United States Office of Air Quality EPA-450/2-80-073
Environmental Protection Planning and Standards June 1980
Agency Research Triangle Park NC 27711
Air
Regulatory Impact
Assessment for the
September 5, 1979,
Proposed Regulations
for Prevention of
Significant Deterioration
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EPA-450/2-80-073
Regulatory Impact Assessment for
the September 5, 1979, Proposed
Regulations for Prevention of
Significant Deterioration
by
PEDCo Environmental, Inc.
Durham, North Carolina 27701
Contract No. 68-02-3173
Task No. 1
EPA Project Officer: James Weigold
New Source Review Office
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Control Programs Development Division
Research Triangle Park, North Carolina 27711
June 1980
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U,S. Environmental Protection Agency
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EXECUTIVE SUMMARY
On September 5, 1979, the Environmental Protection Agency
(EPA) proposed to revise the June 1978 Prevention of Significant
Deterioration (PSD) regulations as a result of the June 1979 sum-
mary decision in Alabama Power Company v. Costle (13 ERC 1225) .
The court issued its final decision on December 14, 1979. In its
opinion the court upheld some of the provisions of the June 1978
regulations and overturned others.
The September 5 regulations following the court's mandate
proposed several changes to the June 1978 regulations including
•the definition of potential to emit, fugitive emissions, major
modification, and baseline; the requirements for ambient moni-
toring; and the establishment of preconstruction notice and
t?e M/c.Ki-cm>LA levels.
This report presents an assessment of the overall impact of
the proposed regulations with respect to several of the major is-
sues or changes in them. This assessment does not attempt to
quantify the impact of every issue nor does it attempt to assess
the overall economic impact associated with the implementation
of the PSD regulations in general. It is designed to provide a
relative assessment of the impact of the proposed versus the cur-
rent regulations in terms of the sources to be affected, their
associated emissions, major requirements that must be met or that
are no longer required to be met, and the direct costs associated
with meeting the additional requirements for sources that would
still be subject to PSD.
Since a number of sources would no longer be subject to PSD
review, there will be some cost savings for sources as a result of
the proposed regulations. Additionally, for those sources that
will remain subject to PSD as a result of the proposed regula-
tions, some additional costs would be incurred over and above the
costs to implement the current PSD regulations. Finally, there
will be costs incurred by sources that will be subject to the new
regulations, but would not have been covered under the old.
The analyses conducted in Sections 3, 4, and 5 of this re-
port provide an estimate of the impact of the current versus the
proposed PSD regulations, the major issues associated with the
proposed PSD regulations, and geographic applicability issues
concerning the location of sources within designated nonattain-
ment areas.
i i i
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The results of this analysis indicate that for the 19 month
period covered by the survey of PSD permits there will be an esti-
mated savings of $3.4 to $9.5 million as a result of the proposal
for sources that are subject to the current regulations, but
which would not be subject to the proposed regulations. If the
sources that have received permits from April 1978 to November
1979 are representative of those which will receive permits dur-
ing the same time period in the future (i.e., 19 months), and
there are data to support that they are, then this would repre-
sent an annual savings of $2.2 to $6.1 million.
Although there is an overall savings for certain sources
that are subject to the current PSD regulations, the proposed
regulations would subject some additional sources to PSD review
that are not subject to PSD review at this time. These would be
modified sources with uncontrolled emissions of less than 100 or
250 tons per year, depending upon whether the source is on the
list of 28 source categories, and controlled emissions of greater
than 10 tons per year but less than 100 or 250 tons per year.
Based on the best estimates available, approximately 1200 addi-
tional modifications would be subject to PSD review per year
based on the proposal. Since these sources are not now subject
to PSD review, they would be required to prepare a PSD permit,
conduct the necessary air quality impact assessments, incur some
delays in construction as a result of undergoing PSD review in
addition to State New Source Review (NSR), and install Best Avail-
able Control Technology (BACT) instead of just meeting the emis-
sion limits required by the State Implementation Plan (SIP) or
New Source Performance Standards (NSPS), as applicable.
As a result of the additional cost incurred by the sources
not currently subject to PSD, the overall cost as a result of the
proposed regulations represents an increase of approximately $20
to $36 million per year. Based on the total number of sources
that would be subject to the proposed regulations (1382), this ad-
ditional cost would average approximately $14,500 to $26,000 per
source. If, however, the current proposal is modified to increase
the proposed d
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DATA BASE USED IN THE ASSESSMENT
Since the current PSD regulations have been in effect since
March 1, 1978, and a number of PSD permits have been issued under
these regulations, it seemed reasonable that an assessment of the
impact of the proposed regulations should center on those sources
that have been issued PSD permits. The assessment, however, does
include an estimate of the sources that were currently not sub-
ject to PSD, but which would be subject to PSD as a result of the
September 5 proposed regulations.
Detailed data were collected on 471 of the 604 permits that
had been issued by certain EPA Regional Offices (III-X) from
April 1, 1978, to November 1, 1979. Regions I and II were not in-
cluded in the survey because of the relatively low level of PSD
activity in these regions.
COMPARISON OF CURRENT AND PROPOSED PSD REGULATIONS
The current and proposed regulations were compared in terms
of the following:
1. The numbers and sizes of sources to be affected by
the current and the proposed regulations
2. The change in total emissions likely to result from
the proposed regulations
3. The amount of increment likely to be consumed by
sources that are no longer subject to PSD review
as a result of the proposed regulations
4. The estimated cost savings by sources no longer
subject to PSD review as a result of the proposed
regulations
5. The estimated cost of meeting BACT for sources
that were not previously subject to PSD but which
would be subject as a result of the proposal
6. The estimated costs of modeling and monitoring un-
der the current and the proposed regulations.
Of the 604 PSD permits that were issued in Regional Offices
III through X, approximately 150(35%) of the new sources and 133
(76%) of the modified sources would be subject to review under
the proposed regulation. Sixty-five percent of the new sources
and 24 percent of the modified sources that have been issued per-
mits would no longer be subject to PSD based on the September 5,
1979, proposed PSD regulations. The major reason that these new
and modified sources would no longer be subject to PSD review is
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that the definition of potential emissions was proposed to be
changed from uncontrolled to controlled emissions. Although
several other changes to the regulations had an effect on the
number of sources subject to review (i.e. exclusion of fugitive
emissions for some source categories, excluding the limitations
on the hours of operation, etc.), the major impact was due to
the change in the definition of potential emissions.
Certain cost savings would be realized if new and modified
sources are no longer required to obtain a PSD permit, apply BACT,
and conduct preconstruction monitoring or air quality assessments.
Other sources, however, would be required to meet some additional
PSD requirements that they were not previously required to meet.
In addition, some sources currently not subject to PSD review
would be subject to PSD as a result of the proposal. Therefore,
some additional costs would be incurred as a result of the
September 5, 1979, proposal. These requirements and the associat-
ed costs or impacts are summarized below.
REQUIREMENT TO OBTAIN A PERMIT
A total of 205 permits were reviewed that would not be sub-
ject to PSD review as a result of the proposal and that could be
assigned a review time. The average review time was about 6%
months per application, which includes time to obtain a State per-
mit. Since each source that would not be subject to PSD review
would still be required to obtain a State NSR permit, the actual
time associated with just the PSD review process was determined
to be 5*2 months. Based on information obtained regarding the
costs due to delay in obtaining a PSD permit, the estimated cost
savings associated with sources that would no longer be required
to obtain a PSD permit is $4.4 million per year. In addition,
approximately 1200 additional sources per year would be required
to obtain a PSD permit that were not previously required to ob-
tain one, and this would amount to an additional cost of $6.9
million per year. Therefore, there will be an increased cost of
$2.5 million per year for permitting.
BEST AVAILABLE CONTROL TECHNOLOGY
Of the new or modified sources not subject to the proposed
regulations, approximately 68 percent have controlled emissions
less than 50 tons per year and under the current regulations were
not required to conduct a case-by-case assessment of BACT. These
sources were only required to meet the applicable NSPS or SIP lim-
it. Therefore, they would not gain any cost savings as a result
of the proposed PSD regulations in terms of not being required to
apply BACT.
Of the 96 sources not subject to the proposed regulations
with controlled emissions greater than 50 tons per year, 65
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sources would be subject to an applicable NSPS limit. A review
of the NSPS limits as compared with the BACT limits for these
sources did not indicate any significant difference between these
emissions levels, and therefore these sources would not incur any
savings as a result of not being subject to the BACT requirements.
The remaining 31 sources that did not have an applicable
NSPS limit could relax their controls to the SIP levels since
they would no longer be required to apply BACT. Based on a limit-
ed survey of control cost associated with meeting a BACT versus an
SIP limit, an overall cost savings for the 19 month period covered
by the survey of $3 to $6 million was calculated for sources that
would no longer be required to apply BACT. ($1.9 to $3.7 million/
yr savings.)
Although certain sources would no longer be subject to PSD re-
view, others that were not subject would now be subject and would
be required to apply BACT. Based on the estimates contained in
Section 4.3 and the information on the percentage of sources in
which BACT is significantly different than the SIP limit, the ad-
ditional cost of BACT for sources not currently subject to PSD
would be on the order of $12 to $24 million per yr.
MODELING
Since some sources would no longer be subject to the PSD
regulations, they would not be required to conduct an assessment
of the air quality impact. Based on the number of sources that
would no longer be subject to review and the level of modeling
that would have otherwise been required, there would be a cost
savings for certain sources amounting to a total of $0.9 million
per yr. However, because some additional sources, would be sub-
ject to review that were not previously subject to review and
these sources would be required to conduct some additional model-
ing, the total cost as a result of modeling would actually repre-
sent an increase of $0.9 million per yr.
MONITORING
The cost of preconstruction monitoring under the current
regulations was calculated by using information on the number of
monitors and type of monitoring that was conducted under the cur-
rent regulations obtained from the permit files, and multiplying
by the costs of monitoring. These costs were calculated by using
the latest equipment and network costs currently available. The
cost associated with the current regulations was approximately
$0.3 million per yr. However, only about 5 percent of the sources
surveyed indicated that they had established a preconstruction
monitoring network. The other 95 percent used existing State or
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local agency monitoring data. If the same percentage of sources
use existing monitoring data in the future that used it in the
past, the cost of monitoring as a result of the proposed regula-
tions would be $0.6 million per year or a $0.3 million per year
increase. If, however, all sources that would be subject to the
proposed regulations would establish their own monitoring net-
works in lieu of using existing State or local agency data, the
additional cost would amount to approximately $7.7 million per yr.
Since postconstruction monitoring may now be required for
certain sources, this would amount to an additional cost of ap-
proximately $2.3 million per year if certain sources such as
large power plants and smelters would be required to establish
and operate postconstruction monitoring networks.
FUGITIVE EMISSIONS
Very little, if any, information regarding fugitive emis-
sions was contained in the PSD permit files. Generally, sources
did not provide any special mention of fugitive emissions except
in those cases in which fugitive dust emissions were involved.
Because of this lack of information on fugitive emissions, very
little in the way of a quantitative assessment could be undertaken.
Based on the limited data available in the PSD permits, only one
major source category appears to be affected by the inclusion of
fugitive emissions in terms of applicability for sources on the
list of source categories published in the September 5 proposal.
Although some other source categories produce emissions in
quantities greater than 100 tons per year that could be considered
fugitive emissions under the proposed definition, these emissions
are currently listed as process emissions. Since these source
categories are listed as those for which fugitives should be con-
sidered in terms of applicability, it does not matter under the
proposal how the emissions are classified in terms of applicability,
If the proposal would be changed, however, so that fugitive emis-
sions would not be included in terms of applicability for certain
sources on the list of 28 and some of the current emissions classi-
fied as process are redefined as fugitives, there could be situa-
tions in which these sources would no longer be subject to PSD
review. This would not be the situation in all cases as some of
these sources may have facilities that would have stack emissions
in excess of 100 tons per yr and therefore the source would still
be subject to review.
For most new sources, either the stack emissions are signif-
icantly above the 100 or 250 tons per year cutoff or the source
had no apparent fugitive emissions at all. Thus, including or ex-
cluding fugitive emissions does not appear to have a major impact
on new sources. It may, however, have more of an impact on major
modifications not subject to the current regulations. Existing
sources, although not really increasing their stack emissions,
could modify their facility so that fugitive emissions (e.g., the
V111
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replacement or addition of valves or pumps, or the addition of a
new storage pile or materials-handling operation) would be above
the proposed do. m^in^m-iA levels and could be subject to PSD review.
No data are currently available that would indicate the magnitude
of this impact. However, it could be substantial, since many mi-
nor modifications could emit fugitive emissions above the propos-
ed da mj,nj,m-iA levels.
VE MIWIMIS EMISSION LEVELS
The da. m^,n-im^ emission levels affect sources in two ways.
The first is that they determine whether a proposed modification
at a major stationary source would be subject to PSD review. The
second is that once a source (either new or modified) is subject
to review, they determine whether a source will be required to
install BACT, conduct an air quality assessment, and include pre-
construction monitoring data for all pollutants it emits in ex-
cess of the dt mj.nJ.mJ,A levels.
Although the d& mJin-im^ levels are pollutant specific, very
few sources emit just one pollutant. In other words, although a
source may no longer be subject to review for TSP because it had
net emission changes of less than 10 tons per year, it could still
be subject to review under the proposal because it had changes in
SOa emissions of 20 tons per year. Information on the 151 modifi-
cations included in the 471 permits that were reviewed in detail
were evaluated and categorized according to the greatest amount of
emissions for any of the criteria pollutants that would be emitted
from the source as a result of a net change in emissions. Data
from this analysis indicate that approximately 87 percent of the
modifications would be greater than 10 tons per yr and approximate-
ly 68 percent of the modifications would be greater than 40 tons
per yr for some pollutants. If the same general emissions distri-
bution of modifications that have received PSD permits holds true
for those 1200 modifications that were not previously subject to
review, but which would be subject based on the proposal, then ap-
proximately 800 additional modifications would be subject to re-
view if the proposed do. m4.n
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reviews for TSP, S02, and NOX would be reduced by 24, 8, and 6
percent, respectively. The amount of TSP, S02, and NOX emissions
subject to review, however, would only be reduced by 3, 0.1, and
0.03 percent, respectively. If on the other had various de. m*.nj,-
HU..6 levels are promulgated (for example, 25 tons/yr for TSP; 40
tons/yr for SO2, NOX, VOC; and 100 tons/yr for CO), then based
on the information available, the number of BACT and air quality
reviews for TSP, S02, NOX, and VOC would be reduced by approxi-
mately, 35, 25, 21, and 41 percent, respectively. The amount of
TSP, S02, NOX' and VOC emissions subject to review, however,
would only be reduced by 5, 0.3, 0.2, and 4 percent, respectively.
NONATTAINMENT AREAS
Of the 604 permits issued under the current regulations, 73
permits were for sources located in nonattainment areas. Thirty-
four of these sources would have controlled emissions less than
100 or 250 tons per yr or the de. m-cnxm^ levels (as applicable) , and
therefore would not be subject to either the nonattainment or the
PSD requirements and would therefore realize some control cost sav-
ings. The remaining sources would either be subject to PSD or
nonattainment review depending on the pollutants they emitted and
the designation of the area for that pollutant. A source was con-
sidered to be subject to nonattainment review and therefore not
subject to PSD review if it proposed to locate in an area desig-
nated as nonattainment for all the pollutants that it emitted. If
it emitted any other pollutants that were designated as attainment,
it was considered to be still subject to PSD for those pollutants.
Of the permits in the survey, 39 sources would no longer be
subject to PSD for a number of the pollutants for which they were
major emitters. In some cases the source will still be subject
to PSD for some of .the major pollutants because the area is desig-
nated as an attainment area for these pollutants. Of these 39
sources, only 8 had applied the Lowest Achievable Emission Rate
(LAER) as required under the nonattainment NSR provisions. The
other 31 sources did not indicate that they had applied LAER, but
would be required to do so under the proposed regulations. There-
fore, these sources would be required to incur some additional
control costs as a result of applying LAER.
Although the 34 sources that would no longer be subject to
PSD review and/or nonattainment review would obtain some cost
savings as a result of the proposed regulations, the 31 sources
that would now be subject to the more restrictive nonattainment
requirements would incur some additional costs. The number of
sources no longer subject to review is very close to the number
that would receive additional review, and the type of sources are
very' similar in each case. 'Therefore, it was assumed based on
the limited data available, that the overall cost as a result of
geographic applicability in terms of nonattainment areas would be
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the same under the current and proposed requirements since the
total savings under one would be offset by the additional costs
imposed by the other.
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CONTENTS
Page
Executive Summary j_j_
Figures XJLV
Tables xv
Acknowledgment xvii
1. Introduction 1
2. Data Base Used in the Assessment 4
2.1 Regional office survey 4
2.2 Final permit review 7
2.3 Pending permit review 9
3. Comparisons of Current and Proposed PSD Regulations 13
3.1 General comparison of current and proposed PSD
regulations 13
3.2 Number of sources subject to PSD review 16
3.3 Emissions from sources not subject to proposed
regulations 18
3.4 Construction cost savings as a result of
sources not being subject to PSD review 18
3.5 Cost of applying BACT 23
3.6 Costs for air quality assessments 29
3.7 Air quality impact of sources that would no
longer be subject to PSD 35
4. Major Issues Associated with the Proposed Regula-
tions 40
4.1 Preconstruction notice requirements 40
4.2 Fugitive emissions 44
4.3 Definitions of source, facility, installation,
and modification 5]_
4.4 Ve. m^n^m-c^ emission levels 61
4.5 Baseline definitions 80
4.6 Other issues and their relative impacts 84
5. Impact of Proposed Regulations on Nonattainment
Areas (Geographic Applicability) 89
xiii
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CONTENTS (continued)
Appendix A Monitoring costs
Appendix B Costs incurred by modifications not cur-
rently subject to the June 19, 1978,
PSD regulations as a result of the pro-
posed PSD regulations 125
Appendix C Summary of the assessment of the
September 5, 1979, PSD proposed regula-
tions 129
xiv
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FIGURES
N limber page
1 Summary Form for September 5, 1979, Proposed
PSD Regulations 5
2 Sample Calculation Sheet for Annualized Costs
of Air Monitoring Network 34
3 Distribution of Particulate Matter Emission
Sources Versus Various Pe titnJimJik Emission
Levels 69
4 Distribution of Sulfur Dioxide Emission
Sources Versus Various Vz M-cn-cm-c.6 Emission
Levels , 70
5 Distribution of Nitrogen Oxide Emission
Sources Versus Various Pe M-cnxlm^ Emission
Levels 71
6 Distribution of Carbon Monoxide Emission
Sources Versus Various Pe HUn^tm^ Emission
Levels 72
7 Distribution of Volatile Organic Compound
Emission Sources Versus Various Ve. M-cKu.m-66
Emission Levels 73
8 Distribution of Mercury Emission Sources
Versus Various Pe Mxcn-tm-ci Emission Levels 74
9 Distribution of Beryllium Emission Sources
Versus Various Ve. Mi.n
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TABLES
Number Page
1 PSD Permits Issued by EPA Regional Offices
III through IX, April 1978 to November
1979 8
2 PSD Permit Applications Pending in EPA's
Regional Offices III through IX, April
1978 to November 1979 10
3 PSD Permits Issued Between April 1, 1978,
and November 1, 1979 12
4 Emission Levels Not Subject to PSD Review
Under Proposed Regulations 19
5 Number of Days to Receive a PSD Permit Un-
der the Current Regulations 21
6 Sources Not Subject to PSD as a Result of
Proposed Regulations 24
7 Comparison of Particulate Matter Emissions
Under BACT and SIP for Sources That Would
No Longer Be Subject to PSD Review 26
8 Selected Examples of BACT/NSPS Limits and
Associated Costs to Meet these Limits 28
9 Modeling Costs for PSD Review 30
10 Travel Costs for Data Collections 31
11 Monitoring Network Costs 33
12 Postconstruction Monitoring Costs 35
13 Cost Impact of PSD Modeling and Monitoring
Requirements 36
14 Modeling Results of Proposed New Sources
Not Subject to Proposed PSD Regulations 38
xvi
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TABLES (continued)
Number Page
15 Estimated Costs for Preparing and Submitting a
Preconstruction Notice 45
16 Estimated Costs for Sources Hypothetically
Affected by Proposed Preconstruction Notice
Requirements 46
17 Maximum Annual Average TSP Concentrations at
Model Plants 50
18 Example of Modifications with Associated Emis-
sion Decreases 57
19 Effects of Proposed Regulations on Modifica-
tions Reviewed Under Current Regulations 58
20 Ve, M£ M^n^im^ Levels 64
22 Effects of Varying Ve. M
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental Pro-
tection Agency, Control Programs Development Division, Research
Triangle Park, North Carolina, by PEDCo Environmental, Inc.,
Cincinnati, Ohio.
The project was directed by Mr. William Kemner, and man-
aged by Mr. David Dunbar. Principal authors were Mr. David Dunbar,
Ms. Barbara Blagun, Mr. Larry Gibbs, Mr. Joe Carvetti, and Mr.
Jack Wunderle.
Mr. James Weigold was the project officer for U.S. EPA, and
his guidance and cooperation were greatly appreciated. The au-
thors thank Messrs. Mike Glowers, Gary McCutchen, Michael Truta,
Warren Peters, and Alex Cristofaro of EPA for their cooperation
and assistance in completing this effort. Special thanks go to
the Regional Office new source review contacts, who made the PSD
files and space available to PEDCo to complete the survey of PSD
permits as quickly as possible.
xviii
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SECTION 1
INTRODUCTION
In 1974, the Environmental Protection Agency (EPA) promul-
gated regulations to prevent particulate matter (PM) and sulfur
dioxide (S02) emissions from significantly deteriorating the air
quality in areas where PM and S02 air quality levels were low-
er than the applicable National Ambient Air Quality Standards
(NAAQS's). These regulations required that new or modified
source construction be prohibited unless the source could demon-
strate that it had applied the Best Available Control Technology
(BACT) for PM and SO2 and that its emissions would not cause
significant deterioration of air quality.
On August 7, 1977, the President signed the 1977 Amendments
to the Clean Air Act (the Act) into law, and thus established new
prevention of significant deterioration (PSD) requirements, which
basically follow the outline of the 1974 regulations but are more
stringent.
On June 19, 1978, EPA amended the 1974 regulations to make
them consistent with the 1977 Amendments. Many industrial and
environmental groups petitioned the U.S. Court of Appeals of the
District of Columbia Circuit to review substantive portions of
the June 1978 revised regulations.
On June 18, 1979, in The Alabama Power Company v. Costle
(13 ERC 1225) case, the court issued a decision that upheld some
of the provisions of the June 1978 regulations and overturned
others. In its opinion, the court summarized its ruling, and
promised a supplemental, comprehensive opinion at a later date.
(The court issued its final opinion on December 14, 1979.) On
September 5, 1979, following the court's mandate, EPA proposed
certain changes in the June 19, 1978, regulations to make the
PSD requirements consistent with the June 1979 summary decision
in Alabama Power. The proposed changes included:
1. Potential to emit
2. Fugitive emissions
3. Major modification
4. Preconstruction notice
5. Baseline definition
6. Ambient monitoring
7. Ve. m-insimsLA levels.
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Each of the above changes under the proposed regulations is dis-
cussed below.
Potential emissions would be determined after application
of emission controls, and would be calculated using maximum annu-
al rated capacity, year-round hours of operation, and any en-
forceable permit condition on the material combusted or processed.
Fugitive emissions would be excluded from a source's annual
potential emissions unless these emissions are from the industri-
al source categories listed in the proposed regulations.
Major modifications would be exempted on a pollutant-by-
pollutant basis from PSD review if the emission levels are less
than the cie m-tn.cm.c6 levels. An exemption would also be granted
if there are sufficient emission reductions to offset the emis-
sion increase caused by the modification, so that no significant
net increase in emissions would result.
A written preconstruction notice to the reviewing authority
would be required (instead of a permit) from the following:
1. Construction not qualifying as a major modifi-
cation because of sufficient offsetting emission
reductions
2. A source with emission reductions to be used
for future offsets
3. Construction not qualifying as a major source
because of application of controls more stringent
than those required by the State Implementation
Plan (SIP), New Source Performance Standards (NSPS),
or National Emission Standards for Hazardous Air
Pollutants (NESHAPS).
The September 5, 1979 proposal revised the definition of
baseline and established the baseline date as the time of the
first completed permit application, after August 7, 1977, within
an Air Quality Control Region (AQCR) designated as either attain-
ment or unclassified.
More ambient monitoring would be required before and after
construction as a result of the proposal, for all pollutants reg-
ulated under the Act—not just the criteria pollutants.*
The regulations also proposed to exempt, on a pollutant-
specific basis, major modifications and new sources from all re-
quirements if the emissions of a specific pollutant are below
the da mJinJimJiA level. The da m^ntm^ air quality levels are to
be used as guidelines for exempting sources from PSD air quality
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analysis on a pollutant-specific basis if the emissions are
above the proposed do. m-tn^cm-cd emission levels.
At the time of the September 5, 1979, proposal, EPA had not
conducted an assessment of the impact of the proposed changes to
the PSD regulations. The Act (Section 317) requires an impact
assessment of regulations and revisions to regulations issued
under Part C of the Act (PSD). Executive Order 12044 similarly
requires an impact assessment of significant regulatory actions.
Section 317 of the Act indicates that this assessment should
contain an analysis of the following:
1. Cost of compliance
2. Potential inflationary or recessionary
effects
3. Effects on competition with respect to
small businesses
4. Effects on consumer costs
5. Effects on energy use.
Section 317 also states that the assessment shall be as extensive
as practicable, taking into account the time and resources avail-
able to EPA.
This report presents an assessment with regard to the over-
all impact of the revised regulations and several of the major is-
sues and or changes outlined above. This assessment does not
attempt to quantify the impact of every issue nor does it attempt
to assess the overall economic impact associated with the imple-
mentation of the PSD regulations. It is designed to provide a rel-
ative assessment of the impact of the proposed versus the current
regulations in terms of the sources to be affected, their associ-
ated emissions, major requirements that must be met or that are no
longer required to be met, and the direct costs associated with
meeting the additional requirements for sources that would still
be subject to PSD.
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SECTION 2
DATA BASE USED IN THE ASSESSMENT
To assess the impact of the September 5, 1979, proposed PSD
regulations as compared with the current June 19, 1978, PSD reg-
ulations, the number of sources to be affected by each set of reg-
ulations had to be obtained. Since the current regulations have
been in effect since March 1, 1978, and since PSD permits have
been issued under these regulations, it seemed reasonable that an
assessment of the impact of the proposed regulations should be
centered on the sources that have been issued PSD permits and on
sources that are in varying stages of PSD review.
Final permits (approved and issued) and pending permits
(waiting to be approved) represent individual proposed sources
with specific sizes, locations, and impacts. Though typical hy-
pothetical sources (or model plants) were used for the impact as-
sessment of the current regulations, actual source data in the EPA
Regional Office files were used for the assessment of the Septem-
ber 5 proposed regulations. The actual rather than the hypotheti-
cal source data were used because it was determined that the
sources that had been issued permits to date represented a rea-
sonable cross section of sources that would have been subject to
the current PSD regulations over the past year or so and which
would be subject in the future. Additionally, this was the only
source of data available that was of sufficient detail to assess
whether certain sources would still be subject to PSD and what
would be the associated impact.
Because a number of issues must be evaluated regarding the
proposed regulations, certain information was necessary in order
to conduct the evaluation. This information was summarized by
issue, and a summary form or table was designed to abstract the
data from individual PSD files. A copy of this table or form is
shown in Figure 1.
2.1 REGIONAL OFFICE SURVEY
Each EPA Regional Office (RO) was contacted to obtain a list
of sources for which permits were pending or approved. These lists
were first summarized by source category and then reviewed to de-
termine which Regional Offices would be visited. Since only a
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few PSD permits had been issued for Regional Offices I and II
under the current regulations, and the data to be obtained were
expected to be limited, it was determined that Regional Offices I
and II would be excluded from the survey. This decision was rein-
forced when it was learned that these files did not have any
unique sources that would not be included by surveying the other
eight regional offices.
Each Regional Office was contacted, and dates were arranged
for reviewing the files and abstracting the data.
RO
III
IV
V
VI
12/79
05-07
11-14
04-07
03-07
RO
VII
VIII
IX
X
12/79
03-07
10-12
10-14
20-21
Of the 604 PSD permits issued to date, data on 471 permits were
collected in RO's III through X. However, some 0f the data need-
ed for completing certain parts of the assessment were unavaila-
ble. Therefore, the data abstracted onto the summary forms were
reviewed, and efforts were undertaken to either supplement or up-
grade the data.
2.2 FINAL PERMIT REVIEW
Assessment of the impact of the proposed regulations was
centered on the final PSD permits because these data had been
reviewed as part of the public comment process and had been ap-
proved by EPA as representing the final emissions and air qual-
ity impacts associated with particular sources.
As of November 1, 1979, approximately 604 sources had been
issued permits by EPA under the current PSD regulations for Re-
gions III through X during the 19 months from April 1, 1978, to
November 1, 1979. (Thirty other sources had been issued permits
in Regions I and II, bringing the total to 634.) Table 1 lists
the final permits by source categories for Regions III through X.
As shown, large numbers of permits had been issued for coal-clean-
ing or preparation plants and for asphalt batch plants. Because
many of these plants were similar in size and emissions and the
resources available to complete the assessment were limited, only
a subset of these two categories were included in the detailed
survey, and no more than 10 sources in each of these two source
categories per Regional Office were included in the detailed sur-
vey. The sources not reviewed in detail were included in the as-
sessment of the number of sources subject to the proposed versus
the current regulations by assuming that these sources would be
subject or not be subject to the proposed regulations in the same
proportion as those that were reviewed in detail. Other portions
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of the assessment, however, did not include these sources because
sufficient information on emissions, air quality impact, etc.,
were not available to permit these sources to be included. There-
fore, with the exception of the total number of sources subject
versus not subject, the assessment for the most part unless other-
wise noted, was based on the data for the 471 sources for which
detailed information was obtained.
A review of the issued permits over the above 19-month time
period indicated that a good cross section of industrial sources
would be included in the assessment. Additionally, because there
were no unique economic conditions prevailing during this time
period that would substantially affect any of the source catego-
ries, this sample of final permits was assumed to be a reasonable
approximation of the sources and source categories that would be
affected by PSD during a similar time period in the future. This
assumption was further verified by reviewing a listing of pending
permits currently being processed by EPA.
2.3 PENDING PERMIT REVIEW
According to the information obtained from the EPA Regional
Offices, approximately 600 PSD permit applications were in vari-
ous stages of review as of November 1, 1979. The distribution of
pending permits for Regional Offices III through IX (Table 2) and
final permits (Tables 1 and 3) were similar within Regional
Offices and among source categories.
A detailed survey of pending permits was not undertaken for
two_reasons: (1) the pending permits were in various stages of
review; therefore no firm estimates of the emissions of air qual-
ity impact could be obtained; for most sources, negotiations were
ongoing to decide the level of control that would be considered
as BACT and to decide which models and conditions should be used
in the final assessment of the air quality impact associated with
the proposed new or modified source, and (2) only limited re-
sources had been allocated for the survey portion of the assess-
ment, so only a limited number of permits could be included in
the data base for a detailed assessment. Even though a detailed
survey was not conducted for all sources with pending permits,
some pending permit data were included in the assessment. This
included a coal gasification facility and an oil shale project.
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SECTION 3
COMPARISONS OF CURRENT AND PROPOSED PSD REGULATIONS
Current and proposed regulations were compared in terms of
the following:
1. The. numbers and sizes of sources to be affected
by the current and the proposed regulations
2. The change in total emissions likely to result from
the proposed regulations
3. The amount of increment likely to be consumed by
sources that are no longer subject to PSD review
as a result of the proposed regulations
4. The estimated construction cost savings as a result
of sources no longer subject to PSD review as a re-
sult of the proposed regulations
5. The estimated cost savings as a result of sources
which would no longer be subject to BACT
6. The estimated cost of meeting BACT for sources
that were not previously subject to PSD but which
would be subject as a result of the proposal
7. The estimated costs of modeling and monitoring
under the current and the proposed regulations.
3.1 GENERAL COMPARISON OF CURRENT AND PROPOSED PSD REGULATIONS
The PSD preconstruction review requirements apply to any
"major emitting facility." This requirement applies to any sta-
tionary source which emits or has the "potential to emit" 100
tons per year or more of any pollutant regulated under the Act
for any of the 28 source categories listed below:
Coal-cleaning plants (thermal dryers)
Kraft pulp mills
Portland cement plants
Primary zinc smelters
13
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Iron and steel mill plants
Primary aluminum ore reduction plants
Primary copper smelters
Municipal incinerators
Hydrofluoric acid plants
Petroleum refineries
Lime plants
Phosphate rock processing plants
Coke oven batteries
Sulfur recovery plants
Carbon black plants (furnace process)
Primary lead smelters
Fuel conversion plants
Sintering plants
Secondary metal production plants
Chemical process plants
Fossil fuel-fired boilers (>250 x 106 Btu/h)
Petroleum storage and transfer units (>300,000 bbl)
Taconite ore processing plants
Glass fiber processing plants
Charcoal production plants
Fossil fuel-fired steam electric plants (>250 x 10 Btu/h)
Nitric acid plants
Sulfuric acid plants
The requirements also include any other source with the potential
to emit 250 tons per year or more of any pollutant regulated un-
der the Act.
3.1.1 Potential to Emit
The current regulations define "potential to emit" as the
"capability at maximum capacity to emit a pollutant in the absence
of air pollution control equipment." Permit restrictions on hours
of operation and capacity could be taken into account in calculat-
ing potential emissions. However, the proposed regulations (in
response to the Court's decision in Alabama Power) define "poten-
tial to emit" as the "capability at maximum capacity to emit_a
pollutant after the application of air pollution control equip-
ment." The proposed regulations further state that the potential
to emit shall be based on full design capacity. Thus at least
under the proposal, restrictions on the hours of operations and
capacity may not be taken into account in calculating potential
emissions. However, for comparison, an analysis was undertaken
to determine the impact of including restrictions on the hours
of operation and on the number of sources that would be subject
to review.
14
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The current regulations in general have exempted from full
review any major new or modified source that had emissions of
less than 50 tons per year, 1000 pounds per day, or 100 pounds
per hour—whichever was more restrictive. Under the current 50-
ton exemption, a source has not had to install BACT, and has not
had to provide an ambient air quality impact assessment. Since
under the proposed regulations, no new 50-ton source would ever
be major, this exemption was dropped as part of the PSD review
process.
3.1.2 Fugitive Emissions
Under the current regulations, fugitive as well as stack
emissions are considered in determining whether a source is sub-
ject to review for all sources. However under the proposed
regulations, fugitive process emissions would be considered along
with stack emissions in determining applicability for the follow-
ing source categories:
Coal-cleaning plants
Kraft pulp mills
Portland cement plants
Primary zinc smelters
Iron and steel mill plants
Primary aluminum ore reduction plants
Primary copper smelters
Municipal incinerators
Hydrofluoric acid plants
Sulfuric acid plants
Nitric acid plants
Petroleum refineries
Lime plants
Phosphate rock processing plants
Coke oven batteries
Sulfur recovery plants
Carbon black plants
Primary lead smelters
Fuel conversion plants
Sintering plants
Secondary metal production plants
Chemical process plants
Fossil fuel-fired boilers
Petroleum storage and transfer units
Taconite ore processing plants
Glass fiber processing plants
Charcoal production plants
Fossil fuel-fired steam electric plants
15
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Any other source category being regulated under Section 111 or
112 of the Act at the time of the applicability determination
would also be included.
3.1.3 Geographic Applicability
The current regulations require that new or modified
sources be subject to PSD review regardless of location. The
proposed regulations (and final court decision), however, would
apply only to new or modified sources and pollutants within
AQCR's designated as attainment or unclassified.
3.1.4 Major Modifications
The current regulations subject a modified source to review
if it is one of the 28 source categories with emission increases
above 100 tons per year or if it is any other source with increas-
es above 250 tons per year; associated emission reductions were
not allowed to exempt the source from PSD review, but reductions
that offset the increase and prevented a net increase were allowed
to be used to avoid BACT review. Under the proposed regulations,
any modification to a major source would be subject to PSD review
if the modification would cause a net increase in the source's po-
tential to emit. The proposal also states that emission increases
offset entirely by contemporaneous emission reductions would not
be considered a modification. However, if a major stationary
source modifies its pollutant emissions so that the net increase
in any pollutant would be above the proposed de. m-Ln^im^ levels, it
would be subject to PSD review for all the pollutants it emits
above the de m-£cu.m,t.4 levels.
3.2 NUMBER OF SOURCES SUBJECT TO PSD REVIEW
As indicated in Section 2 of the 604 permits issued for
Regional Offices III through X, only 471 were reviewed in detail.
Of those reviewed in detail, 22 permits did not have data suita-
ble for this analysis. Therefore of the remaining 449 permits,
114 (36%) new sources and 118 (76%) modified sources would be sub-
ject to the proposed regulations. The figures for modified sources
should be viewed with some caution, however. Under the proposed
regulations, modifications would be reviewed only if they result
in a significant net increase in the emissions from a major sta-
tionary source (or would be a major source as a result of the mod-
ification) . Certainly, some of the modifications included in the
survey of the PSD permits were not modifications of major station-
ary sources at the time that the permit was requested. Therefore,
these modifications would not be reviewed under the proposed regu-
latipns. Because information on the size of the source that was
being modified was not part of the PSD permit file, the number of
modifications that would be subject to review represents an upper
bound on the number of modified sources subject to the proposed
regulations.
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If hours of operation or limitations of capacity were con-
sidered in determining potential emissions, 108(34%) new sources
and 110(71%) modified sources would be subject to the proposed
regulations. The calculations to determine the impact of limit-
ing the hours of operations or capacity used the information on
actual operating hours or capacity as reported in the permit ap-
plication. It was assumed that since the source would be operat-
ing at these levels, it would agree to limit its hours of opera-
tion or capacity to avoid PSD review if permitted to do so under
the proposal. Although this may not be the case for all sources,
it is a reasonable assumption for the purpose of this analysis.
The most important factor in determining whether a modified
source would be subject to the proposed regulations is the de.
mi.n.'imi.A levels. Under the current regulations, modified and new
sources have the same emission cutoff criteria for determining ap-
plicability under PSD. If this current concept of treating modi-
fied sources the same as new sources, in terms of general applica-
bility, were used in the proposed regulation, only about 45 per-
cent of the modified sources that have received permits to date
would be subject to PSD review. That is, only 45 percent of the
modified permits reviewed in detail had potential emission changes
after control of greater than 100 tons per year or 250 tons per
year as applicable.,
If new sources with emissions of 100/250 tons per year or
modified sources with emissions greater than de. m-in-im-i-i, levels
that are proposing to locate in areas designated as nonattain-
ment were also subject to PSD review, approximately 37 percent
of the new sources and 82 percent of the modified sources would
be subject to review. In this analysis, a source was considered
to be subject to nonattainment review and therefore not subject
to PSD review if it proposed to locate in an area designated as
nonattainment for all the pollutants that it emitted. If it
emitted any other pollutants for which the area was designated
as attainment, it was considered to be still subject to PSD for
those pollutants and therefore was considered in the calculation
of the total number of sources subject to the proposed regulations,
It was assumed that if a source was a major emitter of at least
one pollutant, even though it was the nonattainment pollutant, all
other pollutants above the de. m-in limits for which the area
was designated as attainment would still be subject to PSD review.
Twenty-two new or modified sources fell into this category. The
number of sources subject did not change even if the criteria to
subject a source to PSD review was any emissions rather than
emissions above the de. m^n-im^ levels for those other pollutants
for which the area was designated as attainment. The only change
that did result was that for a few of the sources, one or two ad-
ditional pollutants would now be subject to PSD in addition to
the ones they emitted above the de. m-in^m^ levels.
If the 133 permits (604-471) not surveyed in detail were
considered to be subject to review in the same proportion as the
17
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sources that were surveyed in detail, approximately 150(36%) new
sources and 133(76%) modified sources would be subject to review
under the proposed regulations. In summary, of the 604 permits
issued: 22 could not be classified; 283 (150 + 133) would be sub-
ject; and 299 would not be subject to the proposed regulations.
(22 + 283 + 299 = 604)
3.3 EMISSIONS FROM SOURCES NOT SUBJECT TO PROPOSED REGULATIONS
Table 4 presents the estimated quantities of emissions that
would be emitted by the sources in the sample of 471 permits not
subject to the proposed PSD regulations as published. These esti-
mates represent the emission levels in the final PSD permits. Al-
so included in Table 4 are estimates of the total emissions by
pollutant from the permits which would be subject to review under
the proposed regulations. A review of the tcible indicates that
two values seem out of line with respect to the other values in
the table. These values have been noted, and some additional in-
formation is provided in footnotes on the table. In terms of the
S02 values for Regional Office V, 7000 out of the 9000 tons per
year are due to the fact that a number of large S02 emitters are
proposing to locate in a designated nonattainment area for SO2,
and therefore these SO2 emissions as such would not be subject to
PSD review but would be subject to the nonattainment provisions.
In addition, with respect to the particulate matter emissions in
Regional Office VIII, 20,000 of the 23,503 tons per year are from
fugitive emissions from mining operations that would not be in-
cluded in terms of applicability, and therefore these sources
would not be subject to review because they did not have stack
emissions that would exceed 250 tons per year.
Many sources no longer subject to the PSD regulations may
relax the emission limits recorded in the permits if these limits
are significantly more restrictive than the current SIP or NSPS
limits. Because estimates of the SIP limits were not contained
in the PSD permits in most cases, it was not possible to estimate
the total additional emissions that might result from sources re-
laxing their emission limits from BACT to SIP. However, Section
3.5 provides an assessment on a case-by-case basis as to the addi-
tional emissions that might be emitted from selected sources in
terms of the applicable NSPS and SIP limits.
3.4 CONSTRUCTION COST SAVINGS AS A RESULT OF SOURCES NOT BEING
SUBJECT TO PSD REVIEW
Sources in the sample of 471 permits that have undergone PSD
review but which would not be subject to the proposed regulations
may have incurred some costs as a result of obtaining a PSD per-
mit that would no longer have to be incurred and would therefore
represent a potential cost savings. Applying for a permit for
construction of a new or modified source entails several steps:
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1. Refining the requirements for a permit application
2. Monitoring to collect needed data
3. Preparing and submitting an application
4. Preparing comments and responding to requests for
additional information
5. Attending public hearings and responding to public
comments
6. Undergoing final review.
Since the impact in terms of the costs associated with several of
the key elements necessary to obtain a PSD permit will be dis-
cussed in detail in the following sections, this section will ad-
dress the general cost impact associated with the overall time
needed to obtain a permit once a complete application has been
submitted.
3.4.1 Typical Number of Days Necessary to Obtain a PSD Permit
A review of PSD permits issued under the current regula-
tions yielded the times shown in Table 5. The numbers in Table
5 represent the average, maximum, and minimum number of days be-
tween the receipt of a complete PSD application and the issuance
of a final permit for several source categories. The review
times were obtained from information contained in regional office
permit files. A total of 205 permits were reviewed that would
not be subject to the proposed regulations and that could be as-
signed a review time. The average review time for the 205 per-
mits is 192 days, or about 6% months per application.
In addition to the need to obtain a PSD permit, State NSR
permits are also needed to ensure that the source will meet all
applicable State limitations. If it is assumed that the average
State review time is 1 month,1/2/3 the average review time just
for PSD reduces to 5h months. In some cases, the review may be
sequential, but in many cases the State NSR precedes the PSD re-
view process.
In addition to the actual time necessary to conduct a PSD
review, the following factors may affect the amount of time as-
sociated with receiving an approved permit:
1. Obtaining other permits (e.g. for water discharge,
hazardous material, solid waste, etc.)
' 2. Obtaining necessary funding
3. Acquiring property
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4. Purchasing and delivering equipment.
Any one of these items can more than exceed the time normally
required to receive a PSD permit.
Depending on the order in which the applicant attempts to
pursue the above-required steps, the total construction project
leadtime could extend the time for obtaining a permit by several
months to a year. For example, if a source applies for a PSD
permit early on in the project planning process (e.g., when ob-
taining funding or acquiring property), then no additional time
would be spent on obtaining a PSD permit. If an application for
a PSD permit is submitted only after the above steps are taken,
however, a project may be delayed by several months.
3.4.2 Estimated Costs
The applicant experiences certain costs as a result of the
time imposed by the requirement to obtain a PSD permit. Although
a loss of production could cause a loss in income, this is gen-
erally not the case for any delay that may be; incurred as a result
of PSD review, because these delays do not generally reduce the
useful life of the equipment and in most cases the production -can
be made up during later years. However, for example, there could
be a loss for sources that recover waste products as usable forms
of resources or energy, since the raw materials that are discard-
ed during the delays are not recoverable and if generated on site
must be disposed of until the unit is constrxicted and operational.
For example, recovery of municipal waste can yield profits of $6
to $8 per ton.1* This profit would be replaced by disposal costs,
however, if a permit is delayed. Loss of production can also be
translated ijito an additonal cost if an alternative source of the
product must be purchased to compensate for loss of capacity; ex-
amples are purchased steam (as opposed to waste-generated steam),
electric power, and oil and gas supplies.
Energy losses can also be incurred as a' result of delays in
replacing antiquated, inefficient processing units with modern,
energy-efficient units. Replacment of a refinery heater rated at
82 percent efficiency with one rateH at 92 percent can reduce fuel
use by 12 percent and yet deliver the same heat. Therefore, these
could be additional costs that would be associated with any delay
in obtaining a PSD permit.
It is very difficult to quantify the actual cost associated
with any time delays as a result of the PSD review process. For
the source categories in Table 5, the minimum review time is 1 to
3 months; this time probably best represents the actual time neces-
sary to obtain a PSD application, without considering any other
factors. This is based on the fact that under the current regula-
tions Tier 1 reviews were estimated to take from 1 to 3 months.
The 2-year review time for the oil pipeline is not representative,
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as the project was highly debated and the permit application later
withdrawn.
The estimated cost incurred as a result of obtaining a PSD
permit will vary from source to source depending on the size and
type of source that is obtaining a permit. Estimates ranged from
a total cost of $8750 to approximately $2740 per day.5
Since the sources that would no longer be subject would be
smaller sources (i.e. with controlled emissions less than 100
tons per year or 250 tons per year) and would tend to have short-
er review times (i.e. less than 6 months) and therefore incur less
overall cost, the lower end of the above range for the cost in-
curred due to delays in obtaining a PSD permit was used to esti-
mate the cost savings as a result of no longer being subject to
PSD review. Since the minimum amount of time that it would take
to obtain a PSD permit would be approximately 2 months (1 month
review plus 1 month for public comment), the average cost per
month using a total cost of $8750 would be $4375 ($8750 4 2 months)
Given this cost per month of $4375 and the average time for PSD
review of 5% months, the potential savings for the 299 sources
that would no longer be subject to PSD as a result of the proposal
is approximately $7.1 million (299 sources x 5% months x $4375).
The $4375/month seems reasonable for review times of 1 to 6 months
since the average cpst per month is not expected to be signifi-
cantly different for review times of 6-month or less. Additional-
ly, this cost seems reasonable if the sources were not required to
offset a lack of product with purchases from another supplier. In
some cases, however, equipment delivery time exceeds the review
time and no additional cost would be incurred.6
3.5 COST OF APPLYING BACT
Based on the review of 604 final PSD permits, 258 new and 41
modified sources would not be subject to the proposed regulations.
Table 6 lists these sources by categories. Sources no longer
subject to PSD would not be required to demonstrate that they
had applied BACT to all pollutants with levels above the de. m-Ln^-
mt& levels. (The impact of do. m^n^m^A levels on the number of
BACT reviews is discussed in Section 4.5.) These sources would
be required to meet only an emission limit prescribed by an NSPS,
NESHAPS or a SIP. Because a SIP, NESHAPS or NSPS limit is theo-
retically less stringent than BACT, the source could derive a
cost savings by installing equipment with a lower degree of con-
trol than currently required by BACT. This cost savings would be
a direct result of not being subject to the proposed regulations.
3.5.1 Emissions Less Than 50 Tons Per Year
Some sources not subject to the proposed regulations were
not required to apply BACT under the current regulations. If a
source subject to the current regulations could demonstrate that
its controlled emissions would be less than 50 tons per year, it
was not required to demonstrate that it had applied BACT; it had
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to only demonstrate that it would meet the applicable NSPS,
NESHAPS or SIP limit. Of the 299 new or modified sources not
subject to the proposed regulations, approximately 203(68%)
have controlled emissions less than 50 tons per year; thus these
sources were not required to apply BACT or to go to the addi-
tional expense of installing control more stringent than that re-
quired by NSPS or SIP. Many of these sources, however, may have
applied controls beyond those required by NSPS or SIP (but not
equal to BACT), which resulted in emissions of less than 50 tons
per year, and thus they were exempt from the BACT requirements.
Therefore, an attempt was made to calculate the cost savings ac-
crued by sources who would no longer have an incentive under the
proposed regulations to reduce their emissions below 50 tons per
year.
Comparisons of emissions reported in the PSD permits with
those allowed by an applicable NSPS or SIP limit indicated that
more emissions would be emitted by some sources not be subject
to PSD. (NESHAP limits were not included in the analysis since
very little information was contained in the PSD permits with re-
spect to the pollutants covered by NESHAPS.) In many cases the
emissions from meeting the NSPS or SIP limit, however, would be
less than 50 tons per year. Table 7 lists the particulate emis-
sions that could be emitted under the SIP or BACT based on the
permits which were issued from April 1, 1978 to November 1, 1979.
A closer review of the permit data indicated that although
more emissions would be allowed, the difference in control levels
to obtain these emissions would not exceed 2 or 3 percent. For
example, instead of a requirement to install a 99 percent effi-
cient fabric filter, a source would be required to install only
a 97 percent efficient one; this difference in efficiency would
only have a slight variation in cost because the parameters that
affect costs (A/C ratio, number of bags, type of cleaning, etc.)
are determined more by source application than by the desire to
obtain_a particular control efficiency. Although savings associ-
ated with the sizing of fans or other air-moving equipment might
be realized, these savings in comparison to the overall control
equipment cost would be relatively insignificant—thousands com-
pared to tens or hundreds of thousands of dollars. Thus, although
cost savings are possible for sources with emissions less than 50
tons per year, most sources would not incur any savings in con-
trol cost by not being subject to the proposed regulations. It
should be noted that for those sources which emit VOC emissions
there could be some control cost savings as a result of not being
subject to PSD review because in many cases, there are only a few
NSPS and SIP requirements that affect VOC sources, especially
those that would emit less than 50 tons per year.
3.5.2 Emissions More Than 50 Tons Per Year
Of the 96 sources not subject to the proposed regulations
with controlled emissions greater than 50 tons per year, 65
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TABLE 7. COMPARISON OF PARTICULATE MATTER EMISSIONS UNDER BACT
AND SIP FOR SOURCES THAT WOULD NO LONGER BE SUBJECT TO PSD REVIEW
Source category
Secondary aluminum
Steel foundry
Fiberglass
Mineral wool
Steel foundry
Fiberglass
Polyvinylchloride (PVC)
Woodworking
Woodworking
Rice mill
Asphalt plant
Cement plant
Iron borings
Iron foundry
Stone-crushing
Structural steel
Bentonite processing
Emissions,
tons/yr
BACT
9
0
49
20
28
11
6
7
7
26
1
49
15
5
20
2
26
SIP
65
47
171
93
49
14
43
47
12
49
3
142
49
44
98
2
26
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sources consisting of 9 source categories would be subject to an
applicable NSPS limit. Two of these categories (petroleum re-
fineries and iron and steel) only have an NSPS limit for specific
facilities within the source, however, and not all facilities have
an applicable NSPS limit.
A review of the emission limits proposed for these 65 sources
under PSD indicates that in all cases the NSPS limit was equal to
the BACT limit for those facilities for which an applicable NSPS
limit exists. Therefore, with two exceptions (in which not all
facilities were covered by NSPS) there would be no cost savings
for the 65 sources because they are no longer subject to PSD re-
view.
The remaining 31(10%) sources (those with no applicable NSPS
limits and emissions between 50 and 100/250 tons per year) could
relax controls to SIP levels since they would no longer be subject
to PSD. Since SIP limits were available for only a few of the 31
sources (i.e. those in Table 7), a limited analysis was performed
to determine the impact of the potential relaxations that may oc-
cur because the sources are no longer subject to BACT. Table 8
summarizes this analysis for selected sources. In a few cases,
the SIP limit equals the BACT limit; in other cases, the SIP limit
is within a factor of 2 of the BACT limit so the source could meet
the limit by installing a device with an average efficiency of 5
percent less than the device currently proposed. Theoretically,
a source would select a less expensive, less efficient control de-
vice, but in most cases the required control efficiency is such
that the same basic control device would be needed in order to
meet the relaxed limit. If this is the case, there would be little
if any cost savings. If these sources could meet the SIP limits
without any control, the overall cost savings, based on the cost
data in the PSD permits surveyed, would be on the order of $25
million for the period covered by the survey. This would amount
to an average control cost savings of approximately $850,000 per
source. Because some basic level of control would be needed un-
der the SIP, however, the overall cost savings would more likely
be on the order of $3 to 6 million for the period covered by the
survey. ($1.9 to $3.7 million on a yearly basis.) This would
amount to an average savings of $100,000 to $200,000 per source.
Since the SIP limit is not significantly different from the BACT
limit for a number of sources, $100,000 to $200,000 per source is
a reasonable estimate of the possible savings associated with a
source having to meet a less stringent emission limit as a result
of not being subject to PSD. The above costs savings are in terms
of capital cost since no data were available regarding the opera-
tion and maintenance costs for the sources included in the survey.
Although certain sources that are currently subject to PSD
review will no longer be subject, other sources that previously
27
------- An error occurred while trying to OCR this image.
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were not subject will be subject as a result of the proposed
regulations. These sources are those modifications to major
sources that would have increased controlled emissions in excess
of the de. m-Ln-Lm-L^ levels, but uncontrolled emissions less than
100/250 tons per year. Since most of the modifications would have
emissions on the order of 10 to 50 tons per year and would be sub-
ject to at least SIP limits if not NSPS limits, the additional
control technology costs of meeting BACT (since BACT is equal to
NSPS or the SIP in many cases) results in no additional control
costs being incurred. There will be cases, however, in which the
BACT limit would require that additional controls be imposed. If
the above estimates regarding the control cost differential be-
tween BACT and SIP are used and approximately 10 percent of the
modifications (120 sources per year—see Section 4.3 for details
on number of modifications to be subject) that would come under
review would require that additional controls be imposed, the
additional cost would be on the order of $12 to 24 million/yr
(120 sources x $100,000—120 sources X $200,000).
Therefore the net impact in terms of additional control
costs of revising the regulations would be on the order of $10 to
20 million dollars ($12 minus $1.9 million to $24 minus $3.7 mil-
lion) .
3.6 COSTS FOR AIR QUALITY ASSESSMENTS
Under the proposed regulations, all major new and modified
sources with net emissions in excess of the do. m^in-Lm^ levels
must assess the source's impact on the air quality increments and
the NAAQS's through modeling and preconstruction monitoring. The
current regulations only require that an ambient air quality im-
pact assessment be conducted for new and modified sources that
would emit levels in excess of 50 tons per year. Therefore, an
assessment was undertaken to compare the cost associated with
the proposed versus the current regulations, regarding the model-
ing and monitoring efforts needed to comply with the respective
regulations.
3.6.1 Estimates for Preconstruction Modeling
The modeling efforts were divided into five example catego-
ries ranging in complexity from the initial screening to sophisti-
cated modeling with three or four iterations. These example
categories were developed as a result of PEDCo's previous experi-
ences with modeling and the associated cost. Table 9 lists the
five basic categories and their estimated costs.
The level of complexity is a function of meteorological and
geographical considerations, source configurations, and number
and location of receptors. This review considered PTMAX, PTDIS,
and PTMTP as the less sophisticated models and CRSTR, RAM, CDM,
and VALLEY as the more sophisticated models.
29
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TABLE 9. MODELING COSTS FOR PSD REVIEW
Cost
I. $ 500
II. $ 1,500
III.
IV.
$15,000
$30,000
V. $50,000
Description
Initial screening - calculation of ground-level maximum
concentration using basic Gaussian dispersion equations3
Screening models - nonsophisticated models PTMAX, PTDIS,
PTMTP; limited receptor sites and meteorological consid-
erations
Sophisticated modeling - analysis of one facility in
attainment area
Sophisticated modeling - analysis of one facility and
one other major stationary source in attainment area
for three pollutants and in nonattainment area for one
pollutant; source impacts in nonattainment area
Sophisticated modeling - analysis of one facility in
clean pocket of nonattainment area; many other sources
within impact area; three or four iterations
aTurner, D.B. Workbook of Atmospheric Dispersion Estimates PHS Publica-
tion No. 999-AP-26', Environmental Protection Agency, Research Triangle
Park, North Carolina, 1970.
Sophisticated modeling - detailed, sophisticated models such as CRSTER,
RAM, and COM.
Initial screening is defined by air quality impact values
calculated by using the basic Gaussian dispersion equation. Of
the approximately 471 sources for which a detailed survey was
conducted, 440 had some data on the type of model used for the
air quality assessment. These data were reviewed, the modeling
efforts categorized according to the example categories in Table
9, and the modeling cost associated with each of the 440 permits
was calculated by multiplying the number of sources within each
category by the costs in Table 9. Based on these calculations
the cost of modeling under the current regulations was estimated
to be $6 million for the 19 month period covered by the survey
($3.9 million on a yearly basis).
The cost of modeling under the proposed regulations was
calculated by using the cost information in Table 9 and mul-
tiolvina by the number of sources that are subject to the pro-
posed regulations (283) categorized by the extent of -deling
that would be required based on the categories in Table 9.
For example, if five sources would be required to use sophis-
ticated modeling in which only one facility per source would need
30
-------
to be analyzed (Category III), the cost of modeling would be 5 x
$15,000 (cost for category III from Table 9) or $75,000 for these
five sources. Similar calculations were performed for all cate-
gories and the costs summed for all 283 sources subject to the,
proposed regulations. The cost of modeling for these sources as
a result of the proposal for the 19 month period covered by the
survey was estimated to be $4.9 million ($3.0 million on a yearly
basis).
3.6.2 Estimates for Preconstruction Monitoring Review
The current PSD regulations require monitoring only for
pollutants for which NAAQS's exist and only for criteria pollu-
tants emitted in excess of 50 tons per year. The proposed regu-
lations generally require preconstruction monitoring for all
pollutants regulated under the Act and emitted in excess of the
proposed de m^in^m-i^ levels. Up to 1 year of preconstruction
data for criteria pollutants are needed for each permit applica-
tion.
The monitoring network costs7 were calculated on an annual
basis, assuming a sampling schedule of once every sixth day (i.e.
61 visits a year to each site unless otherwise specified). In
reviewing the permits it was assumed that local weather data were
used unless the permit specified costs incurred to establish a
meteorological monitoring network; State monitoring data were used
for air quality assessments under the current regulations unless
the permit specified that a monitoring network was established.
An average base travel cost of $600 for sample collection was in-
cluded in the monitoring cost calculations. Table 10 presents an
example calculation for the travel cost. It assumes an average
distance of 20 miles per visit, and a mileage charge of $0.23 a
mile. The labor cost to and from the network sites was calculated
using a burdened wage rate of $11.50 an hour. Network estimates
were based on having two monitors for TSP, N02, or 03 and three
for SO2 or CO.
TABLE 10. TRAVEL COSTS FOR DATA COLLECTIONS
Vehicl
Labor
e operation
costb
20
20
X
X
Total
61 =
61 =(
$593
1220
1220
X
$0.
45
23 per
mph) x
mile =
$11.50
$281
= $312
- 600
aCost = average distance (20) x number of visits per year (61) :
mileage per year (1220) x charge per mile ($0.23).
Cost = average distance x number of visits per year = mph (45)
x charge per hour ($11.50).
31
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The cost of monitoring under the current regulations was
calculated by using the information regarding the number of moni-
tors and type of monitoring that was conducted under the current
regulations obtained from the permits file and multiplying by the
costs in Table 11. The cost associated with the current regula-
tions based on the 471 permits surveyed in detail was approximate-
ly $0.5 million (this would amount to approximately $0.3 million/
yr). Figure 2 is an example of the calculation sheet that was
used to calculate the cost of a specific type of network, con-
sisting of two TSP and N02 monitors, three SO2 and CO monitors,
and monitoring for Be and Hg. Twenty-two other tables (Tables
A-6 through A-28) similar to Figure 2 were developed for various
combinations of pollutant monitoring and are found in Appendix A
along with the specific cost data used for monitoring TSP, S02,
CO, NOa and ozone (Tables A-l through A-5). These tables were
then used in calculating the cost of monitoring for a specific
source for which a permit had been issued. For example, a parti-
cular cement plant in Regional Office III would have to monitor
for TSP and S02. The table setting forth the specific requirements
for TSP and S02 monitoring was then used to calculate the cost of
monitoring for this source. In this case it was $47,800. The
cost for each source was determined and the total cost was obtain-
ed by adding the costs for all sources subject to the proposed
regulations.
Less than 5 percent of the permits that have been issued to
date reported that a source had established a preconstruction net-
work to comply with the current monitoring requirements. The
other 95 percent were assumed to have used previously established
State or local agency monitoring networks. If 95 percent of
sources required to monitor under the proposed regulations could
use previously established monitoring networks, the total monitor-
ing cost associated with the proposed regulations for the 19 month
period covered by the survey would be approximately $0.9 million
dollars, or less than a 49 percent increase.
The monitoring requirements of the proposed regulations are
more stringent, however, and generally require monitoring of more
pollutants than the current regulations. If all sources subject
to the proposed regulations included in the survey of permits
established their own preconstruction networks, the additional
cost would be in excess of $12 million for the period covered by
the survey ($8.0 million/yr). It is extremely unlikely that all
sources would need to establish a network for all pollutants for
which monitoring is required, thus, the expected cost would be
closer to $0.9 million than to $12 million, the latter being the
outside limit of additional monitoring costs resulting from the
proposed regulations.
3.6^3 Estimates for Postconstruction Monitoring
In addition to 1 year of preconstruction monitoring data,
the proposed regulations may also require data from postconstruc-
tion monitoring for certain large sources. Since specific source
32
------- An error occurred while trying to OCR this image.
-------
*nnunl 1 rrd ntntlon costs (per pollutnnt monitored), before adjustment
Pollutant monitored
TS P
NO*
zo~
NO. Of
stations
£ ,
Annuallzcd
station coat
< $
-^ I I
^ x S
w>
K S
x S
^ • Subtotal
!
Subtotal
Quantity discount
(\ x annualixed- equipment
co3tc x no. of stations)
/ U'5 S - 1 ^ x
Q 7.Q J. 5 - 1 * x
/ -> / ~ 5 - ( \ x
/ 3007 S - ( \ x
/ J S ( * x
7 1"3'-0 s - i \ x
1 73 25 0 •
S
S
S
$
S
x
x
X
X
X
X
Total annuallzod costs
. (per pollutant monitored) .
\ <
) S
) 5
1 5
) I
) s
J-
1 %•
9, 1
7
30
yjs
3 3.3
6^.^ 0
3_^(^> , rO
°i i- v-o.s , £"p
Shelter conts
Shelter oitc, £t
3.5 x 4.0
32.0 X 8.0
Other
No. oC shelters
x
x
•? *
X
X
Coat per shelter
period, years
S *
$ »
s 3tfoO I
$ *
$ »
Subtotal
shelter costs
S
$ 9 o *> o
S '
S
^Q^£
Trove! conta
JNo. ot statloTT't Average distance, miles \ No. of visits"^C year - Yearly mileage
Vehicle operation
Labor cost
... • x 0.
x x - x 0.
x . - ( 1 mph)
x ^
/mile
/mile
x $
x S
- 5
wage rata/h •
wage ratc/h •
$
IV-
fe? O (O
1_^
a Costs obtained Jtrom individual tables in Section 3.0.
b Dependent on vendor and quantity, but generally between 2\ and 1B\.
c AnnualUcd equipment coots obtained from individual tables in Section 3.0.
d Asaumcs 5 years.
Figure 2. Sample calculation sheet for annualized costs of air monitoring network.
-------
categories were not identified in the proposal, assumptions were
made about which sources would be affected by postconstruction
monitoring. Assuming that the same numbers and types of sources
would be issued permits during any 19-month period as in the past
19 months, 18 fossil fuel-fired steam generators, 24 refineries,
and 15 chemical process plants would be required to establish
and operate postconstruction monitoring networks.
Existing networks are not likely to be satisfactory for
postconstruction monitoring, so additional monitoring would be
required. Based on data in Table 11 the additional costs would
be $3.7 million. Table 12 lists the cost estimates by source
category; these estimates were based on a review of individual
permits and the actual emission rates, specifically those above
the de. m
-------
TABLE 13. COST IMPACT OF PSD MODELING AND MONITORING
REQUIREMENTS*
Requirement
Modeling
Preconstruction
monitoring'5
Preconstruction
monitoring0
Postconstruction
monitoring
Current
regulations
$6.1
0.5
0.5
0
Proposed
regulations
$4.9
0.9
12.7
3.7
Difference between
current and proposed
$-1.2
0.4
12.2
3.7
For a 19-month time period.
Assuming 95 percent of sources subject to proposed regulations
use previously established networks.
cAssuming all sources subject to proposed regulations esta-
blish new networks.
36
-------
tons per year, they would be exempt from preconstruction PSD re-
view in terms of their air quality impact and the requirement to
install BACT. The assumption inherent in the 100 and 250-tons-
per-year controlled emission cutoffs is that the air quality im-
pact of these sources would be for the most part of little con-
cern in terms of review on a source by source basis.
Air quality modeling data from sources that would not be
subject to the proposed regulations as a result of the change to
the potential emission definition were analyzed to determine the
significance of the air quality impacts. Table 14 lists the
sources and their EPA region, facility size, TSP or SO2 concen-
tration, and percentage contribution to the respective TSP or S02
increment. The maximum 24-hour concentrations were estimated to
occur at distances ranging from 0.25 to 3.5 km (0.15 to 2.1 mi),
and the average consumed approximately 44 percent of the TSP or
SO2 increment. Although no longer subject to PSD review, if these
sources are constructed after the first permit is received in an
area, they would have the potential to consume significant per-
centages of the allowable TSP or SO2 increment near the source
(e.g., 0.2 to 1 km); the extent of consumption would be directly
dependent on the area of impact associated with the source.
Air quality impacts associated with sources no longer sub-
ject to PSD regulations may be higher than those in Table 14,
since these impacts were calculated assuming that the source had
applied BACT. Because these sources are no longer subject to
PSD review, the levels of emissions permitted could be substantial-
ly greater than those used in the air quality impact analysis if
the SIP or NSPS limits would be significantly less stringent than
BACT.
37
-------
TABLE 14. MODELING RESULTS OF PROPOSED NEW SOURCES NOT SUBJECT
TO PROPOSED PSD REGULATIONS
Source category
Lime plant
Liquid waste incinera-
tor
Municipal incinerator
Clay processing
Opalite plant
Plywood manufacturing
Ref i nery
Coal gasification
Coal preparation
Woodworking
Gold and silver mining
Molybdenum mine
Rock quarry
Aluminum reclamation
Casting facility
Industrial boiler
Silica fusion
Sulfur recovery
Glass fibir product
Asphalt
Asphalt
Capacity or
facility size9
150xl03
9,499
31,200
270X103
ZIOxlO6 Btu/h
200 bbl/day
20xl06 Btu/h
2.3xl06
45xl03 BD ft/wkc
1,000 tons/h
7.9xl06
250xl03
21xl03
352xl06 Btu/h
3,600
31,025
128 tons/h
256 tons/h
Emission,
tons/yr
PM
805
6
22
180
32
116
3
17
47
699
600
44
96
43
33
3
82
72
17
6
S02
150
2:4-h avg cone,
yg/m3
TSP
5
37
13
26
5
29
<1
26
11
37
32
31b
-------
REFERENCES FOR SECTION 3
Personal communication with M. Sowell, Division of Environ-
mental Management, State of North Carolina, Raleigh, North
Carolina, February 19, 1980.
Personal communication with M. DeBusschere, Air Pollution
Control District of Jefferson County, Louisville, Kentucky,
June 30, 1979. *'
Personal communication with C. Marshall, Regional Air Pollu-
tion Control District, Dayton, Ohio, June 30, 1979.
Fermandes, J.H. Economic Utilization of Municipal Refuse,
in Proceedings of the Fifth Annual Northeastern Regional
Antipollution Conference, University of Rhode Island.
July 17-20, 19-72. pp. 153-175.
Summary of the Sixth APCA Government Affairs Seminar. Prob-
lems Solved and Created by the 1977 Amendments, Washington,
D.C. March 22-23, 1978.
Personal communication with G.W. Van, Kepple Co., Kansas
City, Missouri. January 25, 1980.
Cost of Monitoring Air Quality in the United States, U.S.
EPA. Prepared by PEDCo Environmental Inc. under Contract
68-02-3013 Work Assignment No. 1. November 1979.
39
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SECTION 4
MAJOR ISSUES ASSOCIATED WITH THE PROPOSED REGULATIONS
A number of issues have been raised regarding the proposed
regulations:
1. Preconstruction notice
2. Applicability of fugitive emissions
3. Definitions of source, facility, installation, and
modification
4. Vn wLnLmLb levels
5. Area for baseline determination
6. Monitoring requirements (Section 3.6.)
7. Geographic applicability (Section 5.0)
8. Pollutant applicability
9. Innovative technology waiver
10. Secondary emissions
11. Portable facilities
12. Nonprofit institutions.
Assessments of the impacts of the first five issues are in
Sections 4.1 to 4.5, respectively. The sixth issue was previous-
ly discussed in Section 3.6, and the seventh issue will be dis-
cussed in Section 5.0. The remaining issues are discussed in
Section 4.6.
4.1 PRECONSTRUCTION NOTICE REQUIREMENTS
The proposed amendments to the current regulations require
a preconstruction notice from all new and modified sources sub-
ject to, and from selected new and modified sources not subject
to, the proposed regulations. If the source is subject, the no-
tice is only a written statement with the date that construction
will begin. This must be submitted at least 90 days before that
date. If the source is not subject, a notice is required for
(1) a modification to a major source that would have been subject
if it had not had sufficient reductions in contemporaneous emis-
sions, (2) a new source that would have been classified as major
if it had not applied control equipment more efficient than that
generally required by the applicable SIP or other specified
standard, and (3) reductions that will be used for future off-
sets. The following sections outline the requirements, their
estimated costs, and the projected impacts of the preconstruction
notice requirement.
40
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4.1.1 Contents of the Notice
As specified in the proposed regulations the information
required in a preconstruction notice differs slightly between
new and modified sources. For both, the following information
is required:
1. Name and address of owner/operator.
2. Nature of source or modification.
3. Location of source or modification.
4. Potential (controlled) and allowable emission
rates for any pollutant regulated under the Act
for all units within the new or modified source.
5. A schedule of when changes in the emissions of
any regulated pollutant are expected to occur.
6. Any other information deemed necessary by the
EPA Administrator to determine whether a source
is exempt from impact assessment and PSD review.
A modified source using contemporaneous emission reductions
for offsets must include:
7. Calculations of how the contemporaneous emis-
sion reductions identified in a separate noti-
fication would adequately offset any emission
increases of any regulated pollutant.
8. A demonstration that each emission reduction
would be enforceable under the SIP.
The separate notification mentioned in Item 7 is required at the
time any emission reduction would be used for offset; this noti-
fication should include:
1. Name and address of the owner/operator.
2. Type and amount of each emission decrease, and
identification of the affected emission unit.
3. Schedule of when each contemporaneous emission
reduction has or is expected to occur.
4. Other information deemed necessary by the EPA
Administrator to determine if the reductions
are acceptable.
41
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Under Item 6, EPA may request additional data for evaluation of
the notice; as a minimum, EPA is expected to request data on pro-
cess rate, annual operating hours, fuel analysis, and control
equipment design parameters.
4.1.2 Costs of Preparation
Preparation of a preconstruction notice will require time
and effort by the owner/operator or an agent. The level of ef-
fort is expected to vary with the complexity of the proposed con-
struction activity. Effort/cost estimates were based on source
categories and on whether the construction activity was classified
as a new or modified source. Following are discussions of each
item listed above and estimates of man-hours required to satisfy
the information requirements and the preparation of the submittal.
1. Reporting the name and address of the owner/
operator requires negligible cost.
2. Describing the proposed activity briefly or in
detail (depending on EPA guidelines should
include the type of process, raw materials in-
put, products, operating hours, maximum and de-
sign capacity, fuels used, and emission points
identified); such data should be readily avail-
able as part of the design and engineering of
the construction activity. The time required
to assemble the data can vary greatly with the
number of emission units within the source/
modification. The estimated hours needed for
preparation of these data range from 20 man-
hours for simple sources to 120 man-hours for
complex sources/modifications.
3. Specifying the location of source/modifica-
tion will require determining the universal
transverse mercator (UTM) coordinates and
specifying the city, county, AQCR, and the
site address. This is estimated to require
8 to 16 man-hours.
4. Calculating potential and allowable emission
rates can be complex and time consuming for
sources with many emission units emitting
several regulated pollutants. If emission fac-
tors are not readily available, an engineering
analysis should include material balances and
extrapolation of data from other similar_sources.
For a straightforward source with few emission
points and few regulated pollutants, the effort
is estimated at 8 man-hours; for a complex
source/modification with several emission units
and without emission rate data, the estimate is
100 man-hours.
42
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5. The development of a time schedule when changes
in emissions of any pollutant will occur is
estimated to require 4 man-hours.
6. Supplying other EPA required data on the types
of control equipment and the number of emission
units on which control is applied (at a minimum,
control equipment design parameters) may be
simplified by using the specifications of the
owner of the facility or the vendor of the con-
trol equipment. This effort should only require
assembling the necessary data and preparing a
submittal to EPA. For an ESP on a small boiler,
the effort is estimated as 8 man-hours; for a
large power plant with ESP's and limestone scrub-
bing, the estimate is 40 to 100 man-hours, de-
pending on the number of control devices.
7. Calculating the proposed contemporaneous emis-
sion reductions for offsets is an effort similar
to that for estimating emissions from proposed
modifications; for existing processes, emission
calculations may be available for submittal
with little revision or recalculation. If not,
the effort required to prepare offset calcula-
tions for submittal may be up to 100 man-hours.
8. Demonstrating that each contemporaneous emission
reduction would be enforceable under an SIP
would vary greatly with the situation. If the
reduction was to be achieved by shutting down an
emission unit, the demonstration would consist
of a rescission of the State operating permit; a
rescission is estimated at 40 man-hours. If the
operating hours of an emission unit are to be
limited, the operating permit must be revised to
incorporate the limit; this is estimated to re-
quire about 60 man-hours. If the reduction on a
unit is to be achieved by installing more effi-
cient control equipment or by a process change,
a revised operating permit must be obtained
specifying lower emission limits; this is the
most complex and time-consuming situation since
it would be equivalent to obtaining a new permit
subject to complete review it is estimated at
100 to 300 man-hours.
9. Submitting a separate notification, when a modi-
fied source proposed to use contemporaneous
emission reductions as offsets, requires no in-
formation in addition to that already obtained
to fulfill the preconstruction notice require-
ments; the effort required to prepare and submit
43
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the separate notice will vary with the number
of notices (one for each emission unit retire-
ment date), but little effort will be required
for subsequent notices after the first one has
been submitted. The effort is estimated as 20
man-hours.
Table 15 presents estimated costs for Items 1 through 8.
The costs for new and modified sources are based on a burdened
rate of $35 per man-hour. The cost ranges from $2800 for a
simple new source to $26,600 for a complex modification.
4.1.3 Future Effects
The purpose of the preconstruction notice is to provide
EPA with data on construction activities that were borderline
(as far as not being subject) and for which EPA had no other
source of data. Thus, the preconstruction notice requirements
would affect only borderline sources deemed by the owners/
operators as not subject. Since it is difficult to quantify the
number of future borderline sources, the assessment of the impact
of the preconstruction notice requirement was conducted in terms
of the general effects that the proposed regulations would have
with regard to specific preconstruction notice requirements. To
illustrate the effects of the preconstruction notice requirements,
existing PSD permits were reviewed to identify sources that would
be subject to the notice requirements, each source emitting just
above the cutoff being classified as "possibles." The limits as-
sumed for classifying as possible were 100 to 150 tons per year
for the 28 source categories and 250 to 300 tons per year for
other source categories. Each source classified as possible was
further identified as either new or modified and as simple or
complex, as shown in Table 15. Then the costs were calculated
for fulfilling the preconstruction notice requirements. Table 16
summarizes the characteristics of the sources and the estimated
costs of the preconstruction notices. The total estimated cost
based on the information available is approximately $171,500 for
the 19-month period covered by the survey ($0.1 million on an an-
nual basis). This cost estimate is only indicative of the types
of situations in which the preconstruction notice would clearly
have an effect.
4.2 FUGITIVE EMISSIONS
Under current regulations, fugitive emissions were to have
been included in determining source applicability, but not all
sources within the source categories that have fugitive emissions
provided estimates of these on the PSD application. The fugitive
emissions may have been included in the stack or process emission
estimates; the sources may have ignored the fugitive emissions;
or in some cases confusion over what constitutes fugitive emis-
sions may have contributed to the lack of reporting.
44
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------- An error occurred while trying to OCR this image.
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4.2.1 Sources on List of 28
Data from PSD permit and application forms filed in EPA
Regional Offices III through X were reviewed to identify source
categories on EPA's list of 28 (the list would be 26 if sulfuric,
nitric, and HF acid plants are considered to be one category),
which would be subject to proposed regulations by including fugi-
tive emissions in the cutoff of 100 tons per year.
Based on the limited data available coke oven batteries is
the only source category on the list of 28 published in the pro-
posed regulations (see Section 2 for enumeration of this list)
that would be subject to the proposed regulations as a result of
fugitive emissions being included in calculating the potential to
emit. Interpretation of the data was difficult because of incon-
sistencies in emission classifications. Of the four coke oven
batteries in the data sample, a single figure for total particu-
late emissions was reported for one, but no fugitive emissions
were listed for another. At another battery, coal handling was
classified as a fugitive emission source, but charging, pushing,
and coking were classified as process emission sources; at two
other batteries, charging, pushing, and coking were classified as
fugitive emission sources. Thus for the assessment, the emis-
sions from each coke oven were recalculated or redistributed ac-
cording to the definition of fugitive emissions in the proposed
regulations. Coal handling, coking, pushing, quenching, and
charging were considered fugitive sources regardless of how they
were classified on the PSD permit and application forms. Accord-
ingly, all four coke oven batteries would be subject to the pro-
posed regulations if fugitive emissions were considered in de-
termining applicability. If fugitive emissions were not consid-
ered, these sources would not be subject to the proposed regula-
tions.
Sources such as Portland cement plants and coal-cleaning
facilities produce emissions in quantities greater than 100 tons
per year that could be considered "fugitive" emissions under the
proposed definition; however, these emissions were listed as
process emissions in the current PSD applications for these
sources. Since these sources are on the list of 28 source cate-
gories published in the proposal, fugitive emissions are to be
included in the calculation of potential emissions. Therefore,
no matter how these emissions might be defined, based on the pro-
posal the source would be subject to PSD review. If the proposal
would be changed, however, so that fugitive emissions would not
be included in the calculation of potential emissions for these
sources and some of the current emissions defined as process emis-
sions are redefined as fugitive emissions, there could be situ-
ations in which these sources would no longer be subject to PSD
review. This would not be the situation in all cases as some of
these sources may have facilities such as kilns or thermal dryers
that would have stack emissions in excess of 100 ton per year,
and therefore the source would still be subject to review.
47
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Additionally there are other sources such as coal-fired power
plants that emit fugitive particulate matter in quantities greater
than 100 tons per year, but they also emit equal or greater quanti-
ties of process or combustion emissions, and thus would be subject
to the proposed regulations whether or not fugitive emissions were
considered.
Many modifications not subject to current PSD regulations
would be subject to the proposed regulations because of the da
ttu.nou.-6 levels. A modified source may not increase its stack
emissions by the da. m^in-Lm^ amounts, but its fugitive emissions
could be in excess of the de. fruttxLm/c.4 levels and could cause an
otherwise minor modification to be subject to the proposed regu-
lations. For example, the addition of a storage pile handling
41 tons per day of material to an existing source could emit
over 10 tons per year of fugitive particulate matter emissions.
New well-controlled pumps handling 5500 barrels per day could
cause fugitive hydrocarbon emissions in excess of 10 tons per
day.
4.2.2 Sources Not on the List of 28
Two sources in the group of permits reviewed—a limestone-
crushing facility and a gold/silver mine are not subject to the
proposed regulations, but would be subject if fugitive emissions
were considered in the cutoff of 250 tons per year.
In the case of a limestone-crushing facility, fugitive
emissions from storage piles are reported as 750 tons per year
and would be the basis for subjecting this source to PSD review
if included for the purpose of source applicability.
In the case of a gold/silver mine, the particulate emis-
sions from the tailings pond were reported as 635 tons per year
of fugitive dust; for this assessment, these emissions were con-
sidered fugitive emissions because they are a waste product of
processing and they represent a material that had been altered
by operation of the source.
If the considerable quantities of fugitive dust emissions
from surface mines are included for the purposes of determining
applicability for this source category, then all of the mining
operations (which have received permits) would be subject to the
proposed regulations.
4.2.3 Air Quality Impact of Fugitive Emissions for Selected
Sources
Because it is believed that the inclusion of fugitive
emission for certain sources may have a significant air quality
impact especially for those emissions that are associated with
mining operations, a special assessment1 was conducted outside
this effort to determine the air quality impact of fugitive
48
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emissions from mining activities for contiguous (mine-mouth)
processing facilities once a source is subject to review. The
following types of facilities were examined:
Coal-fired power generation
Coal preparation
Indirect coal liquefaction
Direct coal liquefaction
Coal gasification
Oil shale processing
Uranium milling
Since many of the above facilities will be located adjacent to
the mine site, the mining operation would be part of the source
and the fugitive emissions from this mining operation would be
considered in any review of these facilities once the source is
subject to PSD. It should be pointed out, however, that if these
mining operations were located by themselves or were located
adjacent to sources not on the list of sources for which fugitive
emissions are to be considered in terms of applicability, their
fugitive emissions would not be considered in determining appli-
cability and unless the mine had stack emissions greater than 250
tons per year (i.e. subject to PSD), the fugitive emissions as-
sociated with the mining operations would not be considered in
terms of their air quality impact.
This assessment was conducted by developing model plants
and mines for each of the facilities listed above. Each model
plant was assumed to have applied BACT. Emission rates and stack
parameters were developed for each model plant, and the ambient
air quality impact was determined using the Industrial Source
Complex (ISC) model. The ambient impact of the plant was calcu-
lated and compared with the Class I and II increments. The as-
sociated mining operations were added to the plant emissions and
both were modeled. These revised predicted particulate concen-
trations were also compared with the Class I and II increments.
The results of the modeling analysis for the emissions from
the processing facilities alone are rather straightforward. None
of the seven types of facilities would have any problems with the
Class II particulate matter increment. The maximum TSP concentra-
tions ranged from 0.08 yg/m3 to 10.2 yg/m3. Only one facility,
uranium^milling, might exceed the Class I increment. However, if
the mining fugitive emissions are included, substantial violations
of both the Class I and Class II increment are predicted to occur.
The major source of fugitive emissions are the haul roads that
can account for up to 99 percent of the fugitive emissions depend-
ing on the model plant. Table 17 presents a summary of the re-
sults of this analysis. It'should be noted however, that the esti-
mates of the fugitive emissions from mining operations are somewhat
limited and have been questioned as to their representativeness.
In addition since this analysis used the model plant concept, the
49
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TABLE 17. MAXIMUM ANNUAL AVERAGE TSP CONCENTRATIONS AT MODEL PLANTS
Plant type
Oil shale
Coal gasification
Coal liquefaction (direct)
Coal liquefaction (indirect)
Uranium milling
Coal -fired power generation
Coal preparation
Highest concentrations,
,yg/m3
Plant
6.9
0.2
0.6
3.9
10.2
0.1
0.2
Plant and mine
w/o haul roads
25.9
28.5
31.0
33.4
44.2
16.3
16.2
Plant
and
mine
184.4
64.2
58.9
63.2
62.8
39.6
34.2
50
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specific configuration of an individual source will have an
impact upon the results especially since the maximum concentra-
tions associated with these sources were estimated to occur
anywhere from 0.5 to 1.5 km.
4.2.4 Summary
Many sources such as iron and steel mills, crushing or
grinding operations, petroleum refineries, and chemical process
emissions may not be considering fugitive emissions in their
estimates of total emissions because of confusion over fugitive
versus process emissions. Many petroleum and chemical process
sources apparently included fugitive emissions in the process
emissions estimates (based on the relative amount of total emis-
sions estimated) ; most of the sources reported process or stack
emissions that were of such a magnitude that the sources would
be subject regardless of fugitive emissions.
Although including or excluding fugitive emissions does not
appear to have a major impact on new sources (based on the availa-
ble permit data) , it may have an impact on major modifications not
subject to current regulations and not included in the data base.
Although not really increasing their stack emissions, existing
sources could modify their facility so that minor fugitive emis-
sions are emitted (e.g., the replacement or addition of valves or
pumps, ^ or the addition of a new storage pile or materials-handling
operation) that would be above the d& mJ,n£mi.A levels and therefore
the source could be subject to PSD review. No data are currently
available that would indicate the magnitude of this impact. How-
ever, it could be substantial since these minor modifications
could emit fugitive emissions above the de, m^n^mi.* levels.
Very little, if any, information regarding fugitive emis-
sions was contained in the PSD permit files. In most cases sources
did not provide any special mention of fugitive emissions except in
those cases involving fugitive dust emissions. Because of this
lack of information on fugitive emissions, very little in the way
of a quantitative assessment could be undertaken.
Finally based on the assessment of the seven model plants
that may have mining fugitive emissions associated with their
operation, the proposed regulations (which provide that fugitive
emissions associated with activities occurring at any of the 28
sources categories listed in the proposal be included in any PSD
review) _ could prevent the construction of new mine-mouth process-
ing facilities even with the application of BACT on the fugitive
emission sources.
4.3 DEFINITIONS OF SOURCE, FACILITY, INSTALLATION, AND
MODIFICATION
In the proposed regulations, the definitions of source, facil-
ity, installation, and modification differ from the definitions in
51
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the current regulations. The following sections explain the dif-
ferences and assess the effects and implications of these differ-
ences.
4.3.1 Differences in Definitions
In the current regulations, source, facility, installation,
and modification are defined as follows:
Source - any structure, building, facility, equipment,
installation, or operation (or combination thereof)
. . . on one or more contiguous or adjacent proper-
ties . . . owned or operated by the same person (or
by persons under common control).
Facility - an identifiable piece of process equipment.
Installation - not specifically defined, but included
in the definition of "source."
Modification - any physical change ... in the . . .
operation of, or any addition to a source which in-
creases the potential emission rate of any air pollu-
tant regulated under the Act (including any not
previously emitted and taking into account all accu-
mulated increases in potential emissions occurring at
the source since August 7, 1977, or since the time of
the last construction approval issued for the source
pursuant to this section, whichever time is more re-
cent, regardless of any emission reductions achieved
elsewhere in the source) by either 100 tons per year
or more for any source category identified on the
list of 28 or by 250 tons per year or more for any
other source.
As stated, a source is one or more pollutant-emitting facilities
(or installations) on the same property.
In the proposed regulations, source, facility, installation,
and modification are defined as follows:
Source - any structure, building, facility, or instal-
lation which emits or may emit any air pollutant
governed under the Act.
Facility - any grouping of pollutant-emitting activi-
ties ... on one or more contiguous or adjacent pro-
perties . . . owned or operated by the same person
(or persons under common control).
Installation - any grouping of pollutant-emitting acti-
vities '. '. T on one or more contiguous or adjacent
properties . . . are owned or operated by the same per-
son (or persons under common control).
52
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Modification - any physical change ... in the . . .
operation of ... or series of contemporaneous physi-
cal changes in ... operation of a major stationary
source that would result in a significant net increase
in ... potential to emit the pollutant for which the
. . . source is major (or that would make the . . .
source major, taking into account all accumulated net
increases in potential emissions occurring at the
source including any initial construction since August
1, 1977).
As stated, source, facility, and installation are equivalent terms
describing a group of pollutant-emitting activities on the same
property. In the current regulations, a facility is a piece of
process equipment, and a source is one or more facilities; in the
proposed regulations, a facility is equivalent to a source, and a
source is one facility. The new term "emission unit" in the pro-
posed regulations describes individual emission activities; thus
a source (or facility or installation) is a group of emission
units.
In the current regulations, a modification is a change in
any source that produces an increase in emission potential above
the cutoff of 100 or 250 tons per year; no consideration is given
to emission reductions within the source, but accumulated in-
creases from August 1, 1977, are considered. In the proposed
regulations, a modification is a change in a major source (or a
change that would make the source major) that produces a sig-
nificant net increase in the potential to emit the major pollu-
tant!(T.e. greater than the de. m-txu.m.i.4 levels) net increase
indicates the allowance of credit for contemporaneous emission
reductions.
The proposed regulations would cover most changes that
would have been considered modifications under the current
regulations, but would exclude sources with insignificant in-
creases, no increases, or a net decrease in emissions of the
major pollutant because of emission reductions elsewhere within
the source. The proposal would only include changes in a major
source that result in a significant increase (i.e., greater than
d
-------
definition of "potential to emit" from an un-
controlled to a controlled basis (more details can
be found in Section 3).
Second case - A modification to a major source
results in an increase of less than 100 to 250
tons per year in the uncontrolled emissions of the
major pollutant; the controlled emissions of the
major pollutant are above the de. m^in-Lm^ level, and
there are no reductions in emissions elsewhere in
the source. Under current regulations the modifi-
cation is not subject to review, but it is subject
under the proposed regulations because of a sig-
nificant emission increase in the major pollutant
above the proposed de m-tn
-------
review under the proposed regulations, approximately 15 percent
would have at least one facility exempt from PSD review if appli-
cability were based on an installation or facility, and in many
cases the entire plant would avoid review.
The effect of basing PSD applicability on an installation
or facility is somewhat tempered because many plants that have
obtained permits have only one facility or installation. The im-
pact is greater if the assessment includes only the sources that
have more than one facility; on that basis, approximately 50 per-
cent of the plants would have at least one facility exempt from
PSD review, and in many cases the entire source would be exempt;
thus, none of its emissions would be reviewed to assess their im-
pacts on the increments or the NAAQS's. In four cases, the
sources would have emissions when all facilities were considered
that are far in excess of the cutoff of 100 or 250 tons per year.
One source, which would not be subject if all installations were
not considered in combination, would consume 58 percent of the
24-hour TSP increment within the vicinity of the source; therefore,
a significant proportion of the increment could be consumed with-
out review, if the prpposed definitions were modified to assess
PSD applicability on each facility rather than on the entire
source.
4.3.2.2 Using Emission Reductions for Exemption—
Under the current regulations, only increases (not decreases)
in emissions are considered in determining whether a source would
be subject to PSD review; however, once a source is subject, all
increases and decreases are considered in determining whether a
BACT and an air quality impact review are needed. For a BACT ex-
emption, only those decreases that would accompany the modification
would be considered; for an air quality assessment exemption, all
increases and decreases since August 7, 1977, would be considered.
If there is no net increase after considering both the increases
and the decreases, the source would not be required to conduct a
case-by-case BACT review or a pollutant-specific assessment of
the overall air quality impact of the source. No useful purpose
would be served by requiring an impact assessment of sources that
would obviously not degrade air quality.
The proposed regulations expand the use of emission de-
creases to exempt the source from the entire PSD review, not just
the BACT and air quality impact reviews. The court (in Alabama
Power) held that a change in a major source is subject to PSD re-
vJew only if it results in a net increase in the source's po-
tential to emit. The court also held that any emission increase
that is offset entirely by a contemporaneous emission reduction
would not be considered a modification and therefore would not
be subject to review.
Only a physical change in a major source may be considered
in calculating contemporaneous decreases. A narrow interpreta-
tion of "contemporaneous" would restrict emission decreases to
55
-------
those that would occur at the same time as the emission increases.
This interpretation would seem to undercut the incentive for
sources to decrease their emissions by upgrading their control
equipment in advance of the modification or the increase in emis-
sions from the source. Continuing to operate obsolete equipment
with significantly higher emissions than the proposed modifica-
tion makes little economic or air quality sense.
4.3.2.3 Documentation for Reduction Credits—
The proposed regulations would permit the crediting of
any reduction that occurs after the promulgation date of the reg-
ulations but before the proposed increases are scheduled to occur.
Credit may be retained if the source files a notice (within 90
days after promulgation) reporting the shutdown or curtailments
that occurred before promulgation. A followup notice would be
required to document the construction schedule for the proposed
modification and emissions increase.
Since current regulations permit only reductions that occur
at the time of the proposed modification, it is difficult to
assess the overall impact of the proposed changes regarding the
crediting of reductions for avoiding PSD review. Because only
the decreases that occurred with the increase were reported in
the current PSD files, there are no data on how many and what
type of decreases had occurred and could be reported by a source
after promulgation to offset future increases.
4.3.2.4 Impact of Netting Under PSD—
Assessment of the total number of modifications that would
be exempt from review as a result of the netting exemption was
not possible based on the data in the PSD pe;rmit files, but a
limited analysis was undertaken using data on simultaneous emis-
sion reductions that were used by sources to avoid BACT review
under the current regulations. Five example; modifications were
selected: two separate industrial boilers, an electric arc
furnace, natural gas compressors, and a lime; kiln. The increases
and decreases associated with these sources in Table 18 are typi-
cal of those that could be used by sources under the proposed
regulations.
Other types of decreases that may be used have not been
identified to date. Because only simultaneous emission re-
ductions could be used under the current regulations, the effect
of the netting concept could not be completely analyzed. Based
on the data from the permits issued to date,, however, it does ap-
pear that this concept in and of itself in the absence of the de.
m^in-Lm^ concept would have a marked effect on the number of
sources subject to review and on the costs associated with PSD.
4.3'. 2.5 Impact of Modification Definition—
Changing the current definition of modification to the pro-
posed definition would have far-reaching effects on the applica-
bility of the PSD regulations, as shown in Table 19. There are
56
------- An error occurred while trying to OCR this image.
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TABLE 19. EFFECTS OF PROPOSED REGULATIONS ON MODIFICATIONS REVIEWED UNDER
CURRENT REGULATIONS
U.S.
EPA
region
III
IV
V
VI
VII
VIII
IX
X
Total
Number
of
modifi-
cations
13
38
10
49
9
12
18
2
151
• i i • i i
Number with
>100 or 250
tons/yr con-
tolled
5
15
6
32
4
4
11
2
79
Number with <100 or 250
tons/yr
Above
cfe mivumJ*
levels
6
17
3
14
4
4
5
0
52
Below
de. mlrumti
levels
2
6
2
3
1
4
2
0
20
58
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151 modifications for which data were gathered. These modifica-
tions were obviously subject to current regulations. Of the 151,
79 had controlled emissions above the cutoff of 100 to 250 tons
per year without any emission reductions elsewhere within the
source; thus, these 79 would also be subject to the proposed regu-
lations; 52 had controlled emissions below the cutoff of 100 to
250 tons per year, and had one or more pollutants for which con-
trolled emissions exceeded the de. m^in^m^ levels without any off-
sets indicated; the other 20 had no pollutant for which controlled
emissions exceeded the de, m-tfu.m,u, levels. If all 52 were major
emitters for the pollutant exceeding the dz. m^in^m*.* levels, these
modifications would be subject to the proposed regulations, but if
some of the 52 sources were not major, then they would not be sub-
ject. Therefore, 52 is the outside estimate of the number of
modifications below 100 or 250 tons per year that would be subject
to review. The actual number may be somewhat less depending on
the major source status of the existing source. The proposal,
however, would clearly exclude the modifications (20) that result-
ed in emissions less than the de. m^in^im^ levels regardless of
whether the sources were major or not.
The following conclusions were drawn from the analysis of
the proposed and current definitions of modification.
1. Of the modifications subject to the current
regulations, 14 percent would not be subject
under the proposed regulations. (If those
located in nonattainment areas were included,
approximately 24 percent would not be subject.)
2. Of the modifications subject to current regu-
lations, 52 percent would be subject under the
proposed regulation.
3. Of .the modifications subject to the current
regulations, 34 percent may or may not continue
to be subject, depending on whether or not the
source was major before the modification and
whether the sources can offset the increases by
the netting provision.
Based on the data, a higher percentage of modified than
new sources would be subject under the proposed regulations, but
the actual numbers of modified and new sources appear to be less
than under the current regulations. However, this could be an
erroneous conclusion especially for modified sources. Modified
major sources that would increase emissions above the de. m-Ln^im^
limits, but that would have increases less than 100 to 250 tons
per year were not subject to the current regulations (and thus
not in the PSD permit files). They would, however, be subject to
the proposed regulations. Currently these sources are only subject
to the State's NSR procedures. In fact, many States do not con-
sider modified sources of 10 to 20 tons per year a major source of
59
-------
emissions; therefore, these sources are reviewed only to ensure
that they meet the State's emission limits, unless there is evid-
ence that air quality problems may exist as a result of the modi-
fication.
States do not summarize and thus do not routinely report
to EPA the amount of emissions from minor sources, but these data
would be in the State permit file. To determine how many sources
a year would have emissions more than de. m-iYi
-------
the total modifications per year. Thus, the number that would be
expected from only those with existing emissions of greater than
100 tons per year would be approximately 1200. Based on the pro-
posed definition, it is estimated that approximately 1200 addi-
tional modifications per year would be subject to PSD over and
above those that are now currently subject to review and which
would continue to be subject to review based on the proposed "de.
levels.
Because the above estimate was developed as a result of com-
munication with state agency personnel rather than a direct re-
view of the files, no estimate was obtained on the distribution of
these modifications based on their total emissions. An estimate
is made, however, in the following section on the de. mj.n4.m£& emis-
sion levels that can be used to obtain an indication of the rela-
tive number of additional modifications which would be subject to
PSD as a result of modifying de m4.n-e.m-c6 levels in the September 5
proposal.
4.4 VE MIMIMIS EMISSION LEVELS
The goals of improving and preserving air quality are best
served by using the limited control agencies' resources effective-
ly. Neither air quality improvement nor efficient administrative
operations are served by requiring preconstruction reviews of
sources that have no significant impact on air quality. Establish-
ing de m-cn-cm-ti cutoffs enables agencies to centralize efforts,
mobilize resources, and concentrate on sources that significantly
affect air quality.
The PSD requirements are generally more stringent than SIP
or other limits, and thus their implementation, in lieu of other
limits, tends to decrease emissions and to enhance air quality.
Because the requirements are more stringent and complex, greater
manpower and cost demands are imposed on both the permit applicant
and the reviewing authority.
The emphasis of preconstruction review for both the permit
applicant and the control agency reviewer should be on sources
that significantly impact air quality.^ Thus, exemptions have
found favor with both the regulated and the regulator as a method
of eliminating the unimportant from an otherwise all-encompassing
regulation.
The purpose of this analysis was to quantify the changes in
source applicability that would occur as a result of applying the
proposed pollutant-specific and the varying de. m-tn-tm-ci values in
place of the single 50-ton-per-year value as the cutoff criteria
for requiring a detailed review. The analysis does not address
the merits and deficiencies of the de m-tn-tm-cA approach as the
basis for the values in the proposed regulations. The effects
61
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that alternate de. m^n^m^ values would have on inclusion or ex-
clusion of sources and emission units and on review requirements
of the PSD program are examined.
4.4.1 Application of Pe. M/in-im-ca Guidelines
Pollutant-specific guidelines for excluding or limiting
the review of proposed construction can exempt major new and
modified sources from PSD and nonattainment requirements when
emissions are below a specified significant emission rate (de
m-cn-cm-c.4 value) and/or air quality impact for a pollutant.
The de. mJiYiUwLb values in Table 20 are used for two main
purposes:
1. To determine whether a modification to a
major source is subject to PSD and/or nonat-
tainment permit requirements.
2. To identify the pollutants to which BACT must
be applied and an air quality review must be
conducted for a major new or modified source
once the source is subject to PSD.
The values in 'Table 21 are used to limit the requirement
for air quality review. The table is applicable to a source with
the potential to emit regulated pollutants in amounts greater
than the cfe. m^.n^.mx.4 values of Table 20. The table is not applica-
ble to sources in nonattainment areas, to sources that adversely
impact a Class I area, or to sources that emit pollutants in ex-
cess of the cutoff of 100 or 250 tons per year.
4.4.2 Applicability of BACT/Air Quality Peviews
The current and the proposed regulations provide different
criteria for deciding the applicability or nonapplicability of the
BACT and air quality review requirements. The proposed regula-
tions would tend to both increase and decrease the number of
sources subject to BACT and air quality impact reviews. For new
sources, the changes would:
1. Decrease the number of sources subject by
eliminating from BACT and air quality reviews
those sources that have controlled emissions
less than 100 or 250 tons per year by eliminat-
ing those between the present cutoff of 50 tons
per year and the cutoff of 100 or 250 tons per
year (proposed definition of "major stationary
sources") .
2. Increase the scope of reviews for sources sub-
ject (greater than 100 or 250 tons per year
62
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TABLE 20. PE MINIMIS LEVELS
Pollutant
Tons/yr
Carbon monoxide
Nitrogen dioxide
Total suspended particulates
Sulfur dioxide
Ozone (VOC)
Lead
Mercury
Beryllium
Asbestos
Fluorides
Sulfuric acid mist
Vinyl chloride
100
10
10
10
10
1
0.2
0.004
1
0.02
1
1
Total reduced sulfur
Hydrogen sulfide
Methyl mercaptan
Dimethyl sulfide
Dimethyl disulfide
Reduced sulfur compounds
Hydrogen sulfide
Carbon disulfide
Carbonyl sulfide
1
10
10
63
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controlled emissions), by requiring reviews
for all regulated pollutants emitted in greater
than d amounts.
For modified sources, the changes would:
1. Decrease the number of modifications subject,
by eliminating from review proposed modifica-
tions at plants where the overall existing con-
trolled emissions including the emissions from
the proposed modification are less than 100 or
250 tons per year, and by eliminating from re-
view those modifications at major sources whose
emissions would be offset by emission reduc-
tions at the source such that the net increase
in emissions would be less than the de. mJin.Jin\Jik
levels. However, as stated earlier the data
to determine whether a modification occurs at a
major existing source are somewhat limited.
2. Increase the number and depth of the reviews
for modifications at major existing sources by
requiring that any net increase in emissions
in excess of the de. m
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3. The annual tonnage of controlled emissions
from each unit and for each pollutant.
If the annual emissions were not recorded (usually for trace ele-
ments from combusted fuels), emission factors were used in per-
forming the necessary calculations to estimate the annual emis-
sions. '7
4.4.4 Reviews Required by Proposed and Current Values
The data base was examined to determine both the number of
sources that would be subject to review and the approximate num-
ber of BACT and ambient air quality reviews that would be required
if the proposed de. minimi* values (Table 22) were used as the
criteria for the reviews.
Each modified emission unit within an industrial plant
(major stationary source) was assumed to be subject to a BACT re-
view for each regulated pollutant emitted from the source in
greater than de. minimi* amounts. Thus, if a modified cement
kiln at a major existing source emitted S02, PMf and N02 in great-
er than de. minimi* levels, the kiln would be subject to^three BACT
reviews; if the plant had emitted greater than the de. minimi*
values for S02, PM, and NOX and had three modified emission units
that each emitted S02, PM, and N02, nine BACT reviews would be
required.
On a plantwide basis, one air quality review ^was assumed
for each pollutant emitted in greater than de. minimi* amounts.
Thus, even if each of three emission units emitted a common pol-
lutant (and that pollutant only) in amounts greater than de. mini-
mi*, only one review was assumed; if each of the three emitted
three different pollutants all of which were greater than de.
minimi* amounts, on a plantwide basis, nine BACT and three air
quality reviews would be required.
As can be seen from Table 22 the effect -of doubling the
de. minimi* emission limits for TSP, SO2, and NOX would have the
effect of decreasing the number of BACT and air quality reviews
by 24, 8 and 6 percent, respectively. The amount of TSP, S02,
and NOX emissions subject to review, however, would only be re-
duced by 3, 0.1 and 0.0 percent, respectively.
4.4.5 Number of Sources Subject to Review as a Result of Impos-
ing Various Ve. ^nim^* Emission Levels
To examine the effects that alternate de, minimi* values
would have on the number of sources subject, a series of _ graphs
were constructed for each pollutant. Both new and modified
sources were included to increase the number of sources for which
the analysis was performed even though only those sources classi-
fied as modified would be directly affected as far as overall ap-
plicability to PSD is concerned. Only those new sources that
66
------- An error occurred while trying to OCR this image.
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might be representative of the type of emission changes or modi-
fication that would be expected in the future and that had less
than 100 tons per year of emissions per pollutant were included.
On that basis, there were 219 sources of PM, 216 for S02, 217 for
NOX, 167 for CO, 166 for VOC, 65 for Be, 60 for Hg, 1 for TRS, 1
for F, and 1 for Pb. These plots for PM, S02,r NOX, CO, VOC, Hg,
and Be are shown in Figures 3 through 9. Insufficient data were
available to construct similar plots for the other pollutants
listed.
While the de mj.nJ,mi.A levels are pollutant specific, very
few sources emit just one pollutant. Therefore, the above pol-
lutant specific analysis does not necessarily provide an indica-
tion of the absolute number of sources that would be subject to
review given certain de m^in^m^ levels. Thus, while a source
would no longer be subject to review for TSP because it had net
emission changes of less than 10 tons per year, it would still
be subject to review because it had changes in S02 emissions of
20 tons per year. In order to obtain some estimate of the total
number of modifications that would be subject given specific re-
vised de. m emission levels, all 151 modifications of the
471 permits that were reviewed in detail were evaluated and cate-
gorized according to the greatest amount of emission from any of
the criteria pollutants that would be emitted from the source as
a result of a net change in emissions. For example, if a source
had emission changes of 10 tons per year of PM, 25 of S02/ 30 of
NOX/ and 110 of VOC, it was categorized as having an emissions
change of greater than 100 tons per year. Therefore, unless the
de m-ccu.m-t.4 levels were raised to above 100 tons per year for VOC,
it would still be subject to PSD even if the de mJLYii.n\Lt> levels
for all other pollutants it emitted as a result of the change
were raised to 35 tons per year. The data from the above analysis
were plotted and the results shown in Figure 10. Only 5 criteria
pollutants were considered in the analysis of the 151 modifications
since none of the modifications reported emission estimates for
lead and very few provided estimates for noncriteria pollutants.
If the same general emissions distribution of modifications
that have received PSD permits to date holds true for those modi-
fications that were not previously subject to review, then one
can obtain some estimate of the impact of selected de m/tn/tm-cA
levels for all modifications (currently subject plus those not
currently subject to PSD) that would be subject to PSD review
as a result of the proposed regulations. Figure 11 combines both
these data sets on modifications by using the distribution for
the ones that have received permits to date.
Although Figure 11 provides an estimate of the total modifi-
cat^ons that could be subject based on various de m
------- An error occurred while trying to OCR this image.
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140
120
100
t-
ro
OJ
q 80
UJ
60
40
20
Figure 4,
20 . 40 60 80
NUMBER OF SOURCES LESS THAN VE MIWIMIS LEVEL
Distribution of sulfur dioxide emission sources versus various
de m4.YiwU> emission levels.
-------
20
40 60
NUMBER OF SOURCES LESS THAN VE MIWIMIS LEVEL
100
Figure 5. Distribution of nitrogen oxide emission sources versus various dn nvuunvu emission
levels.
-------
N)
120
s_
to
OJ
c:
o
100
80
60
-* 40
uu
20
40 60 80
NUMBER OF SOURCES LESS THAN VE MINIMIS LEVEL
100
Figure 6.
Distribution of carbon monoxide emission sources versus various de
emission levels.
-------
UJ
120
emission levels.
-------
0.8
0.6
0.5
QJ
l/l
q 0.4
0.3
0.2
0.1
20 40 60
NUMBER OF SOURCES LESS THAN VE MINIMIS LEVEL
80
Figure 8. Distribution of mercury emission sources versus various dn
mA-YLimAA emission levels.
-------
Ul
0.05
0.03
0.01
QJ
t/>
2 0.008
uu
0.006
0.004
0.002
20 40 60
NUMBER OF SOURCES LESS THAN VE MIWIMIS LEVEL
Figure 9. Distribution of beryllium emission sources versus vari-
ous de m^Yuji\Li> emission levels.
-------
120 —
CTi
20 40 ' 60 80 100 120
NUMBER OF SOURCES LESS THAN VE MIWIMIS LEVEL
140
Figure 10. Distribution of modifications which had received permits
as of November 1, 1979 versus various dc. m^Yiunit, emission levels.
-------
100
»•
200
300
400 500 600 700 800
NUMBER OF SOURCES LESS THAN PE MINIMIS LEVEL
t major sources
f the September
900
1000
1200
not
-------
combination of de. m-in^im-c^ levels considered. In order to deter-
mine the difference in selecting various de. mxru.m-c.6 levels by
pollutant versus selecting one common level, the following de.
m vs. 50 tons per year cutoff) in emis-
sion units subject, would be 13 percent. The values shown should
not be considered absolute, since the data base was compiled un-
der the current regulations and may not encompass all emission
units or all pollutants that would be subject to the proposed
regulations and does not reflect the impact of sources using the
netting provision to avoid BACT and air quality reviews.
78
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TABLE 23. EFFECTS OF SELECTED VE MINIMIS LEVELS
Cutoff
None
50% of da. mJiYuxiik
V& mlywnuA
200% of do. m-oum-A
300% of do. min^rnU
50 tons/yr
100 or 250 tons/yr
Number of emission units emitting more than cut-
off for one or more pollutants
1
366
310
256
223
208
210
140
2
67
107
95
108
117
101
94
3
111
108
119
90
81
64
36
4
62
59
48
39
27
25
8
5
112
25
13
10
10
37
25
6
6
15
15
19
16
0
0
7
70
28
19
4
2
0
0
8
1
1
0
0
1
0
0
9
1
1
1
1
0
0
0
'To-
tal
799
654
566
494
462
437
303
Number
of
emission
units
subject,
% change
+82
+50
+30
+13
+ 6
0
-31
Number
of
revi ews
required
BACT
2200
1460
1350
1150
885
935
600
AQI
1160
770
710
605
465
490
315
Percent change is percentage increase or decrease in emission units subject, by using the cutoff based on com-
parison of the 50 tons/yr cutoff in current regulations.
BACT is a review to determine if Best Available Control Technology has been applied; AQI is review of predict-
ed impact on air quality.
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4.4.7 Implications of the Analysis
Previous PSD determinations represent the best available
data base for an analysis of this nature, but data limitations
did exist for the intended purpose—the proposed regulations con-
tain new or substantially altered provisions at variance with
those that formed the basis for the original determinations. For
example/ the current regulations exempt major modifications of
less than 100 or 250 tons per year of uncontrolled emissions;
thus, modifications at existing sources that would not increase
the emissions by 100 or 250 tons per year (regardless of the
existing source size) were not subject to PSD review, and thus are
not in the data base. In contrast, the proposed regulations use
de m-tnxtm-cA cutoffs that are generally less than 50 tons per year,
and subject the modifications at major sources with greater than
de mj.ni.m-iA emissions to review. Accordingly, the number of
modifications with emissions between 50 tons per year of control-
led emissions (less than 100 or 250 tons per year uncontrolled)
and the generally lesser de m
-------
PSD permit in any part of an AQCR designated as unclassifiable or
attainment, it establishes the baseline date for PM and S02 in
all parts of the AQCR.
Since there are significant differences between the current
and proposed baseline definitions, an analysis was undertaken to
determine the impacts of the proposed change. Because the court
gave EPA no discretion in using the date of the first permit rath-
er than the uniform date, the analysis centered on the potential
impact of defining the area as an AQCR.
4.5.1 Approach to the Analysis
The basic approach used in this assessment was to determine
the effective baseline date for an area depending upon how the
area would be defined, and then to calculate how much land area
would be included for four time periods under two definitions—
AQCR and county. A third definition—area of source impact—was
not included because limited data were available in the permit
files, and without data on the impact area of a source (area where
concentrations would decrease to insignificant levels), it was
impossible to quantitatively analyze the potential national im-
pact of using this third definition.
Each final permit in the PSD survey that would be subject
to the proposed regulations was reviewed to determine the date
on which the application was completed. These dates were listed
by county for sources subject to the proposed regulations to ob-
tain the date of the first permit in the county, and the counties
were grouped by AQCR's to determine the date of the first permit
in the AQCR. Data on each county and AQCR were collected to de-
termine the amount of land area that would be included under the
proposed and one alternative definition of baseline area.
Four dates from August 8, 1977, to September 5, 1979, were
selected for estimating the land area to be included in the defi-
nition and to analyze the potential impact of choosing one area
definition over another. This assessment does not, however, speak
to the issue of administrative feasibility regarding the selec-
tion of the baseline area. This assessment must be by its very
nature qualitative rather than quantitative. It must address con-
cerns such as: simplicity, uniformity, ease of tracking the
increment, and availability of data for assessing the impacts of
unreviewed sources in terms of increment consumption.
4.5.2 Qualitative Analysis of the Proposed and Alternative Area
Definitions
The proposed regulations define the area subject to PSD as
an AQCR. Because the baseline date would be uniform throughout
an attainment or unclassified AQCR, the administrative problems
resulting from many baseline starting dates are minimized. It
81
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has been argued, however, that the AQCR could encompass a broader
area than needed to avoid multidate confusion.
A source impact area, in contrast, would require a detailed
system to track the many baseline dates within the area. As
more and more permits are issued, the sources' impacts would
overlap and the tracking or recordkeeping would become more com-
plex. Both sources and agency personnel would find it difficult
to ascertain at any given time what area must receive minor
source reviews and when such sources would begin to consume the
available increment. Each proposed new source would find it in-
creasingly difficult to predict how much increment might be left
for consumption, to calculate even roughly how much minor source
growth might have taken place, and to decide what date should be
used in these calculations.
Emissions and air quality data are not readily available on
source impact areas, but they are readily available and easily
retrieved for a county or AQCR. Availability of data makes the
recordkeeping, especially for periodic evaluations, easier for
the general public.
Public participation is a basic objective of the PSD program
set forth in the Act:
... to assure that any decision to permit
increased air pollution in any area . . .
is made only after careful evaluation of all
the consequences of such a decision and after
adequate procedural opportunities for informed
(underlining added) public participation in the
decisionmaking process.
Varying baseline dates within a county would make it difficult
for the general public or the sources to reasonably track the PSD
process and to intelligently determine how area growth has been
or will be allocated. One uniform baseline 'date for the smallest
political jurisdiction possible would increase the public's under-
standing of the baseline concept and allow them to more reasona-
bly participate in the permit-granting process.
4.5.3 Quantitative Analysis of the Definitions
A quantitative analysis was performed and it provided data
on the percentage of AQCR's or counties that would have the base-
line date established at certain times; on what this percentage
might mean in terms of total U.S. land area and the relative size
of the area; and on dates from which minor source growth would
consume the available increment.
Table 24 presents the results of the analysis using the
proposed AQCR and one alternative definition. If a permit had
82
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been received for an area either for TSP or S02, the area was de-
termined to have the baseline established. In the table, the
number of AQCR's and the land area significantly increase as the
number of sources applying for permits increases; thus, the
sources are not necessarily locating in the same AQCR's, but are
geographically spreading across the country. This spreading is
even more dramatic in the county analysis.
TABLE 24. EFFECTS OF BASELINE AREA DEFINITIONS
September
January 1
1, 1977
, 1978
July 1, 1978
January 1
September
, 1979
5, 1979
Total
AQCR
Number
1
5
23
66
98
193
mi2
21,823
193,445
425,420
1,134,175
1,539,150
3,314,013
County
Number
2
7
31
106
172
318
mi2
11,021
24,474
73,140
172,462
227,009
508,106
4.5.3.1 Effects of AQCR—
With 247 AQCR's in the country and with a total U.S. land
area of 3,615,211 square miles, approximately 40 percent of the
AQCR's and 43 percent of the land area already have a baseline
date established as of September 5, 1979. Therefore, minor source
growth would consume increment in these areas. More than 25 per-
cent of the AQCR's have a baseline date prior to January 1, 1979.
For approximately 50 percent of the AQCR's, only one permit has
been issued to date. Therefore, this one permit would cause a
great, deal of area to be affected in terms of increment tracking
under the current proposal.
Because of the large sizes of many of the AQCR's and because
one source could trigger a review of minor source growth for an
entire AQCR, an analysis was conducted to determine if using a
county rather than an AQCR might have the baseline match more
closely the area where the source is expected to have its impact,
and yet be reasonable to administer.
4.5.3.2 Effects of County—
The county analysis indicated that only 6 percent of the ap-
proximately 3000 counties or county equivalents and 6 percent of
the land area would have a baseline date prior to September 5,
1979. By using this approach the amount of area (in number and
size) in which minor source growth would be consuming the availa-
ble increment would be substantially reduced. Although this ap-
proach would not prevent one source from affecting an entire
area's baseline date, it would significantly reduce the area that
would be affected.
83
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The AQCR and county analyses above were based on the assump-
tion that if a permit were issued for either TSP or S02, the base-
line was triggered for both pollutants. If, however, the base-
line is pollutant specific, slightly less area per pollutant would
be included in the baseline for the four time periods used in the
analysis. However, because most of the permits issued to date
were for TSP and S02 and many sources emitted both pollutants,
the amount of land area per pollutant would only be 1 or 2 per-
cent less than the numbers presented above.
4.5.3.3 Effects of Source Impact Area —
If one assumes that the area of impact of a source is a
circle with a radius of 15 miles (half the maximum distance for
which current models can reasonably perdict) , the area would be
approximately 700 square miles; this would equal or exceed the
land area for most counties in the analysis. If two or more
sources in a county have been issued permits, the source impact
areas would overlap and the amount of area would quickly exceed
that of a county. Even if the radius is only 5 miles (not un-
reasonable for a moderate size source) , the impact area would be
75 to 80 square miles, so several sources could still closely
approximate the land area contained in many smaller to moderate
sized counties if the sources were separated by any distance at
all. Thus, the county, based on available data, approximates
the relative amount of land area that would be in an impact
area, but does not introduce the administrative complexities
of having a number of baseline dates within a county or politi-
cal jurisdiction.
4.6 OTHER ISSUES AND THEIR RELATIVE IMPACTS
4.6.1 Pollutant Applicability
The proposed regulations determine on a pollutant-by-pollutant
basis whether a source is subject to PSD review. However, once
a source is subject for the pollutant for which it is major, it
must meet the BACT and air quality requirements for all other
pollutants emitted in levels above the de. m£n.im analy-
sis had ^ more than one pollutant greater than the proposed de. m-c
rr\4.A limits, the impact of considering pollutants other than the
one that is major, could be considerable, depending on which de.
levels are finally promulgated (Section 4.4).
4.6.2 Innovative Technology Waiver
In the current regulations, it was proposed that the innova-
tive technology control waiver be applicable to BACT determina-
tions under PSD; since no adverse comments were received, speci-
fic language has been proposed in the September 5 regulation to
implement the innovative technology waiver for BACT.
84
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Section lll(j) of the Act states
Any person proposing to own or operate a new
source may request the Administrator for one
or more waivers from the requirements of
this section (New Source Performance Stand-
ards—added) for such a source or any portion
thereof with respect to any air pollutant to
encourage the use of an innovative technologi-
cal system or systems of continuous emission
reduction . . .
The proposed regulations require that a source with a Sec-
tion lll(j) waiver must as part of the innovative technology
waiver include an emission limit and a schedule for meeting the
limit. The source must still satisfy the air quality analysis
requirements by using its projected emissions after the lll(j)
controls are installed. Any increase above the permitted emis-
sion level would be treated as temporary and as having an insig-
nificant air quality impact. The regulations also proposed to
apply the innovative technology waiver to sources not subject
to NSPS and therefore not directly eligible for Section lll(j)
waiver. The criteria for these waivers would be similar to
those established for lll(j) waivers.
Since no data were available on the innovative technology
waiver, a quantitative analysis was not conducted. Because this
proposal could increase the likelihood of sources installing in-
novative technology, it would have a positive environmental im-
pact and little adverse economic impact because it would be
something that the source itself would choose to do rather than
something imposed on it. Unless there is a positive financial in-
centive, however, few sources would select innovative controls.
4.6.3 Secondary Emissions
The proposed regulations define secondary emissions as those
from new or existing sources that result from construction and/or
operation of a major source or modification; they do not neces-
sarily come directly from the source. Secondary emissions would
include, but are not limited to the following:
1. Emissions from ships or trains coming to or
from a source or modification.
2. Emissions from support sources constructed
offsite that would increase emissions as a
result of the construction of a major source.
Secondary emissions are not proposed to count in determining the
potential to emit. If a source is otherwise subject to PSD re-
view, the BACT requirement would not apply to secondary emissions.
85
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However, well-known and quantifiable secondary emissions would
be counted in terms of the impacts on the ambient air quality in-
crements or standards. Sources are required to consider all minor
source growth that has taken place since the last permit has been
issued in the area when they assess the impact of their facility;
secondary emissions would be considered minor sources for this type
of analysis. Therefore/ since secondary emissions are to be con-
sidered in terms of their impact on the increment, the only ques-
tion remains when and by whom should they be considered? If the
source to which they are related does not consider them, the next
source to obtain a permit would have to do so; therefore, it seems
reasonable that the source which creates quantifiable secondary
emissions should include them in assessing the* overall impact of
the source.
No additional economic impact would be expected as a re-
sult of the proposal concerning secondary emissions, since these
emissions were included in the current regulations as part of
the minor source assessment of increment consumption. The pro-
posed regulations only propose to shift the responsibility for
conducting the air quality assessment from the applying source
to the source that actually causes these secondary emissions
to occur.
4.6.4 Portable Facilities
Under the current regulations, permitted sources must sub-
mit a 30-day notice prior to relocation. Based on experience
with the current regulations, the proposed regulations reduce
the amount of time to 10 days. While the impact of reducing the
time from 30 to 10 days was not assessed, it is reasonable to
conclude that the shorter time would reduce any previous delay
costs associated with the current regulations. Since most porta-
ble facilities are asphalt plants and since most permitted asphalt
plants would not be subject to the proposed regulations as a re-
sult of the proposed change in the definition of potential emis-
sions, the impact of this change is not expected to be signifi-
cant. However, for the few asphalt plants that would be subject
to the proposed regulations, the time delays between construction
projects would be significantly shortened.
4.6.5 Nonprofit Institutions
Under the current regulations nonprofit .health or education-
al institutions can be exempted from PSD requirements, upon writ-
ten request by the Governor of a State. The proposed regulations
would extend this exemption to modified nonprofit health or edu-
cational institutions (as well as those newly constructed). This
extension would have a major impact on the number of these sources
that would be subject to review. Without this exemption, these
modified institutions would only have to emit in excess of the
86
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de m-cn-tm-c^ levels to be subject to review. Since most modifica-
tions to these facilities (i.e., adding an incinerator or modify-
ing a steam plant) would cause emissions in excess of the cfe. rn.-t.n-
xcm-ci levels, many of these sources would be subject to review ,
without a specific exception.
The impact of not imposing the exemption could be substan-
tial since many modified nonprofit health or educational facili-
ties could be subject to review. However, adverse environmental
impacts associated with imposing the exemption would be minimal
since most facilities would have only minor additional controlled
emissions, but enough to subject them to PSD review because of
the de. m-in^.m^-f> requirements. Because no data were currently avail-
able, no quantitative assessment can be conducted regarding this
provision.
87
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REFERENCES FOR SECTION 4
1. The Impact of Including Fugitive Emissions From Mining
Operations on Contiguous Processing Facilities, Draft,
March, 1980. Energy and Environmental Analysis, Inc.
2. Personal communication with P. Fairchilcl, Northeastern
States Commission on Air Quality Management, February 25,
1980.
3. Personal communication with H. Johnson, Ohio Environmental.
Protection Agency, February 22, 1980.
4. Personal communication with M. Sowell, Division of Environ-
mental Management, State of North Carolina, February 19, 1980.
5. Personal communication with J. Preece, Department of Environ-
mental Regulation, State of Florida, February 21, 1980.
6. Compilation of Air Pollution Emission Factors, Second Edi-
tion, Publication No. AP-42, U.S. Environmental Protection
Agency, February 1976.
7. Emission Factors for Trace Substances, Publication No.
450/2-73-001, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, North Carolina 27711. December 1973.
88
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SECTION 5
IMPACT OF PROPOSED REGULATIONS ON NONATTAINMENT AREAS
(Geographic Applicability)
Several definitions and concepts addressed in the court
decision (Alabama Power) were relevant to the statutory require-
ments for areas where pollutants exceed NAAQS's. Thus, the pro-
posed regulations changed some of the requirements for nonattain-
ment areas. The requirements involve definitions of new and
modified stationary sources subject to preconstruction permitting;
definitions of source, facility, and installation for avoiding
new source review under the no-net-increase provision; and the
issue of geographic applicability—that is the areas to which the
PSD regulations would apply.
In the preliminary opinion (June 1979) to the decision,
the court held that the proposed PSD provisions would apply only
to major new or modified sources locating either in areas desig-
nated as attainment or unclassifiable or in areas for which the
source would substantially impact a clean air portion of another
State; the proposed regulations conformed to this decision. How-
ever, the court's final decision (December of 1979) held that
PSD review would apply only to major sources being constructed
in clean air areas. In order to protect clean air areas from
major sources that may be constructed in any nonattainment areas,
the court indicated that EPA would have to rely on its authority
under Sections 110 and 126 of the Clean Air Act to resolve inter-
state air pollution problems. Accordingly, the proposed PSD reg-
ulations would apply only in attainment or unclassifiable areas
and would not apply as such in nonattainment areas. It should be
pointed out, however, that attainment and nonattainment areas often
overlap and that many areas are designated as both attainment or
nonattainment depending upon the pollutant. The application of
the PSD regulations is dependent on the nature of the pollutants
emitted by a source. For example, some sources that emit pollu-
tants which are designated as nonattainment for certain areas
would have to meet the nonattainment provisions, while for other
pollutants emitted by the source the PSD provisions would apply.
The current regulations apply to sources in all areas, so the
proposed regulations would exclude some sources from review that
were previously subject.
Sources in nonattainment areas might not be subject to the
proposed PSD regulations for certain pollutants. To determine
89
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the potential impact of this requirement, data from the survey
of the final PSD permits were reviewed to identify sources that
had received permits and were planning to locate in a designated
nonattainment area.
Under the current regulations regarding nonattainment new
source review, if a source located in a clean portion of a des-
ignated nonattainment area could demonstrate that it would impact
only the clean portion of that designated area, it did not have
to meet the more restrictive nonattainment requirements—apply-
ing the Lowest Achievable Emission Rate (LAER), obtaining offsets,
and ensuring statewide compliance by all sources owned by the pro-
posed new source. Under the proposed regulations even if a source
demonstrates that it is located in a clean portion of a nonattain-
ment area, it would have to meet the more restrictive nonattain-
ment provisions for the pollutants for which it is major and des-
ignated as nonattainment. Likewise sources located in clean air
areas but which impact nonattainment areas would only have to
meet the PSD requirements.
Of the 604 permits issued under current regulations, 73
permits were for sources located in nonattainment areas—44 new
and 29 modified sources. Table 25 indicates that five of the
modified and 29 of the new sources would have controlled emissions
of less than 100 o£ 250 tons per year or the de. m-cn-tmxC-6 levels
(as applicable), and therefore would not be subject to the nonat-
tainment nor the PSD requirements. The emissions from those
sources that have received PSD permits as of November 1979 and
which would no longer be subject to review are summarized in Ta-
ble 26. These sources would be subject only to the general new
source review requirements of the SIP; therefore, the emission
limits that many of these sources would be required to meet would
be less restrictive than those imposed by either the PSD or non-
attainment requirements. The SIP limits were not in the PSD per-
mit file for most sources, so no overall assessment could be made
of additional emissions that would be permitted by the proposed
regulations.
Overall cost savings to the sources as a result of meeting
less stringent requirements could not be calculated without the
knowledge of the SIP requirements. However, a few permit files
for sources located in nonattainment areas did indicate the SIP
limit. Examples of the emissions associated with these limits
by industry category are in Table 27. The average for the few
source categories for which information was available indicates
that for the source not subject to the PSD and nonattainment re-
quirements there would be an increase of 1.5 to 2 times the cur-
rent emissions. However, most of these sources only have emis-
sions of 25 to 50 tons per year, and therefore this twofold in-
crease would still be less than the cutoff of 100 tons per year
which would subject a source to nonattainment review.
90
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TABLE 26.
EMISSIONS FROM SOURCES LOCATED IN NONATTAINMENT AREAS THAT
WOULD NOT BE SUBJECT TO THE PROPOSED REGULATIONS9
(Tons/yr)
PM
361
S02
373
VOC
271
CO
33.3
N0y
278
Only includes those sources in the survey of PSD permits
conducted as part of this analysis.
TABLE 27. SIP VERSUS PSD PERMIT LIMITS
Source
category
Lime
Fiberglass
Cement
Tape coating
Lead oxide
PM
SIP
42.6
14.0
142.0
19.5
PSD
15.3
11.2
49.9
9.0
Differ-
ence
27.3
2.8
92.1
10.5
S02
SIP
PSD
40.3
12.0
Differ-
ence
VOC
SIP
91.4
PSD
54.0
Differ-
ence
37.4
Many of these sources, instead of increasing their emissions
to the limit allowed, would use the additional reductions as fu-
ture offset credit. Because these emissions represent only slight
differences in control efficiency—99.9 percent for 50 tons per
year and 99.8 percent for 100 tons per year—the associated cost
savings would not be significant. This would not be true if the
source decided to install a less efficient control device, but
even then the source may install the same basic control equipment
and operate it at less than its design efficiency to gain short-
term energy savings until it decides to use the additional emis-
sion reduction (above those specfied in SIP or NSPS) as offset
credit.
A source is considered to be subject to nonattainment review
and therefore not subject to PSD review if it proposed to locate
in an area designated as nonattainment for all the pollutants
that it emitted. If it emitted any other pollutants for which
the area were designated as attainment, it is considered to be
still subject to PSD for those pollutants and therefore considered
in the calculation of the total number of sources subject to the
proposed regulations. Of the permits in the survey, 15 new and
24 modified sources would no longer be subject to PSD for a num-
ber of pollutants for which they are major. In some cases, the
source would still be subject for some of the pollutants for
which it was major because the area has not been designated as a
nonattainment area for these pollutants. It is assumed that if
a source were major for at least one pollutant that all other pol-
lutants above the dn. n\
-------
designated as attainment would still be subject to PSD review.
The number of sources subject to PSD review was not changed even
if the criteria to subject a source to PSD review were any emis-
sions rather than emissions above the de. m
-------
that had applied LAER revealed that (in many cases) the LAER
limit was equal to the BACT limit. Therefore, these sources
would not incur any additional control technology cost. A few
sources indicated that the LAER limit was more stringent than '
the BACT limit, but because of limited data it was impossible to
assign a cost for those few sources.
The cost of obtaining offsets for these sources could not
be determined since no data were available on where these sources
might obtain offsets. Past practices indicate that these sources
would obtain internal rather than external offsets. Because most
of the sources in nonattainment areas were modifications, they
would likely obtain their offsets by replacing or closing down
old polluting facilities or by meeting more stringent controls
on the existing facilities. Little if any data are available on
the costs of obtaining internal offsets since these vary sig-
nificantly from source to source.
Although the 34 sources that would no longer be subject to
PSD review and/or nonattainment review would obtain some cost
savings as a result of the proposed regulations, the 31 sources
that would now be subject to the more restrictive nonattainment
requirements would incur some additional costs. Since the number
of sources no longer subject to review (34) is very close to the
number that would receive additional review (31) and the type of
sources are very similar in each case, it was assumed, based on
the limited data available, that the overall cost as a result of
geographic applicability would be the same under the current and
proposed requirements since the total savings under one would be
offset by the costs imposed by the other.
95
-------
APPENDIX A
MONITORING COSTS
96
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TABLE A-3. NITROGEN DIOXIDE MONITORING COSTS
(1978 dollars)1
COSTS
•Capital costs:
Location:
Selection
Negotiations'5
Easement payments0
Equ ipmen t :
Sampler/analyzers
Calibration equipment
Tel erne try/ recorder s
Shelters^
Installation:
Site preparation
Calibration of equipment
Other:
Personnel/training6
Support equipment
(gas regulators)"5
Spare parts
Operating costs:
Fixed:
Rent'
Utilities (else, and heat]
Insurance/security'
Variable:
Reagents
Zero and span gases
Other supplies
(chart rolls)
Sample/data collection
Maintenance and repair
Supervision and quality
control
Supervisory
Quality control
TOTAL
Purchaa
No.
units
1
1
1
• 2
2
25
Cost, $
5870
8300
820
150
25/mo
263
10
3
Total
cost, S
i
5870
8300
820
300
300
526
250
M
Level/Rate,
S/h
Professional/14 .40
Technician/11. 50
Professional/14. 40
Technician/11.50
Professional/14 .40
Supervisor/21. 20
Chemist/17. 30
inr
Hours
24
I
6
6
260
BO
78
40
Cost, S
346
Total capital
expenditure, S
346
5870
1660C
820
69
87
2990
1152
1654
692
69
87
300
9152
Annual i zed
cost, SJ
69
1174
332
164
14
17
60
300
526
250
2990
1152
1654
692
9394
* Based on 5-year amortization.
b Should be included if costs are incurred.
c Assuming the unit is uoed on 5 analyzers.
d Accounted for in network costs.
e Included in burdened labor rate.
1 Not included if monitor is on public property.
-------
TABLE A-4. OZONE MONITORING COSTS
(1978 dollars)
COSTS
Capital costs:
' Location!
Selection
Negotiations'5
Easement payments"
Equipment:
Sampler/analyzers
Calibration equxpment
Telemetry/recorders
Shelters"
Installation)
Site preparation
Calibration of equipment
Other:
Personnel/training6
Support equipment
(gas regulators)
Spare parts
Operating costs:
Tixed:
Rentc
Utilities (elec. and heat
Insurance/security'
Variable:
Reagents
Zero and span gases
Other supplies
(chart rolls)
Sample/data collection
Maintenance and repair
Supervision and quality
control
Supervisory
Quality control
TOTAL
No.
units
1
1
1
3
2
2
25
Purchase
Cost, S
4500
8300
620
150
25/mo
100
281
10
8
Total
cost, $
4500
8300
820
450
300
200
562
250
Level/Rate,
S/h
Professional/14 .40
-
Technician/11. 50
Professional/14 . 40
*
Technician/11.50
Professional/14.40
%
Supervisor/21.20
Chemist/17.30
Hours
24
6
6
260
80
78
40
Cost, $
346
69
87
2590
1152
1654
692
Total capital
expenditure, $
346
4500
1660C
820
69
87
450
7932
Annual izcd
cost, Sa
69
900
332
164
14
17
90
300
200
562
250
2990
1152
1654
692
_ __ _ —
93B6
.'
o
o
* Based on 5-year amortization.
b Should be included if costs are incurred.
c AoBuwing unit is used on five analyzers.
Accounted for in network costs.
* Includod in burdened labor rate,
f Not included if monitor is on public property.
-------
TABLE A-5. TOTAL SUSPENDED PARTICULATES MONITORING COSTSd
(1978 dollars)1
COSTS
Capital costs:
Location :
Selection
Negotiations^
Easement payments^
Equipment :
Sampler/analyzers
Calibration equipment
Tel erne try/ recorders
Shelters6
Installation:
Site preparation
Calibration of equipment
Other:
Personnel/training f
Support equipment'
Spare parts
(pumps, etc.)
Operating costs:
Fixedi
Rent9
Utilities (clec. and heat)
In sura nee/ security 9
Variable:
Filters
Other supplies
Sample/data collection
Maintenance and repair
Supervision and quality
control
Supervisory
Quality control
TOTAL
Purchases
No.
units
1
1
1
Cost, S
512
170
25
10/mo
25
Total
cost, S
512
170
120
25
L.ibor
Level /Rii to,
S/h
Professional/14. 40
Tcchniciiin/1 1 . 50
Professional/1 4. 40
Technician/11.50
Professional/14.40
Supervisor/21 . 20
Chemist/17. 30
Hours
24
•1
4
61
18
8
8
CcisL, S
34 f,
46
SB
702
259
170
138
Total capital
cix|ien
-------
o
NJ
TABLE A-6. NETWORK CODE (A)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
n.Qnltor,d>. before adjustment
Quantity discount
(\ x annualiied equipment
costc x no. of stations)
Total annualiied costs
(per pollutant monitored)
Shelter costs
Shelter aiie, ft
3.5 x <.0
U>-X_LJ>
<5\J) x B.Q>)
32.0 X 8.0
Other
No. oC shelters
)
i
.5
V— '
Cost per shelter
.
c $ •
< $ «
« 5 3£>oO |
K $ '
* s
Subtotal
tiond
cars
• ••!• 1 1
Annualized
shelter costs
$
$
$ 9 o & &
$ '
s
*s a f> r>
I i ' i'' i i _ ULi i LJI • Yearly mileage
No. of stations Average distance, miles No. of visits per yea 7
wage rato/h • I
wage rate/h » S
Subtotal
Total annualixed network cost
Costs obtained from individual tables in Section 3.0.
" Dependent on vendor and quantity, but generally between 2»
« Annualized equipment costs obtained from individual tables in Section 3.0.
d Aasumes 5 years.
-------
o
co
TABLE A-7. NETWORK CODE (B)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualized station costs (per pollutant monitored), before adjustment _
Pollutant monitored
" T^> P
/N!O ™5
,s&3
cO
No. of
stations
Annualized
station cost
"^ x S f\ ~> n ./
"~> x $ ' ^ ' •
3 x | /JOJ?
~5 x s
•— J x S
Subtotal |
Subtotal
Quantity discount
(% x annualized equipment
cost0 x no. of stations)
S
S
S
S
S
$
$
1 x S
I x S
I x $
\ x S
% x S
\ x 5
\ x S
x )
X )
X )
X )
X )
X )
X )
Total annualized costs
v> v> v> v>
costs
O *-' <^
z ;, ' '.}_xL
Vehicle operation
Labor cost
No. of stations
x
X
X
Subtotal
Total annualized
Average distance, miles No. of visits per year - Yearly mileage
v m X 0 .
x . x 0.
x - ( i mph)
network coat | |
/mile
/mile
x S
x S
- S
- S
wage rate/h ™
wage rate/h -
r
v
S
s
* Costs obtained from individual tables in Section 3.0.
b Dependent on vendor and quantity, but generally between 2\ and 18%.
0 Annualiied equipment costa obtained from individual tables in Section 3.0.
d Assumes 5 years.
-------
TABLE A-8. NETWORK CODE (C)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualired station coats (per pollutant monitored), before adjustment
Pollutant monitored
TS P
;VOv
^
S03
No. of
stations
Annualized
station cost
Subtotal
Quantity discount
l\ x annualized equipment
costc x no. of stations)
Total annualized costs
(per pollutant monitored)
x $///<• S -( \ x $ x )- S Z? -^ "El £>
-? x $ /k' ^ 5 -( *x$ x )- \p~rrF'f>
^ x $ _ 5 -( * * $ x '" !:> C* /
3 x $ /3QO7 5 - ( x x $ x ' " ° •
x$ S -(\x$x '"?
x$ S -|tx$x )-$
Subtotal
L 07C/
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
jieirorxra^ori
32.0 x 8.0
Other
No. of shelters
Cost per shelter
Depreciation^
period, years
x S »
^ x I ^00& 1
^ x S »
x S »
Subtotal
shelter costs
$
$
$
$
S
9/)/),O
Travel costs
Vehicle operation
Labor cost
No. of stations
Average distance, miles
No. of visits per year - Yearly mileage
v * x 0.
. ' x x -
x x . " ( < "P")
Subtotal
Total annualized network cost
/mile
/mile
x S
x $
. — •
- S
- S
wage rata/h •
wage rate/h -
V
S
1 (oGO'l, —
4 Costs obtained from Individual tables in Section 3.0.
b
Dependent on vendor and quantity, but generally between 21 and 18%.
c Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
-------
o
U1
TABLE A-9. NETWORK CODE (D)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED'COSTS OF AIR MONITORING NETWORK
Annualized station t
Pollutant monitored
CO
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0^
32^0 x 8.0
Other
Travel costs
Vehicle operation
Labor cost
.«.»•« (per pollutant monitored), before adjustment
g .... r _.J. --'u ^ = X-.~-^ — <- b
Quantity discount t.
/« v annualized equipment Total annualized costs
.?:;,± .s;:;1^ s^i '»:""»""", .;»;..., <,.« ,»».«« m«.^
t 1 i 91T( 1 "- i i:.i ** i 1 .sIXs
3 x S/
-------
TABLE A-10. NETWORK CODE (E)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
o
cr\
Annualized station costs (per pollutant monitored), before adjustment
Pollutant monitored
SDZ
. ,-v *"
/^s. u y^
No. of
stations
Annualized
station coat
"3. x $
— ^ x S
~) x S
•/— x $
x $
x S
x S
Subtotal
Subtotal
Quantity discount
(\ x annualized equipment
costc x no. of stations)
13027 j : |
*z y £\ */ 5 '
1 J 1 1 $ (
S - (
S - (
S - (
t x
\ X
X
X
X
X
X
S
$
S
5
S
$
$
x
X
X
X
X
X
X
Total annualized costs'"
(per pollutant monitored)
) $
) S
) 5
) S
) S
) S
) S
59 £ mph)
/mile • $
/mile - S
x $ wage rate/h - 5
x S wage rate/h - 5
1 /7/T^
b Dependent on vendor and quantity, but generally between 2\ and 18%.
c Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
. / / / t
b 7 y £/
;
-------
TABLE A-ll. NETWORK CODE (F)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Pollutant monitored
/MOX
'
No. of
stations
Annualizcd
station cost"
Subtotal
(\
Quantity discount
x annualized
cO3tc x no. of
«~i x S / • S 1
x S S - (
x $ S - (
x S S - (
x $ S - (
x S S - (
Subtotal
I x $
I x $
1 x S
\ x S
t x $
t x S
I x $
equipment
stations)
Total annualized coats ~
(per
x ) 5
x ) $
x ) S
x ) S
x ) S
x ) S
x ) $
pollutant monitored)
,s-7£2
/# 7 £/?
Shelter coats
Shelter size, ft
3.5__x_-UO^
(7.0 x 7 . O._i>
16.0 x 8.0
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation^
period, years
x S *
c^> I 5^:*C> ;
x S «
x S »
Subtotal
Annual ized
shelter costs
S
S
S
S
S
VAOD
Travel costs
Vehicle operation
Labor coat
No. of stations Average distance, miles
No. of visits per year - Yearly mileage
x x x 0.
x x x 0.
x x " ( ' rnph)
x x • ( ! roph)
Subtotal
Total annualized network cost
/mile
/mile
x S
x S
- $
- $
wage rate/h • I
wage rate/h - S
I (,00
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 21 and 181.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
-------
o
CO
TABLE A-12. NETWORK CODE (G)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annual
ized station costs (per pollutant
Pollutant monitored
T~<"D
I v— ^ '
£0-2.
faO*
'V^P
NO. Of
stations
monitored), before adjustment
Annualized
station cost
O, * * /
3 x S '-
X S 2
•— * x S
y S
S x S
Subtotal
Subtotal
Quantity
discount
(\ x annualized equipment
cost0 x no.
k /6 $ - (
-, <=} V s ' <
•> ' L $ - t
r>c> ' $ - (
^ S - (
76^*50 s - (
- S - (
\ x $
t x $
\ x $
\ x S
\ x S
t x ?
I x S
of stations)
x
x
x
x
x
x
x
Total annualized costs
(per
) S
) S
) S
) S
) 5
) - s
) " 5
pollutant monitored)
~,^ ?*..&
ft O r>-
i i~\ /O F 1
^i .' <-^CJ '
7 (3*3 • d> (5
^ 1 8 Ul.&D
Shelter costs
Shelter size, ft
3.5 x 4.0
32.0 x"" B.O
Other
Ho. oC shelters
)
>
—^ >
^J >
>
Subtotal
Cost per shelter
c $•
: i^ooo
< s
Depreciation^
period, years
Annualized
shelter costs
S
S
S
S
s
^OOO
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year « Yearly
xx-
XX"
x x -it
X X " ( I
Subtotal
Total annualized network coat
mileage
x 0.
x 0.
mph)
mph)
/mile
/mile
x $
x $
• S
- S
wage rats/h »
wage rate/h •
V
$
1 — • —
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2\ and 181.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
-------
TABLE A-13. NETWORK CODE (H)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualiicd station costs (per pollutant monitored), before adjustment
O
VO
Pollutant monitored
~T~^"V"~'
\ -— ' >
No. of
stations
Annualized
station cost
Subtotal
(t
Quantity
discount
x annualized equipment
costc x no.
-v x $ / / / ^T- $ - (
0X1 x S / ^ ' ^ $ -(
x $ S - (
x $ S - (
x S $ - (
x $ • S - (
x $ S - (
Subtotal
» x $
\ x S
t x S
t x S
I x S
% x $
» X $
of stations)
x
x
x
x
x
X
X
Total annualized costs'"
(per pollutant
$ -0 - -;,
$ O'-' vL>
S
$
s
s
$
monitored)
.
^ 3,^r>
Shelter costs
Shelter size, ft
3.5 x 4.0
1.0 x T.O
16.0 x 8.0
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation .
period, years
x S t
x S f
x $ t
x S *
x S *
Subtotal
Annual izcd
shelter costs
$
S
S
S
S
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles No. of visits per year = Yearly mileage
x x = x 0. /mile - S
x x x 0. /mile - $
x x - ( i mph) x S wage rate/h • 5
x x • ( ; mph) x S wage rate/h - S
Subtotal 1
Total annualized network cost //]/")
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2» and 18%.
Annualized equipment costs obtained from Individual tables in Section 3.0.
Assumes 5 years. f-~j O •— , >.
-------
TABLE A-14. NETWORK CODE (I)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZEU COSTS OF AIR MONITORING NETWORK
An"»»li*od station coats (per pollutant monitored), before adjustment
Pol
lutant monitored
TS>P
co"
Toe.
No. of
stations
Annualized
station cost
Subtotal
Quantity discount
(\ x annualized equipment
cost0 x no. of stations)
^ x S ] U/'O S - (
2 * $ i ,.,.,7, , S - (
-^ x $ -1 O V- V ,' 5 - (
x $ ^ -) ^ __- $ - (
Subtotal
1 x S
I x S
% x $
\ X $
\ x S
1 X $
t x 5
X
X
X
X
X
X
X
Total annualized costs
(per pollutant monitored)
) S
) S
) S
) S
) $
) S
) S
jSJ
V3
O
^ t
•/*y.s~
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation ,
period, years
x S +
x * <', *
^ x $"" *
x S *
Subtotal
Annualized
shelter costs
$
S
$
S
5
9.-.ijn
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year » Yearly mileage
x x - x 0.
x x - x 0.
"x x - ( ' mph)
x x " i ' inph )
Subtotal
Total annualized network cost
/mile
/mile
x $
x S
« S
- S
wage ratc/h -
wage rate/h -
c
V
$
1 __ — ' —
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 21 and 18».
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years,
5^.50
-------
TABLE A-15. NETWORK CODE (J)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualized station costs (per pollutant monitored), before adjustment
Pollutant monitored
Nin
r** v- x •
TST>
NO. of
stations
a.
Annualized
station
~) x $ 93
•^ x $
~N x S / (y
<=J x $
X $
x S
x $
Subtotal
cost*
Subtotal
Quantity discount
(\ x annualized
cost0 x no. of
y^J-S -( » x $
S - ( \ x S
1 *-, S - ( » x S
' ^ $ - ( % x $
S - ( % x S
S - ( 1x5
S - ( % x S
equipment
stations)
x
X
x
x
x
x
X
e.
Total annualized costs
(per
) S
) $
) S
) S
) 5
) S
) S
pollutant
It "."?.'
3 D. ~.O
monitored)
>~
*30 1 *
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
i-$~~ O^XHB — ffi'
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation^
period, years
x S *
x S *
/-, x S— >.3/">A*
«< x 5 ^^ ^U ,
x S »
Subtotal
Annualized
shelter costs
S
S
S
S
S
./ .
a
Travel costs
Vehicle operation
Labor cost
No. of stations
Average distance, miles
No. of visits per year • Yearly mileage
x x x 0.
x x x 0.
x x " ( '' mPh)
x x = ( •: mph)
Subtotal
Total annualized network cost
/mile
/mile
x $
x S
- S
- S
wage roto/h - 5
wage ratc/h - S
C,or>
Costa obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 1\ and 18%.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes S years.
-------
TABLE A-16. NETWORK CODE (K)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annuallied station costs (per pollutant monitored), before adjustment
Pollutant monitored
7~"^>P
1 *— -* *
SO-,
No. of
stations
Annualized
station cost
Subtotal
Quantity discount
(\ x annualized
costc x no. of
9 * s / Lo J ^ $ "' * x $
o< xS S -f 1 x S
^Z * $ i ? i-) 37 s - < *x$
— ' x S /0^ S -( % x $
x S $ - ( I x $
x S S - ( I x S
xS "S - ( .* x S
Subtotal
equipment
stations)
Total annualized costs
(per
x ) S
x ) S
x ) 5
x ) S
x ) S
x ) S
x ) S
pollutant monitored)
3 0 3 O
, ("** /
3?
ft,) »
"2 x $ -*-O <^(-/ f
— > x $ *
x S *
Subtotal
Annual ized
shelter costs
$
$
S
$
S
()
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year • Yearly mileage
x 0.
x x x 0.
x x • = ( i mph)
x x « ( = mph)
Subtotal
Total annualized network cost
/mile
/mile
x $
x S
- $
• $
wage rate/h • C
wage rate/h - S
LOO
a Costs obtained from individual tables in Section 3.0.
b Dependent on vendor and quantity, but generally between 21 and IBt.
0 Annualized equipment costs obtained from individual tables in Section 3.0.
d
Assumes
years.
-------
TABLE A-17. NETWORK CODE (L)
• . . SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annuallzed station coats (per pollutant monitored), before adjustment
OJ
Pollutant monitored
^
No. of
stations
Annualized
station cost8
Subtotal
Quantity discount
(\ x annualized equipment
cost0 x no. of stations)
^ x S , -7/V5Y 5 ( % x S
h"-> x S ' —*^ $ - ( % x $
x $ • S - ( \ x S
x S S - ( t x S
x S S - ( » x $
x S $ - ( t x $
x $ $ - ( \ x S
Subtotal
Total annualized costs
(per pollutant monitored)
x • S
x $
x 5
x S
x $
x S
x ) - 5
37 0 f !
3-s 3 y I
Shelter costs
Shelter
3.5
<^LJ£
"16. 0
32.0
size
x 4.
xT.""
x 8.
. ft
0
b~^
0
Other
No. of shelters
Cost per shelter
Depreciation .
period, years
x S t
<• x $ J> J3 O O t
^ x $ t
x $ i
x $ «
Subtotal
Annualized
shelter costs
$
S
S
$
S
/,•' 'Y '•' ^
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year - Yearly mileage
x x x 0.
x x x 0.
x x » ( i mph)
x x - ( • mph)
Subtotal
Total annualized network cost
/mile
/mile
x S
x S
- 5
- S
wage rato/h « 5
wage rato/h » S
1 fno
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2\ and 18%:
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes S years.
s 1
-------
TABLE A-18. NETWORK CODE (M)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Pollutant monitored
^- _
\ __} A
c o
No. of
stations
Annualized
station cost
Subtotal
Quantity discount
(\ x annualized
costc x no. of
-> x S //, /^ -S - » x S
— •* xS../S - » x S
-2 x S /O*7 V / $ - % x S
-> x $ S - t x $
x $ S - * x $
x S S - ^ x $
x S S - . * x S
Subtotal
equipment
stations)
Total annualized costs "*
(per pollutant
x ) S 3 ^ 3 (
x ) $
x ) $ 3 1 3 ™>
x ) S
x ) S
x ) S
monitored)
1>
3
J?y .< yr.?
Shelter costs
Shelter size, ft
3.5 x 4.0
<~~ T. o x 1 _u>-
16.0 x 8.0
32.0 x 8.0
Other
No. of shelters
Cost per shelter
Depreciationd
period, years
x $ -, *
-^r x 5 cv-—> £-*C^ *
^ x S *
x $ *
x S *
Subtotal
Annualized
shelter costs
$
$
S
S
U^OO
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year » Yearly
x x
XX'
- 1 '
x x - ( «
Subtotal
Total annualized network cost
mileage
x 0.
x 0.
mph)
rnph i
/mile
/mile
x S
x S
- S
• S
wage ratc/h "
wage ratc/h «
J
S
(-,& Q
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 21 and 18%.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
-------
TABLE A-19. NETWORK CODE (N)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualtzcd station costs (per pollutant monitored), before adjustment
«"=• — • — • -- '
Pollutant monitored
-y-C^-p
Pb
No. of
stations
Annualized
station cost
-3 x S
x $
x S
x S
x S
x $
Subtotal
Subtotal
Quantity discount
(% x annualized
cost0 x no. of
ill'— S - ( % x S
/<=»'--' $ - \ x S
- t-; - S - » x $
U? ' ; $ - I x S
S - % x $
S - % x $
S - 1 x $
equipment
stations)
x
x
x
x
x
x
x
Total annuallzed costs
(per
) $
) S
) $
) S
) S
) S
) S
pollutant monitored)
3- 2,6
(^y 1
, :."70-/
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
16.0 x 8.0
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciationd
period, years
x $ *
x $ *
x S t
x $ t
x S *
Subtotal
Annual ized
shelter costs
$
S
S
S
S
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles No. of visits per year « Yearly mileage
x x » x 0. /mile » $
x x » x 0. /mile • S
x x • ( ' mph) x S wage rate/h » 5
x x " ( • mph) x S wage rate/h • S
Subtotal 1 J
Total annualized network cost (a Sj ^~\
a Costs obtained from individual tables in Section 3.0.
b Dependent on vendor and quantity, but generally between 2% and 18». , i
c Annualized equipment coats obtained from individual tables in Section 3.0. (J y ^~ ^-~.
Assumes 5 years. )
-------
L.'.J
TABLE A-20. NETWORK CODE (0)
.. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualiied station coat* (per pollutant monitored), before adjustment
Pollutant monitored
1 A
Ix ^
£.0
-'—
No. of
stations
Annualized
station cost*
Subtotal
Quantity
discount
(I x annualized equipment
costc x no.
'-} x $ £ 3 5" ~J S ~( tx$
x $ $ -(\xS
-7 X $ ,t l)37 $ ' ( l * $
2> x $ '^^ $ - ( t x $
x $ S - { \ x 5
x S S - ( \ x $
x $ $ ( I x S
Subtotal
of stations)
Total annualized costs
(per
x ) $
x ) S
x ) $
x ) $
x ) $
x ) 5
x ) $
pollutant monitored)
10 ^
-------
TABLE A-21. NETWORK CODE (P)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualized station costs (per pollutant monitored), before adjustment
Pollutant monitored
CO
No. of
stations
Annualized
station cost0
Subtotal
Quantity discount
(\ x annualized equipment
coat0 x no. of stations)
•2 x S 1 , vi \J / $ "' * x $
-$ x$/OY// $ -( * x S
-) x $,,/<- $ -( * x s
-< x S ' U ^_ 5 - ( » x $
x. t- /""* c 1 \ %/ C
3x5 i"^.f\ ~) 1 * -I » x *
x $ /•^>^o' 5 . ( i x $
x S S - ( I x $
Subtotal
Total annualized costs
(par pollutant monitored)
x ) $
x ) S
x ) $
x ) $
x ) S
x ) S
x ) $
31 3^> 3
73 d^ ^ .
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
32.0 x eTo '
Other
No. oC shelters
j
j
3 ;
j
Subtotal
Cost per shelter
i S
< $
< $ "2, o C- O
t $
< $
Depreciation^
period, years
Annualized
shelter costs
$
S
$
$
$
-? O 'Vr)
Travel costs
Vehicle operation
Labor cost
No. of stations
Average distance, miles
No. of visits per year - Yearly
x x -
x x "
x x - ( '
x x - ( «
Subtotal
Total annualized network cost
1
mileage
x 0.
x 0.
mph)
mph)
/mile
/mile
x $
x $
• S
• S
wage rato/h •
wage rate/h »
(?0f)
J
$
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 21 and 18t.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes S years.
-------
CO
TABLE A-22. NETWORK CODE (Q)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualtied station costs (per pollutant monitored), before adjustment
Pollutant monitored
/ ^>P
f^O y
S(>2
fce
rl/T
No. of
stations
Annualized
station cost"
Subtotal
Quantity
discount
(\ x annualized equipment
costc x no. of stations)
P. x $ / L> /'" 5 "1 1 x $
-*- x $ ' $ - ( \ x $
•5 x $ /_?op *7 s - ( \ x $
x $ 7 £,? '-/> 5 - ( \ x $
x $ ow$ _{ XxJ
x $ / J-2> O $ - { . » x S
Subtotal
Total annualized costs
(per pollutant monitored)
x ) $
x ) S
x ) 5
x ) S
x ) $
x ) $
x ) $
S o> 3~®
5? "7 S* &
Jfcs I
~7L=>.^ Q
/ ^-^>O
/ '-'• 0 F 1 . o~T>
Shelter costs -^
Shelter sire, ft
3.5 x 4.0
CTe^o—x-B .- o-—--*
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation .
period, years
x S »
x $ t
•2 x 5 3oo
but generally between 2t and 181.
Annualized equipment co«ts obtained from individual tables in Section 3.0.
Assumes S years.
$ /0,£SA
-------
TABLE A-23. NETWORK CODE (R)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualtred station
Pollutant monitored
C-O
Shelter costs
Shelter size, ft
3.5 x 4.0
7.0 x 7.0
32.0 x 8 .V
Other
Travel costs
Vehicle operation
Labor cost
costs (per pollutant monitored), before adjustment
Quantity discount ^
No. of Annualized (\ x annualized equipment Total annualized costs
stations station cost" Subtotal costc x no. of stations) (per pollutant monitored)
3 x$/^vX/-$ -( * x s x ) s -? ; ^ L i
x S ,, ov/ - S - ( t x S x ) * ' - '
S x $ 9 -i ° v - s -( »x$ x ) $;S7£cT
0 x$~^-v>-;-S -( \ x $ x ) 5
3 x s I 2. o 3 / . $ - ( t x $ x ) $ 6 <7 C j. /
xS -5 - ( \ x S x ) S
xS -S - IxSx ) $
Subtotal ft ^ i - • i '
Depreciation. Annualized
No. oC shelters Cost per shelter period, years shelter costs
x S » S
x S » S
3 x $ >30/*0 i s
05 x $ « S
x $ » J
Subtotal ] Q 1 /U^
No. of stations Average distance, miles No. of visits per year - Yearly mileage
x x • x 0. /mile • S
x x x 0. /mile - S
x x - ( ) mph) x S wage rate/h - 5
x x • ( i mph) x $ wage rate/h - S
. /_ O'"")
Coats obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 21 and 18\.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes 5 years.
7?,
-------
TABLE A-24. NETWORK CODE '(S)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
NJ
O
Pollutant monitored
CO
N'O/
TGf
No. of
stations
Annualized
station
-T x S
^ x $
-} x S
^ x S
x 5
O x S
x $
Subtotal
\oy
32
/&/
cost
Subtotal
(\
Quantity discount
x annualized
costc x no. of
( V / S - (
S ~" (
i S v*
3>- '-
i- '.•,
monitored)
-•' *Cj
s
' y
i O
-v/ /,
Shelter costs
Shelter sire, ft
3.5 x 4.0
7.0 x 7.0
«1.6TO_xr870.^
32.0 x 8.0
Other
No. of shelters
Cost per shelter
Depreciation .
period, years
x $ »
x $ »
•^ x 5^3000
x $ I
Subtotal
Annualized
shelter costs
$
S
$
S
S
O n c> f ".
Travel costs
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year » Yearly
XX"
XX"
x x . - ( I
x x • ( i
Subtotal
Total annualized network cost
I
mileage
x 0. /mile
x 0. /mile
mph) x S
mph) x $
•• s
- S
wage rato/h « J
waqe rate/h - $
( 1 (/ (-^
a Coats obtained from individual tables In Section 3.0.
b Dependent on vendor and quantity, but generally between 21 and 1B\.
c Annualized equipment costs obtained from individual tables in Section 3.0.
d ,
Assumes 5 years.
-------
TABLE A-25. NETWORK CODE (T)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualized station costs (per pollutant monitored), before adjustment
Pollutant monitored
3
No. of
stations
Annualized
station cost*
Subtotal
Quantity discount
(\
x annualized
costc x no. of
O^i x S - S I
"— *^J2 x S / -^O ^ / . s |
x $ - $ - (
x S - S - (
x S - S - (
x S - $ - (
x S - $ - (
Subtotal
\ x S
V x S
\ x $
t X $
\ X $
\ x 5
t x $
equipment
stations)
x
X
X
X
X
x
x
t_
Total annualized costs
(per
) S
) $
) 5
) S
1 S
) $
) S
pollutant monitored)
7<^r> <~ \
o i ° r, i
Shelter costs
Shelter size, ft
3.5 x < ^0
1 6 ! 0"1T~8T6>
32.0 x 8,0
Other
No. oC shelters
Cost per shelter
Depreciationd
period, years
x $ _ '
•? x % ^ -: o O *
— ' x $ *
x $ «
x $ <
Subtotal
Annual ized
shelter costs
$
S
S
S
S
V9£)O
Travel costs
Vehicle operation
Labor cost
No. of stations
Average distance, miles
No. of visits per year - Yearly
XX"
x x -
x x - ( '
x x - ( t
Subtotal
Total annualized network cost
\
mileage
x 0.
x 0.
mph)
wph)
/mile
/mile
x $
x S
- S
• $
wage rat«/h • '
wage rate/h • S
(,0ft
Costs obtained from individual tables In Section 3.0.
Dependent on vendor and quantity, but generally between 2\ and IBt.
Annualized equipment costs obtained from individual tables in Section 3.0.
Assumes S years.
-------
TABLE A-26. NETWORK CODE (U)
SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualiied station costs (per pollutant monitored), before adjustment
NJ-
Pollutant monitored
CO
No. of
stations
Annualized
station cost"
3V C /
x SX
3 * * >
x $
x S
x S
x $
Subtotal
Subtotal
Quantity discount
(X x annualized equipment
contc x no. of stations)
0^/1 S - (
S - (
S - (
5 - (
$ - (
X x $
X x S
X x S
X x S
X x $
X x $
X x S
Total annualized costs
(per pollutant monitored)
x ) S ?
X ' $^
x i $ c5
x ) S
x ) S
x ) S
x ) $
7
,5-
0V
1
g
0
*?
Shelter costs
Shelter sire, ft
3.5 x 4.0
7.0_x_JU.O
^i-erd x 8.0— -
3270 x 8.0
Other
No. oC shelters
Cost per shelter
Depreciation .
period, years
x S *
V x $ *
— > x $ .?> OC- O t
x 5 »
x $ »
Subtotal
Annualized
shelter costs
$
S
$
S
$
oryx5*)
Travel coats
Vehicle operation
Labor cost
No. of stations Average distance, miles
No. of visits per year - Yearly
XX"
xx-
x x - ( »
X X " ( '
Subtotal
Total annualized network cost
1
mileage
x 0. /mile
x 0. /mile
mph ) x 5
mph) x S
- $
- S
wage rato/h - 5
wage ratc/n - S
Loo
a Costs obtained from Individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2\ and 181.
c Annualized equipment costs obtained from individual tables In Section 3.0.
Assumes 5 years.
^o.oo?.
-------
to
U)
TABLE A-27. NETWORK CODE (V)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualized station costs (per pollutant monitored), before adjustment ._ ._
Pollutant monitored
.~. — •
1^ ^"L-
fte
HQ
NO. Of
stations
Annualized
station cost
„
31 x S
x S
^— ' Subtotal
Subtotal
Quantity discount
(\ x annualized equipment
cost0 x no. of stations)
) 9f) D"~7 S (
9-"?^ $ - i
fff <* _ /
/ L^?£/ • ^J ^^ C _ (
S - (
/cOO- S - (
\ x $
t x S
\ x $
\ x S
X x $
\ x S
\ x S
x
X
X
X
x
X
X
Total annualized coats
(per pollutant monitored)
) S
) S
) S
) S
1 5
) 5
) S
•^•9 6 /? /
/? 7S£-
7{,J.
.' f 2 0 .
-°
l'°.jV,$l-5V
Shelter costs
Shelter size, ft
3.5 x 4.0
T..o__x_?_._g_
32.0 x 8.0
Other
No. oC shelters
Cost per shelter
period, years
s i ^/ (s(2 ^O
~C* s ^^ ^tP ^^ ClI' f
x 5 *
x $ '
Subtotal
shelter costs
$
S
S
$
$
€/>""!
Vehicle operation
Labor cost
No. of stations
Average distance, miles
x x . x 0.
x x - x 0.
-x - ( i I"?0)
* x . ( i mph)
Subtotal
Total annualized network cost
/mile
/mile
x S
x $
« S
- S
wage rato/h « C
wage rate/h » S
1 £06
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2\ and 181.
Annualized equipment coats obtained from individual tables in Section 3.0.
Assumes S years.
-------
•NJ
TABLE A-28. NETWORK CODE (W)
. SAMPLE CALCULATION SHEET FOR
ANNUALIZED COSTS OF AIR MONITORING NETWORK
Annualizcd station costs (per pollutant monitored), before adjustment
Pollutant monitored
T3? .
^°a
OjO
)£y^~'
No. of
stations
Annualized
station cost
Subtotal
Quantity discount
(\
x annualized
coatc x no. of
1 x s //„ / ^ $ '
tX. x $ 5 ~ (
* t ^ ,
-z x * i "7A "•>*/
-— ? x S /oOo*/ $ - (
x s .WT ,N $ - (
v S / k ** «*3 {/ S ™ (
x 5 - S - t
Subtotal
I x $
X X $
X x $
I x S
X x S
X x $
- X x $
equipment
stations)
x
x
x
x
x
x
x
Total annualized
(per
) $
) S
) 5
) S
) s
) $
) S
costs
pollutant monitored)
3^30
3^0 S |
7 6 ••? .170
V/ S. O^V,^OPi *
•^-* x $ ^ *
x $ '
x $ »
Subtotal
Annualized
shelter costs
$
S
S
S
S
(?c"' O
Travel costs
Vehicle operation
Labor cost
No. of stations
Average distance, miles
No. of visits per year • Yearly
xx-
x x
X X . - ( •
x x - ( «
Subtotal
Total annualized network cost
1
mileage
x 0. /mile
x 0. /mile
mph) x S
mph) x $
• S
- S
wage rato/h •
wage rate/h -
&0C
5
S
Costs obtained from individual tables in Section 3.0.
Dependent on vendor and quantity, but generally between 2X and 18X.
Annualized equipment coats obtained from individual tables in Section 3.0.
Assumes S years.
-------
APPENDIX B
COSTS INCURRED BY MODIFICATIONS NOT CURRENTLY
SUBJECT TO THE JUNE 19, 1978 PSD REGULATIONS AS A
RESULT OF THE PROPOSED PSD REGULATIONS
125
-------
APPENDIX B
COSTS INCURRED BY MODIFICATIONS NOT CURRENTLY SUBJECT TO THE
JUNE 19, 1978 PSD REGULATIONS AS A RESULT OF THE PROPOSED
PSD REGULATIONS
CURRENT PROPOSAL
Based on the estimates available from Section 4 approximate-
ly 1200 modifications per year which are not currently subject to
the PSD regulations would be subject to the proposed regulations
as a result of these modifications increasing the net emissions
by more than the proposed de minimis emission levels. As a result
of these modifications being subject to PSD review they would
incur some additional costs over and above the current costs to
obtain a general State New Source Review permit.
Because these sources are subject to PSD review they would
be required to
1. Conduct an air quality assessment of the impact
of the .proposed modification using an air qual-
ity dispersion model,
2. conduct preconstruction monitoring,
3. prepare a PSD permit
4. undergo review and incur additional costs as a
result of delay in construction, and
5. install BACT.
Modeling
Since these sources would be relatively small in terms of
emissions they could use a PTMAX type model. At a cost of $1500
per source the total cost for these sources would be $1.8 x
(1200 x $1500) .
Monitoring
Since these would be modifications to existing sources, it
is assumed that existing monitoring data in the vicinity of the
126
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is more stringent than the SIP limit, approximately 43
modifications would be subject to the more stringent controls
as a result of the BACT requirement than under the SIP. This
additional cost would amount to approximately $4.3 to 8.6 x
10^ per year. Therefore, the additional costs of BACT as a
result of additional modifications being subject to review is
approximately 12 to 24 x 106 per year.
MODIFIED DE MINIMIS EMISSION LEVELS
Since only a limited amount of information is available
regarding the number of additional modifications which are
currently not subject to PSD review, information on the 151
modifications which have received permits was used to obtain
an estimate of the number of additional modifications which
would be subject if the current de minimis levels were revised
to 25 TPY for TSP, and 40 TPY for~SO^, HOX and HC. The CO de
minimis level would remain the same. Based on this information,
approximately 888 (see Section 4.5) out of the 1200 additional
modifications would be subject to review. Given this estimate
the following costs were calculated:
Modeling
888 x $1500 = 1.3 x 106
Monitoring
No additional cost.
Preparation of Permit
888 x $4300 = 3.8 x 106
Review Time
888 x $5832 = 5.2 x 106
BACT
(1200) (.32) = 384 No Longer Subject
If there are 432 sources less than 50 tons per year and of
these 384 would no longer be subject, then only 48 of the 432
sources less than 50 tons per year would be required to apply
BACT. If 10% of these sources which remain subject would be
required to meet an emission limit under BACT that would be
more stringent than the SIP, then the additional cost would be
on the order of $.5 to $1 x 106. By the same token, if 10% of
the modification with emissions greater than 50 tons per year
would be required to meet an emission limit under BACT that
would be more stringent than the SIP, then the additional cost
would be $7.7 to $15.4 x 106. Total additional cost would be
$8.2 to $16.4 x 106 per year.
127
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source could be used instead of establishing a monitoring network
and thus no additional cost would be incurred as a result of
preconstruction or postconstruction monitoring.
Preparation of PSD Permit
Since these modifications would be subject to PSD they would
be required to prepare a PSD permit application which would re-
quire that slightly more information be gathered than would be
needed for a NSR permit. Based on the amount of information
needed to obtain a PSD permit, a minimum of 123 man-hours is
needed to collect the information and submit the PSD permit
application. Assuming a burden labor cost of $35 per hour, the
total cost would be $4300 per permit or approximately $5.2 x 106
per year assuming 1200 permits would be issued per year.
Review Time
Since these sources would be required to obtain a PSD permit
in addition to a NSR permit, some additional review time would be
incurred which would cause some further delays in construction.
Based on information in Section 3, this delay would cost approxi-
mately $8750 for a' review time of 3 months or $2916 per month. If
the minimum time for obtaining a permit is 3 months and one month
is needed to obtain a State permit then 2 months of the 3 month
period is due solely to PSD review. This two month review would
cost approximately $5832 ($2916 x 2) and would amount to approxi-
mately $6.9 x 106 for the 1200 permits.
BACT
Based on the estimates in Section 4, approximately 768 of
the 1200 modifications would be greater than 50 tons per year
and 432 would be less than 50 tons per year. As a result of a
review of the sources which would have controlled emissions less
than 100/250 tons per year and therefore would not be subject
to PSD review based on the proposed regulations, it was determined
that approximately 10% of the sources with emissions greater than
50 tons per year (but less than 100/250 tons per year) had emission
limits as a result of BACT which would be more stringent than those
emission limits required by the SIP. If this same percentage holds
true for these additional modifications, then approximately 77
modifications would incur some additional costs as a result of
being required to meet a BACT instead of a SIP limit. This cost
would amount to approximately $7.7 to 15.4 x 10^ per year.
Additionally, the modifications with emissions less than 50 tons
per year would also be subject to the BACT. Based on the infor-
mation above regarding the number of modifications where the BACT
128
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APPENDIX C
SUMMARY OF THE ASSESSMENT OF THE
SEPTEMBER 5, 1979 PROPOSED PSD REGULATIONS
129
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing,
1 "=EPORTNO.
ERA-450/2-80-073
|3 RECIPIENT'S ACCESSION NO.
4 TITLE AND SUBTITLE
Regulatory Impact Assessment for the September 5, 1979
Proposed Regulations for Prevention of Significant
Deterioration
OfitS)
David Dunbar, Barbara Blagun, Larry Gibbs, Joe Carvetti,
Jack Wunderle
9 PERFORMING ORGANIZATION NAME AND ADDRESS
PEDCo Environmental Inc.
Durham, NC 27701
5. REPORT DATE
June '80
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO
10 PROGRAM ELEMENT NO.
11 CONTRACT'GRANT NO
68-02-3173 Task 1
S°C\SCRING AGENCY NAME AND ADDRESS
U.S. EPA
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
13 TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
jPPLEMENTARY NOTES
16 ABSTRACT
Report provides a relative impact assessment of several proposed changes
to the current prevention of significant deterioration (PSD) regulations. These
changes fundamentally affect what sources and modifications must obtain a PSD
permit before constructing. The changes include revisions to the definitions of
"potential to emit", "baseline concentration", and "major modifications", additional
monitoring and BACT requirements, and the inclusion of certain minimum size cutoff
for exempting projects from PSD review. The existing regulations and the proposal
were compared in terms of number and size of sources subject to review, amount of
emissions captured, degree of air quality deterioration, and estimated review costs.
ASS .
; Unclassified
COSATi 1 iJ.l, Group
21 NO. OF PA1ES
47
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E P A F o • ~ ? ." ? 0 ~ I I ,r. c v .< - 7 7 , = = E:.O_5E--IO', SOBSO-ETE
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