two narrow
exemptions to this requirement are specified in the regulations and involve
certain existing sources with low BACT emissions and sources of temporary
emissions meeting certain criteria.
In making the above determinations, many PSD sources must first assess
the existing air quality for each applicable air pollutant that it emits in
the affected area. The requirement to monitor existing air quality may not
apply to (a) pollutants for which the new emissions proposed by the applicant
would cause impacts less than the significant monitoring concentrations
(Table A-2), or (b), situations where the background concentration of the
pollutant is below the significant monitoring values. This exemption
should not be used when there is an apparent threat to an applicable PSD
increment or NAAQS based on modeling alone or when there is a question of
adverse impact on a Class I area. When monitoring data are required, the
applicant must provide ambient montioring data that represent air quality
levels in the year's period preceding the PSD application. Where existing
data are not judged representative or adequate, then the applicant must
conduct its own monitoring program. Typically, monitoring data are used
by applicants to support or extend the assessment made with air quality
dispersion modeling.
A-5
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TABLE A-2. SIGNIFICANT MONITORING CONCENTRATIONS
Pollutant
Air Quality Concentration (ug/m3)
and Averaging Time
Carbon monoxide
Nitrogen dioxide
Sulfur dioxide
Particulate Matter
Particulate Matter
Ozone
Lead
Asbestos
Beryl lium
Mercury
Vinyl chloride
Fluorides
Sulfuric acid mist
Total reduced sulfur (including H2S)
Reduced sulfur (including
Hydrogen sulfide
575 (8-hour)
14 (Annual)
13 (24-hour)
10 (24-hour) for TSP
10 (24-hour) for
a
0.1 (3-month)
b
0.001 (24-hour)
0.25 (24-hour)
15 (24-hour)
0.25 (24-hour)
b
c
c
0.2 (1-hour)
dNo specific air quality concentration for ozone is prescribed. Exemptions
are granted when a source's VOC emissions are 100 tons/year.
bNo acceptable monitoring techniques available at this time. Therefore,
monitoring is not required until acceptable techniques are available.
GNo acceptable monitoring techniques available at this time. However,
techniques are expected to be available shortly.
A-6
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In addition to the above discussion, EPA in general intends to limit
the application of air quality models to a downwind distance of 50 kilometers.
This is because dispersion parameters commonly in use are based on experiments
relatively close to sources, and extending these parameters to long downwind
distances results in great uncertainty as to accuracy of the model estimates
at such distances. EPA does not intend to analyze the impact of a source
beyond the point where the concentrations from the source fall below certain
levels (generally based on Class I increments) shown in Table A-3. However,
since the 1977 Clean Air Act Amendments provide special concern for Class I
areas, any reasonably expected impacts for these areas must be considered
irrespective of the 50 km limitation on the above significant values.*
2.5 Part 5 - Source Impact Analysis
The proposed source or modification must demonstrate that significant
net emissions increases (including secondary emissions and fugitive emissions),
would not cause or contribute to air pollution in the violation of any
NAAQS or any applicable maximum allowable increase over the baseline
concentration in any area.
2.6 Part 6 - Additional Impact Analysis
An applicant is also required to analyze whether its proposed emissions
increases would impair visibility, or impact on soils or vegetation. Not
only must the applicant look at the direct effect of source emissions on
these resources, but it also must consider the impacts from general commercial,
residential, industrial and other growth associated with the proposed
source or modification.
2.7 Part 7 - File Complete PSD Application
After completion of the proceeding analyses, the source may submit a
PSD application to the permit granting authority. The application, after
being judged complete and being reviewed for proper determination of appli-
cability, BACT, and air quality impacts, must undergo adequate
*It should be noted that there are three separate and distinct sets of
values which are considered "significant" within the PSD program:
(a) Significant emissions rates;
(b) Significant monitoring concentrations; and
(c) Significant ambient impacts (including the specific significant
Class I area impacts).
As pointed out, each set of values has a different application, and
therefore, this guideline has been worded to clarify the appropriate
values to be used while assessing the need to collect monitoring data.
A-7
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TABLE A-3. SIGNIFICANT AMBIENT AIR QUALITY IMPACTS
_ Averaging Time
Pollutant Annual _ 24-Hour _ 8-Hour _ 3-Hour _ 1 Hour
S02 1 ug/m3 5 ug/m3 -- 25 ug/m3
PM10 1 ug/m3 5 ug/m3
N02 1 ug/m3
CO « 0.5 mg/m3 2 mg/m
NOTE: This table does not apply to Class I areas. A significant impact
for Class I areas is 1 ug/m3 on a 24-hour basis for PMin and SOo.
A-8
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public participation. The regulations solicit and encourage participation
by the general public, industry, and other affected persons impacted by the
proposed major stationary source or major modification. Specific public
notice requirements, including a public comment period and the opportunity
for a public hearing must be met before the PSD review agency takes final
action on a PSD application. The public notice must indicate whether the
reviewing authority has proposed approval, denial, or conditional approval
of the proposed major source or major modification. Consideration is given
to all comments received provided they are relevant to the scope of the
review.
The source shall also submit all information necessary to perform any
analysis in Parts 1-6 above or make any determinations required in Parts
1-6. Such information shall include (a) a description of the nature,
location, design capacity, and typical operating schedule of the proposed
source or modification, including specifications and drawings showing its
design and plant layout, (b) a detailed schedule for construction of the
proposed source or modification, and (c) a detailed description as to what
system of continuous emission reduction is planned for the proposed source or
modification, emission estimates, and any other information necessary to
determine that best available control technology would be applied. The
proposed source or modification shall also provide information on (a) the
air quality impact of the proposed source or modification, including meteoro-
logical and topographical data necessary to estimate such impact, and (b)
the air quality impacts, and the nature and extent of any or all general
commercial, residential, industrial, and other growth which has occurred
since August 7, 1977 in any area the proposed source or modification would
affect.
A-9
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3. DECISIONS FOR MONITORING DATA REQUIREMENTS
Figure A-1 and the discussion that followed in Section 2 provided an
overview of the various activities relating to a PSD permit application.
This section will go into more detail on those activities that need to be
considered in deciding if air quality monitoring data will be required.
It should be noted that the procedures described in this appendix do
not include any details on how the modeling analyses are to be conducted
but only indicate at what points (boxes) the results of such analyses are
necessary. Also, while these procedures lead to a determination of when
air quality monitoring is likely to be required, they do not lead to a
decision as to when meteorological monitoring is necessary (for model
input). Guidance on the requirements and procedures for conducting modeling
analyses is contained in reference 14. Section 5 of this guideline describes
general meteorological monitoring requirements, and reference 62 also
provides further guidance on this subject.
Figures A-2 and A-3 show various steps that must be made for a proposed
PSD source or modification in order to assess how the monitoring data
requirement might apply. The decisions in these flow diagrams must be
applied separately for each regulated pollutant that would be emitted from
a proposed source or modification. Boxes 1-14 apply to Figure A-2 and
boxes 15-29 apply to Figure A-3
Box 1. Is proposed source a major stationary source or major modification
locating in a PSD area?
A major stationary source is defined as any one of 28 source categories
(Table A-4) which emits, or has the potential to emit, 100 tons per year or
more of any pollutant regulated under the Act. In addition, the definition
includes any other stationary source which emits, or has the potential to
emit, 250 tons per year or more of any regulated pollutant. Finally, major
stationary source also means any physical change occurring at a stationary
source (which prior to the change is not major) if the change by itself
would be major. That is, the change itself would result in an equivalent
stationary source which would emit 100 tons per year or more for any pollutant
regulated under the Act for any one of the 28 source categories (Table
A-4), or 250 tons per year for any other stationary source. The pollutants
regulated under the Act were shown in Part 2-Pollutant Applicability
Determination.
A stationary source generally includes all pollutant-emitting activities
which belong to the same industrial grouping, are located on contiguous or
adjacent properties, and are under common control. Pollutant activities
which belong to the same major group as defined in a standard industrial
classification scheme developed by the Office of Management and Budget are
considered part of the same industrial grouping.
The rest of the PSD size applicability for proposed new stationary
sources is simply that the candidate source would be a major stationary
A-10
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1. Is proposed source \
a major stationary source or \ J^Q
4 major modification locating / ^
in a PSD area? / /2.
No PSD
permit needed/
Part 1 -
Source Applicability
Determination
YES
No further PSD
analysts for
that pollutant
NO
3. Is construction proposed
for an area which is designated'
nonattainment area for the /
regulated pollutant? * / 13.
J
Is proposed source
or modification within
10 km of a Class I area?/
YES
Class I area
screening procedure
7. More refined model
(optional). Note: Mav
require gathering of
meteorological data.
10. No further analysis
for that pollutant
Are new emissions or net
emissions increase of the
regulated pollutant > Table
/8. Will the proposed source^
I/ or modification impact
\ on a Class I area?
YES
Part 2 -
Pollutant Applicability
Determination
YES
11. Is proposed construction a
relocation ot a portable
facility with previous permit? l
NO
Are there potential impacts
on a Class I area, or areas
of known increment violation?
, YES
14. Apply BACT
Part 3 -
BACT Analysis
' Procedures are to be repeated for
all regulated pollutants which would
be emitted by the proposed construction.
c
(
Part 4
- Ambient Air Quality Analysis
Part 5
Part 6
- Source Impact Analysis
- Additional Impact Analysis
Part 7
Complete PSD Application
Figure A-2. Procedures used to determine the monitoring data requirement.
A-ll
-------
Part 1 - Source Applicability Determination
Part 2 - Pollutant AppKcabltty Determination
I
Part 3 - BACT Analysis
NO,
YES,
'16. wa the proposed X,
15. Are the allowable emissions or the
net emissions increase temporary,
impacting no Class I area, or impacting
no area where the PSD increment
is violated?
. YES
Are VOC N
emiuiom
< Table A-2? ,
source or modification /
emil VOQ /
. NO
18. Is there an apparent threat\
NO/ to the NAAQS, or is there
a potential advene impact
on a Class I area?
YES
I 19. WM proposed source or
modification perform post-
approval monitoring in feu
of preconstruction monitoring
data?
20. Estimate existing air quality.
Note: May require gathering
of meteorological data.
21. Estimate air quality impacts of
proposed construction.
Use screening procedure
or more refined model
Use "good engineering practice*
Consider 50 ton/ year exemption
22. Is the existing air
quality < Table A-2?
, YES
NO
21 Are the air quatty\_YES_
impacts < Table A-2? /
YES,
25. Are proposed emissionsX NO
a criteria pollulant or VOC?/~~~
34. Is there an apparent threat to \
the PSD increments or NAAQS. \YE5
or is there a potential adverse /
impact on a Class I area? /
NO
26. Is there an approved
monitoring technique
available?
27. Preconstruction monitoring data required.
Use representative air quality data
Monitor (source specific)
28. No preconstruction
monitoring data required
29. Preconstruction monitoring
data may be required
Part 4-
Ambient
Air Quality
Analysis
G
C
Part S - Source impact Analysis
Part 6- Additional Impact Analysis
Part 7- Complete PSD Application
FIGURE A-l PROCEDURES USED TO DETERMINE THE MONITORING DATA REQUIREMENT.
A-l 2
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TABLE A-4. MAJOR STATIONARY SOURCES
1. Fossil-fuel fired steam electric plants of more than 250,000,000
British thermal units per hour heat input
2. Coal cleaning plants (with thermal dryers)
3. Kraft pulp mills
4. Portland cement plants
5. Primary zinc smelters
6. Iron and steel mill plants
7. Primary aluminum ore reduction plants
8. Primary copper smelters
9. Municipal incinerators capable of charging more than 250 tons of
refuse per day
10. Hydrofluoric acid plants
11. Sulfuric acid plants
12. Nitric acid plants
13. Petroleum refineries
14. Lime plants
15. Phosphate rock processing plants
16. Coke oven batteries
17. Sulfur recovery plants
18. Carbon black plants (furnace process)
19. Primary lead smelters
20. Fuel conversion plants
21. Sintering plants
22. Secondary metal production plants
23. Chemical process plants
24. Fossil-fuel boilers (or combinations thereof) totaling of mere than
250,000,000 British thermal units per hour heat imput
25. Petroleum storage and transfer units with a total storage capacity
exceeding 300,000 barrels
26. Taconite ore processing plants
27. Glass fiber processing plants
28. Charcoal production plants
A-13
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source in terms of its potential to emit. The applicability rules for
determining whether a major modification would occur are more complex.
A "major modification" is generally a physical change in or a change
in the method of operation of a major stationary source which would result
in a significant net emissions increase in the emissions of any regulated
pollutant. In determining if a proposed increase would cause a significant
net increase to occur, several detailed calculations must be performed.
First, the source owner must quantify the amount of the proposed emissions
increase. This amount will generally be the potential to emit of the new
or modified unit. Second, the owner must document and quantify all emissions
increases and decreases that have occurred or will occur contemporaneously
(generally within the past five years) and have not been evaluated as part
of a PSD review. The value of each contemporaneous decrease and increase
is generally determined by subtracting the old level of actual emissions
from the new or revised one. Third, the proposed emissions increase and
the unreviewed contemporaneous changes must then be totalled. Finally, if
there is a resultant net emissions increase that is larger than values
specified in Table A-l, the modification is major and subject to PSD review.
Certain changes are exempted from the definition of major modification.
These include: (a) routine maintenance, repair and replacement; (b) use of
an alternative fuel or raw material by revision of an order under sections
2(a) and (b) of the Energy Supply and Environmental Coordination Action of
1974 (or any superseding legislation); (c) use of an alternative fuel by
reason of an order or rule under section 125 of the Clean Air Act; (d) use
of an alternative fuel at a steam generating unit to the extent it is
generated from municipal solid waste; (e) use of an alternative fuel or raw
material which the source was capable of accommodating; before January 6,
1975 or which the source is approved to use under any permit issued under
40 CFR 52.21, or under regulations approved pursuant to 40 CFR 51.24; and
(f) an increase in the hours of operation, or the production rate. The
last two exemptions, (e) and (f), can be used only if the corresponding
change is not prohibited by certain permit conditions established after
January 6, 1975.
If the size of a proposed source or modification thus qualifies as
major, its prospective location or existing location must also qualify as a
PSD area, in order for PSD review to apply. A PSD area is one formally
designated by the state as "attainment" or "unclassifiable" for any pollutant
for which a national ambient air quality standard exists. This geographic
applicability test generally does not take into account what new pollutant
emissions caused the construction to be major. It looks simply at whether
the source is major for any pollutant and will be located in a PSD area.
The one exception is that if a major stationary source emits only non-
attainment pollutants, then no PSD review would apply.
If a proposed source or modification would be subject to PSD review
based on size, location, and pollutants emitted, it still may escape the
PSD review requirements under certain grandfather provisions under 40 CFR
A-14
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52.21(1). For example, a proposed source or modification that was not
subject to the 1978 PSD rules and had received all necessary Federal, State
and local air permits before August 7, 1980, would not be subject to the
1980 regulations. (See the PSD regulations for other exemptions.)
Finally, the PSD regulations contain some specific exemptions for some
forms of source construction. The requirements of the PSD regulations do
not apply to any major stationary source or major modification that is (a)
a nonprofit health or educational institution (only if such exemption is
requested by the governor), or (b) a portable source which has already
received a PSD permit and proposes relocation, or the source or modification
would be a major stationary source or major modification only if fugutive
emissions, to the extent quantifiable, are considered in calculating the
potential to emit of the stationary source or modification and the source
does not belong to any of the categories listed in Table A-4.
Box 2. No PSD permit needed.
If the source has met the appropriate deadlines for construction; and
is not a major stationary source, a major modification, is not located in a
PSD area, or is not subject to the specific exemptions mentioned above, the
PSD program is not applicable, and therefore, no PSD permit is needed.
Box 3. Is construction proposed for an area which is designated
nonattainment area for the regulated pollutant?
If the project is a major stationary source or a major modification,
the prospective location must also qualify as a PSD area in order for the
PSD review to apply. A PSD area is defined as an area formally designated
by the State as "attainment" or "unclassifiable" for any pollutant for
which a NAAQS exists. An area not classified as either "attainment" or
"unclassifiable" would be classified as "nonattainment". If the proposed
construction is in a nonattainment area for any pollutant, proceed to box 4
for that pollutant; for all other regulated pollutants, proceed to box 5.
Box 4. No further PSD analysis for that pollutant.
If the proposed major stationary source or major modification will
emit pollutants from an area that has been designated as "nonattainment",
then the proposed source or modification is exempt from further PSD review
for only those pollutants. However, the proposed source or modification
must meet the applicable preconstruction requirements for each nonattainment
pollutant. (See 40 CFR 51.18 and 40 CFR 52.24.)
The pollutant applicability determination would be continued for all
other regulated pollutants (except nonattainment pollutants) emitted by a
proposed major stationary source or major modification by proceeding to box 5,
A-15
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Box 5. Is proposed source or modification within 10 km of a Class I
area?
The PSD regulations [40 CFR 51.24(b)(23)(iii) and 40 CFR 52.21(b)(23)
(iii)] require that a proposed source or modification, which plans to
construct within 10 km of a Class I area must demonstrate that if it would
not impact the area, (less than 1 ug/m3) even if the proposed emissions are
below the applicable significant emissions rates listed in Table A-l. If
the proposed source or modification is within 10 km of a Class I area,
proceed to box 6; if not, proceed to box 9.
Box 6. Class I area screening procedure.
If the proposed source or modification is within 10 km of a Class I
area, then the screening procedures described in reference 62 may be used
to estimate the impact on the Class I area. This screening procedure is
based on a simple but conservative model for estimating each concentration
due to the emissions from the proposed source or modification.
Box 7. More refined model (optional).
A proposed source or modification may choose not to accept or use the
concentration estimates derived from the screening procedures in box 6, and
may elect to use a more refined model which would more adequately reflect
the impact on the Class I area from the proposed source or modification.
It should be emphasized that in order to perform a refined modeling analysis,
it may be necessary to collect 1 year of on-site meteorological data for
the model input if an adequate amount of representative data are not already
available. The application of any model used in this analysis must be con-
sistent with reference 14 as discussed in section 5.1. The application of
any different model must be approved by EPA in order to avoid any delays in
the processing of the permit application. Applicants should consult with
the reviewing authority before investing considerable resources in the use of
the different models. Therefore, the documentation and specific description
of the model should be provided to the reviewing authority before the
results are submitted.
The concentration estimates from the screening procedure or the refined
model, are subsequently used in the Part 4-Ambient Air Quality Analysis and
Part 5-Source Impact Analysis.
Box 8. Will the proposed source or modification impact on a Class I
area?
If a proposed source or modification is within 10 km of a Class I
area, the proposed source or modification must be prepared to demonstrate
for each regulated pollutant it would emit that there would be no signifi-
cant impact on the Class I area. Significant impact is defined in the PSD
regulations [40 CFR 51.24(b)(23)(iii) and 40 CFR b2.21(b)(23)(111)] as 1
microgram per cubic meter (ug/m3) or more, 24-hour average.
A-16
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Box 9. Are new emissions or net emissions increase of the regulated
pollutant >Table A-l?
If the proposed source or modification is not within 10 km of a Class
I area, or if the proposed source is within 10 km of a Class I area and has
no significant impact on the Class I area, then the emissions for each
pollutant from the proposed source of modification are compared to the
significant emissions rates in Table A-l.
Box 10. No further analysis for that pollutant.
If the emissions from the proposed source or modification are not
significant as defined in Table A-l, no further analysis is required for
that pollutant. However, a similar review must be performed for all other
regulated pollutants by proceeding to box 5 for the next pollutant.
Box 11. Is proposed construction a relocation of a portable facility
with previous permit?
This question is actually an applicability question that is normally
considered under the Part 1-Source Applicability Determination. However,
there are certain other questions (see boxes 3, 5 and 8 of Figure A-2)
which are normally asked under pollutant applicability that are also germane
to permitting a portable facility relocation. Thus, the reason for including
box 11 in Part 2.
The source must be a portable facility which has previously received a
permit under the PSD regulations, the owner proposes to relocate the facility,
and emissions at the new location would be temporary (not exceeding its
allowable emissions). If the facility meets these requirements, then
proceed to box 12; if not, proceed to box 14.
Box 12. Are there potential impacts on a Class I area, or areas of known
increment violation?
The emissions from the portable source should not exceed its allowable
emissions, and the emissions from the temporary source should impact no
Class I area and no area where an applicable increment is known to be
violated. If there are potentially adverse impacts on a Class I area, or
significant impacts on areas of known increment violation, proceed to box
14; if not, proceed to box 13.
Box 13. No PSD permit required.
If there are no potential impacts on a Class I area, or areas of known
increment violation, no PSD permit is required.
Box 14. Apply BACT.
"Best available control technology" means an emissions limitation
(including a visible emission standard) based on the maximum degree of
A-17
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reduction for each pollutant subject to regulation under the Act which
would be emitted from any proposed major stationary source or major
modification which the Administrator, on a case-by-case basis, taking into
account energy, environmental, and economic impacts and other costs,
determines is achievable for such source or modification through application
of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques
for control of such pollutant. In no event shall application of best
available control technology result in emissions of any pollutant which
would exceed the emissions allowed by any applicable standard under 40 CFR
Parts 60 and 61. If the Administrator determines that technological or
on the application of measurement methodology to a
unit would make the imposition of an emissions standard
equipment, work practice, operational standard, or
may be prescribed instead to satisfy the requirement
of best available control technology. Such standard
economic limitations
particular emissions
infeasible, a design,
combination thereof,
for the application
shall, to the degree possible, set forth the emissions reduction achievable
by implementation of such design, equipment, work practice or operation,
and shall provide for compliance by means which achieve equivalent results.
Box 15. Are the allowable emissions or the net emissions increase
temporary, impacting no Class I area, or impacting no area
where the PSD increment is violated?
Temporary emissions are defined as emissions from a temporary source
that would be less than 2 years in duration, unless the Administrator
determines that a longer time period would be appropriate. If all of the
conditions above are not met, proceed to box 16; if they are met, proceed
to Part 7-Complete PSD Application.
Box 16. Will the proposed source or modification emit VOC?
If the proposed source or modification will emit VOC, proceed to box
17; if not, proceed to box 20. Also proceed to box 20 if the pollutants
are TSP, PMio, S02, CO, N02, or Pb.
Box 17. Are VOC emissions < Table A-2?
If the VOC emissions rates from the proposed source or modification
are less than the value in Table A-2 (100 tons/year), proceed to box 18;
if not, proceed to box 19.
Box 18. Is there an apparent threat to the NAAQS, or is there a potential
adverse impact on a Class I area?
If the projected air quality after construction is equal to or greater
than 90 percent of the NAAQS, a threat to the NAAQS would generally exist.
Potential adverse impacts on a Class I area must be determined on a case-by-
case basis by the permit granting authority. Therefore, if there is an
apparent threat to the NAAQS, or if there are potential adverse irrpacts on
a Class I area, then proceed to box 19; if not, proceed to box 20.
A-18
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Box 19. Will proposed source modification perform postapproval monitoring
in lieu of preconstruction monitoring data?
The PSD regulations [40 CFR 51,24(m)(l)(v) and 40 CFR 52.21(m)(l)
(vi)] give special considerations regarding ozone monitoring data to new or
modified sources of volatile organic compounds which have satisfied all
conditions of 40 CFR 51, Appendix S, section IV. This section generally
requires affected sources to meet lowest achievable emission rate limitations,
secure emissions offsets which provide an overall net air quality improvement,
and ensure all other major sources in the same State are in compliance with
the applicable SIP. If a proposed source or modification has met all of
the above conditions for VOC, then the proposed source or modification may
provide postapproval monitoring data for ozone in lieu of providing precon-
struction data. Postapproval monitoring data are data collected after the
date of approval of the PSD application. However, in no case should the
postapproval monitoring be started later than 2 years after the start-up of
the new source or modification.
If the proposed source or modification will provide postapproval
monitoring, proceed to the Part 5-Source Impact Analysis; if not, proceed
to box 20 for the remainder of the ambient air quality analysis.
Box 20. Estimate existing air quality.
The proposed source or modification must perform an initial analysis
to estimate the existing air quality concentrations. The screening pro-
cedures described in reference 62 may be used. The screening procedures
are based on simple models for estimating air quality due to the emissions
from existing and approved but not yet built sources. A proposed source or
modification may choose not to accept or use the concentration estimates
derived from the screening procedure above, and may elect to use a more
refined model which would more adequately reflect the impact from existing
sources. It should be emphasized that in order to perform a refined modeling
analysis, it is generally necessary to collect 1 year of on-site meteorological
data for the model input. The application of any model used in this analysis
must be consistent with reference 14 as discussed in section 5.1. The
application of any model should be approved by the permit granting authority
to avoid any future delays in the processing of the permit application.
Therefore, the documentation of the specific description of the model
should be provided to the permit granting authority before the results are
submitted.
The concentration estimates from the screening procedure or the optional
refined model will be used in the remaining portions of the ambient air
quality analysis.
A-19
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Box 21. Estimate air quality impacts of proposed construction.
The proposed source or modification must estimate its air quality
impacts to demonstrate that its new pollutant emissions would not violate
either the applicable NAAQS or the applicable PSD increment. The proposed
source or modification must use the screening procedures or more refined
model, consider "good engineering practice" for stack height, and consider
the TSP and S02 increment exclusion for Class II areas under 50 tons per
year exemption. These factors are discussed in more detail below.
(a) Screening procedure or more refined model.
If the proposed source or modification used the screening procedure
or more refined model in box 6 or 7 previously to estimate the impact, then
those results may be used in this impact analysis. If the screening procedure
or more refined model was not previously determined, then the screening
procedures described in reference 62 may be used. This screening procedure
is based on a simple model for estimating each concentration due to the
emissions from the proposed source or modification. A proposed source or
modification may choose not to accept or use the concentration estimates
derived from the screening procedure above, and may elect to use a more
refined model which would more adequately reflect the impact from the
proposed source or modification. It should be emphasized that in order to
perform a refined modeling analysis, it is generally necessary to collect 1
year of on-site meteorological data for the model input. The application
of any model used in this analysis must be consistent with reference 14 as
discussed in Section 5.1. The application of any model should be approved
by the permit granting authority to avoid any future delays in the processing
of the permit application. Therefore, the documentation and specific
description of the model should be provided to the permit granting authority
before the results are submitted.
The concentration estimates from the screening procedure or the
optional refined model will be used in the remaining portions of the ambient
air quality analysis.
(b) "Good engineering practice" (GEP) for stack height.
The 1978 PSD regulations [1] provide for requiring GEP in the
impact analysis for stack heights. The degree of emission limitations
required for the control of any air pollutant would not be affected by
stack heights (in existence after December 31, 1970) as exceeds good
engineering practice, or any other dispersion techniques implemented after
then.
(c) Consider 50 tons per year exemption.
The PSD regulations [40 CFR 51.24(1)(7) and 40 CFR 52.21(i)(7)]
as they apply to a major modification exempt PMio and S02 from the Class II
increment consumption review if all of the following conditions are met:
A-20
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(1) the net increase of all pollutants regulated under the Act after appli-
cation of BACT would be less than 50 tons/year, (2) no pollutant would be
causing or contributing to a violation of the standards (NAAQS), and (3)
source must have been in existence on March 1, 1978. The results of the
impact analysis as described in this box will be used for subsequent portions
of the ambient air quality analysis.
Box 22. Is the existing air quality < Table A-2?
The proposed source or modification must determine the existing air
quality concentration in the area of impact of the proposed source or
modification before construction for each applicable pollutant. Modeling
by itself or in conjunction with monitoring data would be used for this
determination. Application of these models must be consistent with
reference 14.
If the proposed source or modification is remote and not affected by
other readily identified man-made sources, two options for determining
existing air quality concentrations from existing data are available. The
first option is to use air quality data collected in the vicinity of the
proposed source or modification, the second option is to use average measured
concentrations from a "regional" site to establish a background concentration.
Additional guidance on determining the background air quality concentrations
may be found in reference 14. See also the discussion or use of representative
air quality data in Section 2.4 of this guideline.
If the existing air quality is less than the values in Table A-2,
proceed to box 24; if not, proceed to box 23.
Box 23. Are the air quality impacts < Table A-2?
The projected impact of the proposed source or modification was
previously determined by the screening procedure or refined model estimates.
These modeled concentrations are compared to the significant monitoring
concentrations shown in Table A-2. If these modeled concentrations are
less than the values in Table A-2, proceed to box 24; if not, proceed to
box 25.
Box 24. Is there an apparent threat to PSD increments or NAAQS, or is
there a potential adverse impact on a Class I area?
An apparent threat to a PSD increment is consumption by the proposed
source or modification of 90 percent or more of the remaining allowable
increment. An apparent threat to the NAAQS is when the projected air
quality after construction is equal to or greater than 90 percent of the
NAAQS. Potential adverse impacts on a Class I area must be determined on a
case-by-case basis by the permit granting authority.
Therefore, if there is an apparent threat to PSD increments or NAAQS,
or if there is a potential adverse impact on a Class I area, proceed to box
29; if not, proceed to box 28.
A-21
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Box 25. Are proposed emissions a criteria pollutant or VOC?
Determine if the pollutant is a criteria pollutant (TSP, PMiQ, S02, CO,
N02 or Pb) or VOC. If the pollutant is a criteria pollutant or VOC, proceed
to box 27; if not, proceed to box 26.
Box 26. Is there an approved monitoring technique available?
Acceptable measurement methods currently exist for some noncriteria
pollutants, while other methods are currently under review and have not
been designated as an acceptable measurement method. Section 2.6 of this
guideline discussed the designation of acceptable measurement methods for
noncriteria pollutants. If an acceptable measurement method does exist,
proceed to box 29; if not, proceed to box 28.
Box 27. Preconstruction monitoring data required.
Preconstruction air quality monitoring data are required for this part
of the ambient air quality analysis. The proposed source or modification
has the option of using representative air quality data or monitoring.
Considerations and constraints on the use of existing data were discussed
in Section 2.4 of this guideline. It should be noted that a dispersion
model may be used in verifying the representativeness of the data. If a
proposed source or modification chooses to monitor instead of using repre-
sentative air quality data, then the specifics to be followed on network
design, probe siting, quality assurance, number of monitors, etc., were
previously discussed in this guideline.
The monitoring data required in this box will be used in Parts 5, 6
and 7 of the PSO permit application.
Box 28. No preconstruction monitoring data required.
If there is no approved monitoring technique for the noncriteria
pollutants, or if there is no apparent threat to PSD increments or NAAQS,
or if there is no potentially adverse impact on a Class I area, then generally
no preconstruction monitoring data will be required. However, proceed to
the Part 5-Source Impact Analysis for remaining analyses.
Box 29. Preconstruction monitoring data may be required.
The permit granting authority must determine on a case-by-case basis
if monitoring data will be required when there is an apparent threat to PSD
increments or NAAQS, or when there is a potential adverse impact en a Class
I area. Special attention must be given to Class I areas where the proposed
source or modification would pose a threat to the remaining allowable
increment. For those situations where the air quality concentration before
construction is near the concentrations shown in Table A-2 and there are
uncertainties associated with this air quality determination then precon-
A-22
-------
struction air quality monitoring data may be required. Some situations
where noncriteria monitoring may be required were discussed in Section
2.1.3 of this guideline.
Regardless of the monitoring data decision, proceed on to the Part
5-Source Impact Analysis for remaining analyses.
A-23
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A-24
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*»*
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A-28
U.S. Environmental Projection Aqency
Region 5, L:';>.".ry (p[-i/;)
12ih
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