EPA-450/4-80-012 c.2
Ambient. Monitoring Guidelines for Prevention oi
Significant Deterioration (PSD)
(U.S.) Environmental Protecticn Agency
Research Triangle 1'arK, UC
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United States Office of Air Quality *
Environments! 'Vcr.ectson Pln.io.-.ji and Standards
Agency Research Triangle Park NC 27711
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EPA-450/4-80-012
November 1980
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NATIONAL TECHNICAL
INFORMATION SEUVICE
U.S. Environmental Protection Agency
R'-f-lon 5, Library (5PL-16)
230 S. Dearborn Stveet, Room 1670
Chicago, IL 60604
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r
TFiCK.JiCAt. RETORT DATA
IF :zse read lnfirucitof.i vit :/.;' rc"rn; before co>~t"lfttnp)
1.
4.
7.
9.
REPORT NO. :2
EPA/450-4-30--012 |
TITLE AND SUBTITLE
Ambient Konitorinj, Guidelines for Prevention
of Significant Deterioration (PSD)
AUTHORISI
PERFORMING ORGANIZATION NAME ANC! A DURESS
Monitoring 6 Data Analysis Division
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADOftcSS
7> o- «•» «-
r^FI 15323 1
5 REPORT DATE
Novenber 1980
6. PERFORMING ORGANIZATION CODE
8. PtHFOPMING ORGANIZATION FFfORT NO.
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF ntPCflT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMfNT \HY NOTF.S
16
T7.
'.3
.ABSTRACT - . . '. -. j ~ • - . -, ^ ,
Amr.ent air mcr.itenng gulden: cs are dep'.riced for sources that r^.av
be required to monitor the air quality under ' ,ie Prevention of Significant
Deterioration (PSD) regulations. Some step-by-srep discussion is presented
for a source to detsrnine if monitoring will be necessary. Situations who^e
existing air quality ar.d meteorological data, modeling, and use of assu~ed
background concuntrationn for certain areas may be used in lieu of monitoring,
are shown.
Tf a source must undertake a r-.onitoring prograni, general guidance is
given for pollutants -_o be monitored, number and location of Monitoring
sites, equipment, frequency and duration of sar.pliag, and data reporting.
More detailed gi'idar.cj is discussed for air quality monitoring probe siting
criteria for various pollutants, meteorological rxinitor ing, and quality-
assurance procedures.
KEY WORD3 A\Q DOCUMENT ANALVS'S
DESCRIPTORS b.lOENTIFi
Prevention of Significant Dete*-iorat~. an
ArrJaient Air Quality y^-nitcring
Meteorological Monitoring
Quality /assurance
L>ISrRIB^.IONST-TLMEN1 13. SF.CUH!
Unlimited uncl.-
?a sccuo'
uncla
fcRS i?E"J ENDED TERMS c. COSATi 1~K d, GlOl'p
1 > CL^SS i :'his t'.t «<..-r, 21 . NO. C^ F AGES
T-. C-^/.Sv ,fhisr~-.fi 22 PRICE
s£if iod
EPA Form Z220-1 (9-7S)
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EPA-450/4-SG-Q-S2
Ambient Et/iOnii
by
Monitoring and Data Analysis Division
Office of Air Quality Plarvung and Standards
and
Environmentai Monitoring Systems Laboratory
Office of Raseardi and Development
U.S. ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina 277V:
Noven-iber 1980
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This report is issued by the Environmental Protection Agency to report technical data of
interest to a limited number of readers. Copies are available - in limited quantities - from
the Library Services Office (MD-35), V.S. Environmental Protection Agency, Research
Triangle Park, North Carolina 27711; or, for a fee, from the National Technical Infor-
mation Service, 5285 Port Royal Road, Springfield, Virginia 22161.
Publica-;ir.n No. EPA-450/1-80-012
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FPr.EHCRD
Many individuals were involved in the preparation of this document
and should be contacted if any questions arise in the application of
the guideline.
Subject Area
Ambient Air Quality
Monitoring
Meteorological
Monitoring
Quality Assurance
(Ambient Air Quality)
PSD Policy and
Interpretation of
Regulations
Acceptable Method for
Non-Criteria Pollutants
Contact
Phone Number
jArea Code 919),
FTS Number
Stan Sleva
David Lutz
James Dicke
Darryl von Lehuiden
Miks Trutna
Larry Purdue
Ken Rehne
541-5351
541-5351
541-5381
541-2415
541-5291
541-2,366
541-2665
629-5351
629-5351
629-5381
629-2415
629-5291
629-2666
629-2:655
11)
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TABLE OF
Pace
1, INTRODUCTION 1
2. GENERAL REQUIREIJEIK'S AND WSTDERAtld.S 3
2.1 Monitoring Data Rati^.ile £
2.1.1 Criteria Pollutants - Ppe cpy-struction P/isss 2
2,1,2 Criteria Pollutants - Pontconetructior. Phase 4
2.1*3 Uoneriteria Pollutants - Pveoonstruction arid
I'ostcor.struction Phase £
2.2 Monitoring Objective and Data Uses £
2.3 VOC and (9, Monitoring Requirements 5
2.4 Use of P.epresentakive Air (fualii-j ^ata 6
2.4.1 Monitor Location ff
2.4.2 lata Quality .-?
2.4.3 "urrentner.s of . ata £.
2.5 Duration of Monitoring
2.5.1 Ihrral Conditirt.z ------------------------------------ 3
2.5.5 Transition Period ------------------ - ---------------- 10
2.6 Sampling Xetliods an.! tjr: :-adurcs ---------------------------- ~3
2.7 Freq-^cno-j of S^plinj ----------------------------------------- JJ
2.8 Monit'irina Plan -------------------------------------------- 11
2.9 Meteorological Para^'cier-3 and !•!> a^ur^ment Methods ---------- 11
3. IlETUOBK DESIGH AI.'D PROBE SI'l'IUG CK11EP.IA ------------------------
3.1 Network Design
3.2 Number a.d Location of Vonitorc
3.2.2 Prec~nst.ru. ?ii( n Phase ------------------------------- 2Z
3.2.2 Poa'.const'i'Kcti'jn Phase ------------------------------ j<'
3.2.3 Special Cor^crm for Locnf' m of Monitor? ----------- 15
.3 Probe Siting Criizr'i ---------------------------------------- 15
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TABLh 07' COF"- 'EHTS (aortinued)
3.3.1 Total Suspends! Partizulatcs (7SP) -------------------- 17
3.5.1.1 /ertical I'l^'jcrr.cnl. ----------------------------- 17
2.3.1.2 Z],acir.,j frcn Obstructions -------------------- 17
3.3.1.3 Spacing "rorr, Roads --------------------------- 17
3.3.1.4 Other Co'^c'cf-ratiortS ------------------------- 17
3.3.2 Sulfur lic,:-ide (SO,,! ------------------------------------ 17
3.3.2.1 Horizontal and Vertical i'robe Placement ------ 17
5.3.2.2 Spacing frc"i Obstruction?, -------------------- '20
3.3.3 Carbon Monoxide (Cu) --------------------------------- •- 20
3.3.3.1 Horizontal arid Vertical Probe Placement ------ 20
3,3.3.2 "picinr. frc~i Obstructions ------------------- 20
3.3.3.3 l^pacir.v /?•>•- Roads ---------------------------
3
.3.4 Ozone OJ
Vertical «/: 2 florizontcl Pror Placement ------ 21
."Baaing j'j*"-; Obstruct lens -------------------- Zl
L'i'acinj _-v-/-. Roads --------------------------- 21
3.3.5 Ilitro'jc'i. dioxide (',>'.'.) ---------------------------------- V"
3.3.5.: Vertical u'.;; Uoripcnial Trobc Placement ------ 22
3.3.5..'; .'j'(".av:'>.-;.- jr: ', ObstruJiicns ------------- • --------- 22
3.3.6 Lead (II. --------------------------------------------- 22
3.3.0.1 .'f.Tiioal i-ls.-c-ient ---------------------------- 22
3.3.0.Z :.'paainj j>:-i (.bstructic-ns -------------------- 22
3.3.6.? .'.paaina j'r;.™r :-loads --------------------------- 23
3.3.6. : C.'ther ~Ccnzidwatior.x ------------------------- 26
3.3.7 Nonsritt'Tia Pollui »•.'*.•• -------------------------------- 2
3.3.7.1 Vertical r~ zc'cr:?nt ---------------------------- 5
3.3.7.2 L'pacino ff-. Obstructions -------------------- 2
Probe Material a>ui rsll-.itz'.i Sample residents Tine -----------
?:e*?~;ar'j of Fr. ': t, S'ltin? '-.crc.ren-.f.ts -------------------------
vi
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TABLE_OF_ CONTEXTS_ (continued)
Page
4.1.2 Quality Control Requirements 20
4.1.2.1 organizational Requirement.*; £9
4.1.2.2 Pr-iniopy Guidance 29
4.1.2.3 Pollutant Standards SO
4.1.')..4 Performance and System Audit Prelaws 30
4.1.2 Data Quality Assessment Requirements 30
4.I.S.I Precision of Automated Methods 30
4.1.2.2 Aceiwacy of Automated Methods 31
4.1.3.3 Precicicn of Manual Methods 32
4.1.3.4 Accuracy of Manual Methods 32
4.1.4 Calculations for Automated Methods 33
4.1.4.1 Single Analyzer Precision 33
4.1.4.2 Single Analyzer Accuracy 25
4.1.5 Calculations for Manual Methods 55
'4.1.5.1 Single Instrument Precision for- TSP and Pb - - 25
4.1.5.2 Single Instrument Accuracy for ~'£? 35
4.1.5.Z Single Instrument Sampling Aceuxaej for PD — 35
4.2.5.2 Sinyle-Anjilysis-Uu.j Accuracy for Pb 36
4.1.C Organization Reporting Requirements 36
4.2 Quality Assurance for Honcriteria Air Pollutants 36
4.2.1 Selection of Method 26
4.2.2 Calibration 36
4.2.3 Data Validation 37
4.2.4 Standard and Split Samples 37
5. METEOROLOGICAL MC1.ITOR1UG 38
5.1 Data Required 38
i
6.2 Exposure of Meteorological Instrumentr 39
C. METEOROLOGICAL I'/STRUME/ITATIO:: 42
6.1 Specifications 42
C.I.I Vina Systems (horizontal wind) 42
6.2.2 Wind L~u.-te.r':s (vertical yind) 42
€.],Z Wind Fluctuations 42
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TABLE OF CONTEUIZ (continued)
Page
6.1.4 Vertical Tenpcralure Diffvrzrsiu 4Z
6.1.5 Temperature • 46
6.1.6 Hvaniditj 43
6.1.7 Radiation - Solar and Terrestrial 43
6.1.8 Mixing Height 43
6.1.9 Precipitation 44
6.1.10 Visibility 44
7. QUALITY ASSURAUCE FOR METEOROLOGICAL uATA 46
8. DATA REPORTING 46
8.1 Air Quality Data Report-ing 46
8.2 Meteorological Data Format and Reporting 4>",
APPENDIX A - PROCE'/J".ES TO DETEP.'-IH.'E IF MOXirOPJNG DATA WILL BE RETIRED
FOR A I-SD APPLICATION
1. HITRuWCTIC'.l A-l
2. PSD PERMIT At f-LICATIOI1 PROCEDURES
2.1 Pai-t 1 - Source Applicability Determination • A-l
2.2 Part 2 - Pollutant Applicability 1/3termination A-S
2.3 Part 3 - ::.\CT Analj.ifs A-T>
2.4 Part 4 - ,'ribier.t Air Duality Analysis A-5
2..j Part 5 - bourse Impact Analysis A-7
2.C Part 6 - Additional Iiipact Analysis A-?
2.7 Part 7 - File Complete PSD Application . /;-7
3. DECISIONS FOR MONITORIKG DATA REQUIhEMEHTS .4-5
REFERENCES A-22
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The Clean Air Act Amendments of 197?, Part C, Prevention of Significant
Deterioration, require that certain new major stationary sources and
major mod;fications be subject to a ^reconstruction review which includes
an ambient air quality analysis. Furti.snnore, the Act requires that an
analysis be conducted in accordence with regulations promulgated by the
EPA. In this regard, the Agency promulgated PSD regulations [1] on June
19, 1978, which included ambient monitoring requirements. Guidelines
were pub1!shed iri Hay 1978 [2j to discuss monitoring for PSD purposes.
However, in response to the June 18, 1979 preliminary Court Decision
(Alabama Power Company v. Costle, 13 ERC 1225), EPA proposed revised PSD
regulations [3] on September 5, 1979. The final cojrt cecision was
rendered December 14, 1979 [4]. Based on the public corraoents to the
September 5-, 1979 proposed PSD regulations and the December 14., 1979
court decision, EPA promulgated new PSD regulations on August 7, 1980.
Some of the pertinent provisions of the 1980 PSD regulations that affect
PSD monitoring are discussed below:
(a) Potential to emit.
The PSD regulations retain the requirement that new major stationary
sources would »e subject to a new source review on th basis
of potential to emit. However, the annual emission potential
of a source will be determined after the application of eir
pollution controls rather than before controls as was
generally done under the 1978 regulations [1].
(b) De min-i.m',5 cutoffs.
The PSD regulations will exer.pt on a pollutant specific basis
major modifications and nc-w major stationary sources from all
monitoring requirements when emissions of a particular pollutant
are below a specific significant emission rate, unless the
source is near a Class I area. Also included are significant
air quality levels which may be used to exempt sources or
modifications from PSD monitorinr, when the air quality impacts
from the sources or modifications are below specified values.
(c) Noncriteria pollutants.
The 1978 PSD regulations [1] required monitoring only for those
pollutants for which national ambient air quality standards
exist. However, there are a number of pollutant; for which
no ambient standards exist (noncriteria pollutants) but which
are regulated under new source performance standards end
national emission standards for hazardous pollutants. The
1980 regulations [5] require an ambient air quality analysis
for all regulated pollutants enittcd in significant amounts.
This analysis will generalIv be based on modeling of the
impact the pollutants in lieu of collecting monitoring data.
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(d) Preconstruction monitoring.
A list of air quality contenlrc-tions is included in the PSD
regulations as criteria for generally exempting proposed
sources or modifications rroro collecting monitoring data.
Basically, monitor inc. data will be required if the existing
air quality and the impact o? tiie proposed source or modification
is equal co or greater than these concentrations. In certain
cases, even though th^ air quality impact or background air-
quality may be less than these concentrations, monitoring data
may be required if the proposed source or modification will
impact a Class I area, nonattainment area, or area where thp
PSD increment is violated.
(e) Postconstruction monitoring.
The PSD regulations include authority to require postconstruction
monitoring, in general, EPA may require postconstruccion
r.ionitoring from large sources or sources whose impacts will
threaten standards or PSD increments. The permit granting
authority will rr.ake this decision on a case-by-case basis.
(f) Transition period for phase-in of new regulations.
Provisions have beer, made in the 1920 PSD regulations [5] to
phase in the new requirements for monitoring. Additional data
gathering beyond the 1978 requirements will not be ef'tctive
until June 3, 1381, which is 10 months after pronulgation of
the PSD regulations, [5j. The new monitoring requirements will
be phased in during the period 10 to 18 months ?Tter pto^ulqatiun.
All monitoring requircuents in the 1980 pSD s-pgtjlaticns will
bf. in effect February 10,1982, 18 months after promulgation.
Becf.use of the above changes, a: well as other revisions to the PSD
regulations, this guideline has been modified to reflect 3ucn revisions.
?h(: purpose of this guideline is to address those items or activities
which a-e considered essential ir. conducting an ambient air quality
monitor.ng program. Guidance is given for designing a PSD air quality
monitoring network as wall as the operational details such as sampling
procedures and methods, -Juration of sampling, quality assurance procedures,
etc. Guidance is also given for a meteorological monitoring program as
well as the specifications for meteorological instrumentation and quality
assurance procedures.
An appendix is included to show how the ambient ai.- quality analysis
fits in the overall PSD requirements. Flow diagrams are presented to
aid a proposed source or r--odi Heat ion in assessing if monitoring da*,a
may be required.
General adherence to the guidance contained in this document should
entire consistency in implementing the PSU monitoring regulations.
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1.1 .'.'.--: '.Coring Dai ? _r_j_
The court decision |.4] has viffirmed tne Congressional intent in the
Clean Air Act as it relates to PSD ronitoring requirements. The court
ruled that Section 165(00) or the Clean Air Act requires that an d'.r
quality onalysis be conducted for each pell in out subject to regulation
under the Act before a rcajor stati- nary source or major modification
could construct. This analysis fray be accomplished by the use of noceli-g
and/or monitoring the air quality. EPA has discretion in specifying tn3
choice of either monitoring 01 modeling, consistent with the provision
in Section 165(e)(2). As will be discussed later, modeling will be uied
in most cases for the analysis fcr the noncriteria pollutants.
The court ruled that Section 165(s)(2) of the Clean Air Act requires.
that continuous preconstruction air qiality nonitoring data must be
collected to deternine whether emissions from a source will result in
exceeding the National Ambient Air Quality Standards (NAAQS). Further,
the data could be used to verify the accuracy cf the mode1ing estirates
since rcdeling will be the princical mechanism to determine /vhether
emissions from the proposed source or modification will result in exceed:**:
allOrt3ole increments. In record to monitoring requirements, the court
statea tnat EPA hid tne autho-ity to exempt .:V •-:.> i"-'.f. situations.
Fi>stconstruciiop iron i tor ing da La requirements are addressed in
Section 165(a)(/) of the Clecn Air Act. Sources nay have to conduct
such ~onitorinc to determine the air quality effect its emissions ma/
have en the area it inputs, firs has the discretion of requiring !ioni::ri-:
data ar;d the court stated thjt Guidelines could be prepared *o show f-.e
circumstances that nay require postconstruction monitoring ;ata.
In view OT' the provisions of Sections 165(e)(l), 165(ej(2), aid
165(ax{7^ of the Clean Air Act, the d( nir.i.-::f concept, and sections cf
the firal PSD regulations, ?r.'t:"_-• o P.2.1, ::.;.: .z>-.i ?..!.? present the
basic rationale which generally will De followed to determine when
monitoring data will or will rot be seqjired. It should be noted that
the siT?equent use of ''monitoring df.ta" refers to either the jse of
existir,; representative air Duality data or monitoring the existing a---
quality.
Additional discussion ard f";o\/ diagran.s are presented in Appendix A
of this guideline which show various decision points leading to a
deterrination as to v,hen mo.iitorir.q data will or will not be reoi;irec.
Also, t^ese procedures indicate at what points a modeling analysis ^^st
be perfe'-ied.
For the crireri; pollutants (TSF, S0?, CO, N0?, Pb) continuous a
quality roTitorinc; oata irust, in cetera!, be us?d TO establish c^isti
air qiairty conce .t^ations in the vicinity of the proposed source or
modification. For \VC emissions, continuous ozone monitoririC data n
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be used to establish existing air quality concentrations in the vicinity
of the proposed source or (rod t-'jcation. However, no preccnstruction
monitoring data K-; 1) generalIy te required if the ambient air quality
concentration before constriction is less than the significant monitoring
concentrations. (The signif icsn"- monitoring concentrations for each
pollutant are shov.n in Table A-.'? in the appendix to this guideline.) To
require monitoring data where me air quality concentration of a pollutant
is less than those values would be questionable because these low level
concentrations c-innot reasonably be determined because of measurement
errors. These roe-isureTient errors may consist of errors in -;-arrple collection,
analytical measurement, calibration, and interferences.
Cases where the projected impact of the source or modification is
less than the significant monitoring concentrations would alsc generally
be exempt from preconstructson monitoring data, coi.Distent with the dc
mini-nis concept. [40 C;"R 51.L'4(i}{8) and 40 CFR 52.21 (i );'>}].
The one exception, to the JT> ~-.r.i,'v'.s exemption occurs when a proposed
source or modification would adversely impact on a Class I area or would
pose a thieat to the renainirq allowable increment or NAAQS. Fo«- those
situations where the Mr quality concentration before construction is
near the significant "onitorirg concentration, and there are uncertainties
associated with this air cuality situation, then preconstruction ai-
quality monitoring ciata mey be required. These situations fust be
evaluated on a cdse-rv-case basis by the permit granting authority
before a final dec'isio^ is made.
2.1.2 r»*.'i-^i_7 r '.' '-.,-->:ts - P^fr^creirnition Fcrre
EPA has discretion in requiring pcstconstruction n'.onitcring data
under Section 165u/(7) of the Clean Air Act and in general will not
require postconstruction monitoring data, however, to require air
quality censoring data implies t^at the petvn't ordfiting authority will
have valid reasons for the data end, in fact, will use the data after it
is collectpc. Generally, this will be applied to large sources or
sources whose impact will threaten tha standords or PSD increments.
Examples of when a Denr.it granting authority may require post-construction
monitoring data may include:
a. NAAQS are threatened - The postconstruction air quality is
projected to be so close to the \AAQS that monitoring is needed to
certify attainment or to trigger appropriate SIP related actions if
nonattainment results.
D- Source i"T3Ct is uncertain or unknown - Factors such as complex
terrain, fugitive cnissions, and ozner uncertainties in source or emission
characteristics result in significant uncertainties about the projected
impact of the source or .nodificat:on. Postccnstruction data is justified
as a perrr.it condition on the basis that model refinement is necessary to
assess the irpact or f.;ti;rj sources of a simile; type and configuration.
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2.2.? ^nQpitcPis_ PC T L';rgr.r o - .- 'i ^_\? : n ; -• t > fict.''cfi end Pest jy»: 3 true tier, r jf~-^y
Consistent with Section I65{e)(l) of the Clean Air Ac*;, EPA believes
that an analysis baseo on tr.oaeling of the impact of noncriteria pollutants
on the air quality should g3r,?raliy be used in lieu of monitoring data.
The permit granting authority, however, does have the discretion of
requiring preconstru^tion ard postconstruction monitoring data. Before
a permit granting .jthority exercises its discretion in squiring monitoring
data, there should t.e an ac'eptable measurement method approved by EFA
(see fcstion 2.6) and the concentrations would generally be equal to or
greater than the significant nonitoring concentrations (shown in Table
A- 2 of the appendix).
A permit granting authorit/ may require monitoring daia in cases
such as (a) where a State or other jurisdiction has a standard for a
noncriteria pollutant and the emissions from the proposed source or
modification pose a threat to tne standard, (D) where the reliability of
emission data used as input to modeling existing sources is highly
questionable, especially for tne pollutants regulated under the national
emission standards fo^ hazarccus pollutants, and (c) .vhc'-e available
models, cr complex terrain rpake it difficult to estimate air quality cr
impact of the proposed source or modification.
The basic objective of FS? nonitoring is to determine the effect
emissions from a source are having or may have on the air quality in eny
area that may be affected by tne emission. Principal uses of the data
are c»$ follows:
(a) To establish background air qualit> concentrations in the
vicinity of the proposed source or modification. These Dackground
levels are important in deterr-'m'ng whether the air quality before or
after construction are or will be approaching or exceeding the NAAQS or
PSD increment.
(b) To validate and refire models. The data will be helpful in
verifying the accuracy of th'; radeling estimates.
Volatile organic compounds (VOC) monitoring is not required since
the G.24 ppm nonmethane 'ircanic compound (N'-'OC) standard is a'guice for
develocing State Implementation Plons to attain the 0, a~sient stenc'arc.
However, VOC emissions are tr.e precursors in tr-e formation of ozone.
Cor.secuently, any new source or "-odified existiry snu-ce located in an
unclassified or attainment area for ozone that is equal to or greater
than u~3 tons per year of \-C emissions ^-il1 be required to monitor
ozone. VGC monitoring will rot be required.
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?.. 4
Jat-a
The use of exis;5rg represent?tfve air quality data was one of the
options discussed in ~. zt-'.on '•'. "" ':or monitoring data. In determining
whether the data are representative, chree major items which need to be
considered are monitor location, oi/sHty of the data, and currentness of
the data.
2.4.2 .'•'.v:itor
The existing mcnitcn'ng data should be representative of three
types of areas: (1) tne locationfs) cf maximum concentration Increase
from the proposed source or modification, (2) the location(s) of the
maximum air pollutant concentration from existing sources, and (3) the
location(c) of the Tixiruri impact area, i.e., whe~e the maximum DO Mutant
concentration would h/pothet1'cally occur based or. the combined effect of
existing sources and the proposed ne.v source or ratification. Basically,
the loc?tious and size of the three types or areas are determined throjcn
the application of air quality models. The areas of naximun concentration
or% maximum combined i'-cuct vary in size and are influenced by factors
such as the size and relative distribution of ground level ard elevated
sources, the a,veragirc rimes of conceTi, and the distances between
"Impact areas and contributing sources.
In situations ••••re'-e there is no existing monitor in the a^ove
areas, rom'tors locates ,'u'tside these three tvpes cf areas may or may
not he used. Each det-r-ination must re made on a case-fay-case basis.
In order to clarify Er.''s intent regarding the use of existing monitoring
data, sore py?'noles are ""nclud'ed to demonstrate the overall intent.
(j) Case I - If :-,
be constructed in an art-
other point sources ard
then monitoring dat? fr;
data. Surh a site co-7a
similar ir nature to t'~
of air quality across 5
source or r,odificatior- i
use of these "regional
them in ar^as of multisr
•i proposed ?c
3 that is ge.i
area sources
- a "regioral
be out of t~
impact area.
oroad region
s located. 7
sites to rela
jrce emission
•jrce or nodi*
erally free f
associated w"
si te may be
e max Imtrr ir3
This sits v.
including tha
he intent of
tively remote
s or areas of
ir.ation will
rev the imcact of
in human acti'/itie:.
used as representative
act area, but must be
ould be characteristic
t in which trie proposed
EPA is to limit the
areas, and not to jse
cc.rolex terrain.
(b) Case II - If t^e proposed construction will be ir. an area of
multisourcf emissions end basically flat terrain, then the proposed
source or -edification ~sy propose f-e use of existiro dat et nea "by
monitoring sites if eit'-e~ of the folie*.ing criteria are met.
st-rg monitor is .vithin 10 k~ cf the points of
1. The
proposed emissions, or
r. The exisv>c ronitor is .-.''thin or net "rather trar 1 i-^
away frc" '-it'.er the ?••-- •:} of the r-?>,i-u". air rr'rjcsnt concent ratio'1
froTi exisfny sources ; • :r-e area(s) c* ir? com^ired raximum i'.pact frc~
existing a-~d proposed ?c--ces.
-------
If the existing morutcrr's) n;?ots either of the above two
corditions, the data could be ur-e.J touetiter with noc-3'. estimates <.o
determine the concentrations at a] three types of areas discussed
earlier in this section.
As an example of the first criterion, if an existing monitor is
located within 10 km f»cm the points :»f proposed emissions but not
within the boundaries of the ;:,odeied areas of either of the three locations
noted above, the datct could bo jsed tocstrer with model estimates to
determine the concentrations at tne three types of required area.
The next example applies to the second criterion. In evaluating
the adequacy of the location of existing r-onitors, the applicant rust
first, through modeling, determine the significant oirbient inpact srea
of the proposed sojrce. In general, except for impact on Class I ^reas,
the application of air quality node"^ for the purpose of determining
significant ambient impact would be limited to 50 km downwind of t^e
source or to that point where tr.e concerfation from the source falls
below the levels shov/n in Tabie A-3 of tre -Appendix. For Class I are?s,
a significant inpact is 1 iig/m - (24-hr) for ISP and S09- The applicant
weula then identify within this significant impact area the area's'' c*
the raxinum air pollutant concentration from existing ^ources anH ---e
a~ea(s) of the combined maxima impact 'ro'n existing and proposed ::.,'-ces.
The araa'.s) of ertir.ated maxi.ru;'. concer.fstion from existing scurc-;? _r
the estimated naxiirun combined I'uect area, (s) are dete>~ir-ed as *:rc^s:
First, within the fodeled significant drrient impact area, estimate :~e
point o~ maximum concentration f-'on. exufng sources, and the poirt "^
combined niaximurn inpact i.exisf'n; and pr censed source'. Using these
concentration values, determine the areas enclosed by air quality cc~;-3r>tration
isopleths equal to or greater tt =n one naif of the respective estv-:-t-:-.
maximum concentration. An existing monitor located within or not *3r~r
-------
It must be emphasised that the oermit granting authority may choose
not to accspt data proposed under t';o cases discussed above. This may
occur because of additional factors, especially in Case II whici were
not discussed but must be considered, such as uncertainties in c-ear period preceding the remit application provided trat an
acceptable measurement method .vas u;ea. For the DO s teens true ti on
the daia rust be coll;-cted after the source or modification LeccT.es
operational .
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2. 5 Duration of Manj-corir.;:
2.,). 1 Nomal Conditions
If a source decides xo Tjnitor because representative air quality
data is not available tor thv reconstruction monitoring data requirement,
then monitoring must be ccnu.".;ted for at least 1 year prior to submission
of the application to construct. Also, if a rource decides to monitor
because represertative air quality data is net available for the post-
ccnstruction monitoring data requirement, tren monitoring must also be
conducted for at least 1 y?&r , fter the soiree or modification becomes
operational. However, under some circumstances, less t^an 1 year of air
quality dcta may be acceptable for t'ie preconstruction and postconstructicn
phases. This will va»-y according +o the pollutant being studied. For
all pollutants, less than a full year will be acceptable if the applicant
demonstrates through historical data o>- dispersion modeling that the
data are obtained during a tine period when maximum air quality levels
can be expected. However, a minimum of £ months of air quality data
will be requiied. As discussed in sect:.-: T.I.3, monitoring *or noncriteria
pollutants will generally not be required.
Special attention needs to ba given to the duration of monitoring
for ozone. Czone monitoring ,vi r. still be reqinrrr-o dun no the tinie
period when ..laxiiiu.n ozone concentrations will be expected. Temperature
is one of the factors that affrct ozone concentrations, arid the 'naxi^un
ozone concentrations will ce-erally occur during the v^rrest 4 mo^tr.s of
the year, i.e., Junt-f.epte.-fcer. !-ioweve<-, historical ro^itoring data
have shown that the maximum Dearly ozore concentration for son/e areas
may not occur from ..~une-Sep;e~Ser. Therefore, ozone p-oritoring will
a_lsp be required for these rcnths when historical ozone data have sr,ov»n
that" the yearly n-axiT/um cio^.e concentrate ens have occurrea during -icnt^s
other than the wa'-mfist 4 trcnths of the year. This requirement is in
addition to POTT tor-ng durin; the warmest 4 months of the year. If
there is an interva'. of tire between the warmest 4 montrs of the year
and month where hic:or"!cal ~onitoring c'ata have shown t--at the maxirum
yearly ozone concertretion ;~3S occurrea, then ironitcrinc rr,wst also te
conducted during cnat interval. For exa^ole, suppose historical data
have shown the maximum yearly ozone concentration for at least 1 year
occurred in April. AUo, suriose the warmest 4 months for that particular
area occurred June-September. In such cases, ozone monitoring would be
required for Apri1 (previous raximum concentration month), May (interval
month), and June-September (warmest 4 months).
Some situations ir.ay occur v;here a scurce owner or operator may not
operate a new source or modification at the rated caoacity applied for
in the PSD perm-'t. Generally, the postconstruction -non i to ring should
not begin until the source is cperating at a rate equal to or greater
than 50 percent of its design capacity. However, in nr case should f-.e
postconstructif-r> nonitorinc te started later than 2 ,vea-s after the
start-up of th.! new source cr podificat-.cn.
-------
If the permit arenting authority har determined that 'less than »
year of ironitorina data is permissible, the source must agi-ec to use thi
appropriate r,axir;ur \V-lu23 collcc'CKi over this short period for ccroar'son
to a". 1 asplicabla shcrt-ten:: stariOnrds, and tiis average \alue fo. th2 -,hort
period as the equivalent cf the annual standard.
It should also bo noted that the above discussion of less than 1
year of data pertains to air qjality data, not meteorological data. Wfen
the air quality impact must be determined using a disoersion model, the
preferred meteorological data base is at least 1 year of on-site data.
Although less than 1 year of data nay be s-.jfficiem to determine the
acceptability for a rode!, once the model has been accepted, a full year
of meteorological data mur-t be used in the PSD analysis.
2. 5. 2 'fansitic•: Psr'od
A transition period has been provided in tne 1980 PSD regulations
[5] for phas'ng in nc-rf monitoring requirements. Additional data gathering
beyond tne requirements of the 1978 PSD regulations [1] will rot be
effective for permit applications submitted be'ore June 8, 1981, 10
months after promulgation &*" the 1980 PSD regulation. The 10 month
period vas derived by assuming that 5 months art- needed for instrument
and equipment procurement, 1 month to install the equi^mert, calibrate
and ensure satisfactory operation, and a minimum of 4 months of monitoring
data.
PSD permit applications submitted from 10 to 13 months aft^r
August 7, 1980, should have data collected from February 9, 1531, to
the tire t'ie PSD application becomes otherwise complete. However, as
discussed in scct:cr. '.5.1, "sess data will be acceptable if the applicant
demonstrates through historical data or dispersion modeling that the
data wo 1.1 Id be obtained during a tiir.e perioa when r,3xii7ium eir quality can
be expected. The minimum of 4 months of air quality data would still be
requiren.
During this 10 to 18 month transition period, the permit granting
authority may waive the additional monitoring requirements for ozone
only, if the monitoring could not be performed during thp maximum
concentration time period es discussed in scotic'i 2.5.1.
PSD Dermit applications submitted later than 18 months after August
7, 19S9, would not be in the transition period and must, therefore, nee,;
all monitoring requirements of the 1980 PSD regulations [5].
2.6 £.rr-;7><7 :-:^i':^3 ::»:f Pi'cizd^rcs
(a) Criteria pollutants.
All ambient air quality monitoring must be done with continuous
Refererce or Equivalent Methods, with the exception of TSP ana lead for
which continuous Reference or Equivalent Methods do r:ot exist. Per TSP
and leai, samples ~i,st be taken in accordance with the Refprence Method.
The Reference Met'iocs are described in -0 CFR SO. A list of designated
continuous Reference ar Eouivdlent Methods c?n r? 'obtained by writing
Envircrrentsl Monito'-i^f Systems Laboratory, DefSft"enr E (MD-76), U.S.
Enviror~entjl Protection Agency, Research Triangl? Park, NC 27711
10
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(b) Noncriteria pollutants.
For noncriteria pollutants, a list of acceptable measurement
methods is available upon request by waiting tnvironmental Monitoring
Systems Laboratory, Quality Assurance Ct^'"sicn (MD-77), U.S. Environmental
Protection Agency, Research Triangle Park, .'.'C 27711. This list of
acceptable methods will be r-svle'-u' at ieA':t annually ar.ci are available fro.n
the above address. Measurement methods considered candidates for the
noncriteria pollutant list should be brougM. tc the attention of EPA at
the address giver, above.
2. 7 Frequt'r^ij of Sampling
For all gaseous pollutants and for all meteorological parameters,
continuous analyzers nust be used. Thus, continuous sampling (over the
time period determined necessary) is required. For oarticulate pollutants,
daily sampling (i.e., one sample every 24 hours) is required except In
areas where tne applicant can demonstrate that significant pollutant
variability is not expected. In these situations, a sampling schedule
less frequent than every day woulf4 be permitted, however, a minimum of
one sample every 6 days will be required for these areas. The sampling
f-equency vould apply to both preconstructior, and poslconstruction
monitoring,
?.. 8 Monitori*:? Plan
A monitoring plan prepared by the source should be submitted to and
approved by the permit granting authority before any PSD monitoring
begins. Note that approval of the monitoring plan before a monitoring
proyram is started is not a requirement. However, since i.;ie network
size and station locations are determined on a case-by-case basis, it
viould be prudent '"or the owner or operator to seet^ review of thl~':-.?3.l Parccv rvr-s and Vc,ir.\r--~?r.t f'c'.h'-'l.i
Meteorological data will be required for input to dispersion models
used in analyzing the impact of the proposed nerf source or modification
on anb-'ent air quality and the analyses o:' effects on soil, vegetation,
and visibility in tne vicinity of the proposed source. In some cases,
rer-resentative data are available from sources sucn as the National
Weather Service. However, in some situations, on-s^te data collection
v.'ill te required. The mc-teurclcgical monitoring and instrumentation
considerations are discussed in s-:-i> i- and s.
11
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TABLE 1. niNIMUfl CCriTfNi^ OF A MONITORING PLAN
I. SOURCE ENVI hQNMtfiV DESCRIPTION (" source)
• topographical description
• land-use description
« topographical map of source and environs (including location of
existing stationary sources, roadways, and monitoring siues)
• clipatolcgical description
• quarterly wind ruses (from meteorological data collected at the
source or other representative meteorological data)
II. SAMPLING PROGRAM DESCRIPTION
• time period for which the pollutant(s) will be measured
• rationale for location of monitors (include modeling results and analysis
of existing sources in the area)
• rationale for joint utilization of monitoring network by otiier
PSD sources
III. MONITOR SITE DESCRIPTION
• Universal Transverse Mercator (UTM) coordinates
» height of sampler (air intake) above ground
9 distance from obstructions and heights of obstructions
• distance from other sources (stationary and mobile)
• photographs of cacti siT.e (five photos: one in each cardinal direction
looking out from each existing sanoler or where a future sampler will
be ""coated, and one closeup of each existing sampler or where a future
sampler will he 1 oca led. Ground cover should be included in trie
closeup photograph.)
IV. MONITOR DESCRIPTION
• name of manufacturer
• description of calibration system to be used
• type of flow control and flow recorder
V. DATA REPORTING
• format of data submission
a frequency oT data ••eporting
vl• QUALITY ASSURANCE PROGRA?I
9 calibration frequency
e independent audit program
» internal qua"Mty control procedures
• data precision and accuracy calculation procedures
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Z. KETVOP.7. _pKSIM_ A11D PPOBE SITING CRITERIA \
A source subject to PSD '.houid only proceed with designing a PSD
monitoring network only after going throucn the procedure in Appendix A
to determine if monitoring data will be required. To fulfill that
requirement, a source may use representative air quality data wlrch was
discussed in section 2.4 or monitor This section presents guidance to
be used if an applicant decides to monitor in lieu of using representative
air quality data.
3. 2 Netiwk Design
The design of a network for criteria and noncriteria pollutants
will be affected by many factors, such as topography, climatology,
population, and existing emission source* . Therefore, the ultimate
design of a network for PSD purposes must be decided on a case-by-case
basis by the permit granting authority. Section 3.2 discusses the
number and location of monitors for a PSD network. Additional guidance
on the general siting of the monitors may be found in references 6-9
which discuss highest concentration stations, isolated point sources,
effects of topography, etc. Probe siting criteria for the monitors are
discussed in section 3.3. The guidelines presented here s.nould be followed
to the maximum extent practical in developing the final FSD monitoring
network.
3. 2 l^cr'ner arifl legation of ''onitors
The number and location of monitoring sites will be determined on 3
case-by-case basis by the -ource owner or operator and reviewed by the
permit granting authority. Consideration should be given to the effects
of existing sources, terrain, meteorological conditions, existence of
fugitive or reentrained dusts, averaging time for the pollutant, etc.
Generally, the number of monitors will be higher where the expected
spatial variability of the pollulant in che area(s) of study is higher.
3. 2. 1 Precons tru-?tion Ffiarc
Information obtained in the ambient air quality analysis in AppenHiv
A will ba used to assist in determining the number and location of
monitors for the preconstruction phase. The air quality levels before
construction were determined by modeling or in conjunction with monitoring
data. The screening procedure (or nore refined model) estimates were
determined in Appendix A.
The source should first use the screening procedure or refined
model estimates to determine the gerer.il lccation(s) for the maximum air
quality concentrations from the proposed source or modification. Secondly,
the source should determine t/y modeling techniques the general lccation(s)
for the maximum air qrality levels from existing sources. Thirdly, the
modeled pollutant contribution ot the proposed source or modification
should be analyzed in conjunction \\ith the modeled results for existing
sources to determine the maximum iirpact area. Application of these
models rr.i'st be consistent with EPA's ".lui.lolii.c. on .'•.-' r ,4<<-:".7 t;v y.oc^.l?"
[34]. This would provide sufficient information for the applicant to
place a monitor at (a) the location(s) of the maxirnu.n concentration
13
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increase expected froni !.tic proposed source or modification, (b) the ,
location(s) r/f the maxif,.«r' air po Mutant concentration from existing ,t
sources of emissions, dud (c) the "iucation(s) of the maximum impact
area, i.e., where the rr?xii7ium polluijnt concentration would hypoth^tically 3
occur based on the coirbination effect of existing sources and the proposed j
new source or modification. In so:/-,- cases, tv/o or more of these locations j
may coincide and thereoy reduce the tiumtar of monitoring stations. f
|
Monitoring should Uu-n be conducted in or as close to these areas I
as possible (also see di'jCusMon in r.c'tion Z.2.Z}. Generally, one to j
four sites would cover 'nor,t situations in multisc-urce settings. Tor \
remote areas in which the pernit granting authority has determined that |
there are no significant existing sources, a minimum number of monitors j
would be needed, i.e., one or probably two at the most. For new sources, j
in these remote areas, as opposed to modifications, some concessions •
will be made on the locations of these monitors. Since the maximum '
impact frorr. these new sources would be in remote areas, the monitors nay !
be located, based on convenience or accessibility, near the proposed new \
source rather than near the maximum impact area since the existing air
quality would b? essentially the same in both areas. However, the
maximum impact area is still the preferred location.
When industrial process fugitive paniculate emissions are involved,
the applicant should locate a monitor at the proposed source site (also
see jr-jii. •>: :•;.?..?>}, If stack emissions are also involved, a dowrwinc
location should also Le selected. For fugitive hydrocarbon emissions,
the applicant should legate a /norr'tur- downwind of thr source at the
point of expected ma/.ip:U'n ozone concentration contribution. This location
will be found downwind during conditions t/iat are most conducive to
ozone formation, such as temoerat'jre above ^0°C (68°F) and high ?,olar
radiation intensity. Fur hydrocarbon emissions from a stack., the aoflleant
should also locate trio ••cni'.or -,ti the ?rsa of expected maximum 07005
concentration. For both fugitive and stack emissions, the selection of
areas of highest ozone concentrations '..'ill require wind speed ar) direction.
data for periods of photochemical activity. Monitoring for o;or>s w"! 1
only be necessary during the seasons when high concentraiions occur.
Since ozone is the ^e^ult of a conolex photocheniical process, the
rate of movement across an area of the air mass containing precursors '•
should be considered. The distance from the proposed source to the
monitor for an urban situation should be about equal to che distance
traveled by the air moving for 5 to 7 hours at wind speeds occurring
during periods of photochemical activity. In an urban situation, ozone
formation over the initial few hours ITVIV be supressed by nitric oxide
(NO) emissions. For a pm'nt source, t/e NO interactions may be rrinimal,
and the travel time to the expected maximum ozone concentration nay be 3
to 4 hours downwind. In general, the dowwind distance for the maximum
ozone site should generally not be more than 15 to 20 miles fro^ the
source because a lower wind speed (2-3 miles per hour) v/ith less dilution
would b? a more critical case. Additionally, tne frequency that, the
wind would blow from the source ov?r the site diminishes with increasing
distances.
As discussed above for preccnstruction monitoring, appropriate dis-
persion mode!ing techniques are used tc estimate the location of the
14
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air quality impact of the new source or modification. Monitors should
then be placed at (a) the expected area of the maximum concentration
from the new source or modification, and (b) the maximum impact area(s),
i.e., where the maximum pollutant concentration will occ'.ir based on the
combined effect of existing sources and the new source or modification. |
It should be noted that locations for these monitors may be different |
from those sites for the prcccnstruction phase due to othe>- new source1" ]
or modifications in the area since the preconstruction monitoring. i
Generally, two to three- sites would b* sufficient for most situations I
in multisource areas. In rr\r,ote areas where there are no significant i
existing sources, one or two sites would be sufficient. These sites j
would be placed at the locations indicated from the model results. The j
same concerns discussed in section 3.2.1 regarding industrial process _'
fugitive particulate emissionsr fugitive hydrocarbon emissions, and ]
ozone monitoring would also be applicable for the postconslruction j
phase. ]
3.2.3 Special Ccnjerns for- Location of I'cnitors ;
For the ^reconstruction and postconstruction phases, modeling is '
used to determine the general area where monitors would be located. Some '
of the moueled locations may be within the confines of the source's
boundary. However, monitors should be placed in those locations satisfying
the definition of ambient air. Ambient air is defined in 40 CFR 50.He)
as "that portion of the atnosphcre, external to buildings, to whirh the
general public has access.1' Therefore, if the modeled locations are
within an area excluded frorr, ambient air, the monitors should be located
downwind at the boundary of that area.
In some cases, it is simply not practical to place monitors at the
indicated modeled locations, Some exair.ples may include over open bodies
of water, on rivers, swamps, cliffs, etc. The source and the permit
granting authority should determine on a case-by-case basis alternative
locations.
3. 3 Probe Si-ting Criteria
The desire for comparability in monitoring data requires adherence
to some consistent set of guide!iiies. Therefore, the probe siting
criteria discussed below rust be followed to the maximum extent possible
to ensure uniform collection of air quality data that are comparable and
compatible.
Before proceeding with the discussion of pollutant specific probe
siting criteria, it is important to expand on the discussion in sect-'-.':
3.2 of the location of monitors. In particular, reference is made to
two monitoring objectives.
e Ca_se_l_: Locating monitors to determine the maximum concentration
from the propo.-ed source and/or existing sources.
e Case ?.: locating r.onitors to determine whe^e the combined
impact of tne proposed source and existing sources
would bo expected to exhibit the highest concentrations.
15
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Fcr Case 1, the driving force for locai:in,g the siting area of the
monitor as well as tne specific location of the probe or instrument
shelter is the objective of measuring the maximum impact from the prooosed
source. Two Case 1 examples an;e objective (maximum concentration from
proposed source), consider the second example in which pollutants would
be emitted from a ground level scjrce. In this case, the concentration
gradient near the ground c^st be large, thereby requiring a much tighter
range of acceptable probe heights. For ground level sources emitting
pollutants with steep vortical concentration gradif-iits, efforts should
be made to locate the inlet protc; for gaseous pollutant monitors as
close to 3 meters (a reasonable practical representation of the bre.ithing
zone) as possible and ror particu'ate monitors using the hi-volume
sampler 2 to 7 meters above grounc level. The rationale for the 3
meters is that for gaseous pollutant measurements, the inlet probe can
be adjusted for various heights even though the monitor is located in a
building or trailer. Conversely, the 2-3 meter height for the In-
volume sampler placement is not practical in certain areas. Th«> 7 meter
height allows for placement on a ore story building and is reasonably
close to representing the? breathing -one,
Turn now to the second monitoring objective, Case 2, wnich i',
locating monitors to determine tie maximum impact are-a taking into
consideration the proposed source as well as existing sources. The
critical element to keep in mind in locating a monitor to satisfy tins
objective is that the intent ib to "•.-!.,ir.ize the combined effect. Thus,
in one circumstance, tho "x.iLlin^ scjrce might contribute the largest
impact. The importance c.< the above discussion t~- the topic of probe
siting criteria is that ir( otterutin-: to locate a iron i tor to achieve
this objective, the plac'-rnent o," ,.hr. probe or instrument snolter can
vary depending upon which source is the predominant influence on the
maximum impact area. As an extreme example, consider the situation
where a proposed elevated source would emit CO into an urban area and 1
have .r.aximum combined CO impact coincident to an urea adjacent to a *
heavily traveled traffic corridor. It i£ known that traffic along
corridors er,iit CO in fairly steep concentration gradients so the placement
of the probe to measure tne areas of highest CO concentration can v«ry
significantly vith probe height as well as distance from the corridor.
In this example, the traffic corridor has the major influence on the
combined impact and therefore controls the probe placement. As noted in
the CO probe sitinq criteria in .-.•-• ^-' ••> ?.s.? as well as Appendix E of
the K:>y 10, 1979 Federal R^JLlsj^er proi-jlgation of the Ambient Air Monitoring
Regulations [10], the required ^robe neiynt in such nicrosralf; c-ise" is
given as 3 +_ 1/2 meters while the distance of the probe t>or>i me roadway
would De between 2 and 19 meters.
16
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As another example, consider the case where the sane proposed CO
source would emit CO at elevated heights and have a corrbined maximun CO
impact in an urban area that is only slichtly affected by CO emissions
from a toadvay. The cc/nained innact area in this case is far enouch
away from tne two sources to provide adequate mixing and ot.ly small
vertical ccncer^ration gradients at the impact area. In this case, the
acceptable probe height h. jld bo in the ranqe of 3-15 meters.
4
It is recognized that there may be other situations occurri ig which
prevent the profce siting criteria from being followed- If so, the
differences rust be thoroughly documented. This documentation should
minimize future questions ebout the data.
The desiri for comparability in monitoring data requires adherence
to some consistent set of gui Klines. Therefore, the probe siting
criteria discussed below nust be followed to the r.axirum extent possible
to ensure uniform collection of air quality data that are comparable and
compatible. To achieve this goal, the specific sitin-i criteria tnat are
prefaced with 3 "must" are defined as a requirement and exceptions must
be approved by the permit granting C'jthority. Ho/vever, siting criteria
chat are prefaced with a "should" are defined as a goal to meet for
consistency, but are not a requirement.
-.->:- _ The most desirable heicnt for a TSP "-.Dm" cor
is near the breathing ^cne. However, practical considerations such as
prevention of vandal is i, security, accessibility, availability of electricity.
etc., generally require f.at the sampler be elevated. Therefore, '\
range of acceptable heights needs to be used. In addition, the type of
source, i.e., elevated or ground level, predominantly influencing the
area of intact ~ust be considered when locating the r.onitor. For purposes
of determining elevated source impact, the sampler air intake must be
located 2-15 reters at.ove ground level. The lower linit was cased on a
cororomise between ease of servicing ihe sampler and the desire to avcid
reer.train-er.t from dusty surfaces. The upper limit represents a -ro-nprc-nise
between tne desire to have ne~sjrements which are most representative of
population exposures, and tne considerations noted earner. For ground
level sources with steep vertical concentration gradients, the air
intate must be as close to the Dreading zcne es practical.
5.2.1.2 f: -.*--.;. ;>.-*•? :~^-:~.ts~icyis - If the sampler is located on a roof
or other structure, then tnere must be a riinimum of 2 meters separation
from walls, parapets, penthouses, etc. Furthermore, no furnace cr
incineration flues should be nearby. The separation distance fror flues
is dependent on the heicnt of the flues, type of waste cr fuel burred,
and qualitv cf the fuel (ash content). For example, if the emissions
from the chir.-.ey are the res'ilt. of natural gas combustion, no special
precautions are necessary except for l":e avoidance of obstructions,
i.e., at least 2 meters separation. On the other hard, if fuel oil,
coal, cr solid waste is burned a,id the stack is sufficiently short so
that the plir* cojid reasc^dDly be expected to impact on the sampler
ihtake a significant part of the tine, other buildi"2o/locations '•" l^~
area that =re free fro," these types ot \ojrces srould be considered for
s^-ipling. frees provide surfaces fo- pa.'ticulate deposition and also
17
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restrict airflow.
meters from trees.
sampler should be pldceti at least 23
Obstacles such 3s bui".c';'~:s r.-jst also be avoided so that the distance
between obstacles and th^ sa^er i-; at least twice the heignt that the
obstacle protrudes atxws the •"'•': *o le?s t^-ar. ?oproxin reters from the ei^e
affic 1^-c- a'-J 2 to 15 -eters above ci cund level.
conclusion that
height of the monitor and J
have beer, reported at monit
heavily traveled roads, vc
within the concentrated pV_
by vehicle traffic. There*
located beyond the concer.tr.
an."! not so close that the
dominate the measured amb
An an!ays is
relationship betw
zone where ths pi
3,000 vehicles ua
by snowing :•..•(.
locations whi-cn a
should be avoices
Roads with lower
da/) are general!
related pollutant
of roni tors in Ic
those cases »vnere
per day, the rori
of the nearest i<~
In the case of elevate:' roadways where? the monitor rvjst be placec
belo^ the level of the rose..*_., tne monito- should be located no r^cc-e-
thai approximately 25 necer;- T'VO.M the ed.;e of the nearest traffic lan^.
This separation aistance; a~r". ;es for those situations where the roa^ ;s
elevated greater ihan 5 rate-'? above the oround level, and applies to
all traffic volu-es.
Or>:-,-i- _.' -»:£•:'-f..-1".;- :'.•_'•.• - Stations should net be located in an
unpaved area unless there •? •eqetative crojnd cover vear rcund so *';;
the impact of reentrained cr fucitive dusts will be kept to a pinirL,-.
Additional information on 75? probe siting nay be found in reference- t
.. _
the ^ost d"esTraTiTF^eig:rr *;
height. Various "'actors c-
probe be elevated. Consice
source predominantly influs"
the inlet prr^» rust be "i
:"_r" "•" •" _-:_-!_V- "/'J " As witn TSP rnon* toriif
an "5iJ^Tn"r~eTy>;"bT)e is rear the breatr-.rc
~erc.t~c" before -3y require that the inl?t
.-.tier njst al;o ce g^ven to the type of
cv:c the irpact area. For elevatsd sources,
}- to 15 -rters above -v'oui.d level. F:-
13
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19
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ground level sources, locate as close to the breathing zone as possible.
If the inlet probe ^ located on the side of the building, then it
should be ""coated :n the windward side of the building relative to the
prevailing winter wind direct. or- !he inlet probe must I"3. io:atec,
more than 1 meter vertically or horizontally away from any supporting
structure and also .!>•,?.;/ from dirty, dusty areas.
S.s.z.2 §r
-------
?.3.C.£ ~~~^:-:~ .">£" -:~i? - For f'OSe situations discussed above where
the emissions from a proposed source \o/id impact c street canyon/corrida'
type area, the ir.let pro?.';- ir.ust be lasted at least 10 meters from an
intersection and prefe^aDly at a mi CLOCK location. The inlet probe
must also be placed 2-iD reters fro- t-,e edge of the nearc3v traffic
lane. Additional inforrsfion on CO j-"T:»e siting may be four.c in reference
8.
? 7 „„.— / ^ }
~~ ' ^ "c ~~
3.3.4.1 "cr-:r - The in'et probe for
ozone monitors should I:?"as close as possible to the breatnir.g zone. The
complicating factors discussed previously, however, require that the
probe be elevated. The neight of tre inlet probe must be located 3 to
15 meters above ground level. The probe must also be locateJ more than
1 meter vertically or horizontally awav fron. any supporting structure.
,r. ,7. 4. 2 ?T~i:.r.:: fro- .'
obstacles enn buildings
the inlet probe is at 1
above the sampler. The
from trees. Since the
than for sc-e of the ot
us^rl in locating the in
unrestricted in an arc
predominant direction f
potential rust be inclu
the side of a buildinc,
cr.":<^rigrg - The probe must be lc ited a'.'ay from
such that the distance between the obstacles and
?ast twice the ".eight that the obstacle protrudes
rrcbe should also be located at 1-east 20 meters
scavenging effect of trees is greater for ozone
^e^ pollutants, strong ccnside-atiDn should be
let prole to avoid this effect. Airflow nust be
of at least 27G; around the irPet arcbe, and the
cr the seaso
ced in the 2TOr
133° clearance "-s required.
f greatest pollutant concentration
arc. If the probe is located on
5.3.-1.? 5r
to minirize
since NQ
Table 2 p--o
is
recalculate
more recent
separation
other sin^
Additional
reference 3.
TABLE
destru'.ti ve
eadily reacts
viaes the re?
d ozone nor't
ens using the
ambient data
flistance must
ar volumes of
information c
interferences
with ozone.
•jired mirir.^'-
oring statior-.
ir.ethodolocy
collecred re
al so be r.a-lr.t
automotive tr
n ozone prc:>
c-ortant in the prote siting Dro:ess
frc.T- sources of ni^nc oxide (NO)
"?carding KO fron nctor vehicles,
separation distances between
Theie cistances were based on
r, reference 9 and validated u->ing
r a major roadway. The ninimum
ained between an o?.one station and
affic, surh as parr.inq lots.
siting criteria may be found in
MINiv:JV SEPARATION DISTANCE BETWEEN OZONE MONITORS
AN? FJADh'AYS (E23E CF NEAREST TRAFFIC LANE)
Roadway Average Caily Traffic,
' Vehicles "er Dav
i < 10,000
15,000
20,003
40,000
70,000
> 110,000
. f-'.im'ruum Separation Distance Between
Roadways aid Monitors, Meters
! >_ 10a
j 20
' 30
; 5"
100
, 250
fDistar,ce- should te :r.terpolatec
:,c = e. en traffic flow.
21
-------
3.3.5
~-?x.c
3.3.5.1 Vert-V:! a*
- As discussed for
previous pollutants, the selectable rairj^s for a monltcr/probe inlet
for monitoring .NCL emissions in an aroa p'-ncipally influenced by an
elevated source is 3-15 r.eters. For arc is influenced primarily by a
ground level source, the r,ei;it should be « close to 5 r-eters as possible.
Regarding the distance of tra probe from the supporting structure, a
vertical or horizontal distance ot 1 meter nust be maintained.
3.2.5.2 Spa^-'--; f»cm_Ob2_li::^-;->:s - Bui'dings, trees, and other obstacles
can serve as scavengers of W~. In order to avoid this 'e probe. Also, a probe inlet
along a vertical wall is undesirable because air moving along that wall
may be sub.iect to possible removal mechanis~s. Similarly, the inlet
probe should also be at least 20 meters frc ! trees. There must be
unrestricted airflow in an a^c cf at least 270° around tr.e inlet probe,
and the predominant direction *cr the sea^C'i of greatest oollutant
concentration potential rr-jst ~: included i«- the 270° arc. If th= rrcne
is located on the side of ~he tail ding, IcT' clearance is required.
Additional inforration on 'O~ probe sitir,: criteria may &e found in
reference 9.
2.5.6 Lead '?r'
V-?}'
t - ) C.
location for tn; vertica
factors previously mention-.:
elevating the sacpler, cons:.'
(whether they be stationer, ;
gradients. Placing the she It
significantly lo^er than t-se
the sampler for ground level
above ground le'.el. In ccrtr
as noted in previous discussi
locating the sa~pler/inlet pr
for monitoring emissions
level.
Ereathing re
r.?-ent cf f.e
!-:;jire that
•?ration must
r -obile sci""
e^ too nigh c
level breare
scarce monir:
?.5t, samplers
on, are allo
cse. For Pb
elevated sou
~";ht is the r
.rb monitor,
the monitor c
re yiven to g
c^s) with ste
rjld result i
a Dy the gene
ring must be
to monitor
ed a wider r2
samplers, the
rces is 2-15
est desirable
r.cwever, .practical
e elpvated. In
r-OL.nd level emissions
en' vertical ccr-centr^ticri
r, ~easurea values
ral public, /^cccrcingly,
located 2 to 7 reiers
c'~ elevated sources,
ge of heights fo,-
acceptable range
eters above around
from walls, parapets, ann oe"
a roof or other structure. \":
nearby. The height of tne fl
waste or fuel burned deter~ir
example, if the enissions fiv
there i? a nigh probability J_:
during most or the savpling ^
the area thai ar-? free fro~- f
the nonitcring site. The Sc.":
from trees, since trees abscr;
j;_/j:£ - A minimum of 2 meters of separation
-.rouses is required for sa~^lers located on
! furnace or •"ncineration flues shoulc ce
on flues, ror
:ad ccntent =3r,d
•n the sanoler
!--icd, then ctrer buildir,;: • 'ocations in
j described sources should ce chosen for
Ser should re placed at leas'". 20 meters
^articles as well as acAe-sely affect airflo.v.
22
-------
The sampler must be located away fron obstacles such as buildings,
so that the distance between obstacles ac.d tha sampler is at least twice
the height that the obstacle protrudes above the sampler. There must
also be unrestricted airflow in an ere. of at least 270° around the
sampler, and thu predominant direction fci the season of greatest pollution
concentrator! potential nu>t be induced in the 270° arc.
2.3.6.3 £>£<*.?"' ng from Ar^fr - For thoro situations discussed in section
3.3.6.1 where tha emvVsibns from a prc;osed source would impact close to
a major roadway (greater than approxinacely 30,000 ADT), the air intake
for the monitor must be locatec withit, 15-30 meters from the edge of the
nearest traffic lane. Monitors located in this area would thus measure
the combined impact from the proposed source and the roadway. The sampler
air intake dust be 2 to 7 meters above ground level.
3.3.6.4 Oi>.cr Consideraticr.s - Stations should not be located in an
unpaved area unless there is vegetative ground cover year round so tnat
tiie impact of reentrained or fugitive dusts will be kept to a minimum.
3.3.7 .Vr-: teria Po I l:i i-a>: ic,
3.3.7.1 :V3':.?'^7 Placarcxt - Similar to the discussion on criteria pollutants,
the most desirable height for monitors -'inlet probes for noncn'teria pollutants
is near the breathing zone. Again, practical factors require that the monitor/
inlet probe be elevated. Furthermore, consideration must. be given to the
type of source, i.e., elevated, ground le/el, stationary, or r.obile. As
the case may be, for noncriteria particulete pollutant monitors, the fo!1cv<-r,g
monitor/inlet probe ranges are acceptable: for impact areas predominantly
influenced by elevated sources, 2-15 raters; for ground "level sources 2 to
7 meters. Regarding noncriteria gasecjs pollutants, acceptable heights
are as follows: areas itrpactea prir:ir.ly by elevated sources, 3-15 neters;
areas affected principally by ground level sources, as close to 3 meters
as possible.
3.3.7.2 ^ y.^ji>:j fro-i Cr^tru c'tior.g - If the sampler/inlet probe is located
on a roof or other structure, then there rust be a minimum of 2 neters
separation from walls, parapets, penthcuses, etc. No furnace or incineration
flues should If. nearby . Th^'s separation distance from flues is dependent
on the height cf the flues, type of waste or fuel burned, and quality of
the fuel. For example, if the emissions from the chimney contain a high
concentrator! of the noncriteria pollutant that is being measured and there
is a high probability that the plume '.could impact the sampler/ inlet probe
during most of the sampling period, then other buildings/locations in the
area that are free from tne described sources should be chosen for the
monitoring sHe. The sampler/inlet probe should also be placed at least
20 meters from trees.
Th2 s?.7;pler/ inlet probe must be located away from obstacles and
buildings such that the distance between the obstacles and the sampler/
inlet probe is at least twice the heicr-.t that the obstacle protrudes
above the sar.pler/inlet probe. Airflcn f-ust be unrestricted in an c.rc
of at least 270° around the sampler/inlet probe, and the preconinar.t
23
-------
direction for the season of grr-atest pollutant concentration potential
must ba included in the 270J arc. If the inlet probe is located on the
side of a building, 180° clearance is required.
3.Z. 7.^ Ote-.fi' C3r.eider<:t.'L_..-i - Stations fcr measuring particulate ncr,-
criteria pollulaTTtTTfiould not b» located in an unpaved area unless
there is vegetative grojna co/er year rouno so that the impact of
recntrained or fugitive dusts will be kept to a minimum.
3. 4 Probe '-'arerial and Pc"::^.ar.t Sgrrolc .-,--.ii-denae Time
For reactive gases, special probe material must be used. Studies [20-24]
have been conducted to determine the suitability of materials such as
polypropylene, polyethylene, polyvinylchloride, tygon, aluminum, brass,
stainless steel, copper, pyrex glass, ard teflon for use as intake
sampling lines. Of the above .^aterials, only pyrex glass and teflon
have been found to be acceptable for use as intake sampling lines for
ell the reactive gaseous pollutants. Furthermore, EPA [25] has specified
borosilicate glass or FEP teflon as the only acceptable probe materials
for delivering test atmospheres in the determination of reference or
equivalent methods. Therefore, borosilicatc glass, FEP teflon, or t--eir
eqjivalent must be used for inlet crobes.
No natter how unreactive the sampling orobe material is initially,
after a period of use, reacti/e particulars ratter is deoosited on t^e
probe walls. Therefore, tr.e tine it takes the gas to transfer from the
probe inlet to the san>3lin? device is also critical Ozone in the presence
of NO will show significcint; losses even in ir,e most i iert probe material
when the residence time exceeas 20 soconos [26]. Other studies [ 27-2j]
indicate that a IC-second or less residence time is easily achievable.
Therefore, sampling probes tcr reactive j-as -onitors rust have a sampler
residence ti>r.e less than 20 seconds.
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4- W.^^lJiLi^-L1'.^-!0?-. A.^..'iUAL^ D/'~'A
On May 10, 1979, EPA profKiVjitec! qjali<-y assurance requirements for
PSD monitoring for S0?, NO-, 0-, CO, -ind ISP. Tnese quality assurance
requirements are Appendix 5 of"'"1', CiT; 58 (part of reference 10). EPA
plans to amend Appendix B to inc'udfo cv;
-------
monitoring, the level uf data quality needed, the expertise of personnel,
the cost of control procedures, pollut:.rc concentration levels, etc.
Accordingly, quality control requirements ire specified in general
terms in tactic -!.1.2 to allow each organisation to develop a quality
control system wMch is most effective for its own circumstances.
For purposes here, 'or-'jar.ization" is defined as a source owner/operator,
a government agency, or their contractor which operates an ambient air
pollution monitoring net^ort- for PSD pjrpor.es.
4, l. 2 Quality Control Rcc:<.~rfrrients
4.1.2.1 Or:Tari-i::ational Pe?>'vf.nentz - Each organization must develop
and imp^e^errFT quaTTty control program consisting of policies, procedures,
specifications, standards, and documentation necessary to:
(a) meet the monitoring objectives and quality assurance requirements
of the permit granting authority.
(b) minimize loss of air quality data due to malfunctions or out-
of-control conditions,
The quality control prog-am must be described in detail, suitably
documented, and approved by the permit granting authority.
4.L2.!' f^'^'ir^ '••"'<"!i!"'-l£ " Primary guidance for developing the cuality
control prc"cj~ra~r.i"is contained i;i references 29 and 30, which also contain
many suggested procedures, checks, ar;d control specifications. Section
2.0.9 of reference 30 describes the specific guidance for the development
of a quality control progr^'i for PSD automated analyzers and ranual
methods. Many ipecific quality control checks and specifications for
manual method: ^re included in the respective reference methods described
in 40 CFR 50, or in the respective equivalent method descriptions available
from £PA (see :t.-r:t.-Lon '.;<}- Similarly, quality control procedures
related to :>pocifica!1y designated reference and equivalent analyzers
are contained in their respective operation ar.d instruction ranuals.
This guidance, and any other pertinent information from ^ppropr^aTe
sources, should be used oy organizations in ''eveloping their quality
control programs.
As a m'nirnurr, each quality control program must have operational
procedures for each of the following activities:
(a) selection of methods, analyzers, or samplers,
(b) installation of equipment,
(c) Ceil ibration,
(d) zero and span chocks and adjustments of automated ar.alyzers,
(e) control checks and their frequency,
(f) control limits for ,?ero, span and other control check-;, and
respective corrective actions when such limits are surpassed*
29
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vg) calibration snd zero/span checks for multinle range analyzers
(h) preventive and rf.^f(Hnl nai^t^nance
(i) recording and va.l id a*,'ing data
(j) documentation of q-iaMl/ control information. .
As previously mentioned, specific yuidaiice for each activity listed ]
above that must be a part of jn organization's quality ccf.trol program
is described ir section 2.0.9 of reference 30.
4.1.2..', Pcllutant Zt^darlo - osseous standards (permeation tubes,
permeation devices or cylinders of compressed gas) used to obtain test
concentrations for CO, SO,,, and I.O- niust be working standards certified
by comparison to a National Bureau of Standards (NBS) gaseous btarid-.:rd
Reference Material (S.\M). A trace-ability protocol for certifying a
working standard by direct comparison to an NBS SRM is given in reference
31. Direct use of an NBS SRM as a working sUr'dard is not prohibited
but is discouraged because of trie- linited supply and expense of NBS
SRM's. When available, gas manufacturers' cylinder gases Certifiec
Reference Materials "CRM" may be subtitled for NSS SRM cylinder got^s in
establishing traceability.
Test concentrations for o;?;/j^ •_: ••>••'_?}"-2L.'-L-' ~ ^^e organisation operating 1
a PSP monitoring network n;ust pa;'.icipate in EPA's national perfoni.anco \
audit program. The pe'mit grantir.q autfiority, or EPA, nay con iuct i
rystein audits of the ambient sir f;onitorino programs of organizations |
operat. ig DSD networ'2t,- ! '•'.__•''>-s.'ds - A one-point precision check I
trust be carried out at least onco r.-very two vv_"?ks on each automated 1
analyzer usea to measure SOp, f;f)?, 00> ard CO. The precision check is ;
made by challenging the anafyzerSntfi a precision check gas of k.iown i
concentration between 0-03 and 0. kJ pp-ii for SO,,, NO,, and 0^ analyzers, |
and between 8 and 10 ppr1. for CO o'.alyzers. The^starioarris from wine*'! »
precision check te^t concen^ratior.s are ct/tsinc-d must root the specification;- ,j
of r.:-t;v". 4.~.2.Z. Cxcept for c^-ita^n CG analyzers described below, j
analyzers must operate in their lo-ral sarrprir,'i mode durir'.'j the rrecinion |
check, and the test atrosphere nust pass thtoJQh all filfcvs, scrubbers, j
conditioners, and othT component: used during normal arrbient saiipli:i-; |
as rr.uch of the ar.bient air ir.K-t systc-". as ia practicable. If permitted >,
30 /
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by the associated operation or instr.c:ion manual, a CO a,ia'ttr the -•"-.alyrer &i a point other than
the normal sample in lot, proyi_ded_ '_'.;.'. the analyzer's response is not likely
to be altered by those Deviations f i: ~ the normal operational rade.
If a precision check is made in conjunction with ziro/span adjustment,
it must be made prior tc such zero ar.ri span adjustments. The difference
between the actual concertratiori of t.~e precision check gas ar.d tr.e
concentration indicated by the arialv;er is used to assess the precision
of the monitoring data as described in .*<•<.-tion -1.2.4.1. Report cata
only from automated analyzers that are approved for use in the t; ^....r. fc1" certain CO
analyzers does not cvply for audits,
The difference between the actual concentration of the ctc't test gds
and the coricentraL-icr, indicated b\
accuracy of the Monitoring data as
data only from autc-^t^J analyzers
network.
-e analyzer is u:ed to a;?e.;s the
5?^ribed in ec:=t'.i.r. ;...-.;. Report
~ st are approved for use in the PSD
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-:.:.;•;.3 PJV:xf.r_n n£_ .••.:;:;,.•; ."-•.'''.-.-;..' - (a) TSP Method. For a given
organi/atTon' s mcni tor in.? r.et.,:>rk, o^e sampling site must have collocated
samplers. A site with in;> nig'ie^t opscted 24-hour pollutant concentration
must be selected. The tv--- samplers rr.^t be within 4 meters of each other
but at least 2 mer.ers ar;-rc to precl.de airflow interference. Calibration,
sampling, and aiialysis :, js, be the ss~e for both collocated samplers as well
as for all other samplers ~'n the network, f^e collocated ss.r.plers must
be operated as a nrirmiuii- every third cay wien continuous sampl-In"1 is used.
When a less frequent sample schedule is used, the collocated sailers must
be operated at least once each week. Frr each pair of collocated samplers,
designate one sampler as tr.e sampler which will be used to report air duality
for the site and designate t~s other as the duplicate simpler. The difference?
in measured cor!_entration Lg/'nM between the two collocated samplers are
used to calculate precision as described in s: ;.-'..'.1.
(b) Pb^eJJijods. The operation of collocated sarrplers at one sampling
site must be used to assess tte orecision of tne reference or an equivalent
lead method. Th^ procedure to be followed for lead methods is tne sare as
described in -.1.3. $(••:) for the TSP method.
-;. ; 3.-! diMiIL'£iL€£ ii-'-^L.^liilJiI ~ (a) TSfJtethcd. Each, sailing
quarter audit *he "f Jow Yate of each high-volume san.p'ler at least once.
Audit the fie*' rate at one flow rate using A reference flow device
described in section 2.2.3 of reference 33, or a similar transfer flow
standard. The device useJ for auditing nust be different fror tre one
used to calibrate the flow of the hig^'-volure sandier being audited.
The auditing device and the calibration device may both, be referenced
to the same primary flow standard. With the audit device in place,
operate the high-volume s;"pler at its norral flow rate. The difference
in flow rate (in rrr/min^ bot-.een the auaH "Ic/^ measurement and tre ."Sow
indicated by the sai.ipler's not~:ia"i flo'-.' indicator is used to calculate
accuracy as described in .^.*^:jn -l.l.?.r..
Great care must be used in auditing high-volume samplers bavin.;
flow regulators because the introduction of resistance plates in the
audit device can cause at-norral flow patterns at the point of flow
sensing. For this reason, the orifice of the flow audit device snould
be used with a normal nlass f'ber filter in place and without resistance
plates in auditing flow rermatad high-volume samplers, or other sto:-s
should be taken to assure tr.at flow patterns are not perturbea at tne
point of flow sensing.
(b) Pb Methods. For the reference method (Appendix G of -0 CFR 50)
each sampiinc quarter auvJit the flew rate of each high-volun.e lead sampler
at least once. Audit the tl^w rate at one flow ,-ate usiiig a reference flow
device described in sectior 2.2.8 of reference 30, or a similar flow
transfer standard. The device used for auditing ir.ust be di^erert fro17!
the one used to calibrate f'c flov; of the high-volu:re sampler being audited.
The auditing device and the calibration de.-ice r^y both be refe*enced to
the same primary flow standarc. With tr.e audit device in pTace, operate
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the high-volurno sampler at its normal fie.* rate. The difference in flow
rate (if" n^/ir.in) between the c^riit flow reasurement and the flow indicated
by the sampler's normal flow indicator is used to calculate accuracy as
described in s-vr:';»i 4.1.5.?.
Hreat care '-ust be used in auditing high-volume sampler having flow
regulators because the introduction of resistance plates in the audit
device can cause aoncrmal tie*,- patterns at, the point of flow sensing.
For this reason, the orifice of the flow audit device should be used
with a normal class fiber filter in place without resistance plates to
audit flow regulated high-voli/~» samplers, or other stens should be
taken to assure that flow patterns are net perturbed at the point of
flow sensing.
Each sampling quarter, audit the ""ead analysis using glass fiber
filter strips containing a known Quantity of lead. Audit samples are
prepared by depositing a leaa solution on 1.9 cm by 2C.3 cm (3/4 inch
by 8 inch) unevposed glass fiber filter strips and allcwirc to dry
thoroughly. The audit samples r.ust be prepared using r-arents different
from those used to calibrate the lead analytical equiprent being audited.
Prepare audit sa~ples in the following concentration ranges:
Equivalent Ambient
Pange Cone, vg Fb/strij) Cere. -g_Pb/ni'*
1 100 to 3CO 0.5 to 1.5
2 600 to 1C30 3.0 to 5.0
*Equivalent ambient lead concentration in --g/.n3 is based on samoling
at 1.7 m?/rcin fcr 24 hours en 20.3 cm x 25.4 cm ( 3 inert x 10 inc! '> class
fiber filter.
Audit sa-ples nust be extracted using the same extraction procedure
used for exposed filters.
Analyze at least one ana-It sample in each of the two ranges each
day that sa:r;-»1es a*"c analyzed. Th" difference between th.e audit concentration
'in ug Pb/strir'- and the analyst's measured concentratiers (in ijg Pb/st'"'o)
are used Lo calculate analysis accuracy as described in ?e-:.-rfc-»: 4.1.;. -.
The accuracy of an equivalent nethod is assessed in the seme nar.ne**
as the referer-ce rethod. Ire flow auditlr.c device and lead analysis
audit samples -jst be conipatiMe with tr.e specific requirements of tie
equivalent rc-tio'i.
r, organization, 5t the end of each
sampling quar:-;r, shall ccl'j'.ate and rc-ro«*t a precision rrobaoilit> interval
for pacri an^Krer. Dirpct-:cp- fnr caic-/.atior.s are ai\en below r.nd directions
for reporting are given in .VJT:V': -«'.-. t\ If r.onitorirg cata are invalidated
33
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r~
during the period represented by u given srecision check, the results
of that precision check shall be excl^-ieC from the calculations.
Calculate the percentage difference .j.) for eacn precision check
us ing equation 1.
Y - x.
di =—XT
where: Y. - analyzer's indicated concentration from the i-th p>-ecicion
1 check,
X. = known concentration of the test gas used for the i-tti precision
check.
For each instrunent, calculate the charter"! y average (d.)» equation 2, and
the standard deviation (S,- }, ecuaticr. 3. J
(2)
Where n is the number of precision c^ec'-.s on the instrument rradc- during
rhe sampling quarter. For example, n srould be 6 cr 7 if span checks are
rade biweekly during a quarter.
Calculate the 95 Percent proDabil:ty limits for precision using
eouations 4 and 5.
Upper 95 Percent Probability Li-it = 3. + 1.96 S. (A)
J J
Lower 95 Percent Probability Li"it = 5 - - 1.96 S- (5)
•J tJ
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4.1. -'.2 Si>:j:c Ar.jl-j-.-.cv ,;.•.•:.!»- "z - lach organization, at the end of each
sampling quarter, shall calculate and report the percentage difference for
each audit concentration for each analyzer audited during the quarter.
Directions for calculations art given below (directions for reporting
are given in .-.•.•:•;.,>: 4. '.,•:,*.
Calculate and report the percentage difference (d^) for eech audit
concentration using equation 1 where Y.. is the analyzer's indicated
concentration from the i-tn audit check and X^ is the known concentration
of the audit gas used from the i-th audit check.
4.1.5 Co Ifi-^'l-^ :::••> is for '•Lvr.i-'. Methods
4. 15.1 Sir.^'-c -r.strwnf>".T P?.:--i~icY> for 75? ?r.l .-'*• - Estirates of precision
for ambient air quality measurements from the TSP method are calculated
from results obtained from the collocation of two samplers at one sampling
site as described in sc.c-t '. j*\ ~.1.2.z(a) for TSP and •?.;.". ?.(b) for Pb.
At the end of each sampling quarter, calculate and report a precision
probability interval using v>ee*;ly collocation sampler results. Directions
for calculations are given below and directions for reporting are given in
section 4.1. f .
For the paired measurer er.ts described in section -'.1.',:.?(a) or
4, '..?.. 3(b>* calculate the percentage- difference (d.), using equation 1
where Y. is the TSP or Pb ce: contrition measured by tne duplicate sampler
and X.j Is the TSP or Pb concentration measured by the sanpler reporting
air quality for tiie site. Circulate the quarterly fverace percentage
difference (3:), equation 2, standard deviation (s,-)» equation 3, and
upper and lower 95 percent probability limits for precision (equations
6 and 7}.
Upper 95 Percent °robability Limit = d, + 1.96 S./>r~2 (6)
•j J
Lower 95 Percent Probability Limit = d- - 1.96 S./>1> (7)
J J
4.1.5.2 Si^j'r ' ':•? '. r>nr,cr. r _.~. c_^r^z. for> -'-T ~ Each organization, at the
end of each"^¥FpTir,g quarter, snail calculate and report the percentage
difference for each high-volu~e sampler audited during the quarter.
Directions for calculations are given below and directions for reporting
are given in sc.^icn 4. I.e.
For the flo'.v rate audit described in section 4.1.5. 4, let X.
represent the known flow rate and Y.. represent the indicated flow rate.
Calculate the percentage difference (d.) usirg equation 1.
4.1. 6. 3 5^>:_:r,- ^''.-fTrtf/y':^ 5-:-ri'-;7 Aacurzoj f'T Pb - Each organization,
at the end of eacr. sampling charter, shall calculate arm report the
percentage difference fo^ eacr: nigh-volume lead sampler audited during
the quarter. Directions for calculations are given in .-: :•:-_'_-?: ~.:.t.^
and directions for reportii.c are given in j.;;r:'r?i s'.^.f
35
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3.1.5.4 Si >:.? Is-Ana £yf^ "-^l^LAggliL'^Z..-. /JUJLi: " Each organization, at the
end of each sar.pl ing quarter, shall 1> icJl.ite and report the percentage
difference for each Pb a:\-i3.vsis audit c'jnrig the quarter. Directions
for calculations are give?' beiow and directions for reporting are given
in section »*. ?. G.
For each analysis sucric for Pb described in i-~?tion 4.2.$.-(•:•), let
X. represent the known value of the audit sample and Y^ the indicated
value of Pb. Calculate tr.s percentage difference (d.) for each audit at
each concentration level using equation 1.
4.1.8 Organ:z.-tion B<;r±~."r:'•: ? ?f.c,4-'TV".^r.~s
At the end of eacfi sampling quarter, the organization must report
the followinc. data assessment inf elation' (a) for automated analyzers -
precision probability li-nts from ?cj~:c>. •?. 2.4. 1 and percentage differences
from cectica '..1.4.'', aid (hj for -^nu^l n^thods - precision probability
limits frorr. <---•>tion ;.:.<:.: and percentage differences froni cc^-^-'or.s
-.1.5.2, *.:.£. 3 and -;.:.,'.-'. The orecision anj accuracy inforration
for the entire sampling quarter nust be submitted with the air trcnitoring
data. All data used t) calculate reportea estimates of precision and
accuracy including span creeks, collocated sampler and audit results
must be made availabls to ir>e permit graitirig authority upon request.
At the present ti~8» there are no EPA regulations on quality assurance
for PSD monitoring of no'icriten'a cir pollutants. Trie following are EPA
recctnmendations for a ^j^j_^2 Quality assurance program for noncriteria
pollutants.
4. 2.1 Solution of .Vrr^-_j
Selection of the measurement rethod for tioncriteria air pollutants
is extremely important. A list of acceptable measurement methods for
noncriteria air pollutsrits :s availaole and may be ootained Vy ^riting:
U.S. Envircr.rr,ental Prrtectior: Agency, Environmental Monitoring Systems
Laboratory, Quality Assurance D^isi^n (V.D-77), Research Triaig".e Park,
North Carolina 27711. T.nis list of acceptable :retnods will be revised
at least annually and be available frox the above address. Measurement
methcds considered candidates for the noncriteria pollutant list should
be brought to the atterricn of EPA at the address given above.
Calibration procedures described in the acceptable methods should
be followed end a schecjls for calibrations should be established. In
addition, flow measurement devices useJ to neasLre. sampling rate should
be calibrated and a sc-.ec-le established fo-- recal ;b--ation. Calibr?tion
procedures for several f.o.v neasure-ent devices (rotaneter, critical
36
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orifice, mass flow neter, an<1 wet test fi.eter) are described in section
2.].?. of reforenc-:- 30. All cal;L>-ation p'-ccedures znoulc he written and
ira-.ntained up-to-date by a do.cu;-ent control ..ystem. A ^er-cr-iption of
one document co.iTol syster iner: ias bser, found to be effective is
discussed in section 1.4.1 of reference 29.
Data ','::: :"77?V,'7
Measurerant data of poor quality nay be wors-: than no data at
all. Therefore, tre monitoring organization should establish data validation
procedures and implement these procedures to invalidate data of questionable
quality. Examples of data validation procedures for criteria pollutants
described in section 2.0.9 of reference 30 nay be useful as 3 gjide in
establishing data validation procedures for noncriteria pollutants.
plit '.7~r.-7.--c
Where possible, standard samples containing the pollutant of
interest should ^e analyzed periodically during the analysis of collected
samples. This practice is useful in helping to determine if the andlytical
system is in control. Splitting samples with another laboratory is
quite useful in cetermim'ng if there :->rp unidentified oiases in the
analytical systp-i.
37
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5.1 Data Required
The preconstruction review of proposed major emitting facilities
will require the use of meteorological d^.ta. It is essential that
such data be representative of atmospheric dispersion conditions at
the source and at locations where the source may have a significant
impact on air quality. The representativeness of the data is dependent
upon (a) the proximity of the meteorological monitoring site to the
area under consideration, (b) the comple>ity of the topography of
the area, (c ) the exposure of t.ne meteorological senscrs, and (d} the
period of time during which the data are collected, '''ore guidance
for determining representativeness is presented in reference 33.
A data base representative of the site should consist of at
least the following data:
a. hourly average wind speed and direction
b. hourly average atmospheric stability based en Pasquill stability
category or wind fluctuations (--..}, or vertical temperature
gradient combined with wi;:d speea
c.
hourly surface temperature at standard height for climatological
comparisons and plume rise calculations
d. hourly precipitation amounts "or climatologies! comparisons.
In addition, hourly average, mixing neishts may be necessary for the
air quality irrpact analysis. Ir most rases, this nay be limited to an
extrapolation of twice-daily taciosonde measurements routinely collected
by the National K'pather Service (NWS). .-"- --ions 6.: -.r-.i 6.1 contain
specific information on instruiv^it exposure and specifications.
Requirements for additional inslrur.entation and data will deoend
upon the availability of infc"nation needed to assess the effects of
pollutant emissions on ambient air quality, soils, vegetation, and
visibility in the vicinity of the proposed source. The type, quantity,
ard format of th.? "-eqi'ired meteorological data will also be infljenced
by the input recjirements of the dispersion modeling techniques jsed in
the air quality analysis. Anv application of dispersion node!in3 rust
be consistent with the EPA ".;.",:,;,-;,-•-•:.-• • -. V ^;!:'-.. '.'-. ;>',?" [34.. The
guideline makes soacific recommendations corcerninq ai- qjality rodels and
data bases. It also specifies those situations for w-'c.*, rrodels. data'and
techniques other than those recommended therein, may t~ applied.
33
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Site-specific data are always preferable to data collected off-site.
The availability of sire-specific rr,«rceorc logical data permits relatively
detailed meteorological analyses and subsequent improvement of dispersion
model estimates. Off-site meteorological data m?y be used in lieu of
site-specific data only if it is agreeo by source owner and permit granting
authority that the off-site data are reasonably representative of atmospheric
conditions in the area under consideration. The off-site meteorological
data can sometimes be derived from routine measurements by NWS stations.
The data are available a=> individual observations and in summarized form
from the National Climatic Center, Federal Building, Asheville, NC 23801.
On the other hand, if the nearest source of off-site data is considerably
removed fro:n the area under consideration, and especially if tnere are
significant terrain features, urban areas, or large bodies of water
nearby, it may be necessary that the required meteorological data be
site-specific.
In some case, it will be necessary that data be collected at more
than one site in order to provide a reasonable representation of
atmospheric conditions over ths entire area of concern. Atmospheric
conditions nay vary considerably over the area. In sone case, (e.g.,
complex terrain) it will not be feasible to adequately monitor the
entire meteorological field of concern. Then the only recourse is
to site tne stations in areas where characteristic and signficant
airflow patterns are likely to be encountered. In any event, one
of the meteorological stations should be located so that it represents
atmospheric conditions in the in>mediaie vicinity of the source.
Although at least 1 year of meteorological data should be cvailaole,
a shorter period of record that conforms to the air quality monitonrg
period of record discussed in ?>?-jticr. :. L is acceptable when approved
by the permit granting authority. Tf more than 1 year of data is
available, it is recommenced that such data be included in the analysis.
Such a multiyear data base allows for more comprehensive consideration
of variations in meteorological conditions that occur from year to
year. A 5-year period of record will usually yirld an adequate ireteorological
data base for considering such year-^o-year variations.
In all ca^es, the meteorological data used must be of at least
the quality of data collected by the Ncci^ial Weather Service. Desired
features of instrumentation for collecting meteorological data are
discussed in iea~i.cn 6. '.
5.2 Exposure c +'-'etecrc ..j- -?;'7;. Lnsti^cvr.is
Measurement5: of most reteorolcgical paremeters are affected by the
exposure of the sensor. To obtain cuir.parable observations at different
sites, the exposures must be similar. Also, the exposure should be n^c
that the measured parameters provide a good re-presentation of oollutant
transport and dispersion within thc area that the monitoring site is
supposed to represent. For example, if wind flow dac-">. over a f?irly
broac area are desired, the wind sensors should be a^ay from the i've
influence of trees, buildings, steep slopes, ridger,, cliffs, or helices.
39
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The standard exposure of wind instruments jver level open terrain
is 10 meters above the ground. Open *errairi is defined as an area where
the distance between the anemometer and any obstruction to the wind flow
is at least five times the height of the obstruction. Where a standard
exposure is unobtainable at this height, the anemometer should be installed
at such a height that its indications are reasonably unaffected by local
obstructions and represent as closely as possible what the wind ai. 10
meters would be in the absence of V~>a obstructions. Detailed guicance
on assessing adverse aerodynamic effects due to local obstructions is
contained in reference 35. In locating wind sensors in rough terrain or
valley situations, it will be necessary to determine if local effects
such as channeling, slope and valley winds, etc., are important, or
whether the flow outside those zones of influence is to be measured. If
the analysis concerns emissions from a tall stack, it may be desirable
to avoid the local influences. On the other hand, if pollution from
low-level sources is the main concern, the local influences may be
important.
If the source emission point is substantially above the standard
10-meter level for wind measurements, additional wind measurements at
the height of the emission point d:d at plume height are desirable.
Such measurements are used to determine the wind regime in which the
effluent plume is transported away from the source. (The wind speed and
direction 50 to 100 meters or more above the surface are often considerably
different than at the 10-meter level.) An instrumented to.ver is the
r.ost common means of obtaining meteorological measurements at several
elevations in the lower part of the atmospheric boundary layer. For
wind instruments mounted ort the side of a tower, precautions •"•jst be
taken to ensure that the wind mea^jrc^nts are not unduly infl>;enceo by
the tower. Turbulence in the i rimed iite wake of a tower (even a lattice-
type tower) can be severe. Thus, defending on the supporting structure,
wind measuring equipment should be .nouuted (e.g., on booms) at least two
structura widths away from the structure, and two systems rcountec! on
opposite sides of the structure will sometimes be necessary. A wind
instrument mounted on top of a tower should be mounted at least one
tower width aoove the top. If there is no alternative to mounting
instruments on a stack, the increased turbulence problem [36], p'i'St be
explicitly resolved to the satisfaction of the permit granting authority.
Atmospheric stability is anocher key factor in pollutant dispersion
downwind of a source. The stability category is a function of static
stability (related to temperature change with height), convective turbulence
(caused by heating of the air at ground level), and mechanical tuibtlence
(a function of wind soeed ard surface roughness). A procedure for
estimating stability category is given by Turner ^37] which requires
information on solar elevation angle, cloud cover, ceiling height, and
wind speed. The hourly observations at NWS stations include cloud
cover, ceiling height, and wind spec-d. Alternative procedures tor
estimating stability cateco-*y may be applied if representative data are
available. For example, stability category estimates may be based upon
horizontal wind direction fluctuations I 33], or vertical gradients of
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temperature and wind speed [39] '-. o ubtain a representative reading of
the air temperature, 'ilfc temperature sensor should be protected f*~om
thor^al i^iLio'i from the sun, sky, cat ...h, and o^y Currounding objects,
una must be adequately vcnliletcd. AL- pi rated radiation siiieios are
designed *c fovide such protection. (Note that ambient temperature
data are also rrwinionly rcq;-;>-(;u for plur.ie rise estimate* used in dispersion
model calculations. )
Mixing height is another oarage" thuL car, be important in some
cases. Hiving height i^ tne distance at/ove the ground to which relatively
free vertical fuxing occurs in the atmosphere. For estimating long-tern
average concentrations, it is adequate tc use a representative annual
average mixing height [40]. However, in many cases, ^nd especially for
estimates of short-term concentrations, ivnce-daily or hourly nixing
height dat^ are necessary. 5ucn data can sometirres be derived [40] from
represent ^r'!vc surface temperatures arid twice-daily upper air soundings
collected ..y selected NWS stations.
Precipitation collectors must be located so that obstructions do
not prevent the precipitation fron falling into the collector opening or
force precipitation into the opening. Several collectors may be required
for adequate spatial resolution in complex topographic regires.
Visibility systems must be located to pro.'ide representative measurements
not only prior to construction of the facility, but also for facility
operational periods. Assessment of visibility impact is currently under
study by EPA and other Federal agencies. Visibility definitions, monitoring
methods, node! ing considerations and impact assessment approaches are
among the si.bjects of a report entitled, "P-?otec-i,',--:>: '.'isi-bi.' l'^: An "-•'.
Kr: jrt to Cor. ;rv.-;/j" [41]. v Since Vina! visibility regulations have not
Leen promulgated, only interim monitoring guidance for visibility is
available at this time.
Additional information and guidance on siting and exposure of
meteorological instruments is contained in reference 42.
*ln connection with E^A's proposed visibility regulations, the Agency
published thr?e draft documents in July 1980, for public review and
coirar.ent thai jre pertinent to the PSD Monitoring Guideline. Thy first
is "Interim Guidance for Visibility Monitoring," and its contents are
arranged in similar fashion, though without as much detail as the PSD
Monitoring Guideline. The other docunents are: "Workbook for Estimating
Visibility I".pari:nent" and "User's Manual J-'or the Plume Visibility Model
(PLUVJE)." These draft documents are available frcrr the Office of Air-
Quality Planning and Standards, CPDD (KO-15) Research Triangle Park, f.C
?7711. The documents will be published in final form when the visibility
regulations are promulgated.
41
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6. 1 Specifications \
Meteorological instrumentation used for PSD monitoring must yield I
reasonably accurate and precise ddta. Accuracies and allowable errors |
are expressed in this section as absolute valuas for digital systems; j
errors in analog systems may be 5U percent greater. For example, an i
allowable error expressed as 5 percent means the recorded value should |
be within ±5percent of the true value for digital systems, and ^7.5 j
percent for analog systems. Records should ije dated, and should be '
accurate to within 10 minutes. Wind speed and direction (or vector ;
components). should be recorded continuously on strip recorders at .
intervals not to exceed 60 seconds for a given variable; digital ;
recorders may be u:,ed as backup. These specifications apply to th^
meteorological instruments used to gather the site specific ddta that
will accompany a PSD permit application. When the use of existing
representative meteorological data is approved by the permit granting
authority, the instrumentation should meet, as a minimum, ?<'. oxi'mum error not to exceed 2.5 m/s). The
damping ratio of the? wind vane should be between 0.4 and 0.65 and the
distance constant should not exceed 5 m. Wind direction system errors
should not exceed 3 degrees froi.i true 10-min or greater averages , including
sensor orientation errors. Wind vane orientation procedures should be
documented.
6.1.2 f'itid System? (vertical \\ind)
In complex terrain, down//ash of plumes due to significant terra -"n
relief nay pose a problem. If such a prob'i am potentially exists, it r*,y
be necessary to measure the vertical component of the wind at the proposed
site, and as close as possible to stack height. The starting threshold for
the vertical wind speed component should be less than 0.25 TT/S. Required
accuracy for the vertical wind (;peed comporent is as specified in se^i-.f. €.2.
for horizontal speeds.
6. j.3 Vlnd
Determination of the on-site standard dei/iacion of v/ind fluctuations,
or derived standard deviations of cross-plume concentrations may be nc-ci-ssary
if dispersion parameters a>-e being developed for use at a specific site. Sirica
the analytical framework within which such wind fluctuation measurements/
statistics are to be incorporated is expected to be unique or applied on a
case-by-case basis, appro/al by the permit granting authority is required
42
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i
and no general requirements regarding specification!: are outlined in this
guideline. Considerable care is required in the selection of wind
instruments and data logging systems, especially in the choice of sampling
and averaging timos. Thus, response characteristics of wind sensors are
especially critical [45,46 J. Owners or operators designing programs incorporating
these capabilities should subruit a statement from a qualified consultant
identifying the adequacy of such wind system(s) within the context of che
overall PSD ambient monitoring program.
6. 1.4 Vertical T'-np^rature. i^.'.fffrence 5
Errors in measured temperature difference should not exceed 0.003
°C/m. 1
6. 1. L Temperature
Errors in temperatures should not exceed 0.5°C if fog formation,
icing, etc., due to water spray or watsr vapor emitted from the facility
may be a problem. Otherwise, errors should not exceed 1.G°C.
6. 1.6 'lumiditu
- -«/
Atmospneric humidity can be measured and expressed in several ways.
If the permit granting authority determines that a significant potential
exists for fog formation, icing, etc., due to effluents from the proposes
facility, error in the selected measurement technique shou'd not exceed
an equivalent dewpoint temperature error of 0.5°C. Otherwise, errors in
equivalent dewpoint temperature should not exceed 1.5'C over a dewpoint
range of -30°C to +20°C.
G.I.7 Ead-Latior. -Solar' and Terrestrial
The determination of Pasouill stability cla^s iray be based en
whether the solar radiation is termed strong, moderate, or slight. .Stability
class can be determined from sun elevation and the presence, height, .itid
amount of cloud:. [37], or by ut,inga pyranonieter rind/or net radioneler
during the daytirr.e and a net radion-?ter at night. Such radiation-to-'jtability
relationships are expected to D*- site-specific, and the responsibility for
demonstrating thc-ir accuracy lies with the permit applicant. General accuracy
for pyranometers and net radiometers used in a l^SD monitoring network is
expected to be +5 percent.
6. \3 Mixing Hci'jht
Mixing heiqht date may be derived from NWS upper air data. If
available data are determined to be inappropriate by the permit g
authority, such data may be obtained on-s-ite by the pernit appl leant
The instrument system to be used is not specified in this guideline, but
its precision and resolution should not exceed the limits associated with
:
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C.I.9 Preaipitatien
A recording precipitation collector should have a resolution of
0.25 mm (0.01 inches) liquio precipitation per hour at precipitation
rates up to 7.6 cm/hour. Accuracy should tr- within 10 percent nf the
recorded value. A heated system should DC used to assure proper measurement
of frozen precipitation. A suitrble windscreen should be used.
6.1.10 Visibility
Visibility can be measured within 5 percent o. trut over visuul
ranges of about 80 meters to J km with available trcnsmissometers.
Estimates can be based upon very short path lengths using other types of
equipment such as nephelometers 1,48]. At this time, tha ccmbined use of
a multi-wavelength telephotometer, integregrating repc.elometer and
particulate monitor, together with color photography, should prove most
helpful in documenting baseline visibility related parameters. These
components of a visibility "io:ntoring program ore discussed in tne draft
document "Interin Guidance for Visibility Monitoring," referred to
previously at the end of zceiAc.n !>.2 of this yuidelire. Referer.ce 41
also contains mucn background informatio:'.
44
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All equipment should receive an appropriate examination and calibration
prior to initial irislai K-ti'cn ta assure- the acquisition of the maxi-um
amount of usable data within the e-'ior limits specified herein. Inspection,
servicing, and calibration of equipment must be scheduled throughout the
measurement program «it appropriate intervals to assure at least 90 percent
data retrieval for eoch v^riar.lc- mecsured at sites where continuous air-
quality monitors are beinj occrcited. At remote sites, data retrieval
for measured .'ariables sh^ul^ -.ot fall below 80 percent. In addition,
the joint frequency for the recovery ui wind and stability data should not
fall below 90 percent on an ar.r.ual ba^sis; missing data period? must not
show marked correlation with the various meteorological cycles.
C?libration of systems should be accomplished no less frequently
than once every 6 months. In corrosive or dirty arta^, the irtervai
.should be reduced to assure adequate and valid data acquisitio:-.
If satisfactory cai .'oration of a measuring system can be provided
only by tne manufacturer or in special laboratories, such as wind-tunrel
facilities, arrangements snculd be made for such calibrations prior to
acquisition of ir.o equipment. A parts inventory should be maintained at
a readily accessible locatior to minimize delays in restoring operations
after system failures.
An independent meteoroic:. ical audit ("by ether Ih3n one *.ho concucts
th;: routine calir^dtion anu c:?ration of ths network) should ~e perfsv-ea
to provide an on-site calibration of instruments as well as an oxa'uaticn
of (a) the netiori- instailaf ?n, (b) inspection, maintenance, end calitrr.fic-
procedures, and loggir.q tne^erf, (c) data reduction rrocedures, inclw-ir:;
spot checking of data, and (3 < data logging and tabulation procedures.
The on-site visit (requiring as little as 1 da> in nany cases) snojld be
made within 60 days after ti™e network is nrst in fu'l operation, and a
written audit/evaluation shcjld be provided to the o.vter. This reocrt
should be retaired by the c^ner. Any problems should be corrected a^.d duly
noted as to action taken in an addendum to tne ai'dit report. A reprod
copy of the audit report and the addendum should be furnished with the
source construction permit application.
Such independent meteorological audit-evaluations should be performed
about each 6 months. The last such inspection should be made no more than
30 days prior to the termination of the measurement program, and wnfle the
measurement operation is in progress.
45
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8.
8.1
A summary of tS-> Air quality data, the raw air quality data, and
the quality assurance data discu?s?3 in section -1.1,6 mjst be submitted
to the permit granti"? suthoriv. it tne time of submittal of the PSD
application. There o'.ould be a pvicr agreement between the source e»nd
the permit granting authority as to whether the raw data should be
submitted in addition to a summary of the data. Some sources nay also
desire to submit data periodicall., to the permit granting authority for
review to identify any problems K the data as they occur. Note that
this is not a requi-v-ent. The ar?1icant and the permit granting authority
should have a prior .-.:reement as t- the format and procedure for the
data submission 7-e air Quality dna should oreferably be s-jbrn^ted in
SAROAD *orm;>t and in, i machine »va_st>1e form. A printout o* the contents
of the tope or card?, sno'jld disc :-•? included. All raw data not previously
submitted (i.e., air r.al'ty data c?.i isracion data, flov rate?, etc. )• >uouid
be retained -:or 3 ys^rs and subinittsd upon request to the pen-.ic granting authority,
4
For continuous 3~alyzers, at least 80 percent of the individual
hourly value; shou"- ^e reporter, ry the source in ary sarplii.i period
For nr.rual ..lethods ,'?- and port-:j"ate pollutants',, **0 rcrcert of the
individual 2^-hour .^'s.1^ shouu re reported in any sai.'plin^ period.
This capture rate i> --Dorteinr c^tajse of the snort dur.uion c^ ^ PSD
monitoring program. '.'• addition, fere should not be a correlation
between missing duta reriods and 'oected highest concentrations.
Because of the Afferent dats requirements for different types of
analyses that micht .Ke used to e\:1 uate various facilities, t^ere is no
rixed format that -rriies to al": ;ata sets. However, a generalization
can be riade: ull r :?teDroloc,ical rarameters ir.ust be coilatec in chronological
order and tabulated .-.^cording t? f 5 observation time, and be furnishec
to the permit ytvtv-v.r authority uron request. All meteorclocical
variables that, hav* = SAROAH paj\-."eter code should be sub/nttc-d in
SAROAO fot.nat. All ..-its should r- in the SI system (International
Systen of Units) [-."•". A\ll input ,;sta (in the format required by the
analytical procedu*"^? selected) ..sea in, and all results of, the air
quality analyses ."u
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APPENDIX A
PROCEDURES TO DETERMINE IF KONITORIN3 :ATA WILL BE
REQUIRED FOR A PSO APPLICATIC'i
-------
This appendix
reviewing authoriti
data will or will f.
leading to a monito
in this appendix.
and the ninir.ium Sta
the reviewing autho
control agency, or
For a complete disc
referred to the PSD
r,
rity, \,'hetner it te the local or S
the Regional Office of E?A for the
u:,sion on the complex PTD issues,
regulations and the prearale disc
e to aid both the
te>— ining if r,onitoring
o»" considerations
ified for presentation
eral requirements
-ortent to identify
tcte air pollution
final requirements.
the reader is
ussion [5].
Figure A-i shc/.vs a simplified organizational over
to be followed in t~.e oreparation of a PSD tef.iit appl
A-l shows that these procedures are divides into sever.
division is only fe1
strative purposes within this
intended only to separate the complex procedures into
Within the Part 1-Scurce Applicability OeteTination.
and rodified major sources are reviewed to sea if PSD
The Fart 2-Pollutar.t Applicao1" n'ty Dete>~ir5t:on sho.-,s
emitted from subject sources tnat may or --ay rot be e>
atial/sis. Tht Pare 3-EACT Analysis is to ensure the D
dvailcble control tecimolcg/ ;5-CT^ on sj:;ect poPut?-
analysis covered in D=rt 4 induces both -Deling &r,~
view of the p ,edures
ication. Figure
Darts. This
appendix and is
distinct subparts,
Poth candidate nev
''eview will asoly.
'.hose pollutants
5~oted fron fjrther
edication of best
considerations for certain
ts. Air quality
-^nitoring d^ta
pollutants. Tne Part t-Source IrTact
^tlc not c^ust
^e-it. The P?.:". 6-
£ed emiss'io-.s
:~. s and vegetation.
n wnich transfers
Analysis is to ce~o-is trace tna; t^c prcpcsei e^issio^s
or contribute tu a violation cf onv NAAQS :.r ."SD incre
Additioual Impact Araiysis is to ensure that tr.e pro:c
increases would not impair .'iribility, or -'-part on sr>
Finally, Part 7 recresents the complete PS."- applicatio
to the permit granting authority the results of all
the first six parts. Not-rally, the source atdicant w
information including the BACT and air quality analyse
necessary determinations. Eac-'i cf these se.'en parts i
in f--.-j:r.i:>ns ?..l-C.~. 5^r-:'j\- ,-' contains f!c« diagrars
the first four parts that pertain to the cecision whet
data will or will not be required.
t"5 analysis froii
ill supply all the
s to make the
s discussed belcw
and discussion of
her nouitoring
The first step in the PSD program is to determine if a proposed new
or modified source is subject to the PSD '•erdations. The first test
for PSD applicability is that the proposes cc"Structicr. nust involve a
major stationary source. Trui, the candici'e construction nust eitner
be a proposed new r.ajor stationary source or -involve the modification of
an existing major stationary source. The criteria in Determining whether
A-l
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Part 1 - Source Applicability Determination
r?
Part 2-
Part 3 - BACT Analysis
I Part 4 - Ambient Air Quality Analysis
Part 5 - Source Impact Analysis
. £ I
Part 6 - Additional Impact Analysis
Part 7 - Complete PSD Application
Figure A-"I. Simplified procedures for the preparation of a PSO permit application.
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the affected source is sufficiently large (in terms cf emissions! to be
a new major stationary r^jrce or inajcr modification is based on cc^-ideration
of its potential to 6T.it at rates exceeding certain trresho'M values.
Potential to emit ii IK1 c^p?bi) itj.- <;t rax imam design capacity to e~.it a
pollutant after the rfppncctiori cf all required sir pollution cc^fol
equipment, taking iito account oil foJcrally enforce.-de requirements
restricting the type or 3-,r-unt of source operation. A major modification
is generally a physical chnnge in or a change in the r.ethod of operation
of * major stationary so^ce which would result in a significant ret
emissions increase for a-y regulated oo'llutant. (There are several
changes that ari exempted from being considered a majoi modification.)
Also, the proposed source or modiriceiion oust locate in a PSD a^ea—an
area designated as "attainment'' or "unclassifiable." If the proposed
source or modification wculd meet certain tests ar.d commence constrjction
in a continuous fashion at the proposed site within a reasonable time, a
PSD permit under the August 7, 1980 regulations would rot be necessary.
Lastly, there are specific new sources and modifications that are exempted
from PSD review. All of the above considerations a>~e explained in rare
detail in s.:et- a?p"y.
If a source applicant has detervned that a proposed new scvre or
modification would be sjjject to the PSD requirement-;, then the ar:: ic
>rust assess whether th_- col'utants trc project would erit are sur__rt to
FSD. If a new rajor stationary source emits pollutants for whic-. fe
area it locates in is ceslc-are-d nonattainmeiit, then tHe source 1:
exempt from PSD review f^^ those pollutants. These scjrces must,
however, meet the ajp.icar-le requirements of new source review (',."""} for
each nonattainment pollutant. If a rrajor construction crossed -"'.'• a
PSD area involves only cnar^es for nonattainment pollutants, ther- -.-e
source is not subject to PSD. Tnese sources must meet the appro-••'ate
nonattainmenc N'SR oncer the SIP for the pollutant. Cp.ce the quest-"en of
f\SR jurisdiction is "esolved, thf-n the PSD review applies to significant
er.iissions increases of regulated air pollutants.
Specific numerical cutoffs whicn defiie what emissions incrtares
are "significant" are sno«n in Table A-l. These emissions rates rfill be
used for pollutants to be emitted rrom a PSD source unless the r,z#
source or modification is to be located within 10 km cf a Class I =rea
[1]. For these situations, the proposed source or modification r.jst be
prepared tc demonstrate trat it wou'id not have a cignificant inTjac: /nth
respect to a Class I area. A Class I significant impact is defire- as
one nicrogram per cub~'c Tster (ugAfi-) or more for a 2-5-rour averdce.
Furtner details on how i'-^s significar.t emission rates in Table A-1 ->ere
derived may be found in the preamb'e discussion of the P3D regulators
[5].
If the emissions fro- a new source will be significant, or if t'-e
net emissions increase frc~ a proposed modification will be signi^-'r^nt-;
then one must proceed tc -;he Part 3-BACT Analysis for f.ese pollutants.
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TABLE A-l. SIGNIFICANT EMISSIONS RATES
Pollutant
Carbon nonoxide
Nitrogen oxides
Sulfur dicxide
Total suspended participates
Ozone (volatile orqanic compound^}
Lead
Asbestos
Beryllium
Mercury
Vinyl chloride
Fluorides
Sulfuric acid mist
Total reduced sulfur (including H,S)
Reduced sulfur (including H^S)
Hydrogen sulfide
Emissions Rate (tons'year)
100
40
40
25
40
0.6
0.007
O.OOC4
0.1
1.0
3
7
10
10
10
-4
A-4
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2 . 3 Part 3 - 5 ACT Anil:..-:s_
Any major stationary source or iMjor modification subject to PSD
must conduct an analysis to ensure application of tn..t available control
technology (BACT) for all applicable oo/lutants. During each analyses,
which will be done on a case-by-case basis, the reviewing authority will
evaluate the energy, environments! > econnnic, ar.d other costs associated
with each alternative technology. The reviewing authority will then
specify an emissions lin'tation for the source tnat reflects the maximum
degree of reduction achievable with all these concerns in mind for each
pollutant regulated under the Act. In no event can an emission limitation
be required wh^ch would be less stringent than any applicable standard
of performance under 40 CFR Parts 60 and 51.
After the BACT determination, the source must then investigate the
need for eath pollutant subject to BACT (BACT pollutant) to also undergo
the remaining analyses for this pollutant.
2.4 Par+- 4 - Aibient. .•'•'?' .','.< a Zit.y Aral^s'ls
Each application by a PSD source or modification nust contain en
air quality analysis /or each BACT oollutant to demonstrate that its new
pollutant emissions would not violate either the acrlicable NAAQS or the
applicable PSD increment, li-.is aralysis ensures that the existing air
quality is better than fat required by national s^-^aards 3rd fat
baseline air quality is not degraded beyond the apr-licable PSD increment.
Two narrow exerrtions to this requirement are specified in the regulations
and involve certain. existing sources with low BACT fissions and sources
of ternporar.' emissions r^eting certain criteria.
In traki ng the abov*: determinations, naiiy PSD scjrces must first
assess the existing ?V ».?lity for c-ach applicable sir pollutant that
it emits in the affectec c. rea. The "-ec'jirement to ronitor adstir.q
air quality r^;v r.oi eppr' 'co (a) poi Intents for vhi-:i ths iis>-,
scurce or nooif icat-icr, '-.r^ld cause induces lass t^an t!i? siGn^"'ca:.t
nionitoring concentraticis (Table A-2), or (b), situ?.ticns where the
background ccnctntratie:; of the pollutant is below t~e significant
monitoring values. This exemption should not be use^ when the>s is an
apparent threat to an applicable PbD increnent or V-..A3S based or fcdtilin^
alone or when there is a question of adverse impact on a Class I area.
When monitoring data are '-equired, the applicant rust provide d~bipnt
mo.itioring date that res-esent air quality levels in the year's period
preceding the PSD application. Where existing data are not judged
represent? five or adequate, then the applicant must conduct, its c^n
monitorirq program. Typscally, monitoring data are jsed by applicants
to support o>- extend ths assessment made with air oil ity dispersion
modeling.
In addition to tie above discussion, EPA in gereral intends to
Mmit the application c*: air quality ror'els to a dOh"xiind distance of 50
kilometers. Tnis if beccuse dispersion carameter^ c;"monly in use are
based on exueriments relatively close to sources, ard extending these
parameters to iong dcwrr,~.ind distances results in grc^t uncertainty as to
accuracy of the model estimates at si,ch distances. EPA does not intend
to dndly/e tiie impact of a source be>ond the point ~~--re the concentrations
frcm the source fall belc'v certain levels (generally based on Class I
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TABLE A-2. SIGNIFICANT MONITORING CONCENTRATIONS
Pollutant
Carbon monoxide
Nitrogen dioxide
Sulfur dioxide
Total suspended particulates
Ozone
Lead
Asbestos
Beryl!ium
i-'ercury
Vinyl chloride
Fluorioes
Sulfuric acid mist
Total reduced sulfur (including H,S)
Reduced sulfur (ircluding il^S;
Hydrogen sulfide
! Air Quality Concentration (vg/m3)
• and Averaging Time
575 (8-hour)
14 (24-hour)
13 (24-hour)
10 (24-hour)
a
0.1 (24-hour)
b
O.GOOb (24-hour)
0.25 (24-hoir)
15 (24-hour)
0.25 (24-hour)
b
c
-i (1-hour)
No specific air quality concentration for ozone is prescribed. Fxeirptions
are granted when a source's VOC emissions are <100 tons/year.
DNo acceptable monitoring techniques available at this time. Therefore,
monitoring is not required until acceptable techniques are available.
c'Ho acceptable monitoring techniques available at this time. However,
tecnniques are expected to be available shortly.
A-6
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increments) shown in ""itle A-2. Ho, ever, since tne 1977 Clean Air Act
Amendments provide special concern for Class I areas, any reasonably
expected impacts for t*',ese areas --Jtt be considered irrespective of the
50 km 'lirr.itation on the above sigT.ficar-t values."
Tne proposed source or modification must deronstrate that significant
net emissions increases (including secondary emissions and fugitive
emissions), would not cause or contribute to air pollution in the /iclation
of any N'AAQS or any applicable maxi-uT, allowable increase over Lhe
baseline concentration in any area.
2.6 Part C - Add-itic*;-il l^ract .-'.». i~--sis
An applicant is also required to analyze whether its proposed
emissions increases would i~pair visibility, or irpact on soils or
vegetation. Not only rust the applicant lock at the ci7"re'~t effect of
source emissions on these resources, but it also must consider the
impacts from general cc-ir.^rcial, residential, industrial and other
growtn associated witn the proposed source or modification.
nftf.r completion of thf preceeiinq ana?yses, the source may submit
a PSD application to *,'-e permit renting authority, inp appl ic11 co."~0;r>ts received provided they are relevant
to the scope of the review.
The source shall also submit all informatior necessary to perform
any analysis in Parts 1-6 above or rji.e any determinations required in
Parts 1-6. Such infcr-ation shall include (a) a description of the
nature, location, design capacitv, ard typical operating schedule of the
*It should b2 noted that there are three seoarate and distinct sets of
values v.hicn are coniir.ered "significant" within the PSD program:
(a) significant emissions rates;
(b) Signiticont ~onitoring concentrations; and
(c) Significant ambient i.^pac's (including the specific significant
Class I area irr.p-icts).
As pointed out, each set of values rjs a different appl icatior., and
therefore, this guideline has been warded to clarify the appropriate
values tt"» be used while assessing the need to collect monitoring data.
A-7
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TABLE A-3. SIGNIFICANT AMBIENT AIR QUALITY IMPACTS
Pollutant
so2
TSP
N02
CO
AVERAGING TIME
Annual
1 M g/m3
1 bg/ro3
1 jjg/m3
--
24-Hour
5 pg/m3
5 pn/in-
__
--
8-Hour
--
—
--
0.5 ug/m~'
3-Hour
25 ug/m3
—
--
1 Hour
—
—
--
2 v-g/n3
NOTE: This table dees not apply to Class I a rocs. A significant irrpact
for Class I areas is 1 pg/nij on a 24-hour basis for TSP and 50,..
A-8
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i
proposed source or modification, including specifications and drawings j
showing itr. design and plant layout, (b) a d-jtailed schedule for construction j
of the proposed source or modification, and (c) a detailed description \
as to what system of continuous emission reduction is o.anned for t^e j
proposed source or modification, mission estimates, ard any other \
information necessary to detenrritv that best available control technology |
would be applied. The proposed source or modi'ication shall also provioe {
information on (a) the air quality irpact of Ue proposed source or I
modification, including neteorological and topographical data necessary |
to estimate such impact, and (b) the air quality impacts, and the nature <
and extent of any or all general cc-rcercial, residential, industrial, ;
and other growth which has occurred since August 7, 1977 in ar.y area the 3
proposed source or modification would affect. I
s
JZCISIOXS f 0:: '^ITORIIIG DA TA
Figure A-l and the discussion that followed in scctiy: .? provided
an overview of the various activities relating to a PSD permit application.
This section will go into -nore detail on those activities that need to
be ccnsiuered in deciding if .jir quality monitoring data will be •'equired.
It should be noted that the procedures described in this appendix
-Jo not include any details en how t1 e modeling analyses, are to be conducted
buc only -'ndicate at what points <'Lc*es) the results of such analyses
are necessary. Also, v/rn'ic- these procedures lead to a determination of
when air quality monitoring is liK-'iy to be required, they do not lead
to a dec'sion as to when r,:eteorolc'jical monitoring is necessary (for
model input). Guidance on the requirements and procedures for conducting
modeling analyses is contained in reference 34. i Action £ of this
guideline describes ger.eral nieteorjicg'cal monitoring requirements , and
reference 50 also provides further ",ji dance on this subject.
Figures A-2 and A-3 show v^no^s steps that must be made for a
proocsed PSO source Ci rodificetion in order to assess how the r.onitoring
data requirement might f;^. or no; or rodifi
losc.t-lng in a. ?,->•' urea?
A major stdtionar> source is defined as any one of 28 source categories
(Table A-4) which emits, or has the cotential to emit, 100 tons per year
or more of any pollutant regulated •.^•dar the Act. In addition, the
definition includes any other static-.ary source which e.nits, or has the
potential to emit, 25C tons per yea- or more of any regulated pollutant.
Finally, major stationary source a",cD means any physical change occurring
A-9
.J
-------
pr tp^-vef vi
* major «,u; nan source or
a major M't'jrt
in 3 f^:i *.IA'
/ 2 So PSD
V permit n«-tjd*-(.'t
'3 Is construction p'upou-d ^v
(or ^n a'Pi which is riosi^n^r
nonatlj:nmenl area lor the
1
Part 1 -
J
*"_•" X--, /; '" p"'r"'"'d v''"tte \ iu
or modification v\iihtn
\
fO tm of a Cb«.v (
/ 4 Arc ne« em",«.(• 01 or no
sr '
\ rt-t'uKitt'd pt/^uni J lab!" A-i>
\ on j CU».s I JH-a' /
'' 11 K pr -pc^id uld
b" cTiitud tc. 1'n- pr(ipo*.'*d con<.itjet-*:
Pjri 4 - Amtjicn! \n Qujli!\ Ani
Par; 3 - Si^j'c* l'n[>act An.n\s's
Hjr4 fc - Adcilioru! Uupitt -\njlwiv
M
Part " - Ccimtik'U- P^D •
Poii'jtanl Appi
BACT
Figure A-2. Procedjrs; usc>d to determine th° monitoring data requirement.
A-i:
-------
LT'j.1
fl'ic! ', -
r\ * pott-nut j.lvrr-f impjtt
\ on 4 CUv. I J'«-J
-! I'ROt [DIKS1. I Mil I'} ;.'
-------
at a stationary source (which pric»- ;o the change is not major) if the
change by itself KOU'C; be najor. >at is, the change itself would
result in an equiva^'-.t stationery •source which would emit IOC tons per
year or nore for an> pollutant r^.-jfated under the Act for any one of
the 28 source catey-cr:es (Table A-«t-}, or 250 tons per year for any other
stationary source. 7>-? polluters regulated under the Act were shown in
Part 2-Pollutant Arnncabili ty Ceiemination.
A stationary scarce general',_> includes all pol1utar.t-e"r"tting
activities which belr-.g to the Sc.'e industrial grouping, are located on
contiguous or adjacent properties, ,»rui are under common control. Pollutant
activities which be'cng to the ia"e rajor grojp as cofir.ed in a standard
industrial classification scheme ccveloped by the Office cf Management
and Budget are considered part of tne same industrial grouping.
The rest of the PSD size applicability for proposed new stationary
sources is simply t'-at the candidate source would be a rrsjor stationary
source in terms of its potential to emit. The applicability rules for
detenr.ini rig whether d ~ajor modification would occur are rore co.iiplex.
A "r.ajor modif'
change in tne met hoc
would result in a si
any repaid ted poll.-t
cause a significant
must L£ perforned. ;
the prcrosed emi.ss'.c
potential to emit c>*~
document and quanta*
occurred or wil1 ooc
years) and have net
of each contempora^e
subtracting the ol>:
one. Third, the pi
changes rust then r
emissions increase
the modification is r
Certain cha.vces
These include: (aN -\
of an alternative f«-.
sections 2(a) and {r
Action of 1974 (or r
fuel by reason of 3"
Act; (d) use of an a
extent it is generat-:
fuel or raw materia'
January 6, 1975 or -*•
under 40 CFR 52. CK :
and (•*;. an increase
last tv-o exemptior.s,
chance is not pror:r
January 6, 1975.
cation" is ger
cf operation
c'Mficant net
i't. In deif
i- = t increase :
v-st, the sc'j-
••5 increase.
tbe new or -:
, all emissic'
rien evaliute:
:.s decrease .?
" -:vel of act.;
rosed emissic"
totalled. F-
-it is larger
and sur;
rally a physical chanae in or a
a major stationary source which
issions increase in the enissions ct"
:ning if a proposed increase woula
occur, several detailed calculat'c-<
e cwppr n:u:>L quantify tne amount cf
••is amount will general 'y be the
-fied unit. Second, t".e c.>ner mjst
increases and decreases that have
eucly (generally witnin the past fv,e
= s part of a PSD rev.e.v. T!ie value
3 increase is generally determined S-
emissions from the r.e* cr revisrd
increase and the ui reviewed ccntt-ro
ally, if there is a resultant net
raneot-s
an values specified in
t to PSD review.
-l,
are exemptec
utine inainte
•\ or raw r.at
of the Ene>-
.. supersedi-
order or ru'r
ternative t\
a froin munic
•>hich the s;
ich tne so..'
- und^r rec^
n the hou>~5
.e) and (f .
ted bv cert;
from the definition of rajcr modification.
"•r.ce, repair and reolace-ent; (b) use
jr;al by revision cf ar- order under
;..• Supply and Environ rental Coordination
j legislation); (c) use of en alterrafive
:- -jnder section 125 of the Clean Air
-". at a stean generating unit to the
•ral solid waste; (e^ -se cf an alterative
. vce was capable of accc-r-cdating; be*c-re
;•? is approved to use jr.cer any per- it issued
'ations approved pursuant to 40 CFK 51.2i;
:~ operation, or the rrcduction rate. Trie
Can be used only if t".e corresoonc^-c:
"" permit conditions established aftcy-
A-12
-------
TABLE .Wt. M/JOR STATIONARY SC:.-;£S
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
Fossil fuel-fired 3t-am electric plants of no ft t.'un 25.".TO?.
British thermal ...nits per ho ir heat input
Coal cleaning plants (with thermal dryars)
Kraft pulp mills
Portland cement pisnts
Primary zinc smelters
Iron and steel mill plants
Primary aluminum ore reduction plants
Primary copper shelters
hiunicipal incinerators capable of charging rwe than 253 *:~.s of
refuse per day
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 ^furnace process)
Primary lead smelters
Fuel conversion plants
Sintering plants
Secondary metal production plants
Chemical process plants
Fossil-fuel boilers (or- combinations thereof) totaling o* rc^e than
250,000,000 British thermal units per hour ne*t imput
Petroleum storage 3^3 transfer units with a tots", storac? c^
exceeding 300,000 r^rrels
Taconite ore processing plants
Gluss fiber process.-,ng plants
Charcoal production clants
£-13
-------
If tne si^e of a prc,'vs£d S'-..rce or modification thus qualifies a^
major, its prospect". v<; location cr existing location must also qualify
as a PSD area, in o'-der for ?5? <"~«-;siv to apply. A PSD area is one
formally designated oy the state as 'attainrrpnt" or "unclassifiable" for
any p^lluant for which a njtic'-j" c-Ln'ent air quality standard exists.
This geographic applicability "..->: generally does not take into account
what new pollutant enissixj cc .>>:•- the construction to be major. It
looks simply at whether Vis sc.^;:.- is niajor for any pollutant Ond will
be located in a PS3 area, "re ?•'•= o-.ception is that if a najor stationary
source emits o:ily ncnattair.-eii ri-Ilutants, then no PSD review would
apply.
If a proposed source c- recv""~cation would be subject to PSD review
based on size, location, and rol^-tants emitted, it still may escape the
PSD review requirements under certain grandfather provisions under 40
CFR 52.21(1). ror example, a rrrrcsed source or modification that was
not subject to the 1978 PSD rules sr.d had received all necessary Federal,
State and Iccel air permits :efer-e -ugust 7, 1980, would not be subject
to the 1980 regulations. (See f.e ~SD regulations for other exemptions.)
Finally, the PSD reguu:tic-s contain some specific exemptions for
some ferns of source construct:;".. The requirements of the PSD regulations
do not apply to any major stit::~~-*/ source or -ajor modification that
is (a) a nonprofit realth or t-c.rrt'onal institution (only if such
exemption is requested by tre ..:.r""~or), or (b) 3 portabl"1 source which
has already received z PSD r»-:-"^-~ =~d proposes relocaticn, or the source
or modification would be a "-jc-- 5:i^ionary soj>-ce or major modification
onV if fugitive erosions, r: fe -extent quantifiable, are considered
in Calculating th?? potential' ;c e~"t of fie stationary scarce or mod,'ricef'
and the source does not belcr: -,z i-.y of the categories listed in Table
/U4.
Box 2. r,o PS2 rcf^it wzs'ici.
If the source has met tre srr'cpriate deadlines for construction;
and is not a major stationary sr-'-re, a major rodificatior, is not
located in a PSD area, or '"s -r: s.rject to the specific exemptions
mentioned above, the PSD prccra^ -;s not applicable, and therefore, no
PSD permit is needed.
Box 3. Is ccnstr-c~ isn v".~:\\~:;" ."V:1 an area '~r'.',j><. is dc^i^nj.ted nor>atJ:^'.'>T'„
area for :<'• i-i-:j\iar--:l r/.' '.-^tznt-?
If the project is a ma;o'- stationary source or- a major modification.
the prospective location must a'so 7jalify as a PSD area in order for
the PSD review to apply. A r?7 -ire- is defined a? an area formally
designate •'. by the State as '2:t;i—-ent" or "unc^ssifiable' for any
pollutant for whic.i a NAAQS ei:?ts. An area net classified as either
"attainment" or 'unclassifiar's v:>lc be classified as "ronattain^ent".
If the proposed construction. :s fr a nonattainrent area for any pollutant,
proceed to la~ •: for tnat pcll..:i':; for all other regulated pollutants,
proceed to ic.r t".
A-14
-------
f-rx 4. Y.T father r.-T ^v; .'%,r£s fcr r;::r r:
If tre proposed raj,?'" 5, tatieaarv scarce or raicr ~odif1c;f":- .-/ill
emit pollutants fron; ar area that hfs ^-:en design?.:-^ e; "ner;tt = -r,r.ent",
then the proposed source or rnodif :cct/C"; is exempt fur. furtre^ -\:j
review for only those rcTtutants. iiov,r,er, the proposed sou^c- r-
rrodificatian must meet t(-e applicable ^reconstruction :-equirf---sr*.i for
each nonattainment poT^tar.t. (See 40 CF.R 51.18 and 43 CFR 52.:-.}
Tiie pollutant arc"! ic-ijil ity determination would be contir^c for
all other regulated pc>!' jtvnts (except ronatta indent pollutants emitted
by a proposed major sts;-ionar> source or major modification b> t-cceeding
to tcx •'>.
Pox ,5. r,? rroposed t e^issicrs rates ""s*.ed in
Table A-l. If the proposed source or -edification -. s •.vithin IT <:~ of a
Class I area, proceed to .'-v.r J; if not, proceed to :•,-.;- .-.
If tre proposed source or modification is within 1C km of ~ TTass I
area, then tne screenir.c procedures described in reference 50 ~i.» re
used to estirate the v^ract on the Class I area. This screeni^r r-ocedure
is based en a simple b^: conservative ~c-el for estT"a'_'"c: ear.' ::~cer:trstir;i
due to the emissions fr?" the proposed source or rcaifieaticn.
I?ox 7, .':'^''. refined "•.\:V." (optional).
A prcrosed source c-r modification -ay choose not to acccot r- ^s'e
the concentration estimates derived frc~i the screening r'-ocePL'ir •>( .;,\-
C, and may elect to use a nore refined rcdel which woj}3 n^ore irr-i.-ately
reflect the inpact on fe Class I area from the proposed source :~
modificaticn. it should re emphasized that in order to ?3rfor~ c -^^inea
modeling analysis, it ray be necessary to collect 1 \ear of ox-;--,~
meteorological data for t~e model input if an adeo-cate amount c~ -erresent^fi
data are r.2t already available. The application of a*'y rodel ,if-; ~:n
this analysis must be consistent with reference 34 as iiscusse; ~~
z?(*tion f.:. The application of any different pioJc'i ~ust be a-r-r.ed by
EPA in ora?r to avoid ary delays in the orocessiro o* ;•••? oer--~
Applicants s~cjld cons-"; oith the reviening authority re*"ore -'.
considerable resources i" the use of t-e different "\"col?. 7he"=-
the documentation and s-erific descrrjt:rn of the "•cd^l should :-: .--ovided
to the rev'e.->iRg author-' t> before tha results are SLT'itted.
The rc'-caritrat'ion estimates from t'e screen-'rc v'-cccdure :~ •. ~e refir.e
rode! , are ?^~ sequent ;y ..sea in the Fart --Ambient Air v,\,ality :"r" sis
and Part 5-Zrjrce Impact -''
,
-------
Box c. V%ZZ t.<:-~ pvp-'Sc:^ cc*.t.» v cr r-.cdi-fio^.'icn impact o>; .3 Class I
area?
If a proposed source or -odif icatic.i is within 10 km of a Class I
area, th^ proposed source or Codification must oe prepared to demonstrate
for eacn regulated pollutant, it would emit that there would be no significant
impact on the Class I area. Significant impact is defined in the PSO
regulations [40 CFR 51 .24(b)?23}(iii ) and 40 CFR 52.21 (b)(23)(iii )] as 1
microgram per cubic meter ( g/n } or no re, 24- hour average.
Eoz S. Ave nc~' c~''$s;'.one cr •:.-•: <.".~?s£o':s {•>:?* rase of r-:s' re
te:?- > lable .-•-')"
If the proposed source or modification is not within 19 km of a
Class I area, 3r if the proposed source is within 10 km or a Class I
area and has no significant irpact on the Class I area, then the emissions
for each pollutant from the proposed source of modification are compared
to the significant emissions rates in Table A-l.
,70 ;";<;T•;<.-.-
If the errssicns from the proposed source or modification are nc-*
significant as cefined in Table A-l, no further analysis -is required for
that pollutant, However, a similar review :rust be perfcr~ed for all
otrer regulated pollutants by proceeding to : - «:> for the ''ext pollutant.
faciii~.-
This quest'on is actually an appl icabili t.y question that is normally
considered under the Part 1-So.jrce Applicability Deterni nation. Ho«ever,
there are certain other questions (see boxc? ,~, f n:d S of Figure A-2)
which are nonrally asked under pollutant applicability t-at are also
ger-ane to pan-fitting a porthole facility lelccaticn. Th^s, the reason
for including :.r ll in Part 2.
The source rust be a portable facility which has previously received
a permit under the PSD regulation, the cv;ne~ proposes to relocate f?
facility, and enissions at trie new location .vcisld be temporary {not
eAreedir.g its alienable emissions). If the facility meets thesp retirements,
then proceed to r..~ J':; if not, proceed to :\r 14.
Bex 1^. Are t'.nv ^otcnti-a.1 '. '"\tJtf en a C'^c.'s I arfa, /»* c.^eas cf ::-.r:.x
ir.erc ~-.'~:r :':.elatic*:~
The emissions from Lhs rrrtable source should not exceed its
allowable emissions, and the erosions fro':; tre te.iporor;. source should
iroact no Class 1 area and no area where an applicable ir;rement is
kno^n to be violated. If there ai-e potentially adverse i~?acts on e
Class I area, or sirnificai.t i~?3Cts on areas cf known increment violation,
proceed to I\\r :~; if iiot, procc^J to ccx :.•'.
r;-r 13. :,'o F^r •••.-•'•-: t rt.-r:«.':v.;.
If there a%"e no potential inpaccs on a Class I a^ea, or areas or"
know!) increment violation, no TSj permit is required.
A-l 6
-------
Box 14. Apply bACT.
"Best available control technology" means an eniss'-'ons limitation
(including a visible enp'ssion standard} based on the maximum degree of
reduction for each pollutant subject to regulation undi.T the Act which
would be emitted from any proposed riajor stationary source or .uajor
modification wnich the Adilnistratr.r, on a case-by-case basis, taking
into account fnergy, envirornentals and economic inpacts and other
costs, determines is achievable for such source or modification through
application of production processes or available methods, systems, and
techniques, including f'jLsl cleaning or treatment or innovative fuel
combustion techniques for control of ruch pollutant. In no event shall
application of best available control technology result in emissions of
any pollutant which would exceed the emissions allowed by any applicable
staMard under ^0 CFR Perts 60 and 61. If the Administrator determines
that technological or economic limitations on the application of measurement
methodology to a particular emissions unit would make the imposition of
an emissions standard infeasible, a design, equipment, work practice,
operational standard, or combination thereof, may be prescribed instead
to satisfy the raquirement for the application of best available co>:tro1
technology. Sucn standard shall, to the degree possible, set forth the
emissions reduction achievable by implementation of such design, equipment,
work practice or operation, and shall provide for compliance by means
which achieve equivalent results.
Sox lii. Are the a£7-o;A7r7c errisft'^nu or the rci cr.issions ir.sreuce
temporary 3 inrctsting r.o Ci-asc I arcc, cv inpa^ir.g r.o area
•i3t-.3?>e the PSr ir.?rerr.er.t Is vi.olatea."
Temporary emissions are defined as emissions from a temporary
source that would be less than 2 years in duration, unless the Administrator
determine^ that a longer t'iii'e period would be appropriate. If all of
the conditions above are not met, proceed to i.rx 16; if they are met,
proceed to Part 7-Complete PSD Application.
Box 16. Hill the psoposfj; source cr modifies: ic->: <:mit VOC'i
If the proposed source or modification vn'll emit VOC, proceed to
hrr .?r; if "ot* prnrc^pd to ''-~,x 20. Also proceed to box 20 if the
pollutants are TSP, S02> CO, N02, or ^b.
Box 17. Are VOC emissicr.s <7ab1e • -2?
If the VOC emissions rates from the proposed source or modification
are less than the value in Table A-2 (100 tons/year), proceed to lax 18;
if not, proceed to box 1$.
??x 18. Is there an arr/rrrKi thr?\it to the A'A"«,5, or is there a. potential
ad:\rse impact c\ a Cla.sc ' urea?
If the projected aiV quality after construction is equal to or
greater than 90 percent of the NAAQS, a threat to the NAAQS would generally
exist. Potential adverse impacts on a Class I area must be deteri'inad on
A-17
-------
a case-by-case b^? :-y the permit granting authority. Therefore, if
there is an arr^^Ti threat to the 'iAAQS, or if there are potential
adverse iTipac'i-s CT x -Llass I area, then proceed to box is\ if not,
proceed to box ^:.
Box 13. 'rlill ..-,"• *r,-^!i"' aourcc rr,;^:^ 'cation perform postapproval, rcTrir^ri'.'
in It*-;. ,•„-' ~T-,ojn.stn< •**••:" j»: monitoring aata?
The PSD rcc-Jirftns [40 CFR 51.24(m)(l)(v) and 40 CFR 52.2UnOO;
(vi)] give special considerations regarding ozone monitoring data to new
or modified sou1-;^ -f volatile organic compounds which have satisifie-3
all conditions c- ~: 1FR 51, Appendix A, section IV. This section
generally requires x~*ected sources to meet Iciest achi3vable emission
rate limitations. i£C-.re emissions offsets which provide an overall net
air quality irp:.:,.-£^-it» and ensure all other major sources in the sa~e
State are in cc--cl-i-.ee with the applicable SIP. If a proposed source
or modification -is ret all of tne above conditions fr-r VOC, then the
proposed source ;•* Tc-2if ication ~:ay provide postapprcval monitoring cista
for ozone in lie^ ;- croviding preconstruction data. Postapproval
monitoring data -.-- ^;ta collected after the date of approval of the ?S2
application. .-.-.••51'?'. in no case should the postapproval rroritoring ce
started later t~a- 1 years after the start-up of the new scarce or
modification.
If the prcrci-j-r source or '"edification /ri~.l provide p&itaoproval
monitoring, prrc;-^ :o the Part 5-Source Impact Analysis; if not,
proceed tc i.:~ ,~; ~:" the remainoer of the ambient air quality analyses.
air ^::^
The propose: £rjrce or modification must perform an initial a
to estimate t^e ev-ting air quality concentrations. ";he screening
procedures ds^c-*" :>-:.: in reference 50 may be used. The screening trr.:e:.~es
are based on s~ :"i ~ode1s for estimating air quality due to the e. :isr ;-~..:,
from existing i™o ir^roved but not yet built sources. r^ proposed sc_-ce
or modificat-Ic- -.r> cnoose not to accept or use the concentration esc-r-ates
derived fro^ tr= i-i'tening procedure above, and may elect to use a r;re
refined model e1*'^- ^ould more adequately Deflect the ir.pact frcrr, ex'sf'ig
sources. It s-;-"x De emphasized that in order to perfcrr- a refir.ea
modeling enal.is's, I is generally necessary to collect 1 .year of cr.-
c-itp n&teoro'iccic^" data for the model input. The application of ar.
mcdel used in ^- *? analysis must be consistent with reference 34 as
discjssed in ^ .-- -- c.l. Th3 application of any model s^culd ne ac:'"C'«sd
by the permit ~-2'Tt-.rg authority to avoid any future delays in the
processing cf t-.i ri'-pit application. Therefore, the docjrertation c~
the specific c~5c--:tion of the rode! should be provided to the perr.it:
granting aut'c -::.<• rsfore the results are submitted.
The co-c?'t"i ,' on estimates from the screening procedure or fe
optional ret"-;-; ~.::ei v/111 be used in the rerr.aining portions of tne
ambient air -;_:'• 7- analysis.
A-18
-------
Box 21. Ee^inats air ^M;T>V iwa^rs of proposed construot''.:r..
The proposed source or modification must estimate *ts air quality
impacts to demonstrate th.at its new pollutant emissions would not violate
either the applicable .N-V-QS or the applicable PSD incrt-ment. The proposed
source or modification rust use the screening procedures or more refined
model, consider "good en;ir-?ering practice" for stack height, and consider
the TSP end SO, increment exclusion for Class II areas under 50 tons per
year exemption. These factors are discerned in .uore detail below.
(a) Screening proce-c'ura or more refined model.
If the proposed source or .Codification used the screening
procedure or more refined model in :_-;? 6 cr 7 previously to estimate the
impact, thpn those results nay be used in this impact analysis. If the
screening procedure or r-ore refined node! was not previously determined,
then the screening procedures described in reference 50 may be used.
This screening procedure is based on a simple model for estimating each
concentration due to the emissions from the proposed source cr modification.
A proposed source or nodification nay choose not to accept or use the
concentration estimates derived fre-i the screening procedure above, and
may elect to use a more refined nodel which would more adequately reflect
the impact from the proposed source or modification. It should be
emphasized that in order to perfom a refined modeling analysis, it is
generally necessary to collect 1 year of on-site reteorolocical data for
the model input. The application of any model used in this analysis
must be consistent with reference 3-1 as discussed in section ~.i. The
application of any model should be approved by tne permit granting
authority to avoid any future delays in t'.e processing of the permit
application. Therefore, tne documentation and specific description of
the modei should be provided to the permit granting autnority before the
results are submitted.
The concentration estimate* frci the screening procedure or
the optional refined nroael will be used in the remaining portions of-the
ambient air quality analysis.
(b) "Good engineering practice1* (GEP) for stack height.
The 1978 PSD regulations [lj provide for requiring GEP in the
impact analysis for stack Heights. The degree of emission limitations
required for the control a;' any air pollutant would not be affected by
stack heights (in existence after December 31, 1770) as exceeds good
engineering practice, or any other dispersion techniques impltnented
after then.
(c) Consider 50 tors per year exemption.
The DSD regulations [40 CFF 51.24(i)(7} and 40 CFR 5?.21(i)(7}]
as they apply to a major rodificatio'i exempt TSP and SO,, fro- the Class
II increment consumption review if all of the fjllov/ing'cond-'t-'ons are
met: (1) the net increase of all polljtants regulated under tne A;t
after application of B.-VCT «-ould be less tr3n 50 tens/year, (2) no pollutant
would bt causing or contributing to a violation c^ tne standards (NAAQS),
and (3) source must have Ire-en in existence on March 1, 1978.
A- 73
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The resists of the impact analysis as described in this box wi',1 be
used for subsequent portions of the ambient air quality analysis.
Box 22. Is the existing air ^::.ilizy qualli'j Cr.r^zts xic-s;\T:j .: criteria vclluta^.t cr "."C?
Determine if the pollutant is a criteria pollutant fTSP, S07, CC,
N0?, cr ?b) or VOC. If the pollutant is a criteria pollutant or~VCC.
proceed to coj: ",'; if rot, proceed to box "0.
A-20
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Box 26. Is there ar. arpro'Jec TOPKT'torir.j Lechni'jue
- Acceptable measuremaiu methods currently exist for son:e noncriteria
pollutants, while other r.iethodi aie currently under review and have not
been designated as an acceptable.- measurer on t method. Cation 2.6 of
this guideline discussed the o'osignat.on of acceptable measurement
methods for noncriteria pollut.itics. If c.n acceptable measurement method
does exist, proceed to lc.~ 29; if not, proceed to box is.
Box 27. Preconstrusiion monitor'Ini d?t*z required.
Reconstruction air quality monitoring data are required for this
part of the ambient air quality analysis. The proposed source or mocificition
has the option of using representative air quality data or monitoring.
Considerations and constraints on the use of existing data were discjssed
in section 2.4 of this guideline. It should be noted that a dispersion
model may be used in verifyino the representativeness of the data. If a
proposed source or modification chooses to monitor instead of using
representative air quality data, then the specifics to be followed en
network design, probe siting, quality assurance, number of monitors,
etc., were previously discussed in this guideline.
The monitoring data required :n this oox will be used in Parts 5,
6 and 7 of the PSD permit application.
Box 23. *.':i'tr:'.?ti9n rncnitorir.? data required.
If there is no acproved monitoring technique for the noncriteria
pollutants, or if there is no apparent threat to PSD increments or
NAAQS, or if there is no potentially adverse impact on a Class I area,
then generally no preconstruction nor.itoring data will be required.
However, proceed to the Part 5-Source Impact Analysis for remaining
analyses.
Box 29. Pfeoor.stru'J'i^ri nionitori; .3 data men be require':..
The permit granting authority must determine on a case-by-case
basis if monitoring data will be required when there is an apparent
threat to PSD increments or NAAQS, or when there is a potential adverse
impact on a Class I area. Special attention must be givon to Class !
areas where the proposed source or modification would pose a threat to
the regaining allo\-,-ble increment. For those situations where the air
quality concentration before construction is near the concentrations
shown in Table A-2 and there are uncertainties associated with this air
quality determination then preconstruction air quality monitoring data
may be re-quired. Sc~e situations where nopcriteria monitoring may be
required were discussed in section 'l.l.Z of this guideline.
Regardless of the monitoring data decision, proceed on to the
5-Source Impact Analysis for remaining analyses.
a-21
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-------
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j
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25. CFR Title 49 Part 53.22, July 1976.
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J
30. Quality Assurance Handbook for Air Pollution Measurement Systems; Volume II - \
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j
31. Trac.eabil ity Protocol for Establishing True Concentrations of Gases Used for- j
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I
32. Transfer Standards for Calibration of Ambient Air Monitoring Analysers for i
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j
33. Cole, U.S. Guidance for NAQTS: Pevieu of Meteorological Data Sources. !
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January 1978 (draft). j
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on Towers or Stacks. Pull. Arer. Meteorol. Soc. 4_8: 665-674, Septeroer 1^:7.
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*EPA published in craft fern for publii. review and co. r.ent, "Proposed Devisicrs
to th^ Guideline en Air ;J-;]T*V Models, October 19?0." This document provides -:--e
detailed guidance 71 air c^ality modeling and is availaole fro-., the Agency's So-rce
Receptor Analysis Branch ^XD-14), Research Triangle Park, NC 27711,
A-24
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39. Weber, A.M. Atmospheric Dispersion Parameters in Gaussian ?lure Modelirc -
Part 1: Review of Current Systems and Possible Future Developments. '^.^.
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mental Purposes. Meteorology and Assessment Division, U.S. environ.entil
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and Atmospheric Administration, Sterling, VA. 'iOAA Technical Memoranda"!
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the Test enci Evaluation Division Functional Testing Progrc". In: Pr?pr:''.t.
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Denver, CO. /'pril 10-14, 1378.
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Eudney, L.J., Guidelines for Air Quality i^.interar.ce Plarni'/ and Aral/',-'-
Volume 10 (Revised): Prcctdures for Evaluating Air Quai^-v ''-,-^t of '.'-..
Stationary Sources. U.S. En/ironnenta; Prote-*-; >- A^onc/ "••••'•"•^h "•-"•'
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Pollutants. Instrument Society of America, Pittsburgh, PA, 1973.
I
45. Mazzaralla, D.I'. Meteorological Instrjn^nts for Use Tiear tne Ground - ]
Their Selection and Use in Air Pollution Studies. Science Ac,',ociafes, ''';., |
Princeton, NJ. (Presented 6t Conference on Air Quality !'.-2teorology a.',c .>
Atfiospheric Ozone, Boulder, CO., 1977.) "' '
1
^7. Johnson, W.3. and R.E. Ru'f. Observational Systens and Tccr-r.iques in A;-- |
Pollution Meteorology. In: Lectures on Air Pollution and £r,yiron~enta! ]
Impact Analyses. American Meteorological Society, Boston, '.'.'•. 1975. ]
48. Gcorae, D.H. and K.F. Zeller. VisibiMty Sensors in Your AT- Quality j
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Environmental Pollutants. Instrument Society of America. Pittsburgh, t', \
1973. !
\
49. American Society for Testing Materials. Stancarj for Metric Practice, |
F.-3SO-76. ASTM, 1916 Race Street, Philadelphia, PA 191C3. Vill. \
A- 2 5
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d.3. En\TIronmental Protection Agency
'I^-i-on-Sf -Liarar-jr,. ( 5.fX(-16}_ , ^^
2'/0 S. Dearborn C'o-cet, Room 1670'
Chicago, IL /60b04
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