United States Region 3 903/9-82 -OOSb
Environmental Protection 6th and Walnut Streets
Agency Phtedefchla, PA 19106 June 1982
V>EPA NSR AND PSD
PROGRAM ASSISTANCE
AND DEVELOPMENT IN
EPA REGION III
VOLUME 2
Unit* III Library
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EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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Regional Center for Environmental Information
US EPA Region III
1650 Arch St.
Philadelphia, PA 19V03
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EPA Contract No. 68-02-2536
Work Assignment No. 14
EPA 903/9-82-008b
FINAL REPORT
NEW SOURCE REVIEW AND PREVENTION OF
SIGNIFICANT DETERIORATION PROGRAM ASSISTANCE
AND DEVELOPMENT IN EPA, REGION III
VOLUME 2
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I June, 1982
I Prepared for:
Air Programs Branch
•United States Environmental Protection Agency
Region III
Sixth and Walnut Streets
_ Philadelphia, Pennsylvania 19106
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U ? E
f.: /.'.! IH ^'jrmattefl SeaWS
Cor'ar (?'':.';52)
841 CiiK'-nut Street
PA Ww«
Robert Blaszczak - Project Officer
Thomas Blaszak - Project Manager
Prepared by:
Pacific Environmental Services, Inc.
Midwest Operations Division
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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DISCLAIMER
This report was furnished to the Environmental Protection Agency
by Pacific Environmental Services, Inc., Midwest Operations Division,
465 Fullerton Avenue, Elmhurst, Illinois 60126 in fulfillment of
Contract No. 68-02-2536, Work Assignment No. 14. This document has
been reviewed by the Air Media and Energy Branch, U.S. Environmental
Protection Agency, Region III and approved for publication. Approval
does not signify that the contents necessarily reflect the views and
policies of the Environmental Protection Agency, nor does mention of
trade names or commercial products constitute endorsement or
recommendation for use.
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Section
APPENDIX Q
APPENDIX R
APPENDIX S
APPENDIX T
APPENDIX U
APPENDIX V
APPENDIX W
APPENDIX X
APPENDIX Y
APPENDIX Z
APPENDIX AA
TABLE OF CONTENTS
VOLUME II
DETERMINATION OF PSD BASELINE DATES
DETERMINATION OF REVISED PSD BASELINE DATES FOR THE
STATE OF VIRGINIA
DETERMINATION OF THE REVISED PSD BASELINE DATES
FOR THE STATE OF MARYLAND
DETERMINATION OF THE REVISED PSD BASELINE DATES FOR
THE STATE OF WEST VIRGINIA
DRAFT POSITION PAPER ON PSD INCREMENT TRACKING . . .
PSD REGULATION FOR THE STATE OF DELAWARE
RESPONSE TO PUBLIC COMMENTS REGARDING THE
STATE OF DELAWARE PSD REGULATION
PSD REVIEW PROCESS FLOWCHART
PROCEDURES MANUAL AND CHECKLIST FOR PSD REVIEW
IN THE STATE OF DELAWARE
PSD REGULATIONS FOR THE STATE OF WEST VIRGINIA . . .
BASELINE EMISSION INVENTORY FOR THE WASHINGTON, D. C.
METROPOLITAN AREA
Page
Q-l
R-l
S-l
T-l
. U-l
V-l
W-l
X-l
Y-l
. Z-l
AA-1
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APPENDIX Q
Determination of PSD Baseline Dates
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I EPA Contract No. 68-02-2536
Work Assignment No. 14
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DETERMINATION OF PSD BASELINE DATES
• WITHIN U.S. EPA REGION III
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I Robert Blaszczak - Project Officer
Thomas Blaszak - Project Manager
• Louis Skibicki - Principal Author
_ Revised
• December, 1980
I Prepared for:
I Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
I Philadelphia, Pennsylvania 19106
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Prepared by:
Pacific Environmental Services, Inc.
• 465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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1.0 INTRODUCTION
As with all newly promulgated regulations, a plethora of admini-
strative considerations must be addressed. One such consideration is
the establishment of a new baseline date. As specified in the Federal
Register of Thursday, August 7, 1980 (45 FR 52676) at 52.21(b)(14)(i),
""Baseline date" means the earliest date after August 7, 1977 on which
the first complete application under 40 CFR 52.21 is submitted by a
major stationary source or major modification subject to the require-
ments of 40 CFR 52.21. (ii) The baseline date is established for each
pollutant for which increments or other equivalent measures have been
established if: (a) the area in which the proposed source or modifi-
cation would construct is designated as attainment or unclassified
under Section 107(d)(l)(D) or (E) of the Act for the pollutant on the
date of its complete application under 40 CFR 52.21; and (b) In the
case of a major stationary source, the pollutant would be emitted in
significant amounts or, in the the case of a major modification, there
would be a significant net emissions increase of the pollutant."
Therefore, different baseline dates may exist for different pollu-
tants and a source may trigger a baseline in a nearby area in which it
impacts, but in which it is not located. Consequently, Region III
needs to know the baseline date(s) for each pollutant and the Section
107 designated areas to which they apply. Sources constructing after
the baseline date would also need to be identified, since they do
consume the available increment.
Pacific Environmental Services, Inc. (PES), has been contracted by
U.S. EPA Region III to assist in this re-evaluation of all completed/
pending PSD permit applications. The purpose of this assistance is to
delineate and define the various baseline dates for each pollutant and
their associated baseline areas.
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2.0 METHODOLOGY
In order to effectively and efficiently accomplish this task, a
methodology hers been devised which addresses all areas of concern and
is consistent with the newly promulgated regulations. The following
is a synopsis of that methodology.
2.1 PSD PERMIT STATUS/CHECKLIST
Prior to actual examination of Region Ill's files, a checklist was
developed and implemented to insure accurate and complete data gath-
ering. The checklist defines distinct aspects of the PSD permit
process (see Table 2-1 - PSD Permit Status/Checklist). Page 1 was
supplied by the Project Officer who provided continual guidance
throughout this particular sub-task. Additional information was
deemed necessary, however, in order to allow for a more thorough
assessment of each application and to gather data consistent with the
newly promulgated definitions. The provisions and requirements of the
new regulations necessitated this approach. Examples of additional
data required are:
• Exact source location;
• Potential emissions (as defined in the 8/7/80 Federal Register)
of existing facility;
• Potential emissions (as defined in the 8/7/80 Federal Register)
of proposed source/modification;
• Claimed reductions, enforceability, and actual emissions; and
• Modeling input data.
2.1.1 EXACT SOURCE LOCATION
In order to determine the baseline area, it is necessary to know
the exact location of the source. It is not sufficient to merely know
what county a source is located in, because it is possible for a county
to contain more than one Section 107 designation. As defined in the
new regulations 52.21(b)(15)(i), ""Baseline area" means any intrastate
area (and every part thereof) designated as attainment or unclassified
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Table 2-1.
PSD PERMIT STATUS/CHECKLIST
Source Name
Project Officer
Model er
State/County/City /
New Source*
Modification*
/
Type/Capacity/SIC / /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec ' d/Compl . Detr. /
Emissions (T/Y)* PM S02 NOX
Potential
Actual
Net Increase
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones YES NO
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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Table 2-1.
PSD PERMIT STATUS/CHECKLIST (continued)
D
Ka9e
Source: __
Location:
UTM: Hor.
Vet.
Zone
Facility
Major:
Yes
No
New Source/
Modification Major Yes
No
Potential Emission (Pursuant to 8/7/80 regulation)
Existing Facility
TSP
SOo
N0>
HC
CO
New Source/Modification
TSP
S02
NOX
HC
CO
Claimed Reduction: Yes
Type/Capacity/SIC:
No
/
/
Actual Emissions for Previous Two Years (for claimed reductions)
Year _ _ Allowable
TSP _ _ _
S0
NO,
HC
CO
Is claimed reduction part of PSD permit? Yes
Note:
No
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•Table 2-1.
PSD PERMIT STATUS/CHECKLIST (continued) Page 3
• MODELING INPUTS (for each stack)
• Specify Units
| 1. Emission Rate
. PM
* S02
• CO
NOX
I HC
• Fugitive
2. Stack Height
3. Stack Gas Temperature
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Either:
• 4. Vol. Flow
or
15. Stack Gas Vel.
and:
_ 6. Stack Diameter
7. From air quality modeling study, distance
• at which air quality impact falls to 1 ug/m3;
TSP
I S02
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under Section 107(d)(l)(D) or (E) of the Act in which a major source
or modification establishing the baseline would construct or would
have an air quality impact equal to or greater than 1 ug/m (annual
average) of the pollutant for which the baseline date is established."
Therefore, the UTM coordinates were obtained for all sources possible.
Where UTM coordinates were not obtainable, the location was pinpointed
as specifically as possible.
2.1.2 POTENTIAL EMISSIONS OF EXISTING FACILITIES
In many instances, information regarding potential emissions rates
of existing facilities was not provided in the PSD permit application.
This information, however, is vital when assessing an application for
a modification to an existing source. As a result of the new regula-
tions, to determine baseline date (52.21(b)(14)(ii)(b)) ". . . or, in
the case of a major modification . . .", it has become necessary to
determine if a modification is major or not. The regulations define
at 52.21(b)(2)(i) ""major modification" as any physical change in or
change in the method of operation of a major stationary source that
would result in a significant net emissions increase of any pollutant
subject to regulation under the Act." Therefore, further evaluation
of the permit application is impossible without ascertaining as to
whether or not the existing source is major. Those instances where it
has been determined that a modification is significant, yet no infor-
mation is provided for the existing source, will be listed in Chapter
4.0, Exceptions.
2.1.3 POTENTIAL EMISSIONS OF PROPOSED SOURCE/MODIFICATION
As previously stated in 52.21(b)(14)(ii), the baseline date is
established for each pollutant for which increments or other equiva-
lent measures have been established if: (b) In the case of a major
stationary source, the pollutant would be emitted in significant
amounts, or, in the case of a major modification, there would be a
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significant net emissions increase of the pollutant. Inherently at
52.21(b)(23)(i) ""Significance" means, in reference to a net emissions
increase or the potential of a source to emit any of the following
pollutants, or rate of emissions that would equal or exceed any of the
following rates:
Pollutant and Emissions Rate
Carbon monoxide: 100 tons per year (tpy)
Nitrogen oxides: 40 tpy
Sulfur dioxide: 40 tpy
Particulate matter: 25 tpy
Ozone: 40 tpy of volatile organic compounds
Lead: 0.8 tpy
Asbestos: 0.007 tpy
Beryllium: 0.0004 tpy
Mercury: 0.1 tpy
Vinyl chloride: 1 tpy
Fluorides: 3 tpy
Sulfuric acid mist: 7 tpy
Hydrogen sulfide (^S): 10 tpy
Total reduced sulfur (including h^S): 10 tpy
Reduced sulfur compounds (including I^S): 10 tpy"
As mentioned in 52.21(b)(14)(ii), only pollutants ". . . for which
increments . . . have been established ..." are subject to baseline
determinations. Only particulate matter (PM) and sulfur dioxide
(502) have increment restrictions. Therefore, potential emission
rates for proposed sources or modifications were obtained ami evalua-
ted for these two pollutants.
2.1.4 CLAIMED REDUCTIONS, ENFORCEABILITY, AND ACTUAL EMISSIONS
As stated in 52.21(b)(3)(vi), a decrease in actual emissions is
creditable only to the extent that: (a) the old level of actual emis-
sions or the old level of allowable emissions, whichever is lower,
exceeds the new level of actual emissions; (b) it is federally enforce-
able at and after the time that actual construction on the particular
change begins. Therefore, any/all pertinent information regarding
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claimed reductions was obtained. This information was, more often
than not, omitted because there was no proviso for net emissions in
the August 7, 1977 PSD regulations. Consequently any information
regarding claimed reductions was of minimal value and usually not
provided. Therefore, where such information was not supplied and is
deemed crucial for a definitive evaluation, it will be noted in Chap-
ter 4.0, Exceptions.
2.1.5 MODELING INPUT DATA
As previously mentioned at 52.21(b)(15)(i), ""baseline area" means
any intrastate area . . . establishing the baseline date would con-
struct or would have any air quality impact equal to or greater than 1
ug/m (annual average) of the pollutant for which the baseline date
is established." As previously agreed to, the screening procedures as
described in the U.S. EPA "Guidelines on Air Quality Modeling" have
been followed. Briefly, PES utilized the PT-series of models of the
UNAMAP package, together with time correction factors (Ref: D.B.
Turner, Workbook on Atmospheric Dispersion Estimates) to determine a
radius at which the above conditions exist. The boundary of the area
of significant impact shall extend up to a maximum of 50 kilometers
from the source.
Specifically, three models were used. For those facilities having
only one source/modification, PTMAX was run.
PTMAX - A program that performs an analysis of the maximum short-
term concentration from a single point source as a function of
stability and wind speed. A separate analysis is made for each
stack. Required inputs to the program include ambient air temper-
ature, emission rate, physical stack height, and stack tempera-
ture; either stack gas volume flow or both the stack gas velocity
and inside diameter at the top are required. The program computes
effective height of emission, maximum ground level concentration,
and distances of maximum concentration for each condition of
stability and wind speed.
In some instances, PTMAX did not provide sufficient information to
determine the baseline radius due to the fact that maximum
3
concentrations sometimes exceeded 1.0 ug/m at the greatest distance
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analyzed by PTMAX. For these cases, PTDIS was run. The meteorology
of PTMAX was used to calculate air quality impacts at greater
distances from the source. As atove, the distance from the source at
3
which the annual impact of 1.0 ug/m was determined.
For those facilities which have more than one source, PTMTP was
run.
PTMTP - Calculates hourly concentrations at up to 30 receptors
whose locations are specified from up to 25 point sources.
Required inputs to the program consist of the number of sources to
be considered, the emission rate, physical height, stack gas temp-
erature, volume flow or stack gas velocity and diameter, and the
stack locations in coordinates. The number of receptors, the
coordinates of each and the height above ground are required.
Concentrations for a number of hours up to 24 can be estimated,
and an average concentration over this time period is calculated.
The hourly meteorological information required consists of wind
direction and speed, stability class, mixing height, and ambient
air temperature. Worst case meteorology (stability classes 5 or
6, whichever produced the greatest downwind concentration, and
wind speed of 2.0 m/sec) was used in all analyses. Wind direction
was assumed constant. One hour concentrations were obtained.
Annual concentrations were subsequently computed utilizing the
aforementioned Turner time correction factors. Receptor heights
were assumed to be at ground level directly downwind. Stack
coordinates were assumed to be co-located.
While these proposed models may not be appropriate for quantifying
impact in complex terrain, they were used since for determining a
radius of impact, they are conservative. The conservative radius
resulting from the assumption of flat terrain is desirable.
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3.0 RESULTS
Once all data was gathered, compiled, and ultimately utilized as
q
input for the PT-model series, the baseline triggering radii (1 ug/m
annual average) were defined. These results are presented in Table 3-1,
Table 3-1 (Status Overview) will consist of the following parame-
ters (this listing also supplies the superscript notes referenced in
the table itself):
Facility Name
Pollutant
Concentrations
Baseline
Triggering Radii
In alphabetical order, as it appears on PSD
permit application.
For PM and S02 expressed as annual average
concentrations in ug/m3. They will be pre-
sented as:
(a) NA - not applicable due to:
1) permit application pre-August 7, 1977
2) facility/modification major; however,
either no SO^ or no TSP are emitted
3) facility/modification not major
(b) NS - no significant amount of emissions
(c) =0.a - the number shown which is less
than 1.0 ug/rrH and equals the
maximum concentration predicted
(d) =1.0 - farthest distance at which annual
average equals 1.0 ug/m3 (50 km
maximum)
(e) >1.0 - At 50 km (the maximum distance
examined) the concentration
remained above 1.0 ug/m3
In km from source/modification for associated
concentration.
In addition, this table provides the data needed to determine if
an individual source would impact a Section 107 area in which it is
not physically located.
Table 3-2 lists the actual baseline dates determined by using the
baseline triggering radii listed in Table 3-1 and plotting locations
of the sources on maps showing the attainment/unclassified areas (The
3-1
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1 Table 3-1. STATUS OVERVIEW
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FACILITY
DELAWARE
Delmarva Power & Light
Delaware Reclaruat ion Project*
MARYLAND
Armco Steel Co.
Arundel Corporation
Bethlehem Steel Co.,
Sparrows Point*
Campbell - Grove Division
Celanese Fibers Co.
Craig Blacktop & Paving Co.
Eastalco Aluminum Co.
Firestone Plastic Co.*
Flintkote Co.
Francis O'Day Company, Inc.
Maryland Materials, Inc.*
Mettiki Coal Co.
Miller Asphalt Product
PPG Industries
Pulaski Highway Solid Waste
Reduction Center (City of
Baltimore)
Sykesville Construction Co.
TSP DISTANCE
Qjcj/m3) (km)
NA1
No Input Data
NA3
NA3
No Input Data
NA3
=1.0 1.4
NA3
>1.0 50.0
No Input Data
NA3
NA3
=1.0 39.7
NA1
NA3
=0.8 0.8
=0.5 0.7
NA3
(continued)
3-2
(ug/m3)
NA1
No
NA3
NA3
No
NA3
>1.0
NA3
>1.0
>1.0
NA3
NA3
NA2
NA1
NA3
NS
=0.9
NA3
DISTANCE
(km)
Input Data
Input Data
50.0
50.0
50.0
_— — «.
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Table 3-1.
FACILITY
PENNSYLVANIA
Abex Corporation
Airco-Speer
Allegheny-Ludlum Steel Corp.*
Allen Products
Arco Pipe Line Co.
Berks Products*
Bethlehem Steel Corp.*
(Johnstown Plant)
Breneman, E.J.
Burrell Construction &
Supply Co.
Cop! ay Cement Manufacturers*
(Option 1)
(Option 2)
GAP Corp. - Chemical Group
General Battery Co.
Highway Material In.
Herbert Imbt Inc.
Inmetco
International Materials
& Chemical Corp.
Millcreek Township Asphalt
Plant
Molycorp Inc.
TSP
STATUS OVERVII
DISTANCE
^ug/m-3! (km)
NS
=0.3
=1.0
NA3
NA2
=1.0
No
NA3
=1.0
NA1
NA1
NA3
NS
NA3
NA3
NA3
NA3
NA3
=1.0
1.0
14.4
15.2
Input Data
16.4
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__ _ _
....
__ _ _
0.7
(continued)
3-3
DISTANCE
(ug/m3) (km)
NA2
>1.0 50.0
NA2
NA3
NA2
NA2
NA2
NA3
NA2
NAj
NA1
NA3
=1.0 23.8
NA3
NA3
NA3
NA3
NA3
>1.0 50.0
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Table 3-1. STATUS OVERVIEW (continued)
FACILITY
PENNSYLVANIA (con't)
Philadelphia Gas Works*
Smith-Kline Co.*
Stackpole Carbon Co.
Sun Petroleum Products
Tonolli Corp.
Transco
United Refining Co.*
U.S. Dept. of Interior*
(Bureau of Mines)
U.S. Steel Battery
13, 14, 15, 20
U.S. Steel (Duquesne)
Wilkes-Barre Steam Heat
Authority
Windsor Services, Inc.*
Zarlengo Bros. Inc.
VIRGINIA
Anheuser-Busch
Burlington Industries, Inc.*
Clinchfield Coal Co.
Coal Industry Services Co.,
Inc.
Continental Forest Industries
TSP DISTANCE
(ug/m3) (km)
NA2
=1.0 17.3
NA3
NS
NA3
NA1
NA2
NA3
=1.0 23.5
NS
=0.7 0.5
NS
NA3
=1.0 13.5
No Input Data
=1.0 8.1
NA3
>1.0 50.0
(continued)
3-4
so
(ug/m3)
>1.0
=1.0
NA3
=1.0
NA3
NA1
DISTANCE
(km)
50.0
24.0
2.2
Net Decrease
NA3
=1.0
NS
=1.0
=1.0
NA3
=1.0
No
=1.0
NA3
>1.0
•V •• B mm
16.3
47.2
21.7
30.9
Input Data
44.3
50.0
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Table 3-1. STATUS OVERVIEW (continued)
FACILITY
VIRGINIA (con't)
Georgia Pacific Co.
Greer Lime Co.
Hampton Roads Energy Company
Locher Brick Works Inc.
Lone Star Industries
Lone Star LaFarge Inc.
Lynchburg Foundry
M.A. Layman and Son
Marvin Templeton & Sons Inc.
Masonite Co.
Nifty Paving Co.
Norfork & Western Railroad Co.
Pendleton Construction Co.
Radford Army Ammunition Plant
Roanoke Electric Steel Corp.*
Southeastern Public Services
Authority of Virginia
W & W Paving Co.
WEST VIRGINIA
Badger Coal Co.
E.E. Moore Paving Inc.
Elkay Mining Co.
TSP DISTANCE
(ug/m3) (km)
NS
NA1
>1.0 50.0
NA3
NA3
NA1
NA3
NA3
NA3
NA3
NA3
=1.0 0.5
NA3
No Net Increase
=0.5 1.3
=1.0 1.2
NA3
NA3
NA3
=1.0 25.9
(continued)
3-5
S02
(ug/m3)
NS
NA1
>1.0
NA3
NA3
NA1
NA3
NA3
NA3
NA3
NA3
=1.0
NA3
No Net
NA2
> 1.0
NA3
NA3
NA3
=1.0
DISTANCE
(km)
___ _
50.0
__ « _
29.2
Increase
50.0
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Table 3-1. STATUS
OVERVIEW (concluded)
TSP DISTANCE S02
FACILITY (ug/m3)
WEST VIRGINIA (con't)
Inland Creek Coal Co. No Vol. Fl
(Northern Plant)
Island Creek Coal Co. NA3
(Pond Fork Plant)
Morgantown Asphalt Co. NA3
Morgantown Energy Research NS
Center
S & S Asphalt Co. NA3
Superior Sand & Asphalt Co. NA3
W. Virginia Paving Co. NA3
Westmoreland Coal =1.0
(Triangle-Has lam Plant)
* See Chapter 4.0 - Exceptions.
3-6
(km) (ug/mj)
ow nor Gas Exit Vel . Given
NA3
NA3
=1.0
NA3
NA3
NA3
38.4 =1.0
DISTANCE
(km)
21.1
15.8
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Table 3-2.
BASELINE AREA
DELAWARE (TSP)
City of Wilmington
Section Within City of Newark
Remainder of New Castle County
Kent County
Sussex County
DELAWARE (S00)
Newcastle
Kent
Sussex
MARYLAND (TSP)
Metropolitan Baltimore AQCR
Cumber! afld-Keyser AQCR
Central Maryland AQCR
National Capital AQCR
Southern Maryland AQCR
Eastern Shore AQCR
MARYLAND (S00)
1"~~n £
State of Maryland
Election District #8, Luke, MD
DISTRICT OF COLUMBIA (TSP)
National Capital AQCR
DISTRICT OF COLUMBIA (S00)
£J_
National Capital AQCR
BASELINE DETERMINATIONS
TRIGGERING
FACILITY
Possibly Triggered (A)
Possibly Triggered (A)
Possibly Triggered (A)
Possibly Triggered (A)
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Eastalco
Eastalco
Eastalco
Eastalco
Not Triggered
Firestone
Eastalco
Celanese Fibers
Not Triggered
Not Triggered
3-7
BASELINE
DATE
3/20/79
3/20/79
J/^0/79
3/20/79
11/10/77
11/10/77
11/10/77
11/10/77
9/01/78
11/10/77
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BASELINE AREA
Table 3-2. BASELINE DETERMINATIONS (continued)
TRIGGERING
FACILITY
PENNSYLVANIA (TSP)
I
Metro Philadelphia AQCR
A. City of Philadelphia:
Census Tracts 13-75, 143,
158-161, 178-189, 295-297,
322, 324, 327
Remainder of City
B. Montgomery County:
West Conshohocken Boro
Lower Merion Boro
Narberth Boro
Upper Merion Twp.
Bridgeport Boro
Norristown Boro
Plymouth Twp.
Whitemarsh Twp.
Montgomery Twp.
Upper Gwynedd Twp.
North Wales Boro
Towamencin Twp.
Hatfield Twp.
Pottstown Boro
Upper Pottsgrove Twp.
Lower Pottsgrove Twp.
Upper Providence Twp.
-• Chester County:
City of Coatesville
Cain Twp.
East Fallowfield Twp.
BASELINE
DATE
Not Triggered
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Not Triggered
Possibly Triggered (B) 6/17/79
Possibly Triggered (B) 6/17/79
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Possibly Triggered (B) 6/17/79
Not Triggered
Not Triggered
Not Triggered
3-8
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Table 3-2. BASELINE DETERMINATIONS (continued)
BASELINE AREA
C. Chester County (continued):
Modena Boro
Valley Twp.
North Coventry Twp.
East Coventry Twp.
Schuylkill Twp.
D. Remainder of AQCR
II. Northeast Pennsylvania AQCR
III. Southcentral Pennsylvania AQCR
IV. Central Pennsylvania AQCR
A. Lycoming County:
South Williamsport Boro
DuBoistown Boro
Armstrong Twp.
Susqueharma Twp.
Woodward Twp.
Old Lycoming Twp.
Loyal sock Twp.
Montoursville Boro
B. Blair County:
Logan Twp.
Allegheny Twp.
C. Remainder of AQCR
V. Southwest Pennsylvania AQCR
VI. Northwest Pennsylvania AQCR
A. Mercer County:
Hickory TWP
Sharpsville Boro
Wheatland Boro
B. Remainder of AQCR
3-9
TRIGGERING
FACILITY
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Possibly Triggered (B)
Not Triggered
Willkes-Barre (C)
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Possibly Triggered (D)
Possibly Triggered (D)
Bethlehem Steel
U.S. Steel
Not Triggered
Not Triggered
Not Triggered
Airco Speer
BASELINE
DATE
6/17/79
9/10/79
3/29/79
3/29/79
3/29/79
7/10/78
3/2/78
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Table 3-2. BASELINE DETERMINATIONS (continued)
BASELINE AREA
PENNSYLVANIA (S021
I. Metropolitan Philadelphia AQCR
A. City of Philadelphia:
Census Tracts 2, 3, 4, 5,
6, 7, 8, 9, 11, 12
Remainder of City
B. Remainder of AQCR
II. Northeast Pennsylvania AQCR
III. Southcentral Pennsylvania AQCR
IV. Central Pennsylvania AQCR
A. Northumberland County:
Upper Augusta Twp.
Sunbury Boro
Northumberland Boro
B. Snyder County:
Monroe Twp.
C. Remainder of AQCR
V. Southwest Pennsylvania AQCR
A. Beaver Valley Air Basin
B. Remainder of AQCR
VI. Northwest Pennsylvania AQCR
A. Warren County:
Warren Boro
Mead Twp.
Clarendon Boro
Pleasant Twp.
B. Beaver Valley Air Basin
C. Remainder of AQCR
3-10
TRIGGERING
FACILITY
Philadelphia Gas Works
Philadelphia Gas Works
Philadelphia Gas Works
Willkes-Barre (E)
Possibly Triggered (E)
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Airco-Speer
Not Triggered
U.S. Steel
Not Triggered
Airco Speer
Not Triggered
Not Triggered
Not Triggered
Airco Speer
BASELINE
DATE
5/16/78
5/16/78
5/16/78
9/10/79
2/23/79
3/2/78
7/19/78
3/2/78
3/2/78
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BASELINE AREA
Table 3-2. BASELINE DETERMINATIONS (continued)
TRIGGERING
FACILITY
VIRGINIA (TSP)
Buchanan County
City of Galax
City of Norton
Tazewell County
Washington County
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Remainder of Southwest Virginia AQCR Clinchfield Coal
Frederick County
Pulaski County
Roanoke County
Warren County
City of Waynesboro
Remainder of Valley of Virginia AQCR
City of Bedford
Henry County
Lynchburg
Patrick County
Pittsylvania
Prince Edward County
Remainder of Central Virginia AQCR
Northeast Virginia AQCR
City of Hopewell
City of Richmond
Sussex County
Not Triggered
Not Triggered
Norfork & Western RR
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Possibly Triggered (G)
Not Triggered
Possibly Triggered (G)
Possibly Triggered (G)
Continental Forest
Industries
Hampton Roads Energy Co.
Continental Forest
Industries
Not Triggered
Continental Forest
Industries
BASELINE
DATE
8/7/78
9/25/79
10/27/78
10/27/78
10/27/78
8/30/78
6/28/78
8/30/78
8/30/78
3-11
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Table 3-2. BASELINE
BASELINE AREA
Remainder of State Capital AQCR
City of Chesapeake
Remainder of Hampton Roads AQCR
City of Alexandria
Arlington County
City of Fairfax
Prince William
Remainder of National Capital AQCR
VIRGINIA (S00)
C.
Southwest Virginia AQCR
Valley of Virginia AQCR
Central Virginia AQCR
Northeast Virginia AQCR
State Capital AQCR
Hampton Roads AQCR
National Capital AQCR
WEST VIRGINIA (TSP)
Arden Magisterial District
in Berkeley County
Remainder of State
WEST VIRGINIA (SO?)
Piedmont Magisterial District
in Mineral County
Remainder of State
DETERMINATIONS (concluded)
TRIGGERING
FACILITY
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Clinchfield Coal
Norfork & Western RR
Continental Forest
Industries
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Not Triggered
Not Triggered
Westmoreland
Coal Triangle
Not Triggered
Westmoreland
Coal Triangle
BASELINE
DATE
6/28/78
6/28/78
6/28/78
8/7/78
9/25/79
8/30/78
6/28/78
6/28/78
6/28/78
12/20/77
12/20/77
3-12
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attainment/unclassified areas listing is current to October 31, 1980).
Maps depicting the baseline areas that have been triggered to date are
shown in Figure 3-la to 3-lf. It should be noted that the areas
presently designated as non-attainment are not shown. This is done
for three reasons: first, a baseline date is meaningless in a non-
attainment area (which is the present situation); second, it would
congest the figure; and thirdly, whenever an area is rectesignated, the
determination of the baseline triggering date is appropriate at that
time.
An additional comment must be made to emphasize a major difference
between Table 3-2 and Figures 3-la to 3-lf. Some areas are listed in
Table 3-2 as either being possibly triggered or as being previously
triggered. These areas are noted by parentheses ( ). Section 4.0,
Exceptions, and the following "Noted in Section 4.0" further elaborate
these areas. In Figures 3-la to 3-lf, the possibly triggered areas
are shown as not yet triggered.
NOTED IN SECTION 4.0
(A) See Delaware Reclamation Project
(B) See Smith-Kline
(C) See Berks Products
(D) See Bethlehem Steel
(E) See Windsor Service or General Battery
(F) See Roanoke Electric
(G) See Burlington Industries
3-13
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DSLA.WAKS
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4.0 EXCEPTIONS
As described earlier, the PSD files examined were assembled under
a different set of regulations. As such, for various reasons, these
files do not contain all the information necessary for making a defini-
tive decision concerning the individual PSD source's impact on the
baseline data and the baseline area. Listed in Table 4-1 are the
sources which have been determined MAY have an impact on the baseline
area and/or the baseline date. This impact is dependent on the evalua-
tion of the missing data. To the extent possible, comments are pro-
vided which describe the type of missing information, and the source's
probable impact on the baseline area/date.
4-1
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Table 4-1. EXCEPTIONS
DELAWARE (TSP AND SO?)
1. Delaware Reclamation
Would trigger a baseline date of 3/20/79; however, no modeling
input data was supplied in permit application, making a baseline
area determination impossible.
MARYLAND (TSP)
1. Bethlehem Steel (Sparrows Plant)
Would not trigger a baseline date even though modeling input data
was not supplied in permit application. All possible adjacent
baseline areas have previously been triggered.
2. Firestone Plastic Company
Three stacks are identified. Although no specific stack data was
given for TSP emissions of 1.09 g/sec, it is possible to estab-
lish a baseline date of 9/1/78 by its mere presence in the
eastern shore area. All other possible adjacent baseline areas
have previously been triggered.
3. Maryland Materials Incorporated
Would not trigger a baseline date even if existing source is
major. All possible adjacent baseline areas have previously been
triggered.
MARYLAND (SO?)
1. Bethlehem Steel (Sparrows Plant)
Would not trigger a baseline date even though modeling input data
was not supplied in permit application. All possible adjacent
baseline areas have previously been triggered.
PENNSYLVANIA (TSP)
1. Allegheny-Ludlum
Claimed reductions not stipulated in EPA permit. Also would not
trigger baseline area as it has previously been triggered.
2. Berks Products
Would trigger a baseline date of 7/13/79 for the baseline area,
Northeast Pennsylvania AQCR, if existing source is major. There
was no information provided regarding existing source. Also
claimed reductions not stipulated in permit.
(continued)
4-2
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Table 4-1. EXCEPTIONS (continued)
3. Bethlehem Steel (Johnstown Plant)
Would trigger a baseline date of 3/29/79. Even though modeling
input data was not supplied in permit application, it is possible
to establish this date by source's mere presence in the appli-
cable baseline area. It may also trigger the following areas,
depending on its triggering radius:
(a) Logan Twp.
(b) Allegheny Twp.
4. Burrell Construction
Would not trigger baseline date even if existing source is major.
All possible baseline areas have previously been triggered.
5. Smith-Kline
Would trigger the following baseline areas if existing source is
major. There was no information provided regarding existing
sources.
(a) Remainder of Philadelphia 6/17/79
Montgomery County:
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(D
(J)
(k)
(D
(m)
West Conshohocken Boro
Lower Merion Boro
Narberth Boro
Upper Merion Twp.
Bridgeport Boro
Norristown Boro
Plymouth Twp.
Whitemarsh Twp.
Montgomery Twp.
North Wales Boro
Towamencin Twp.
Upper Providence Twp.
Chester County:
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
6/17/79
(n) Schuylkill Twp. 6/17/79
PENNSYLVANIA (SO?)
1. General Battery
_ May possibly trigger Northeast Pennsylvania AQCR and Southcentral
• Pennsylvania AQCR, depending on its permit application completion
• date. Other applicable facilities:
(with regard to Northeast Pennsylvania AQCR)
(a) Winsor Service 2/23/79 (if existing facility is major)
(b) Willkes-Barre 9/10/79
(continued)
4-3
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Table 4-1. EXCEPTIONS (concluded)
PENNSYLVANIA (SO?) (continued)
(with regard to Southcentral Pennsylvania AQCR)
(a) Windsor Service 2/23/79 (if existing source is major)
2. Philadephia Gas Works
Modeling analysis based on 3600 hours/year
3. United Refinery
Modification shows a net decrease of SOg emissions. Federal
enforceability of proposed shutdown of existing facility must be
upheld.
4. Windsor Service, Incorporated
Would trigger the following baseline areas if existing source is
major. There was no information provided regarding existing source.
(a) Northeast Pennsylvania AQCR
(b) Southcentral AQCR
VIRGINIA (TSP)
1. Burlington Industries
There was no information provided regarding existing source. Also,
modeling input data was not supplied. May trigger the following
baseline areas if existing source is major.
(a) Lynchburg
(b) Pittsylvania
(c) Prince Edward County
2. Roanoke Electric
May possibly trigger Roanoke County, depending on its permit appli-
cation completion date. Ther other applicable facility (with regard
to Roanoke County) is Norfolk & Western Railroad, 9/25/79.
WEST VIRGINIA (TSP AND S0?l
1. Inland Creek Coal Company
Would not trigger a baseline date. Even though modeling input data
was not supplied, all possible baseline areas have previously been
triggered.
2. Morgantown Energy Research
Would not trigger baseline date even if existing source is major.
There was no information provided regarding existing source.
4-4
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APPENDIX R
Determination of Revised PSD Baseline Dates
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Iueuenn i riaL i UTI ui t\t:v lieu rou Ddbeii
for the State of Virginia
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EPA Contract No. 68-02-2536
Work Assignment No. 14
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•DETERMINATION OF REVISED PSD BASELINE DATES
FOR THE STATE OF VIRGINIA
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I September, 1981
I Prepared for:
I Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
• Philadelphia, Pennsylvania 19106
Robert Blaszczak - Project Officer
Thomas Blaszak - Project Manager
Prepared by:
Pacific Environmental Services, Inc.
I 465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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1.0 INTRODUCTION
As with all newly promulgated regulations, a plethora of adminis-
trative considerations must be addressed. With regard to the
Prevention of Significant Deterioration (PSD) regulations promulgated
in August, 1980, a major administrative activity during implementation
of the program is the establishment of new baseline dates. As speci-
fied in the Federal Register of Thursday, August 7, 1980 (starting at
45 FR 52676) and specifically defined in Section 52.21(b)(14)(i):
"'Baseline date1 means the earliest date after August 7, 1977 on which
the first complete application under 40 CFR 52.21 is submitted by a
major stationary source or major modification subject to the require-
ments of 40 CFR 52.21. (ii) The baseline date is established for each
pollutant for which increments or other equivalent measures have been
established if: (a) the area in which the proposed source or modifi-
cation would construct is designated as attainment or unclassified
under Section 107(d)(l)(D) or (E) of the Act for the pollutant on the
date of its complete application under 40 CFR 52.21; and (b) In the
case of a major stationary source, the pollutant would be emitted in
significant amounts or, in the the case of a major modification, there
would be a significant net emissions increase of the pollutant."
Therefore, different baseline dates may exist for different pollu-
tants and a source may trigger a baseline in a nearby area in which it
impacts, but in which it is not located. Consequently, Region III and
the State of Virginia needed to know the baseline date(s) for each
pollutant and the Section 107 designated areas to which they apply.
Sources constructing after the baseline date would also need to be
identified, since they are consuming the available increment.
Pacific Environmental Services, Inc. (PES), was contracted by U.S.
EPA Region III to assist in this re-evaluation of all completed/pending
PSD permit applications. The purpose of this assistance was to delin-
eate and define the various baseline dates for each pollutant and
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their associated baseline areas. This task under Work Assignment No.
14 was completed in accord with EPA Region III guidance in November,
1980 (Revised December, 1980).
The following report, responsive to additional Region III guidance
received June 5, 1981, revises and further delineates baseline dates
for the State of Virginia due to proposed Section 107 area designation
changes and additional source information.
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2.0 METHODOLOGY
In order to effectively and efficiently accomplish this task, a
methodology has been devised which addresses all areas of concern and
is consistent with the newly promulgated regulations. The following
is a synopsis of that methodology.
2.1 PSD PERMIT STATUS/CHECKLIST
Prior to actual examination of Region Ill's files, a checklist was
developed and implemented to insure accurate and complete data gather-
ing. The checklist defines distinct aspects of the PSD permit process
(see Table 2-1 PSD Permit Status/Checklist). Page 1 of the checklist
was supplied by the Project Officer who provided continual guidance
throughout the previous Work Assignment. Additional information was
deemed necessary, however, in order to allow for a more thorough
assessment of each application and to gather data consistent with the
newly promulgated definitions. The provisions and requirements of the
new regulations necessitated this approach. Examples of additional
data required are:
o Exact source location;
o Potential emissions (as defined in the 8/7/80 Federal Register)
of existing facility;
o Potential emissions (as defined in the 8/7/80 Federal Register)
of proposed source/modification;
o Claimed reductions, enforceability, and actual emissions; and
o Modeling input data.
2.1.1 EXACT SOURCE LOCATION
In order to determine the baseline area, it is necessary to know
the exact location of the source. It is not sufficient to merely know
what county a source is located in, because it is possible for a county
to contain more than one Section 107 designation. As defined in the
new regulations at Section 52.21(b)(15)(i), "'Baseline area' means any
intrastate area (and every part thereof) designated as attainment or
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Table 2-1.
PSD PERMIT STATUS/CHECKLIST
Source Name
Project Officer New Source*
Modeler Modification*
State/County/City / /
Type/Capacity/SIC / /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/Compl. Detr. /
Emissions (T/Y)* PM S02 NOX
Potential
Actual
Net Increase
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones YES NO
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Veqetation/Visibility
Class I Area Impact
Prel irninary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximira uncontrolled and actual are the maximum allowable under the PSD permit.
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Table 2-1.
PSD PERMIT STATUS/CHECKLIST (continued)
Page 2
Source: _
Location:
UTM: Hor.
Vet.
Zone
Facility
Major:
Yes
No
New Source/
Modification Major Yes
No
Potential Emission (Pursuant to 8/7/80 regulation)
Existing Facility
TSP
3\Js\
New Source/Modification
TSP
S00
HC
CO
N0;
HC
CO
Claimed Reduction: Yes
Type/Capacity/SIC:
No
Actual Emissions for Previous Two Years (for claimed reductions)
Year Allowable
TSP
S00
NO,
HC
CO
Is claimed reduction part of PSD permit? Yes
Note:
No
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_ Table 2-1.
• PSD PERMIT STATUS/CHECKLIST (continued) Page 3
• MODELING INPUTS (for each stack)
• Specify Units
I 1. Emission Rate
- PM
* S02
• CO
NOX
I HC
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• Fugitive
- 2. Stack Height
3. Stack Gas Temperature
Either:
I 4. Vol. Flow
or
5. Stack Gas Vel.
and:
6. Stack Diameter
7. From air quality modeling study, distance
I/, r r UHI air quality muueimy i>tuuy, uibLd
at which air quality impact falls to 1
• S02
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unclassified under Section !07(d)(l)(D) or (E) of the Act in which a
major source or modification establishing the baseline would construct
or would have an air quality impact equal to or greater than 1 ug/m
(annual average) of the pollutant for which the baseline date is
established." Therefore, the UTM coordinates were obtained for all
sources possible. Where UTM coordinates were not obtainable, the
location was pinpointed as specifically as possible.
2.1.2 POTENTIAL EMISSIONS OF EXISTING FACILITIES
In many instances, information regarding potential emissions rates
of existing facilities was not provided in the PSD permit application.
This information, however, is vital when assessing an application for
a modification to an existing source. As a result of the new regu-
lations, to determine baseline dates for modified facilities, (as
specified in paragraph 52.21(b)(14)(ii)(b): ". . . or, in the case of
a major modification . . .") it has become necessary to determine if a
modification is major or not. The regulations define 'major modi-
fication1 as any physical change in or change in the method of oper-
ation of a major stationary source that would result in a significant
net emissions increase of any pollutant subject to regulation under
the Act. Therefore, further evaluation of the permit application was
impossible without determining whether or not the existing source is
major. Since the previous report, additional data has been developed
for those sources where it was determined that a modification was
significant, yet no information was provided for the existing source.
Our further evaluation of these additional sources is included in
Section 3 of this report.
2.1.3 POTENTIAL EMISSIONS OF PROPOSED SOURCE/MODIFICATION
As previously stated, the baseline date is established for each
pollutant for which increments or other equivalent measures have been
established if: "In the case of a major stationary source, the pol-
lutant would be emitted in significant amounts, or, in the case of a
major modification, there would be a significant net emissions
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increase of the pollutant." In the regulations, at Section
52.21(b)(23)(i), "'Significant1 means, in reference to a net emissions
increase or the potential of a source to emit any of the following
pollutants, a rate of emissions that would equal or exceed any of the
following rates:
Pollutant and Emissions Rate
Carbon monoxide: 100 tons per year (tpy)
Nitrogen oxides: 40 tpy
Sulfur dioxide: 40 tpy
P articulate matter: 25 tpy
Ozone: 40 tpy of volatile organic compounds
Lead: 0.8 tpy
Asbestos: 0.007 tpy
Beryllium: 0.0004 tpy
Mercury: 0.1 tpy
Vinyl chloride: 1 tpy
Fluorides: 3 tpy
Sulfuric acid mist: 7 tpy
Hydrogen sulfide (H2S): 10 tpy
Total reduced sulfur (including h^S): 10 tpy
Reduced sulfur compounds (including ^S): 10 tpy"
As mentioned in Section 52.21(b)(14)(ii), only pollutants ". . .
for which increments . . . have been established . . ." are subject to
baseline determinations. Only particulate matter (PM) and sulfur
dioxide (SOp) have increment restrictions at the present time.
Therefore, potential emission rates for proposed sources or modi-
fications were obtained and evaluated for only these two pollutants.
2.1.4 CLAIMED REDUCTIONS, ENFORCEABILITY, AND ACTUAL EMISSIONS
As the regulations state in Section 52.21(b)(3)(vi), "A decrease
in actual emissions is creditable only to the extent that: (a) the
old level of actual emissions or the old level of allowable emissions,
whichever is lower, exceeds the new level of actual emissions; (b) it
is federally enforceable at and after the time that actual construc-
tion on the particular change begins." Therefore, any/all pertinent
information regarding claimed reductions was obtained. This infor-
mation was, more often than not, omitted because there was no
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proviso for net emissions in the August 7, 1977 PSD regulations.
Consequently any information regarding claimed reductions was of mini-
mal value and usually not provided.
2.1.5 MODELING INPUT DATA
As previously mentioned, (see Section 2.1.1), "'baseline area1
means any intrastate area ... in which the major source or major
modification establishing the baseline date would construct or would
o
have any air quality impact equal to or greater than 1 ug/m (annual
average) of the pollutant for which the baseline date is established."
As previously agreed to by the Project Manager, the screening proce-
dures as described in the U.S. EPA "Guidelines on Air Quality Modeling"
have been followed. Briefly, PES utilized the PT-series of models of
the UNAMAP package, together with time correction factors (Ref: D.B.
Turner, Workbook on Atmospheric Dispersion Estimates) to determine a
radius at which the above conditions exist. The boundary of the area
of significant impact shall extend up to a maximum of 50 kilometers
from the source.
Specifically, three models were used. For those facilities having
only one source/modification, PTMAX was run. A brief description of
PTMAX follows:
PTMAX - A program that performs an analysis of the maximum short-
term concentration from a single point source as a function of
stability and wind speed. A separate analysis is made for each
stack. Required inputs to the program include ambient air tem-
perature, emission rate, physical stack height, and stack tem-
perature; either stack gas volume flow or both the stack gas velo-
city and inside diameter at the top are required. The program
computes effective height of emission, maximum ground level con-
centration, and distances of maximum concentration for each con-
dition of stability and wind speed.
In some instances, PTMAX did not provide sufficient information to
determine the baseline radius due to the fact that maximum concentra-
tions sometimes exceeded 1.0 ug/m at the greatest distance analyzed
by PTMAX. For these cases, PTDIS was run. The meteorology of PTMAX
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was used to calculate air quality impacts at greater dis- tances from
the source. As above, the distance from the source at which the
3
annual impact of 1.0 ug/m was determined.
For those facilities which have more than one source, PTMTP was
run. In summary,
PTMTP - Calculates hourly concentrations at up to 30 receptors
whose locations are specified from up to 25 point sources.
Required inputs to the program consist of the number of sources to
be considered, the emission rate, physical height, stack gas tem-
perature, volume flow or stack gas velocity and diameter, and the
stack locations in coordinates. The number of receptors, the
coordinates of each and the height above ground are required.
Concentrations for a number of hours up to 24 can be estimated,
and an average concentration over this time period is calculated.
The hourly meteorological information required consists of wind
direction and speed, stability class, mixing height, and ambient
air temperature.
Worst case meteorology (stability classes 5 or 6, whichever pro-
duced the greatest downwind concentration, and wind speed of 2.0
m/sec) was used in all analyses. Wind direction was assumed
constant. One hour concentrations were obtained. Annual con-
centrations were subsequently computed utilizing the afore-
mentioned Turner time correction factors. Receptor heights were
assumed to be at ground level directly downwind. Stack coor-
dinates were assumed to be co-located.
While these proposed models may not necessarily be appropriate for
quantifying impact in complex terrain, they were used since for deter-
mining a radius of impact, they are conservative. The conservative
radius resulting from the assumption of flat terrain is desirable.
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3.0 RESULTS
Once all data was gathered, compiled, and ultimately utilized as
input for the PT-model series, the baseline triggering radii (1 ug/m
annual average) were defined. These results are presented in Table 3-1.
Table 3-1 (Status Overview) will consist of the following para-
meters (this listing also supplies the superscript notes referenced in
the table itself):
Facility Name
Pollutant
Concentrations
Baseline
Triggering Radii
In Alphabetical order, as it appears on PSD
permit application
For PM and S02 expressed as annual average
concentrations in ug/m3. They will be pre-
sented as:
(a) NA - not applicable due to:
1) permit application pre-August 7, 1977
2) facility/modification major; however,
either no SO? or no TSP are emitted
3) facility/modification not major
(b) NS - no significant amount of emissions
(c) = O.a - the number shown which is less
than 1.0 ug/m3 and equals the
maximum concentration predicted
(d) = 1.0 - farthest distance at which annual
average equals 1.0 ug/m3 (50 km
maximum)
(e) >1.0 - at 50 km (the maximum distance
examined), the concentration
remained above 1.0 ug/m3
In km from source/modification for associated
concentration
In addition, this table provides the data needed to determine if
an individual source would impact a Section 107 area in which it is
not physically located.
Tables 3-2 and 3-3 present the significant data developed from the
analysis for total suspended particulates (TSP) and sulfur dioxide
(S02) arranged by source and by triggering date. The "Significant
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Table 3-1. STATUS OVERVIEW
FACILITY
VIRGINIA
Adolph Coors Co.
Anheuser-Busch
Chesapeake Corp.
Clinchfield Coal Co.
Coal Industry Services Co.,
Inc.
Continental Forest Industries
Georgia Pacific Co.
Greer Lime Co.
Hampton Roads Energy Company
Locher Brick Works Inc.
Lone Star Industries
Lone Star LaFarge Inc.
Lynchburg Foundry
M.A. Layman and Son
Mason ite Co.
Nifty Paving Co.
Norfolk & Western Railroad Co.
Pendleton Construction Co.
Phillip Morris, Inc.
Radford Army Ammunition Plant
TSP DISTANCE
(ug/m3) (km)
=1.0 13.0
=1.0 13.5
=1.0 1.3
=1.0 8.1
NA3
>1.0 50.0
NS
NA1
>1.0 50.0
NA3
NA3
NA1
NA3
NA3
NA3
NA3
=1.0 0.5
NA3
>1.0 50.0
No Net Increase
SO
(ug/m3)
1.0
= 1.0
1.0
=1.0
NA3
>1.0
NS
NA1
>1.0
NA3
NA3
NA1
NA3
NA3
NA3
NA3
= 1.0
NA3
»1.0
No Net
DISTANCE
(km)
50.0
30.9
50.0
44.3
50.0
50.0
— _ _ «
29.2
— _
50.0
Increase
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• Table 3-1. STATUS OVERVIEW (continued)
I TSP DISTANCE SO? DISTANCE
FACILITY (ug/m3) (km) (ug/m3) (km)
VIRGINIA (con't)
I
Roanoke Electric Steel Corp. =0.5 1.3 NA2
• Southeastern Public Services =1.0 1.2 >1.0 50.0
Authority of Virginia
• Swan Oil Company >1.0 50.0 >1.0 50.0
W & W Paving Co. NA3 NA3
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Impact Radius" was developed through application of the modeling tech-
niques identified in Section 2.1.5 of this report. When these radii
were plotted to scale on a map of Virginia, the identified areas
(i.e., "Counties/Cities Triggered") were intersected by or enclosed
within the plotted radii. Brief descriptions of impact areas pre-
viously triggered by other sources are included as appropriate.
Sources listed in Table 3-1 but not in Tables 3-2 or 3-3 do not
trigger a baseline area.
Tables 3-4 and 3-5 again present the data regarding "triggered"
area, "triggering" facility and baseline date; however, the data is
arranged by AQCR and the Section 107 designation area rather than by
source and date. This was done primarily to assist Region III, the
State of Virginia, and future PSD sources in identifying previously
triggered areas in which there may be interest. All Section 107
designated areas are included and those areas which have not been
triggered have been so indicated.
The data contained in these tables are the same as that presented
for Virginia in Tables 3-1 and 3-2 of RES' November 1980 report, with
the following exceptions and modifications:
o Four new sources have been added to the listing:
— Swan Oil
~ Phillip Morris
— Chesapeake Corporation
~ Adolph Coors Company
o The Exceptions Section (4.0) of the previous report has been
eliminated.
o The source Marvin Tempieton and Sons, Inc. has been dropped
because its PSD permit was rescinded by U.S. EPA.
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Table 3-2. BASELINE DATES AND SIGNIFICANT IMPACT
RADIUS FOR TSP INDEXED BY SOURCE
FACILITY
Hampton Roads
Energy Company
SIGNIFICANT
IMPACT RADIUS
50.0 km
BASELINE
DATE
6/28/78
Clinchfield Coal
8.1 km
Continental Forest
Industries
50.0 km
8/7/78
8/30/78
Swan Oil
50.0 km
9/6/78
COUNTIES/CITIES
TRIGGERED
Gloucester County
Isle of Wight County
James City County
Matthews County
Northampton County
Southampton County
Surry County
York County
City of Chesapeake
City of Hampton
City of Newport News
City of Norfolk
City of Poquoson
City of Portsmouth
City of Suffolk
City of Virginia Beach
Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
Amelia County
Charles City County
Chesterfield County
Dinwiddie County
Goochland County
Hanover County
Henrico County
King and Queen County
King William County
New Kent County
Nottoway County
Powhatan County
Prince George County
Sussex County
City of Colonial Heights
City of Hopewell
City of Petersburg
City of Richmond
City of Williamsburg
Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
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Table 3-2. BASELINE DATES AND SIGNIFICANT IMPACT
RADIUS FOR TSP INDEXED
SIGNIFICANT BASELINE
FACILITY IMPACT RADIUS DATE
Roanoke Electric 1.3 km 3/12/79
Steel Corporation
S.E. Public Service 1.2 km 8/4/79
Authority
Norfolk & Western 0.5 km 9/25/79
Railroad
Anheuser-Busch 13.5 km 11/5/79
Phillip Morris 50.0 2/20/80
Chesapeake Corp. 1.3 km 6/23/80
Adolph Coors Co. 13.0 km 12/19/80
BY SOURCE (concluded)
COUNTIES/CITIES
TRIGGERED
Roanoke County
City of Roanoke
Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
Baseline triggered by
Roanoke Electric on
3/12/79 in this source's
entire area of impact.
Baseline triggered by
Hampton Roads on 6/28/78
and Continental Forest
Industries on 8/30/78 in
this source's entire
area of impact.
Caroline County
Baseline triggered by
Continental Forest
Industries on 8/30/78 in
this source's entire
area of impact.
Albermarle County
Rockingham County
Greene County
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Table 3-3. BASELINE DATES AND SIGNIFICANT IMPACT
RADIUS FOR SO? INDEXED BY SOURCE
FACILITY
Hampton Roads
Energy Company
SIGNIFICANT
IMPACT RADIUS
50.0 km
BASELINE
DATE
6/28/78
Clinchfield Coal
44.3 km
Continental Forest
Industries
50.0 km
8/7/78
8/30/78
Swan Oil
50.0 km
9/6/78
COUNTIES/CITIES
TRIGGERED
Gloucester County
Isle of Wight County
James City County
Matthews County
Northampton County
Southampton County
Surry County
York County
City of Chesapeake
City of Hampton
City of Newport News
City of Norfolk
City of Poquoson
City of Portsmouth
City of Suffolk
City of Virginia Beach
Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
Amelia County
Charles City County
Chesterfield County
Dinwiddie County
Goochland County
Hanover County
Henrico County
King and Queen County
King William County
New Kent County
Nottoway County
Powhatan County
Prince George County
Sussex County
City of Colonial Heights
City of Hopewell
City of Petersburg
City of Richmond
City of Williamsburg
Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
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Table 3-3. BASELINE DATES AND SIGNIFICANT IMPACT
RADIUS FOR SO? INDEXED BY SOURCE (cone 1uded)
FACILITY
S.E. Public Service
Authority
Norfolk & Western
Railroad
SIGNIFICANT
IMPACT RADIUS
50.0 km
29.2 km
Anheuser-Busch
30.9 km
Phillip Morris
Chesapeake Corp.
50.0 km
50.0 km
Adolph Coors Co.
50.0 km
BASELINE COUNTIES/CITIES
DATE TRIGGERED
8/4/79 Baseline triggered by
Hampton Roads on 6/28/78
in this source's entire
area of impact.
9/25/79 Bedford County
Botetourt County
Craig County
Floyd County
Franklin County
Montgomery County
Roanoke County
City of Roanoke
City of Salem
11/5/79 Baseline triggered by
Hampton Roads on 6/28/78
and Continental Forest
Industries on 8/30/78 in
this source's entire
area of impact.
2/20/80 Caroline County
6/23/80 Essex County
Lancaster County
Middlesex County
Northumberland County
Richmond County
Westmoreland County
12/19/80 Albermarle County
Augusta County
Culpepper County
Greene County
Louisa County
Madison County
Nelson County
Orange County
Page County
Rappahannock County
Rockingham County
Shenandoah County
City of Charlottesville
City of Harrisonburg
City of Staunton
City of Waynesboro
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Table 3-4. BASELINE DETERMINATIONS FOR TSP INDEXED BY AREA
TRIGGERING BASELINE
BASELINE AREA FACILITY DATE
EASTERN TENNESSEE SOUTHWEST
VIRGINIA INTERSTATE AQCR
(VIRGINIA PORTION)
Bland County —- Area Not Triggered
Buchanan County -— Area Not Triggered
Carroll County — Area Not Triggered
Dickenson County — Area Not Triggered
Lee County — Area Not Triggered
Russell County — Area Not Triggered
Scott County — Area Not Triggered
Smyth County — Area Not Triggered
Tazewell County — Area Not Triggered
Washington County — Area Not Triggered
Wise County — Area Not Triggered
Wythe County — Area Not Triggered
City of Bristol — Area Not Triggered
City of Gal ax — Area Not Triggered
City of Norton — Area Not Triggered
VALLEY OF VIRGINIA INTRASTATE AQCR
Alleghany County — Area Not Triggered
Augusta County — Area Not Triggered
Bath County — Area Not Triggered
Botetourt County —- Area Not Triggered
Clarke County — Area Not Triggered
Craig County — Area Not Triggered
Floyd County — Area Not Triggered
Frederick County — Area Not Triggered
Giles County — Area Not Triggered
Highland County — Area Not Triggered
Montgomery County — Area Not Triggered
Page County --- Area Not Triggered
Pulaski County — Area Not Triggered
Roanoke County Roanoke Electric 3/12/79
Rockbridge County — Area Not Triggered
Rockingham County Adolph Coors Co. 12/19/80
Shenandoah County — Area Not Triggered
Warren County — Area Not Triggered
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Table 3-4. BASELINE DETERMINATIONS FOR TSP INDEXED BY AREA (Continued)
BASELINE AREA
VALLEY OF VIRGINIA INTRASTATE AQCR
City of Buena Vista
City of Clifton Forge
City of Covington
City of Harrisonburg
City of Lexington
City of Radford
City of Roanoke
City of Salem
City of Staunton
City of Waynesboro
City of Winchester
TRIGGERING
FACILITY
Roanoke Electric
CENTRAL VIRGINIA INTRASTATE AQCR
Amelia County
Amherst County
Appomattox County
Bedford County
Brunswick County
Buckingham County
Campbell County
Charlotte County
Cumberland County
Franklin County
Halifax County
Henry County
Lunenburg County
Mecklenburg County
Nottoway County
Patrick County
Pittsylvania County
Prince Edward County
City of Bedford
City of Danville
City of Lynchburg
City of Martinsville
City of South Boston
Continental Forest
Industries
Continental Forest
Industries
BASELINE
DATE
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
3/12/79
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
8/30/78
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
8/30/78
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
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Table 3-4. BASELINE DETERMINATIONS FOR TSP INDEXED BY AREA (Continued)
BASELINE AREA
NORTHEASTERN VIRGINIA INTRASTATE AQCR
TRIGGERING
FACILITY
Accomack County
Albermarle County
Caroline County
Culpeper County
Essex County
Fauquier County
Fluvanna County
Gloucester County
Greene County
King and Queen County
King George County
King William County
Lancaster County
Louisa County
Madison County
Mathews County
Middlesex County
Nelson County
Northampton County
Northumberland County
Orange County
Rappahannock County
Richmond County
Spotsylvania County
Stafford County
Westmoreland County
City of Charlottesville
City of Fredericksburg
STATE CAPITAL INTRASTATE AQCR
Charles City County
Chesterfield County
Dinwiddie County
Goochland County
Greensville County
Adolph Coors Company
Phillip Morris
Hampton Roads Energy Co.
Adolph Coors Company
Continental Forest
Industries
Continental Forest
Industries
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
BASELINE
DATE
Area Not Triggered
12/19/80
2/20/80
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
6/28/78
12/19/80
8/30/78
Area Not Triggered
8/30/78
Area Not Triggered
Area Not Triggered
Area Not Triggered
6/28/78
Area Not Triggered
Area Not Triggered
6/28/78
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
8/30/78
8/30/78
8/30/78
8/30/78
Area Not Triggered
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Table 3-4. BASELINE DETERMINATIONS FOR TSP INDEXED BY AREA (Continued)
BASELINE AREA
STATE CAPITAL INTRASTATE AQCR
Hanover County
Henrico County
New Kent County
Powhatan County
Prince George County
Surry County
Sussex County
City of Colonial Heights
City of Emporid
City of Hopewell
City of Petersburg
City of Richmond
HAMPTON ROADS INTRASTATE AQCR
Isle of Wight County
James City County
Southampton County
York County
City of
City of
City of
City of
City of
City of
City of
City of
City of
City of
Chesapeake
Franklin
Hampton
Newport News
Norfolk
Poquoson
Portsmouth
Suffolk
Virginia Beach
Williamsburg
TRIGGERING
FACILITY
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Hampton Roads Energy Co.
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Continental Forest
Industries
BASELINE
DATE
8/30/78
8/30/78
8/30/78
8/30/78
8/30/78
6/28/78
8/30/78
8/30/78
Area Not Triggered
8/30/78
8/30/78
8/30/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
Area Not Triggered
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
8/30/78
-------
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1
1
1
1
1
1
1
1
1
1
1
Table 3-4. BASELINE DETERMINATIONS FOR TSP INDEXED
TRIGGERING
BASELINE AREA FACILITY
NATIONAL CAPITAL INTERSTATE AQCR
(VIRGINIA PORTION)
Arlington County —
Fairfax County
Loudoun County —
Prince William County
City of Alexandria —
City of Fairfax
City of Falls Church
City of Manassas
City of Manassas Park —
BY AREA (Continued)
Area
Area
Area
Area
Area
Area
Area
Area
Area
BASELINE
DATE
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
-------
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Table 3-5. BASELINE DETERMINATIONS FOR SO? INDEXED BY AREA
BASELINE AREA
EASTERN TENNESSEE SOUTHWEST
VIRGINIA INTERSTATE AQCR
(VIRGINIA PORTION)
Bland County
Buchanan County
Carroll County
Dickenson County
Grayson County
Lee County
Russell County
Scott County
Smyth County
Tazewell County
Washington County
Wise County
Wythe County
City of Bristol
City of Gal ax
City of Norton
VALLEY OF VIRGINIA INTRASTATE AQCR
Alleghany County
Augusta County
Bath County
Botetourt County
Clarke County
Craig County
Floyd County
Frederick County
Giles County
Highland County
Montgomery County
Page County
Pulaski County
Roanoke County
Rockbridge County
Rockingham County
Shenandoah County
Warren County
TRIGGERING
FACILITY
Adolph Coors Company
Norfolk & Western RR
Norfolk & Western RR
Norfolk & Western RR
Norfolk & Western RR
Adolph Coors Company
Norfolk & Western RR
Adolph Coors Company
Adolph Coors Company
BASELINE
DATE
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Area Not
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
12/19/80
Area Not Triggered
9/25/79
Area Not Triggered
9/25/79
9/25/79
Area Not Triggered
Area Not Triggered
Area Not Triggered
9/25/79
12/19/80
Area Not Triggered
9/25/79
Area Not Triggered
12/19/80
12/19/80
Area Not Triggered
-------
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Table 3-5. BASELINE DETERMINATIONS FOR SO? INDEXED BY AREA (Continued)
BASELINE AREA
VALLEY OF VIRGINIA INTRASTATE AQCR
City of Buena Vista
City of Clifton Forge
City of Covington
City of Harrisonburg
City of Lexington
City of Radford
City of Roanoke
City of Salem
City of Staunton
City of Waynesboro
City of Winchester
TRIGGERING
FACILITY
Adolph Coors Company
Norfolk & Western RR
Norfolk & Western RR
Adolph Coors Company
Adolph Coors Company
CENTRAL VIRGINIA INTRASTATE AQCR
Amelia County
Amherst County
Appomattox County
Bedford County
Brunswick County
Buckingham County
Campbell County
Charlotte County
Cumberland County
Franklin County
Halifax County
Henry County
Lunenburg County
Mecklenburg County
Nottoway County
Patrick County
Pittsylvania County
Prince Edward County
City of Bedford
City of Danville
City of Lynchburg
City of Martinsville
City of South Boston
Continental Forest
Industries
Norfolk & Western RR
Norfolk & Western RR
Continental Forest
Industries
BASELINE
DATE
Area Not Triggered
Area Not Triggered
Area Not Triggered
12/19/80
Area Not Triggered
Area Not Triggered
9/25/79
9/25/79
12/19/80
12/19/80
Area Not Triggered
8/30/78
Area Not Triggered
Area Not Triggered
9/25/79
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
9/25/79
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
8/30/78
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
Area Not Triggered
-------
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Table 3-5. BASELINE DETERMINATIONS FOR SO? INDEXED BY AREA (Continued)
BASELINE AREA
NORTHEASTERN VIRGINIA INTRASTATE AQCR
TRIGGERING
FACILITY
Accomack County
Albermarle County
Caroline County
Culpepper County
Essex County
Fauquier County
Fluvanna County
Gloucester County
Greene County
King and Queen County
King George County
King William County
Lancaster County
Louisa County
Madison County
Mathews County
Middlesex County
Nelson County
Northampton County
Northumberland County
Orange County
Rappahannock County
Richmond County
Spotsylvania County
Stafford County
Westmoreland County
City of Char!ottesvilie
City of Fredericksburg
STATE CAPITAL INTRASTATE AQCR
Charles City County
Chesterfield County
Dinwlddie County
Adolph Coors Company
Phillip Morris
Adolph Coors Company
Chesapeake Corporation
Hampton Roads Energy Co.
Adolph Coors Company
Continental Forest
Industries
Continental Forest
Industries
Chesapeake Corporation
Adolph Coors Company
Adolph Coors Company
Hampton Roads Energy Co.
Chesapeake Corporation
Adolph Coors Company
Hampton Roads Energy Co.
Chesapeake Corporation
Adolph Coors Company
Adolph Coors Company
Chesapeake Corporation
Chesapeake Corporation
Adolph Coors Company
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
BASELINE
DATE
Area Not Triggered
12/19/80
2/20/80
12/19/80
6/23/80
Area Not Triggered
Area Not Triggered
6/28/78
12/19/80
8/30/78
Area Not Triggered
8/30/78
6/23/80
12/19/80
12/19/80
6/28/78
6/23/80
12/19/80
6/28/78
6/23/80
12/19/80
12/19/80
6/23/80
Area Not Triggered
Area Not Triggered
6/23/80
12/19/80
Area Not Triggered
8/30/78
8/30/78
8/30/78
-------
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Table 3-5. BASELINE DETERMINATIONS FOR SO? INDEXED BY AREA (Continued)
BASELINE AREA
Goochland County
Greensville County
Hanover County
Henrico County
New Kent County
Powhatan County
Prince George County
Surry County
Sussex County
City of Colonial Heights
City of Emporia
City of Hopewell
City of Petersburg
City of Richmond
HAMPTON ROADS INTRASTATE AQCR
Isle of Wight County
James City County
Southampton County
York County
City of
City of
City of
City of
City of
City of
City of
City of
City of
City of
Chesapeake
Franklin
Hampton
Newport News
Norfolk
Poquoson
Portsmouth
Suffolk
Virginia Beach
Wi Miamsburg
TRIGGERING
FACILITY
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Hampton Roads Energy Co.
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Continental Forest
Industries
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Hampton Roads Energy Co.
Continental Forest
Industries
BASELINE
DATE
8/30/78
Area Not Triggered
8/30/78
8/30/78
8/30/78
8/30/78
8/30/78
6/28/78
8/30/78
8/30/78
Area Not Triggered
8/30/78
8/30/78
8/30/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
Area Not Triggered
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
6/28/78
8/30/78
-------
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Table 3-5. BASELINE DETERMINATIONS FOR SO? INDEXED BY AREA (Continued)
TRIGGERING BASELINE
BASELINE AREA FACILITY DATE
NATIONAL CAPITAL INTERSTATE AQCR
(VIRGINIA PORTION)
Arlington County — Area Not Triggered
Fairfax County — Area Not Triggered
Loudoun County — Area Not Triggered
Prince William County — Area Not Triggered
City of Alexandria — Area Not Triggered
City of Fairfax — Area Not Triggered
City of Falls Church — Area Not Triggered
City of Manassas — Area Not Triggered
City of Manassas Park — Area Not Triggered
-------
APPENDIX S
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_ Determination of the Revised PSD Baseline Dates
I for the State of Maryland
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LOS ANGCLES. CA
CHICAGO. ILL
RESEARCH TRIANGLE PARK NC
WASHINGTON DC
PACIFIC ENVIRONMENTAL SERVICES. INC.
March 31, 1982
Mr. Robert Blaszczak
Air Programs Branch
U.S. EPA Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania
Dear Mr. Blaszczak:
19106
Consistent with our discussions of the past two weeks, the PSD baseline dates
for the State of Maryland have been re-evaluated. The first aspect of this
review was to include additional information and new PSD permits which were not
included with the baseline determinations made by PES in a report dated December,
1980. The second aspect of this task assignment was to produce baseline deter-
minations reflective of using different geographic boundaries for the Section 107
designation areas. This letter and attached tables present the results of that
re-evaluation.
Table 1 lists the eight potential PSD baseline triggering sources considered in
this re-evaluation, together with their respective significant radii and base-
line trigger dates. As noted in the references, for five sources the screening
analysis used in the December, 1980 report determined the impact radius and is
very conservative. The use of a more detailed analysis would likely reduce this
radius and affect the triggered areas. Also note that for some radii, the phrase
"max = O.a" implies that the annual average impact did not exceed that value.
Therefore, only the area in which the respective source is located is poten-
tially triggered. Table 2 shows, on a county basis, those counties that would
be triggered if each of the sources were considered individually (Note: the
Section 107 designation of Luke, Maryland has been treated as a county). Tables
3, 4, and 5 list the baseline determinations for increasing smaller geographic
areas. Table 3 uses the Section 107 designation areas as they are presently
codified at 40 CFR 82.321. Table 4 uses the AQCR as the basic designation area,
while Table 5 uses the county as the basic unit.
e be any questions concerning this re-assessment, please call. This
ompleted under U.S. EPA Contract No. 68-02-2536, Work Assignment No. 14.
I
TPB/cas/453
Attachments
r
MOWEST OPERATIONS 465 Fulterton Ave. Elmhurst. ILL 60126 (312) 530-7272
-------
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Table 1. Potential PSD Baseline Triggering Sources
Within the State of Maryland
1
Source Name
• Celanese Fibers Co.
IDelmarva Power & Light Co
Vienna Power Plant
1 Eastalco Aluminum Co.
• Firestone Plastic Co.
. Mettiki Coal Co.
PPG Industries Inc.
Pulaski Highway Solid
• Waste Reduction Center
_ South West Resource
I Recovery Faci 1 i ty
Source Location
Coordinates
km E km N
692.2 4391.0
426.0 4260.0
290.3 4356.1
407.3 4379.1
644.0 4365
City of
Cumberland
365.9 4351.0
Baltimore
• Notes: NA - area is non-attainment
NS - emissions are below signi
References
Allegheny Co.
Dorchester Co.
Frederick Co.
Cecil Co.
Garrett Co.
Allegheny Co.
Baltimore City
City
Significant Radius
TSP S02 Reference
1.4 50.0 A
max=0.1 5.0 B
within
NS borders of C
Frederick Co.
NS 50.0 A
1.4 50.0 A
max=0.8 NS A
max=0.5 max=0.9 A
NA max=0.2 D
Baseline
Date
8/14/78
5/29/80
11/10/77
8/12/78
1/17/78
8/29/79
8/24/78
7/27/81
ficance level
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Report entitled, "Determination of PSD Baseline Dates within U.S. EPA, Region III,
December, 1980
PSD permit application: Significant radius for S0£ is less than 5.0 km for all
directions except 40° to 50°. However, in this direction, Dorchester County is
adjacent to the Delaware border.
Communication from R. Blaszczak relating results of U.S. EPA, Region III examination
of impact radius.
PSD permit application
-------
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Table 2. Maryland Counties within the
Pollutant
Particulates
Delmarva Power & Light Co. Dorchester
Vienna Power Plant
Celanese Fibers Co. Allegheny
Eastalco Aluminum Co. NS
Firestone Plastic Co. NS
Mettiki Coal Co. Garrett
PPG Industries, Inc. Allegheny
Pulaski Highway Solid Baltimore City
Waste Reduction Center
Southwest Resource Recovery NA
Facility
NA - area is non-attainment
NS - emissions are below significance level
* Section 107 Designated Area as of March 31, 1982
Significant Impact
Sulfur Dioxide
Dorchester
Wicomico
Allegheny
Washington
Garrett
City of Luke*
Frederick
Cecil
Kent
Queen Annes
Baltimore County
Baltimore City
Harford
Garrett
Allegheny
City of Luke*
NS
Baltimore City
Baltimore City
Radius
Baseline Date
(if appl icable
5/29/80
8/14/78
11/10/77
8/12/78
1/17/78
9/29/79
8/24/78
7/27/81
-------
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APPENDIX T
Determination of the Revised PSD Baseline Dates
for the State of West Virginia
T-l
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LOS ANGLLES. CA
CHICAGO. ILL
MSCAWCH tWANGLE I*ARK NC
WASHINGTON DC
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'ACIFIC ENVIRONMENTAL SERVICES. INC.
April 22, 1982
Mr. Robert Blaszczak
Air Programs Branch
U.S. EPA, Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
Consistent with our recent discussions, the PSD baseline dates for the State
of West Virginia have been re-evaluated. The first aspect of this review was
to include additional information and new PSD permits which were not included
with the baseline determinations made by PES in a report dated December,
1980. The second aspect of this task assignment was to produce baseline
determinations reflective of using different geographic boundaries for the
Section 107 designation areas. Since both the Section 107 designations and
the AQCR's utilize a sub-county area described as "Magisterial Districts," the
report cannot be completed until maps requested from the Tax Department of the
State of West Virginia are received. This letter and the attached tables
(marked draft) present the results of this re-evaluation to date. Blanks
within the tables indicate a region affected by the geographic boundaries of
"Magisterial Districts."
Table 1 lists the modeling input parameters of the nine potential PSD baseline
triggering sources considered in this re-evaluation. Table 2 presents the
respective significant impact radii and the baseline trigger dates. The
impact radii were determined utilizing the screening analysis which was
described in the abovementioned December, 1980 report. As noted in that
report, this approach is extremely conservative. Consequently, the use of a
more detailed analysis would likely reduce this radius and affect the trig-
gered areas. Also note that for some radii, the phrase "max = O.a" implies
that the annual average impact did not exceed that value. Therefore, only the
area in which the respective source is located is potentially triggered.
Table 3 shows, on a county basis, those counties that would be triggered if
each of the sources were considered individually. (Note: where the Section
107 designation and the AQCR definition has utilized geographic areas of
"magisterial districts," these sub-county areas have been treated as a
county.) Tables 4, 5, and 6 list the baseline determinations for increasingly
smaller geographic areas. Table 4 uses the Section 107 designation areas as
they are presently codified in 40 CFR 81.349 (as of March 31, 1982). Table 5
uses the AQCR as the basic designation area, while Table 6 uses the county as
the basic unit.
I
MOWEST OPERATIONS 4§5 Fulterton Ave. Elmhurst. ILL 60126 (312) 530-7272
-------
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I
Mr. Robert Blaszczak
April 22, 1982
This analysis will be finalized when the maps of the West Virginia "Magis-
terial Districts" are received. Should there by any questions concerning this
re-assessment thus far, please call. This work was completed under U.S. EPA
Contract Wo. 68-02-2536, Work Assignment No. 14.
_ _
Thomas PY\«la<
Project Manag^
TPB/jlf/453
inc.
-------
5 CA
CHCAGO. ILL
RESEARCH TWANGLE ffAKK. NC
DC
ACtftC ENVIRONMENTAL SERVICES INC
1
1
1
•
1
April 27, 1982
Mr. Robert Blaszczak
Air Programs Branch
U.S. EPA, Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
The attached six tables comprise the finalization of the reanalysis of
the PSD baseline areas for the State of West Virginia. As noted in
previous correspondence dated April 22,
1982, some AQCRs and Section
107 designations used a sub-county area called "Magisterial Districts"
as geographic areas descriptions and as
ysis could not be completed until maps
such the PSD baseline retnal-
of the "Magisterial Districts"
were received from the State of West Virginia. All descriptive infor-
1
1
|
•
mation for these tables was included in
the previous correspondence.
As noted there, the grouping of contiguous "Magisterial Districts"
within a single county were treated the
107 designation area in Tables 5 and 6.
This work was completed under U.S. EPA
Assignment No. 14. Should there be any
O 1 llCrOl \jAjf •
^L^^^
Project Manager
TPB/jlf/453
Enc.
same as a county or Section
Contract No. 68-02-2536, Work
questions, please call.
MIDWEST OPERATIONS 465 FuHerton Awe. Ehnhurst. ILL 60126 (312) 530-7272
1
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-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Table 3. West Virginia Counties within the
Significant Impact Radius
Facility
Badger Coal Co.
Elkay Mining Co.
Island Creek Coal Co.
(Tallmansville)
Island Creek Coal
(Bob White)
Morgantown Energy
Research Center
Co.
Pollutant
Particulates Sulfur Dioxide
Upshur
Logan
Mingo
Wyoming
Boone
Lincoln
Upshur
Randolph
Barbour
Boone
Logan
NS
Upshur
Barbour
Harrison
Lewis
Randolph
Logan
Mingo
Wyoming
Boone
Upshur
Lewis
Webster
Randolph
Barbour
Harrison
Boone
Logan
Baseline Date
(if applicable)
11/07/78
3/02/7-9
8/14/78
5/08/78
8/28/78
Monongalia
Marion**
• Union Magisterial Dist.
west of Highway 1-79
• Winfield Magisterial Dist.
west of Highway 1-79
• Remainder of County
Preston
NS - Emissions are less than significance levels
* - AQCR does not encompass the entire county
** - Section 107 designated area as of March 31, 1982
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Facility
Table 3. West Virginia Counties within the
Significant Impact Radius (Continued)
Pollutant
Particulates Sulfur Dioxide
Westmoreland Coal Co.
Ashland Chemical Co.
Pennsylvania Coke
Technology, Inc.
Baseline Date
(if applicable)
8/10/78
Raleigh Raleigh
Mercer Fayette*
• Fayetteville Magisterial Dist.
• Mountin Cove Magisterial Dist.
• Nutall Magisterial Dist.
• Quinnimont Magisterial Dist.
• Sewell Magisterial Dist.
McDowel1
Logan
Summers
Kanawha
Fayette*
t Fayetteville Magisterial Dist.
• Mountain Cove Magisterial Dist.
• Nutall Magisterial Dist.
• Quinnimont Magisterial Dist.
• Sewell Magisterial Dist.
t Falls Magisterial Dist.
• Kanawha Magisterial Dist.
Boone
Wyoming
NS Wayne
Cabell
Raleigh Raleigh
Logan
Boone
Kanawha
NS - Emissions are less than significance levels
* - AQCR do«s not encompass the entire county
** - Section 107 designated area as of March 31, 1982
2/22/79
8/01/80
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Table 3. West Virginia Counties within the
Significant Impact Radius (Concluded)
Facility
Pollutant
Particulates Sulfur Dioxide
Pennsylvania Coke
Technology, Inc. (continued)
Baseline Date
(if applicable)
Fayette* 8/01/80
t Fayetteville Magisterial Dist.
• Mountain Cove Magisterial Dist.
• Nutall Magisterial Dist.
• Quinnimont Magisterial Dist.
• Sewell Magisterial Dist.
• Falls Magisterial Dist.
• Kanawha Magisterial Dist.
Wyoming
Mingo
McDowel1
Mercer
Summers
Greenbrier
DOE-Gulf Minerals SRC-II
Monongalia
Preston
Taylor
Barbour
Marion**
Monongalia
Preston
Taylor
Barbour
Marion**
11/24/80
• Union Magis- • Union Magisterial
terial Dist. District west of
west of Hwy 1-79 Highway 1-79
t Winfield Magis- t Winfield Magisterial
terial Dist. District west of
west of Hwy 1-79 Highway 1-79
• Remainder of t Remainder of County
County
Marshall Marshall
Wetzel Wetzel
Harrison Harrison
NS - Emissions are less than significance levels
* - AQCR does not encompass the entire county
** - Section 107 designated area as of March 31, 1982
-------
1
1
1
1
1
1
•
1
1
1
1
•
1
1
1
1
1
Table 4. Baseline Determinations by Section 107 Designations
(40 CFR 81.349 as of March 31, 1982)
Baseline Area
Participates
Steuben vi 1 1 e-Wei rton-Wheel i ng
Interstate AQCR
Parkersburg-Tygart Magisterial
District in Wood County
Kanawha County and Valley
Magisterial District in
Fayette County
In Marion County, all portions of
Union and Winfield Magisterial
Districts west of Highway 1-79
Arden Magisterial District in
Berkeley County
Remainder of State
Sulfur Dioxide
New Manchester-Grant Magisterial
District in Hancock County
Wellsburg Magisterial District in
Brooke County
Piedmont Magisterial District in
Mineral County
Remainder of State
Triggering Facility
DOE-Gulf Minerals SRC-II
Not Triggered
Westmoreland Coal Co.
Morgantown Energy Research
Center
Not Triggered
Island Creek Coal Co.
(Bob White)
Not Triggered
Not Triggered
Not Triggered
Island Creek Coal Co.
(Bob White)
Baseline Date
11/25/80
8/10/78
8/28/78
5/8/78
5/8/78
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Table 5. Baseline Determinations by AQCR*
Baseline Area
Participates
Triggering Facility
Steubenvi11e-Wei rton-
Wheeling Interstate AQCR
- Brooke County; Wellsburg
Magisterial District**
- Hancock County; New
Manchester-Grant
Magisterial District**
- Remainder of AQCR
DOE-Gulf Minerals
SRC-II
Parkersburg-Marietta
Interstate AQCR
- Wood County; Parkersburg- Not Triggered
Tygart Magisterial Dist.**
- Remainder of AQCR DOE-Gulf Minerals
SRC-II
Huntington-Ashl and-
Portsmouth-Ironton
Interstate AQCR
Not Triggered
Kanawha Valley Intrastate Westmoreland Coal Co.
AQCR
Southern West Virginia
Intrastate AQCR
North Central West Virginia
Intrastate AQCR
- Marion County; Union
Magisterial District west
of Highway 1-79**
- Marion County; Winfield
Magisterial District west
of Highway 1-79**
Island Creek Coal Co.
(Bob White)
Morgantown Energy
Research Center
- Remainder of AQCR
Island Creek Coal Co.
(Tallmansville)
Sulfur Dioxide
Baseline Triggering Facility
Date
Not Triggered
Not Triggered
11/25/80 DOE-Gulf Minerals
SRC-II
11/25/80 DOE-Gulf Minerals
SRC-II
Ashland Chemical Co.
8/10/78
5/8/78 Island Creek Coal Co.
(Bob White)
8/28/78
8/14/78
Island Creek Coal Co.
(Tallmansville)
Baseline
Date
11/25/80
11/25/80
2/22/79
5/8/78
8/14/78
* Hypothetical baseline determination if AQCR is used as the basic §107 designation area
** Section 107 designated area for pollutant shown as of March 31, 1982
-------
I
Baseline Area
I
I
I
I Cumber!and-Keyser Interstate AQCR
I
• Central West Virginia
I
Table 5. Baseline Determinations by AQCR* (Concluded)
Participates
Triggering Facility
- Mineral County; Piedmont
Magisterial District**
- Remainder of AQCR
Sulfur Dioxide
Baseline Triggering Facility
Date
Not Triggered
Baseline
Date
Not Triggered
Island Creek Coal Co. 8/14/78
(Tallmansville)
Intrastate AQCR
Allegheny Intrastate AQCR Westmoreland Coal Co. 8/10/78
Eastern Panhandle Intrastate AQCR
- Berkeley County- Not Triggered
Arden Magisterial Dist.**
• - Remainder of AQCR Not Triggered
Not Triggered
Island Creek Coal Co.
(Tallmansville)
Island Creek Coal Co.
(Tallmansville)
8/14/78
8/14/78
Not Triggered
I
I
I
I
I
I
I
I
I
* Hypothetical baseline determination if AQCR is used as the basic §107 designation area
** Section 107 designated area for pollutant shown as of March 31, 1982
-------
I
I
I
I
I
I
I
Table 6. Baseline Determinations by County***
Baseline Area
Participates
Triggering Facility
(Steubenville-Weirton-Wheeling
Interstate AQCR--41 CFR 81.33)
Brooke County
- Wellsburg Magisterial
District**
- Remainder of County
• Hancock County
- New Manchester-Grant
Magisterial District**
I- Remainder of County
Marshall County
Ohio County
(Parkersburg-Marietta
Interstate AQCR—41 CFR 81.70)
I
I
• Jackson County
• Pleasants County
Tyler County
JWetzel County
Not Triggered
Not Triggered
Not Triggered
Not Triggered
DOE-Gulf Minerals
SRC-II
Not Triggered
I
I
I
I
I
Wood County
- Parkersburg-Tygart
Magisterial District**
- Remainder of County
*
Not Triggered
Not Triggered
Not Triggered
DOE-Gulf Minerals
SRC-II
Not Triggered
Not Triggered
Sulfur Dioxide
Baseline Triggering Facility
Date
Not Triggered
Not Triggered
Not Triggered
Not Triggered
11/25/80 DOE-Gulf Minerals
SRC-II
Not Triggered
Not Triggered
Not Triggered
Not Triggered
11/25/80 DOE-Gulf Minerals
SRC-II
Not Triggered
Not Triggered
Baseline
Date
11/25/80
11/25/80
AQCR does not encompass the entire county
** Section 107 designated area as of March 31, 1982
*** Hypothetical baseline determination if county is used as the basic §107 designation area
-------
I
I
I
I
Table 6.
Baseline Area
Baseline Determinations by County*** (Continued)
Particulates
Triggering Facility
Sulfur Dioxide
Baseline Triggering Facility
Date
I (Huntington-Ashland-Portsmouth-Ironton
Interstate AQCR—41 CFR 81.64)
I Cabell County
Mason County
I
Wayne County
Not Triggered
Not Triggered
Not Triggered
I (Kanawha Valley Intrastate
AQCR—41 CFR 81.233)
I Kanawha County
• Putman County
Fayette County*
• - Falls Magisterial Dist.
- Kanawha Magisterial
District
Westmoreland Coal Co. 8/10/78
Not Triggered
Westmoreland Coal Co. 8/10/78
(Southern West Virginia
Intrastate AQCR--41 CFR 81.235)
Boone County
I
I
Lincoln County
• Logan County
• McDowell County
Mercer County
Island Creek Coal Co.
(Bob White)
Elkay Mining Co.
Island Creek Coal Co.
(Bob White)
5/8/78
3/2/79
5/8/78
I
I
I
Westmoreland Coal Co. 8/10/78
Westmoreland Coal Co. 8/10/78
Ashland Chemical Co.
Not Triggered
Ashland Chemical Co.
Pennsylvania Coke
Technology Inc.
Not Triggered
Pennsylvania Coke
Technology Inc.
Island Creek Coal Co.
(Bob White)
Not Triggered
Island Creek Coal Co.
(Bob White)
Pennsylvania Coke
Technology Inc.
Pennsylvania Coke
Technology Inc.
*
I**
Baseline
Date
2/22/79
2/22/79
8/1/80
8/1/80
5/8/78
5/8/78
8/1/80
8/1/80
AQCR does not encompass the entire county
Section 107 designated area as of March 31, 1982
*** Hypothetical baseline determination if county is used as the basic §107 designated area
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Table 6. Baseline Determinations by County*** (Continued)
Baseline Area
Mingo County
Raleigh County
Wyoming County
Fayette County*
- Fayetteville Magisterial
District
- Mountain Cove
Magisterial District
- Nuttall Magisterial
District
- Quinnimont Magisterial
District
- Sewell Mountain
Magisterial District
(North Central West Virginia
Intrastate AQCR--41 CFR 81.234)
Particulates
Triggering Facility
Elkay Mining Co. 3/2/79
Westmoreland Coal Co. 8/10/78
Westmoreland Coal Co. 8/10/78
Sulfur Dioxide
Baseline Triggering Facility
Date
Elkay Mining Co.
Westmoreland Coal Co.
Elkay Mining Co.
> Westmoreland Coal 8/10/78
Co.
Barbour County
Harrison County
Marion County
Island Creek Coal Co.
(Tallmansville)
DOE-Gulf Minerals
SRC-II
8/14/78
11/25/80
Island Creek Coal Co.
(Tallmansville)
Island Creek Coal Co.
(Tallmansville)
- Union Magisterial Dist.
• west of Highway 1-79**
- Winfield Magisterial
I
DOE-Gulf Minerals 11/25/80 Morgantown Energy
SRC-II
Dist. west of Highway 1-79**
- Remainder of County DOE-Gulf Minerals
I
I
I
Mommgalia County
SRC-II
DOE-Gulf Minerals
SRC-II
Research Center
11/25/80 Morgantown Energy
Research Center
11/25/80 Morgantown Energy
Research Center
Baseline
Date
3/2/79
8/10/78
3/2/79
Westmoreland Coal Co. 8/10/78
8/14/78
8/14/78
8/28/78
8/28/78
8/28/78
* AQCR does not enconpass the entire county
** Section 107 designated area as of March 31, 1982
*** Hypothetical baseline determination if county is used as the basic §107 designation area
-------
I
I
I
I
Ritchie County
I Roane County
Table 6. Baseline Determinations by County***
(Continued)
Baseline Area
I
I
I
I
Upshur County
Webster County
Wirt County
Particulates
Triggering Facility
Not Tri ggered
Not Triggered
Island Creek Coal Co. 8/14/78
(Tallmansville)
Not Triggered
Not Triggered
Sulfur Dioxide
Baseline Triggering Facility
Date
Not Triggered
Not Triggered
Island Creek Coal Co.
(Tallmansville)
Island Creek Coal Co.
(Tallmansville)
Not Triggered
(Allegheny Intrastate
AQCR—41 CFR 81.230)
Greenbrier County
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Island Creek Coal Co. 8/14/78
(Tallmansville)
Westmoreland Coal Co. 8/10/78
Not Triggered
Not Triggered
• Hampshire County
Hardy County
• Monroe County
• Pendleton County
Pocahontas County
HRandolph County
•Summers County
•Tucker County
Grant County*
•~ Grant Magisterial Dist.
- Milroy Magisterial Dist..
•* AQCR does not encompass the entire county
** Section 107 designated area as of March 31, 1982
•*** Hypothetical baseline determination if county is used as the basic §107 designation area
Pennsylvania Coke
Technology Inc.
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Island Creek Coal Co.
(Tallmansville)
Pennsylvania Coke
Technology Inc.
Not Triggered
Not Triggered
Baseline
Date
8/14/78
8/14/78
8/1/80
8/14/78
8/1/80
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1
•Table 6. Baseline Determinations by
(Continued)
_ Baseline Area
I Preston County
1 Taylor County
Particulates
Triggering Facility Baseline
Date
DOE-Gulf Minerals 11/25/80
SRC-II
DOE-Gulf Minerals 11/25/80
SRC-II
County***
Sulfur Dioxide
Triggering Facility
Morgantown Energy
Research Center
DOE-Gulf Minerals
SRC-II
Baseline
Date
8/28/78
11/28/80
I (Cumber! and- Keyser Interstate
AQCR-41 CFR 81.59)
1 Grant County*
- Union Magisterial
• District
Mineral County*
• - Elk Magisterial Dist.
*- New Creek Magisterial
District
I - Piedmont Maaisterial
District** " J
• (Central West Virginia
Intrastate AQCR--41 CFR
| Braxton County
• Calhoun County
Clay County
• Doddridge County
Gilmer County
Blew is County
Not Triggered
Not Triggered
81.231)
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
• Nicholas County Not Triggered
* AQCR does not encompass the entire county
• ** Section 107 designated area as of March 31, 1982
*** Hypothetical baseline determination if county is used as
1
Not Triggered
Not Triggered
Not Triggered
Not Triggered
Not Tri ggered
Not Triggered
Not Triggered
Not Triggered
Not Triggered
the basic §107 designation area
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Baseline Area
Table 6. Baseline Determinations by County*** (Concluded)
Sulfur Dioxide
Particulates
Triggering Facility
Baseline Triggering Facility
Date
Baseline
Date
Mineral County*
- Cabin Run Magisterial
District
- Frankfort Magisterial
District
District
I- Wei ton Magisterial
n
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APPENDIX U
Draft Position Paper on PSD Increment Tracking
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POSITION PAPER
PREVENTION OF SIGNIFICANT DETERIORATION
INCREMENT CONSUMPTION TRACKING
INTRODUCTION
The Clean Air Act (CAA) of 1970 had as one of its significant
objectives the preservation of clean air in those areas of the United
States which have ambient air whose quality is better that that re-
quired by the National Ambient Air Quality Standards. That objective
was strongly supported in the CAA revisions of 1977. In response to
this legislatively mandated goal and various Court challenges, the
U.S. Environmental Protection Agency (U.S. EPA) developed rulemaking
procedures for the "Prevention of Significant Deterioration (PSD)" of
air quality in "clean air areas" in 1975, 1978, and 1980. These regu-
lations established the mechanisms by which major pollutant emitting
sources proposing to locate in clean air areas would be extensively
reviewed prior to construction. In addition, EPA recognized that no
degradation in air quality is an impossible goal if economic growth of
the country is to continue. Therefore, these same rulemaking proce-
dures quantified the level of increased pollution that would be per-
mitted. The regulations also established the date or baseline from
which to "start counting" the amount of air quality that is "used up"
by the new or modified major pollution sources (or as is more commonly
referred to, "the baseline date after which the increment is con-
sumed").
Neither the CAA of 1970 (or its subsequent revisions in 1975 and
1977) nor any of U.S. EPA's rulemakings illustrate the mechanics of
tracking increment consumption. The purpose of this paper is to dis-
cuss various concepts as to how this increment can be tracked. The
mechanics of the process (for the most part, computer information
management software) is beyond the scope of this task.
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INVENTORY MANAGEMENT SYSTEMS
PSD PERMIT FILE SEPARATION
The PSD rules require the issuance of a permit w»d is, in a sense,
the first step in any increment tracking process. Indeed, for purposes
of tracking, a regulatory agency could simply attach a flag to each
PSD source. Each subsequent application would make its demonstration
that the total increment consumed by its own proposed source and the
previous sources does not exceed the regulation specified increments.
While this approach puts the minimum burden on the agency in terms of
tracking, it would seem to be a disincentive to major new industry
planning to locate in the area. Industry would be required to do its
own searching through agency files for emission and modeling data and,
as the number of PSD sources increase, this increasingly difficult
requirement would "encourage" industry to simply avoid areas where
previous PSD sources had built.
The PSD rules state that growth in emissions from existing point
and area sources also consume the increment once the baseline date has
been established. The agency could implement this requirement in this
simplistic case by first identifying the baseline date and baseline
area as it occurs (a one-time determination of previously issued PSD
permits would be required). The second desired activity would be for
the agency to archive each of its general emissions inventory updates;
thereby, providing that data would be available for any applicant to
evaluate increment consumption by existing sources. Again, this type
of system may encourage industry to avoid areas where increment con-
sumption is perceived to be high because it has not been quantified.
The mechanics of implementing a PSD separation system can simply
be the physical separation of PSD permit files from other files or by
the addition of a "flag" to any computer emissions inventory system
currently in existence. As a necessary side issue, even this simplis-
tic system must include sources which have filed permit applications,
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but have not as yet been granted a permit to construct. As 1s probably
obvious, the increment tracking effort must include all facilities
which have been granted a permit but have not begun operation.
SPECIAL PSD DATA FILE
In this scenario, PSD-related data is generated and stored in a
special PSD file to assist in tracking PSD sources and the PSD
increment. However, because increment consumption is temporally and
spatially unique, this is an informational PSD increment, rather than
a true increment tracking scheme. Additionally, since a PSD applicant
need only demonstrate that the PSD increment will not be exceeded,
this file will inherently be conservative with respect to the incre-
ment consumed. The level of conservatism will be based on the degree
of conservatism implemented by the applicant in his demonstration.
More specifically, this special PSD file will contain all of the
information that would be needed by a future PSD permit application
for all PSD increment consuming sources. The file will contain an
emission inventory for all the various averaging times. This inven-
tory will reflect any permit conditions such as limitations in the
hours of operation and/or fuel specifications which are imposed on the
permitted source. Data on geographic location, dynamic and physical
stack characteristics, and fugitive source descriptions will also be
included.
Lastly, the file will contain the quantification of the PSD incre-
ment consumed. This sub-file should contain increment consumption for
the five pollutant-averaging time combinations presently required by
the PSD regulations. This data would come from the applications them-
selves. A brief commentary with each number would assist any future
reviewer of the file to assess the level of conservatism incorporated
into the quantification of the increment. For example, the remark
"used screening model" would indicate a higher degree of conservatism
than the remark "using MPTER with actual emissions rather than allow-
able emissions for existing sources." In this instance, the second
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comment would indicate that state-of-the-art computer simulation
techniques were used and that spatial and temporal compatability may
be the most significant factor in determining whether another source
could be sited in this area, rather than the absolute quantification
of the previously consumed increment.
SIGNIFICANT IMPACT RADIUS
It is of value for both the PSD applicant and the regulatory
agency to "know" the sphere of influence of the PSD source on the air
quality. Since all dispersion of air pollutants follows an exponen-
tial decay type function, its impact theoretically never becomes zero.
However, its impact does become sufficiently "small" such that it
cannot be distinguished from background (i.e., it cannot be identifi-
able in a cause-effect type relationship). U.S. EPA has provided
guidance relating to cutoff values at which the impact of an indivi-
dual source becomes "insignificant." Each pollutant averaging time
combination will result in a downwind distance at which the impact of
the PSD source is reduced to the "insignificant impact" level. The
maximum of this set of radii is the significant impact radius. A full
description of this radius and the methodology for quantifying it is
contained in Appendix A.
The data file of significant impact radii should be incorporated
into the above special PSD file. This information is useful in two
aspects relating to PSD. First it can be used to determine if a PSD
source establishes a baseline area and baseline trigger date. How-
ever, the methodology is conservative and hence, it may indicate areas
being triggered that may not be triggered using a less conservative
approach. The individual states have the prerogative of finalizing
the degree of conservatism they may wish to use in determining the
baseline area.
The second use of the significant impact radius is identification
of the number of sources which must be considered in the air quality
impact analysis of the proposed PSD source. This is useful both for
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the applicant and the regulatory agency in both minimizing the number
of sources modeled and ensuring that no area is overlooked. As stated
previously, the methodology for determining the significant impact
radius is described in detail in Appendix A. To utilize the radii,
one would make a comparison of the proposed new source and all of the
remaining PSD sources. For each pair, the sum of the individual radii
of significant impact is compared to the distance between the two
sources. If the distance between the two sources is greater than or
equal to the sum of the impact radii, the previous PSD source must be
included in the proposed source's impact assessment for total incre-
ment consumption. Figure 1 illustrates the various possible combina-
tions. Figure la shows that Source A is located outside Source B's
impact area (as defined by the radius of significant impact) and its
impact area does not overlap. Hence, Source A does not have to be
considered by Source B in its PSD application. In Figure Ib, a
similar situation exists in that Source A is located outside Source
B's impact area but that the impact area of Source A overlaps or may
even totally encompass the impact area of Source B. Hence, Source A
must be considered in the Source B PSD application. Figure Ic shows
the case where Source A is physically located within Source B's impact
area. This is the obvious case in that all sources located within the
Source B impact area consistute the minimum number of sources which
must be considered in Source A's application.
ADDITION OF INDIVIDUAL SOURCES' INCREMENTS
This is the first true PSD increment tracking approach rather than
the inventory management techniques described earlier. In this
approach, isopleths of PSD increment consumption would be developed
for pollutant-averaging time combinations. The degree of sophistica-
tion of this approach is based on the degree of detail of the isopleth,
whether angular direction is incorporated, and the type of model used
to draw the isopleth.
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Figure la.
Figure Ib.
Figure Ic.
Figure 1. AREAS DEFINED BY SIGNIFICANT IMPACT RADII
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The first item of sophistication is the degree of detail of the
isopleth lines. One could select a step function approach based on
percent of total increment with the number of steps decided upon by
the regulatory agency. The ultimate would be infinite steps described
by an algebraic function or a finely detailed data set.
The second item to be integrated with the isopleth lines is whether
angular direction is incorporated. One could simply take a downwind
distance and its associated impact to draw circles. This series of
annular rings would reflect the maximum increment consumption for
those distances from the sources. Integrating radial distribution
into the scenario would result in "truer" isopleth lines.
The last item to be incorporated is the level of the "state-of-
the-art" modeling to be used in quantifying the increment consumption
values. On the simplistic side, screening techniques similar to those
described in the radius of impact analysis described previously could
be used. On the other extreme, state-of-the-art models would be used.
A mixed hybrid could also be used when the applicant has supplied
state-of-the-art modeling and other data in sufficient detail; or,
screening techniques could be employed by the state whenever an appli-
cation does not provide sufficient information (Note: this latter
case is true for a PSD increment consuming source which, for various
reasons, is not subject to PSD review for a specific pollutant).
Irrespective of the level of detail of the isopleths developed,
increment consumption is tracked by overlaying the isopleths and
summing the individual contributions of each PSD source. This summa-
tion could be done manually if graphical isopleths are drawn and the
number of sources are not large. Also, computer software does pre-
sently exist (i.e., SYMAP) to do this summing.
This increment tracking procedure is better suited for the annual
average tricking than for the short term time periods. For the short
term periods, overlapping isopleths which are not temporally com-
patible would result in an ultra-conservative estimate of increment
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consumption. However, as a first cut, this procedure can be highly
useful where a large number of sources or closely located sources are
being evaluated.
REPLACEMENT TECHNIQUE
This increment tracking technique actually builds upon the "addi-
tion scenario" described previously. As noted in the addition
scenario, temporal incompatability adds extreme conservatism to the
increment consumption, especially for the short term averaging time.
As before, the number of isopleths, integration of angular separation,
and the state-of-the-art level of modeling would be a predetermined
level of sophistication of the system. In the scheme, all the inter-
acting increment consuming sources are modeled simultaneously allowing
for spatial separation. Then, all impacts which would be predicted to
be over 25 percent of the increment (or some other triggering percen-
tage) would replace that region of the increment consuming map. The
additive procedure would still remain in use for those areas beyond
the area replaced.
FULL PSD INCREMENT TRACKING
This scenario is the ultimate alternative in terms of detail to be
described in this paper. In this alternative, the entire state would
be modeled to track PSD increment consumption. Beginning with the
base year inventory, all changes in the inventory since the base year
would be tracked. This would include (in addition to the new sources)
an annual update in emissions inventory of actual emissions. Shutdown
in sources could be handled as negative emissions inputs. The output
from the modeling would be isopleth maps showing increment consump-
tion. To implement such a scenario, a modeling methodology would need
to be developed especially in the region of urban-rural interfaces.
At present, no one model represents both levels of urbanization and no
methodology exists to handle the transition. This type of tracking is
most conducive to attracting industry, since increment availability is
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known to the limits of the state-of-the-art. Aside from the labor
intensiveness of this procedure, it has an additional drawback in that
temporal and spatial distribution of the impacts of a proposed new
source may be consistent with an' area in which high increment consump-
tion has taken place (i.e., the source may still fit despite the lack
of significant available increment).
ACTUAL PRACTICE
In the preliminary development of this paper, a search for PSD
increment tracking procedures currently being employed was made.
Basically, various forms of inventory management procedures are being
pursued with most of the emphasis and manpower being expended on the
software needed to implement the procedures. The most elaborate system
found may be categorized as a special PSD file. In only one case,
Texas, was there any discussion of tracking the increment per se. The
Texas approach would use the TEM and TCM models and do full PSD
Increment tracking whenever a significant change in the increment
consuming inventory would occur (whether it is to be a new source or
growth from existing sources). This tracking system has yet to be
implemented.
CONCLUSION
The above discussions treat briefly various methodologies for PSD
increment consumption tracking which could be pursued, depending on
the priorities of the regulatory agencies. In all cases, start up is
a significant task. However, as with all dynamically changing systems,
unless the continuous update expense is considered and expended to the
level warranted by the complexity of the system chosen, the system
would soon become worthless. The ability to maintain a PSD tracking
system should be the prime criteria for the selection of any system to
be implemented.
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APPENDIX A
METHODOLOGY FOR DETERMINING THE SIGNIFICANT IMPACT RADIUS
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In this methodology to quantify the significant impact radius of a
source, the screening procedures, as described in the U.S. EPA
"Guidelines on Air Quality Models" (EPA-450/2-78-027) were followed.
Briefly, the PT-series of models in the UNAMAP package, together with
the time correction factors (Ref: D.B. Turner, Workbook on Atmos-
pheric Dispersion Estimates) were used to determine a radius of signi-
ficant impact for each PSD source. The significant impact area is
defined as that area where ambient air pollutant concentrations equal
or exceed the following levels:
Table 1. AVERAGING TIME
Pollutant
so2
TSP
N02
CO
Annual
1 ug/m
1 ug/m
1 ug/m3
—
24-Hour
5 ug/m3
5 ug/m
—
—
8-Hour 3-Hour
25 ug/m3
—
—
0.5 ug/m3
1-Hour
__
—
—
2 ug/m3
The boundary of the area of significant impact extends up to a maximum
of 50 kilometers from the source, the extreme limitation of applica-
bility of Gaussian dispersion models.
The basic methodology was most applicable to single stack sources
where the ground level impacts were reduced to the significance impact
levels using the internally generated meteorological parameters
(Note: Multiple identical stacks can be equated to a single stack
source since this model is incapable of stack separation.). This
approach, which coincides with the approved methodology without varia-
tion, is described as Scenario 1 below. In some cases, however, the
air quality impacts did not reduce to significant impact levels under
this scenario. In those instances, described in detail as Scenario 2,
the PTDIS model was used to determine the air quality impacts at larger
distances from the source. Since the meteorology used was identical
to that internally generated by PTMAX, this procedure is consistent
with the agreed methodology.
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Under the third scenario, sources having multiple different stacks
were analyzed using the PTMTP model. Since the total ground level
impact is the sum of the contributions of each stack, this model was
used for this summation, since the meteorology was limited to that
generated by PTMAX, this variation is consistent with the agreed
methodology.
The following is a step-by-step explanation of these scenarios and
how they were used to quantify the radius of significant impact.
SCENARIO 1 - PTMAX
(a) Meteorological data (internally generated data were used)
(b) Source parameters
Output
(a) Maximum one-hour concentrations
(b) Associated distances
The following is the procedure used to definitize the radius of
significant impact for Scenario 1. First, the one-hour concentrations
(direct output of the model) were multiplied by the applicable time
correction factors for each pollutant and respective averaging times.
These values were then evaluated with respect to the respective signi-
ficant impact levels listed in Table 1. The radius of significant
impact (pollutant specific) was then ascertained. This radius was
calculated to be the greatest distance at which the air quality impact
equalled the significant impact level. In most cases, a linear extra-
polation of two adjacent concentrations/distances, one being above and
one being below significant impact levels was necessary.
SCENARIO 2 - PTDIS
(a) Distances (beginning with the distances predicted by PTMAX
and extending out to 50 km)
(b) Source parameters (identical to PTMAX)
(c) Meteorological (identical to PTMAX)
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Output
(a) Distance (user specified)
(b) Associated one-hour concentrations
In some instances, PTMAX did not provide sufficient information to
determine the radius of significant impact due to the fact that maxi-
mum concentrations sometimes exceeded significant levels at the
greatest distance analyzed. For these cases, PTDIS was run. As in
PTMAX, the one-hour concentrations were multiplied by the applicable
time correction factors for each pollutant and respective averaging
times. Again, these values were evaluated with respect to the respec-
tive significant impact levels listed in Table 1. The radius of
impact was then calculated to be the greatest distance at which the
air quality impact equalled the significance levels.
SCENARIO 3 - PTMTP
(a) Source parameters (per stack)
(b) Receptors (a series of downwind receptors up to 50 km - a
denser spacing nearer the source was utilized)
(c) Meteorological data (identical to PTMAX but constant wind
direction to downwind receptors)
Output
(a) One-hour concentrations
(b) Associated receptors (i.e., downwind distances)
As previously mentioned, Scenario 3 deals with multiple stack
sources. Receptor concentrations (downwind distances) must sum partial
contributions from all stacks under the same meteorological conditions.
PTMTP is equipped to handle just such conditions. Once PTMTP was run,
the one-hour concentrations (output) were subjected to the same
analyses as PTMAX output concentrations. They were multiplied by the
applicable time correction factors for each pollutant and respective
averaging times, and these values were evaluated in regard to the
respective significant impact levels listed in Table 1. From this
point on, the procedure is identical to PTDIS.
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APPENDIX V
PSD Regulation for the State of Delaware
V-l
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PACIFIC
ENVIRONMENTAL
SERVICES, INC.
LOS ANGELES. CA
CHICAGO. ILL
RESEARCH TRIANGLE PARK. N.C
WASHINGTON DC
September 12, 1980
Mr. Robert French
Department of Natural Resources and
Environmental Control
Division of Environmental Control
P.O. Box 1401
Edward Tatnall Building
Dover, Delav/are 19901
Dear Mr. French:
Enclosed please find the draft version of the PSD regulations
for the State of Delaware. Also included is the explanation
sheet detailing all necessary deletions from the August 7, 1980
Federal Register on 40 CFR 52.21. One additional regulation was
deemed necessary in Regulation XXV, Section 1. This addendum is
labeled XXY, Section 1.8. PES assembled a complete listing of
the current PSD regulations (August 7, 1980) and is included
for reference purposes.
If you need any assistance in reviewing this material, please
feel free to contact either Mr. Thomas Blaszak, or myself at
(312)530-7272.
Sincerely,
Charles J. Mackus
Midwest Operations Division
CJM/11/453
Enc.
cc: Robert Blaszczak, Region III (without enc.)
MIDWEST OPERATIONS 465 Fuilerton Ave Elmhurst, ILL 60126 (312) 530-7272
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Section 3 - Prevention of Significant Deterioration of Air Quality
3.1 Definitions - For the purposes of this section:
A. "Major Stationary Source"
(1) Major stationary source means:
(i) Any of the following stationary sources of air
pollutants which emits or has the potential to
emit, 100 tons per year or more of any pollutant
subject to regulation under the CAA: Fossil fuel-
fired steam electric plants of more than 250
million British thermal units per hour heat input,
coal cleaning plants (with thermal dryers), kraft
pulp mills, portland cement plants, primary zinc
smelters, iron and steel mill plants, primary
aluminum ore reduction plants, primary copper smel-
ters, municipal incinerators capable of charging
more than 250 tons of refuse per day, hydrofluoric,
sulfuric, and nitric acid plants, petroleum re-
fineries, 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 more
than 250 million British thermal units per hour
heat input, petroleum storage and transfer units
with a total storage capacity exceeding 300,000
barrels, taconite ore processing plants, glass
fiber processing plants, and charcoal production
plants;
(ii) Notwithstanding the stationary source size speci-
fied in paragraph 3.1A(1) of this section, any
stationary source which emits, or has the potential
to emit, 250 tons per year or more of any air
pollutant subject to regulation under the CAA; or
(iii) Any physical change that would occur at a station-
ary source not otherwise qualifying under paragraph
3.1A as a major stationary source, if the change
would constitute a major stationary source by
itself.
(2) A major stationary source that is major for volatile
organic compounds shall be considered major for ozone.
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B. "Major Modification"
(1) Major modification means any physical change or change
in the method of operation of a major stationary source
that would result in a significant net emissions in-
crease of any pollutant subject to regulation under the
CAA.
(2) Any net emissions increase that is significant for vola-
tile organic compounds shall be considered significant
for ozone.
(3) A physical change or change in the method of operation
shall not include:
(i) Routine maintenance, repair and replacement;
(ii) Use of an alternative fuel or raw material by rea-
son of an order under sections 2(a) and (b) of the
Energy Supply and Environmental Coordination Act of
1974 (or any superseding legislation) or by reason
of a natural gas curtailment plan pursuant to the
Federal Power Act;
(iii) Use of an alternative fuel by reason of an order or
rule under section 125 of the CAA;
(iv) Use of an alternative fuel at a steam generating
unit to the extent that the fuel is generated from
municipal solid waste;
(v) Use of an alternative fuel or raw material by a
stationary source which:
(a) The source was capable of accomodating before
January 6, 1975, unless such change would be
prohibited under any previously issued permit
condition which was established after January
6, 1975.
(b) The source is approved to use under any pre-
viously issued PSD permit or under Regulation
XXV, Section 3.
(vi) An increase in the hours of operation or in the
production rate, unless such change would be pro-
hibited under any previously issued permit condi-
tion which was established after January 6, 1975;
(vii) Any change in ownership at a stationary source.
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C. "Net Emissions Increase"
(1) Net emissions increase means the amount by which the sum
of the following exceeds zero:
(i) Any increase in actual emissions from a particular
physical change or change in method of operation at
a stationary source; and
(ii) Any other increases and decreases in actual emis-
sions at the source that are contemporaneous with
the particular change and are otherwise creditable.
(2) An increase or decrease in actual emissions is contem-
poraneous with the increase from the particular change
only if it occurs between:
(i) The date five years before construction on the
particular change commences; and
(ii) The date that the increase from the particular
change occurs.
(3) An increase or decrease in actual emissions is credit-
able only if the Department has not relied on it in
issuing a permit for the source under this section,
which permit is in effect when the increase in actual
emissions from the particular change occurs.
(4) An increase or decrease in actual emissions of sulfur
dioxide or particulate matter which occurs before the
applicable baseline date is creditable only if it is
required to be considered in calculating the amount of
maximum allowable increases remaining available.
(5) An increase in actual emissions is creditable only to
the extent that the new level of actual emissions ex-
ceeds the old level.
(6) A decrease in actual emissions is creditable only to the
extent that:
(i) The old level of actual enrissons or the old level
of allowable emissions, whichever is lower, exceeds
the new level of actual emissions;
(ii) It is enforceable at and after the time that actual
contruction on the particular change begins; and
(iii) It has approximately the same qualitative signifi-
cance for public health and welfare as that attri-
buted to the increase from the particular change.
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(7) An increase that results from a physical change at a
source occurs when the emissions unit on which construc-
tion occurred becomes operational and begins to emit a
particular pollutant. Any replacement unit that re-
quires shakedown becomes operational only after a rea-
sonable shakedown period, not to exceed 180 days.
D. "Potential to Emit" means the maximum capacity of a station-
ary source to emit a pollutant under its physical and opera-
tional design. Any physical or operational limitation on the
capacity of the source to emit a pollutant, including air
pollution control equipment and restrictions on hours of
operation or on the type or amount of material combusted,
stored, or processed, shall be treated as part of its design
if the limitation or the effect it would have on emissions is
enforceable. Secondary emissions do not count in determining
the potential to emit of a stationary source.
E. "Stationary Source" means any building, structure, facility,
or installation which emits or may emit any air pollutant
subject to regulation under the CAA.
F. "Building, Structure, Facility, or Installation" means all of
the pollutant-emitting activities which belong to the same
industrial grouping, are located on one or more contiguous or
adjacent properties, and are under the control of the same
person (or persons under common control). Pollutant-emitting
activities shall be considered as part of the same industrial
grouping if they belong to the same "Major Group" (i.e.,
which have the same first two digit code) as described in the
Standard Industrial Classification Manual, 1972, as amended
by the 1977 Supplement (U.S. Government Printing Office stock
numbers 4101-0066 and 003-005-00176-0, respectively).
G. "Emissions Unit" means any part of a stationary source which
emits or would have the potential to emit any pollutant sub-
ject to regulation under the CAA.
H. "Construction" means any physical change or change in the
method of operation (including fabrication, erection, instal-
lation, demolition, or modification of an emissions unit)
which would result in a change in actual emissions.
I. "Commence" as applied to construction of a major stationary
source or major modification means that the owner or operator
has all necessary preconstruction approvals or permits and
either has:
(1) Begun, or caused to begin, a continuous program of
actual on-site construction of the source, to be com-
pleted within a reasonable time; or
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(2) Entered into binding agreements or contractual obliga-
tions, which cannot be cancelled or modified without
substantial loss to the owner or operator, to undertake
a program of actual construction of the source to be
completed within a reasonable time.
J. "Necessary Reconstruction Approvals or Permits" means those
permits or approvals required under Delaware air quality
control laws and regulations.
K. "Begin Actual Construction" means, in general, initiation of
physical on-site construction activities on an emissions unit
which are of a permanent nature. Such activities include,
but are not limited to, installation of building supports and
foundations, laying underground pipework and construction of
permanent storage structures. With respect to a change in
method of operations, this term refers to those on-site acti-
vities other than preparatory activities which mark the ini-
tiation of the change.
L. "Best Available Control Technology" means an emissions limi-
tation (including a visible emission standard) based on the
maximum degree of reduction for each pollutant subject to
regulation under CAA which would be emitted from any proposed
major stationary source or major modification which the De-
partment, on a case-by-case basis, takes into account energy,
environmental, and economic impacts and other costs, deter-
mines is achievable for such source or modification through
application of production processes or available methods,
systems, and techniques, including fuel cleaning or treatment
or innovative fuel combustion techniques for control of such
pollutant. In no event shall application of best available
control technology result in emissions of any pollutant which
would exceed the emissions allowed by any applicable standard
under Regulation XX and XXI. If the Department 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
requirement for the application of best available control
technology. Such 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.
M. "Baseline Concentration"
(1) Baseline concentration means that ambient concentration
level which exists in the baseline area at the time of
the applicable baseline date. A baseline concentration
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is determined for each pollutant for which a baseline
date is established and shall include:
(i) The actual emissions representative of sources in
existence on the applicable baseline date, except
as provided in paragraph 3.1M(2);
(ii) The allowable emissions of major stationary sources
which commenced construction before January 6,
1975, but were not in operation by the applicable
baseline date.
(2) The following will not be included in the baseline con-
centration and will affect the applicable maximum allow-
able increase(s):
(i) Actual emissions from any major stationary source
on which construction commenced after January 6,
1975; and
(ii) Actual emissions increases and decreases at any
stationary source occurring after the baseline date.
N. "Baseline Date"
(1) Baseline date means the earliest date after August 7,
1977, on which the first complete application is sub-
mitted by a major stationary source or major modifica-
tion subject to the requirements of Regulation XXV,
Section 3.
(2) Baseline date means the earliest date after August 7,
1977, but before the effective date of this regulation,
on which the first complete application by a major
stationary source or major modification which would have
been subject to the requirements of Regulation XXV,
Section 3 if the application were submitted after the
effective date of this regulation.
(3) The baseline date is established for each pollutant for
which increments or other equivalent measures have been
established if:
(i) The area in which the proposed source or modifica-
tion would construct is designated as attainment or
unclassifiable for the pollutant on the date of its
complete application under this section; and
(ii) In the case of a major stationary source, the
pollutant would be emitted in significant amounts,
or, in the case of a major modification, there
would be a significant net emissions increase of
the pollutant.
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0. "Baseline Area"
(1) Baseline area means any intrastate area (and every part
thereof) designated as attainment or unclassifiable in
which the major source or major modification establishing
the baseline date would construct or would have an air
quality impact equal to or greater than 1 ug/m^ (annual
average) of the pollutant for which the baseline date is
established.
(2) Area redesignations cannot intersect or be smaller than
the area of impact of any major stationary source or
major modification which:
(i) Establishes a baseline date, or
(11) Is subject to this section.
P. "Allowable Emissions" means the emissions rate of a stationary
source calculated using the maximum rated capacity of the
source (unless the source is subject to enforceable limits
which restrict the operating rate, or hours of operation, or
both) and the most stringent of the following:
(1) The applicable standards as set forth in Regulations XX
and XXI;
(2) Other applicable Delaware State Implementation Plan
emissions limitations, including those with a future
compliance date; or
(3) The emissions rate specified as an enforceable permit
condition, including those with a future compliance date.
Q. "Secondary Emissions" means emissions which would occur as a
result of the construction or operation of a major stationary
source or major modification, but do not come from the major
stationary source or major modification itself. For the
purpose of this section, secondary emissions must be speci-
fic, well defined, quantifiable, and impact the same general
area as the stationary source or modification which causes
the secondary emissions. Secondary emissions may include,
but are not limited to:
(1) Emissions from ships, trains, or other vehicles coming
to or from the new or modified stationary source; and
(2) Emissions from any offsite support facility(s) which
would not otherwise be constructed or increase its
emissions as a result of the construction or operation
of the major stationary source or major modification.
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R. "Innoyative Control Technology" means any system of air
pollution control that has not been adequately demonstrated
in practice, but would have a substantial likelihood of
achieving greater continuous emissions reduction than any
control system in current practice or of achieving at least
comparable reductions at lower cost in terms of energy econo-
mics, or non-air quality environmental impacts.
S. "Fugitive Emissions" means those emissions which could not
reasonably pass through a stack, chimney, vent, or other
functionally equivalent opening.
T. "Actual Emissions"
(1) Actual emissions means the actual rate of emissions of a
pollutant from an emissions unit, as determined in
accordance with subparagraphs (2) through (4) below.
(2) In general, actual emissions as of a particular date
shall equal the average rate, in tons per year, at which
the unit actually emitted the pollutant during a two-
year period which precedes the particular date and which
is representative of normal source operation. The
Department shall allow the use of a different time
period upon a determination that it is more representa-
tive of normal source operation. Actual emissions shall
be calculated using the unit's actual operating hours,
production rates, and types of materials processed,
stored, or combusted during the selected time period.
(3) The Department may presume that source-specific allow-
able emissions for the unit are equivalent to the actual
emissions of the unit.
(4) For any emissions unit which has not begun normal opera-
tions on the particular date, actual emissions shall
equal the potential to emit of the unit on that date.
U. "Complete" means, in reference to an application for a per-
mit, that the application contains all of the information
necessary for processing the application.
V. "Significant"
(1) Significant means, in reference to a net emissions in-
crease or the potential of a source to emit any of the
following pollutants, a rate of emissions that would
equal or exceed any of the following rates:
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Pollutant and Emissions Rate
Carbon monoxide: 100 tons per year (TRY)
Nitrogen oxides: 40 TRY
Sulfur dioxide: 40 TRY
Part icu late matter: 25 TRY
Ozone: 40 TRY of volatile organic compounds
Lead: 0.6 TRY
Asbestos: 0.007 TRY
Beryllium: 0.0004 TRY
Mercury: 0.1 TRY
Vinyl chloride: 1 TRY
Fluorides: 3 TRY
Sulfuric acid mist: 7 TRY
Hydrogen sulfide (HgS): 10 TRY
Total reduced sulfur (including H2$): 10 TRY
Reduced sulfur compounts (including ^S): 10 TRY
(2) "Significant" means, in reference to a net emissions
increase or the potential of a source to emit a pollu-
tant subject to regulation under the CAA that paragraph
3.1V(1) does not list, any emissions rate.
(3) Notwithstanding paragraph 3.1V(1), "significant" means
any emissions rate or any net emissions increase asso-
ciated with a major stationary source or major modifica-
tion, which would construct within ten kilometers of a
Class I area, and have an impact on such area equal to
or greater than 1 ug/m^, (24-hour average).
3.2 Ambient Air Increments. In areas designated as Class I, II or
III, increases in pollutant concentration over the baseline con-
centration shall be limited to the following:
Maximum allowable increase
(Micrograms per cubic meter)
Class I
Pollutant
Part icu late matter:
Annual geometric mean 5
24-hour maximum 10
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Class I
Sulfur dioxide:
Annual arithmetic mean 2
24-hour maximum 5
3-hour maximum 25
Class II
Pollutant
Particulate matter:
Annual geometric mean 19
24-hour maximum 37
Sulfur dioxide:
Annual arithmetic 20
24-hour maximum 91
3-hour maximum 512
Class III
Particulate matter:
Annual geometric mean 37
24-hour maximum 75
Sulfur dioxide:
Annual arithmetic mean 40
24-hour maximum 182
3-hour maximum 700
For any period other than an annual period, the applicable maxi-
mum allowable increase may be exceeded during one such period per
year at any one location.
3.3 Ambient Air Ceilings. No concentration of a pollutant shall
exceed:
A. The concentration permitted under the national secondary
ambient air quality standard, or
B. The concentration permitted under the national primary am-
bient air quality standard, whichever concentration is lowest
for the pollutant for a period of exposure.
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3.4 Restrictions on Area Classifications.
A. All Areas in the State of Delaware are designated Class II,
but may be redesignated as provided in 40 CFR 52.51(g).
B. The following areas may be redesignated only as Class I:
(1) Bombay Hook National Wildlife Refuge; and
(2) A national park or national wilderness area established
after August 7, 1977 which exceeds 10,000 acres in size.
3.5 Exclusions from Increment Consumption.
A. Upon written request of the governor, made after notice and
opportunity for at least one public hearing to be held in
accordance with procedures established by the State of Dela-
ware, the Department shall exclude the following concentra-
tions in determining compliance with a maximum allowable
increase:
(1) Concentrations attributable to the increase in emissions
from stationary sources which have converted from the
use of petroleum products, natural gas, or both by rea-
son of an order in effect under sections 2(a) and (b) of
the Energy Supply and Environmental Coordination Act of
1974 (or any superseding legislation) over the emissions
from such sources before the effective date of such an
order;
(2) Concentrations attributable to the increase in emissions
from sources which have converted from using natural gas
by reason of a natural gas curtailment plan in effect
pursuant to the Federal Power Act over the emissions
from such sources before the effective date of such plan;
(3) Concentrations of particulate matter attributable to the
increase in emissions from construction or other tempor-
ary emission-related activities of new or modified
sources;
B. No exclusion of such concentrations shall apply more than
five years after the effective date of the order to which
paragraph 3.5A(1) refers or the plan to which paragraph
3.5A(2) refers, whichever is applicable. If both such order
and plan are applicable, no such exclusion shall apply more
than five years after the later of such effective dates.
3.6 Stack Heights
A. The degree of emission limitation required for control of any
air pollutant under this section shall not be affected in any
wanner by:
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(1) So much of the stack height of any source as exceeds
good engineering practice, or
(2) Any other dispersion technique.
B. Paragraph 3.6A of this section shall not apply with respect
to stack heights in existence before December 31, 1970, or to
dispersion techniques implemented before then.
3.7 Review of Major Stationary Sources and Major Modifications -
Source Applicability and Exemptions.
A. No stationary source or modification to which the require-
ments of paragraphs 3.8 through 3.15 of this section apply
shall begin actual construction without a permit which states
that the stationary source or modification would meet those
requirements. The Department has authority to issue any such
permit.
B. The requirements of paragraphs 3.8 through 3.15 of this sec-
tion shall apply to any major stationary source and any major
modification with respect to each pollutant subject to regu-
lation under the CAA that it would emit, except as this sec-
tion otherwise provides.
C. The requirements of paragraphs 3.8 through 3.15 of this sec-
tion apply only to any major stationary source or major modi-
fication that would be constructed in an area designated as
attainment or unclassifiable.
D. The requirements of paragraphs 3.8 through 3.15 of this sec-
tion shall not apply to a particular major stationary source
or major modification, if:
(1) The source or modification would be a nonprofit health
or nonprofit educational institution, or a major modifi-
cation would occur at such an institution, and the
governor requests that it be exempt from those require-
ments; or
(2) The source or modification would be a major stationary
source or major modification only if fugitive emissions,
to the extent quantifiable, are considered in calcu-
lating the potential to emit of the stationary source or
modification and the source does not belong to any of
the following categories:
(i) Coal cleaning plants (with thermal dryers);
(ii) Kraft pulp mills;
(iii) Portland cement plants;
(iv) Primary zinc smelters;
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• (v) Iron and steel mills;
• (vi) Primary aluminum ore reduction plants;
(vii) Primary copper smelters;
I (viii) Municipal incinerators capable of charging more
than 250 tons of refuse per day;
I (ix) Hydrofluoric, sulfuric, or nitric acid plants;
(x) Petroleum refineries;
I (xi) Lime plants;
• (xii) Phosphate rock processing plants;
(xiii) Coke oven batteries;
I (xiv) Sulfur recovery plants;
(xv) Carbon black plants (furnace process);
I (xvi) Primary lead smelters;
• (xvii) Fuel conversion plants;
(xviii) Sintering plants;
I (xix) Secondary methal production plants;
(xx) Chemical process plants;
| (xxi) Fossil-fuel boilers (or combination thereof)
totaling more than 250 million British thermal
• units per hour heat input;
(xxii) Petroleum storage and transfer units with a total
storage capacity exceeding 300,000 barrels;
' (xxiii) Taconite ore processing plants;
• (xxiv) Glass fiber processing plants;
(xxv) Charcoal production plants
I (xxvi) Fossil fuel-fired steam electric plants or more
than 250 million British thermal units per hour
heat input;
• (xxvii) Any other stationary source category which, as of
August 7, 1980, is being regulated under sectin 111
• or 112 of the CAA; or
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(3) The source is a portable stationary source which has
previously received a permit under this section, and
(i) The owner or operator proposes to relocate the
source and emissions of the source at the new loca-
tion would be temporary; and
(ii) The emissions from the source would not exceed its
allowable emissions; and
(iii) The emissions from the source would impact no Class
I area and no area where an applicable increment is
known to be violated; and
(iv) Reasonable notice is given to the Department prior
to the relocation identifying the proposed new
location and the probable duration of operation at
the new location. Such notice shall be given to
the Department not less than ten days in advance of
the proposed relocation unless a different time
duration is previously approved by the Department.
E. The requirements of paragraphs 3.8 through 3.15 of this sec-
tion shall not apply to a major stationary source or major
modification with respect to a particular pollutant if the
owner or operator demonstrates that, as to that pollutant,
the source or modification is located in an area designated
as non-attainment.
F. The requirements of paragraphs 3.9, 3.11, and 3.13 of this
section shall not apply to a major stationary source or major
modification with respect to a particular pollutant, if the
allowable emissions of that pollutant from the source, or the
net emissions increase of that pollutant from the modifica-
tion:
(1) Would impact no Class I area and no area where an appli-
cable increment is known to be violated, and
(2) Would be temporary.
G. The Department may exempt a stationary source or modification
from the requirements of paragraph 3.11 with respect to moni-
toring for a particular pollutant if:
(1) The emissions increase of the pollutant from the new
source or the net emissions increase of the pollutant
from the modification would cause, in any area, air
quality impacts less than the following amounts:
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Carbon monoxide: 575 ug/m , 8-hour average;
Nitrogen dioxide: 14 ug/m , annual average;
3
Total suspended particulate: 10 ug/m , 24-hour average;
3
Sulfur dioxide: 13 ug/m , 24-hour average;
Ozone
3
Lead: 0.1 ug/m , 24-hour average;
Mercury: 0.25 ug/m , 24-hour average;
Beryllium: 0.0005 ug/m , 24-hour average;
Fluorides: 0.25 ug/m , 24-hour average;
3
Vinyl chloride: 15 ug/m , 24-hour average;
Total reduced sulfur: 10 ug/m , 1-hour average;
Hydrogen sulfide: 0.04 ug/m , 1-hour average;
Reduced sulfur compounds: 10 ug/m-3, 1-hour average; or
(2) The concentrations of the pollutant in the area that the
source or modification would affect are less than the
concentrations listed in paragraph 3.7G(1), or the
pollutant is not listed in paragraph 3.76(1).
3.8 Control Technology Review
A. A major stationary source or major modification shall meet
each applicable emissions limitation of the State of Dela-
ware's Air Pollution Control Regulations.
B. A new major stationary source shall apply best available
control technology for each pollutant subject to regulation
under the CAA that it would have the potential to emit in
significant amounts.
C. A major modification shall apply best available control tech-
nology for each pollutant subject to regulation under the CAA
for which it would result in a significant net emissions
increase at the source. This requirement applies to each
No de minimis air quality level is provided for ozone. However,
any net increase of 100 tons per year or more of volatile organic
compounds subject to PSD would be required to perform an ambient
impact analysis including the gathering of ambient air quality data.
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proposed emissions unit at which a net emissions increase in
the pollutant would occur as a result of a physical change
or change in the method of operation in the unit.
D. For phased construction projects, the determination of best
available control technology shall be reviewed and modified
as appropriate at the latest reasonable time which occurs no
later than 18 months prior to commencement of construction
of each independent phase of the project. At such time, the
owner or operator of the applicable stationary source may be
required to demonstrate the adequacy of any previous deter-
mination of best available control technology for the source.
3.9 Source Impact Analysis. The owner or operator of the proposed
source or modification shall demonstrate that allowable emission
increases from the proposed source or modification, in conjunc-
tion with all other applicable emissions increases or reductions
(including secondary emissions), would not cause or contribute
to air pollution in violation of:
A. Any national ambient air quality standard in any air quality
control region; or
B. Any applicable maximum allowable increase over the baseline
concentration in any area.
3.10 Air Quality Models.
A. All estimates of ambient concentrations required under this
section shall be based on the applicable air quality models,
data bases, and other requirements specified in the "Guide-
line on Air Quality Models" (OAQPS 1.2-080, U.S. Environmen-
tal Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, N.C. 27711, April, 1978
or its subsequent revisions). This document is incorporated
by reference.
B. Where an air quality impact model specified in the "Guide-
line on Air Quality Models" is inappropriate, the model may
be modifed or another model substituted. Such a change must
be subject to notice and opportunity for public comment
under paragraph 3.15 of this section. Written approval of
the Department must be obtained for any modification or
substitution. Methods like those outlined in the "Workbook
for the Comparison of Air Quality Models" (U.S. Environmen-
tal Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, N.C. 17711, May, 1978 or
its subsequent revisions) should be used to determine the
comparability of air quality models.
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3.11 Air Quality Analysis.
A. Preapplication Analysis.
(1) Any application for a permit under this section shall
contain an analysis of ambient air quality in the area
that the major stationary source or major modification
would affect for each of the following pollutants:
(i) For the source, each pollutant that it would have
the potential to emit in a significant amount;
(ii) For the modification, each pollutant for which it
would result in a significant net emissions in-
crease.
(2) With respect to any such pollutant for which no National
Ambient Air Quality Standard exists, the analysis shall
contain such air quality monitoring data as the Depart-
ment determines is necessary to assess ambient air
quality for that pollutant in any area that the emis-
sions of that pollutant would affect.
(3) With respect to any such pollutant (other than non-
methane hydrocarbons) for which such a standard does
exist, the analysis shall contain continuous air
quality monitoring data gathered for purposes of deter-
mining whether emissions of that pollutant would cause
or contribute to a violation of the standard or any
maximum allowable increase.
(4) In general, the continuous air quality monitoring data
that is required shall have been gathered over a period
of at least one year and shall represent at least the
year preceeding receipt of the application, except that,
if the Department determines that a complete and ade-
quate analysis can be accomplished with monitoring data
gathered over a period shorter than one year (but not
to be less than four months), the data that is required
shall have been gathered over at least that shorter
period.
(5) The owner or operator of a proposed stationary source
or modification of volatile organic compounds who
satisfies all of the following conditions may provide
post-approval monitoring data for ozone in lieu of
providing preconstruction data as required under para-
graph 3.11A.
Condition 1: The new source is required to meet an
emission limitation which specifies the
lowest achievable emission rate for such
source.
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Condition 2:
Condition 3:
Condition 4:
The applicant must certify that all
existing major sources owned or operated
by the applicant (or any entity con-
trolling, controlled by, or under common
control with the applicant) in Delaware
are in compliance with all applicable
emission limitations and standards under
the CAA (or are in compliance with an
expeditious schedule approved by the
Department).
Emission reductions ("offsets") from
existing sources in the area of the pro-
posed source (whether or not under the
same ownership) are required such that
there will be reasonable progress toward
attainment of the applicable NAAQS. Only
intrapollutant emission offsets will be
acceptable (e.g., hydrocarbon increases
may not be offset against SC^ reduc-
tions).
The emission offsets will provide a
positive net air quality benefit in the
affected area (see 40 CFR Part 51 App. S).
Atmospheric simulation modeling is not
necessary for volatile organic compounds
and NOX. Fulfillment of Condition 3
will be considered adequate to meet this
condition for volatile organic compounds
and NOX..
B. Post-construction monitoring. -The owner or operator of a
major stationary source or major modification shall, after
construction of the stationary source or modification con-
duct such ambient monitoring as the Department determines is
necessary to determine the effect emissions from the sta-
tionary source or modification may have, or are having, on
air quality in any area.
C. Operations of monitoring stations. The owner or operator of
a major stationary source or major modification shall meet
the Quality Assurance Requirements for PSD Air Monitoring as
preapproved by the Department during the operation of
monitoring stations for purposes of satisfying paragraph
3.11 of this section.
3.12 Source Information. The owner or operator of a proposed source
or modification shall submit all information necessary to per-
form any analysis or make any determination required under this
section.
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A. With respect to a source or modification to which paragraphs
3.9, 3.11, and 3.13 of this section apply, such information
shall include but not be limited to:
(1) A description of the nature, location, design capacity,
and typical operating schedule of the source or modifi-
cation, including specifications and drawings showing
its design and plant layout;
(2) A detailed schedule for construction of the source or
modification;
(3) A detailed description as to what system of continuous
emission reduction is planned for the source or modifi-
cation, emission estimates, and any other information
necessary to determine that best available control
technology would be applied.
B. Upon request of the Department, the owner or operator shall
also provide information on:
(1) The air quality impact of the source or modification,
including meteorological and topographical data neces-
sary to estimate such impact; and
(2) The air quality impacts, and the nature and extent of
any or all general commercial, residential, industrial,
and other growth which has occurred since August 7,
1977 or the applicable baseline date(s), in the area
the source or modification would affect.
3.13 Additional Impact Analyses.
A. The owner or operator shall provide an analysis of the
impairment to visibility, soils and vegetation that would
occur as a result of the source or modification and general
commercial, residential, industrial and other growth asso-
ciated with the source or modification. The owner or opera-
tor need not provide an analysis of the impact on vegetation
having no significant commercial or recreational value.
B. The owner or operator shall provide an analysis of the air
quality impact projected for the area as a result of general
commercial, residential, industrial and other growth asso-
ciated with the source or modification.
3.14 Public Participation.
A. Within 30 days after receipt of an application to construct,
or any addition to such application, the Department shall
advise the applicant of any deficiency in the application or
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in the information submitted. In the event of such a defi-
ciency, the date of receipt of the application shall be, for
the purpose of this section, the date on which the Depart-
ment received all required information.
B. Within one year after receipt of a complete application, the
Department shall make a final determination on the applica-
tion. This involves performing the following actions in a
timely manner:
(1) Make a preliminary determination whether construction
should be approved, approved with conditions, or dis-
approved.
(2) Make available a copy of all materials the applicant
submitted, a copy of the prelininary determination, and
a copy or summary of other materials, if any, consi-
dered in making the preliminary determination.
(3) Notify the public, by advertisement in a newspaper of
general circulation in each region in which the pro-
posed source or modification would be constructed, of
the application, the preliminary determination, the
degree of increment consumption that is expected from
the source or modification, and the opportunity for
comment at a public hearing as well as written public
comment.
(4) Send a copy of the notice of public comment to the
applicant and to officials and agencies having cog-
nizance over the location where the proposed construc-
tion would occur as follows: the chief executives of
the city and county where the source or modification
would be located and any comprehensive regional land
use planning agency whose lands may be affected by
emissions from the source or modification. Addi-
tionally, if the proposed source would have significant
interstate impact, the Governor of that impacted state
would be notified.
(5) Provide opportunity for a public hearing for interested
persons to appear and submit written or oral cownents
on the air quality impact of the source or modifica-
tion, alternatives to the source or modification, the
control technology required, and other appropriate
considerations.
(6) Consider all written comments submitted within a time
specified in the notice of public comment and all com-
ments received at any public hearing(s) in making a
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1C. Approval to construct shall not relieve any owner or opera-
tor of the responsibility to comply fully with applicable
provisions of any other requirements under local or Federal
_ law.
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final decision on the approvability of the applica-
tion. No later than ten days after the close of the
public comment period, the applicant may submit a
written response to any comments submitted by the pub-
lic. The Department shall consider the applicant's
response in making a final decision. The Department
shall make all comments available for public inspection
in the same locations where the Department made avail-
able preconstruction information relating to the pro-
posed source or modification.
(7) Make a final determination whether construction should
be approved, approved with conditions, or disapproved
pursuant to this section.
(8) Notify the applicant in writing of the final determina-
tion and make such notification available for public
inspection at the same location where the Department
made available preconstruction information and public
comments relating to the source or modification.
3.15 Source Obligation.
A. Any owner or operator who constructs or operates a source or
modification not in accordance with the application sub-
mitted pursuant to this section or with the terms of any
approval to construct, or any owner or operator of a source
or modification subject to this section who commences con-
struction after the effective date of these regulations
without applying for and receiving approval hereunder, shall
be subject to appropriate enforcement action.
B. Approval to construct shall become invalid if construction
is not commenced with 18 months after receipt of such
approval, if construction is discontinued for a period of 18
months or more, or if construction is not completed within a
reasonable time. The Department may extend the 18-month
period upon a satisfactory showing that an extension is
justified. This provision does not apply to the time period
between construction of the approved phases of a phased con-
struction project; each phase must commence construction
within 18 months of the projected and approved commencement
date.
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D. At such time that a particular source or modification be-
comes a major stationary source or major modification solely
by virtue of a relaxation in any enforceable limitation
which was established after August 7, 1980, on the capacity
of the source or modification otherwise to emit a pollutant,
such as a restriction on hours of operation, then the re-
quirements or paragraphs 3.8 through 3.15 of this section
shall apply to the source or modification as though con-
struction had not yet commenced on the source or modifica-
tion.
3.16 Innovative Control Technology
A. An owner or operator of a proposed major stationary source
or major modification may request the Department in writing
no later than 30 days after the close of the public comment
period to approve a system of innovative control technology.
B. The Department shall, with the consent of the Governor of
Delaware, determine that the source or modification may
employ a system of innovative control technology, if:
(1) The proposed control system would not cause or contri-
bute to an unreasonable risk to public health, welfare,
or safety in its operation or function;
(2) The owner or operator agrees to achieve a level of
continuous emissions reduction equivalent to that which
would have been required under paragraph 3.8B by a date
specified by the Department. Such date shall not be
later than four years from the time of startup or seven
years from permit issuance;
(3) The source or modification would meet the requirements
of paragraphs 3.8 and 3.9 based on the emissions rate
that the stationary source employing the system of
innovative control technology would be required to meet
on the date specified by the Department;
(4) The source or modification would not before the date
specified by the Department:
(i) Cause or contribute to a violation of an appli-
cable national ambient air quality standard; or
(ii) Impact any Class I area; or
(iii) Impact any area where an applicable increment is
known to be violated; and
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(5) All other applicable requirements including those for
public participation have been met.
C. The Department shall withdraw any approval to employ a
system of innovative control technology made under this
section, if:
(1) The proposed system fails by the specified date to
achieve the required continuous emissions reduction
rate; or
(2) The proposed system fails before the specified date so
as to contribute to an unreasonable risk to public
health, welfare, or safety; or
(3) The Department decides at any time that the proposed
system is unlikely to achieve the required level of
control or to protect the public health, welfare, or
safety.
D. If a source or modification fails to meet the required level
of continuous emission reduction within the specified time
period or the approval is withdrawn in accordance with para-
graph 3.16C, the Department may allow the source or modifi-
cation up to an additional three years to meet the require-
ment for the application of best available control tech-
nology through use of a demonstrated system of control.
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AMENDMENT TO REGULATION XXV
SECTION 1
1.8 Any stationary source that implements, for the purpose of gaining
relief from Regulation XXV, Section 3, by any physical or opera-
tional limitation on the capacity of the source to emit a pollu-
tant, including (but not limited to) air pollution control
equipment and restrictions on hours of operation or on the type
or amount of material combusted, stored, or processed, shall be
treated as part of its design and the limitation or the effect
it would have on emissions is enforceable, not withstanding any
emission limit specified elsewhere in the State of Delaware
Regulations Governing the Control of Air Pollution. If a source
petitions the Department for relief from any resulting limita-
tion described above, the source is subject to review under
Regulation XXV, Sections 2 and 3 as though construction had not
yet commenced on the source or modification.
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Section
40 CFR 52.21 (a)
(b)(17)
(b)(24)
(b)(25)
(b)(26)
(b)(27)
(b)(28)
(e)(l)
and (2)
(f)(l)(
(f)U)(
DELETIONS
Reason
applies to federal enforcement of PSD in
States that do not have approved PSD regula-
tions in their SIP.
definition of federally enforceable, therefore
irrelevant to SIP.
definition of Federal Land Manager - No
Federal land managers
definition of High Terrain - none in State
definition of Low Terrain - inapplicable since
(b)(25) is deleted.
definition of Indian Reservation - none in
State.
definition of Indian Governing Body - none in
State.
restrictions describe mandatory Class I areas.
There are none in the State of Delaware.
iv) no services outside of U.S. contribute to
Delaware's air quality.
v) this exclusion refers to temporary increases
which result from SIP revisions which would
allow a source to be uncontrolled (or lesser
controlled) while the new control equipment is
being installed. For the following reasons it
had been dropped:
(1) Such exclusion could not exceed two
years and requires extensive public
participation procedures.
(2) The increment becomes available after
the temporary emissions cease and there
would be no long term effect on incre-
ment consumption.
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(f)(3) refers to (f)(l)(v) only which has been drop-
ped.
(g) redesignation - Not applicable to this SIP
submittal since this section refers to subse-
quent SIP revisions. It has, however, been
incorporated by reference in XXV (3.4).
(i)(4) Grandfather clause for old Federal PSD regula-
tions. Not needed since Delaware did not have
previous PSD regulations.
(i)(9) same as above.
(m)(l)(v) Grandfather and transition period for air
quality monitoring requirements. In light of
effective date of Delaware regulations, no
sources are likely affected.
(p) deleted since there are no Federal Class I
areas in the State. Should one be created in
the future, this section would be required as
a SIP revision.
(s) deleted Environmental Impact Statement re-
quirements.
(t) deleted since there are no Indian Governing
Bodies in the state.
(u) no delegations needed since Delaware has no
"local" agencies.
(w) permit revisions will apply only to previously
issued Federally granted PSD Permits.
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I APPENDIX W
•Response to Public Comments Regarding the
State of Delaware PSD Regulation
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LOS ANGELES, CA
CHICAGO, ILL
RESEARCH TWANGLE PARK. NC
WASHINGTON DC
PACIFIC
ENVIRONMENTAL
SERVICES, INC.
November 25, 1980
Mr. Robert French
Department of Natural Resources
and Environmental Control
P.O. Box 1401
Edward Tatnall Building
Dover, Delaware 19901
Dear Mr. French:
In regard to the public comment received by your office on October 31,
1980 concerning the deletion of Section 51.24 f(l)(v) from the pro-
posed Delaware PSD regulations (Regulation XXV, Section 3) (Note: in
addition to the plan revision, additional stringent conditions must be
met), there are three basic reasons this section was deleted from the
proposed regulation:
(1) This particular exclusion from increment consumption is
directly linked to "...stationary sources which are affected
by plan revisions approved by the Administrator...". This
statement necessitates the formal submittal of a SIP revision
to the U.S. EPA concerning the proposed SIP relaxation as a
necessary condition for the temporary emission to quality for
the exclusion. Since this is the case, the source (or state)
could simultaneously submit a request for a site specific
exclusion as part of the SIP revision package.
(2) Ease of tracking exclusions from increment consumption.
Since each increment consumption exclusion would become part
of the state SIP. Therefore, no confusion would exist over
questionable or borderline cases of "temporary emissions
exclusions."
(3) Finally, the deletion of this section was an effort to sim-
plify an already complex regulation.
As a practical matter, Pacific Environmental Services, Inc. believes
that the opportunity to grant an exemption under Section 51.24 f(l)(v)
is remote. Additionally, the consequences of not having the exemption
would have no long term effect on the State of Delaware, since the
increment availability returns when the temporary emissions increase
cease, at most, two years later. In the short term, two effects are
possible. First, during the two-year period during which the tempor-
ary emissions exist and consume the increment, a PSD source may be
prevented from starting up due to an increment violation (Note: con-
struction would not be delayed if planned startup was after the end
MIDWEST OPERATIONS 465 FuHerton Ave Elmhurst. ILL 60126 (312) 53O-7272
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Mr. Robert French -2- November 20, 1980
of the temporary emissions period). Generally, the entire PSO process
for a subject source takes wore than two years (i.e., from the start
of the field monitoring of air quality through the permit process,
construction, and finally startup). If a source is in the process of
a PSD application (or preparation thereof) and would be affected by
the "non-exemption" for temporary emissions, the exemption from incre-
ment consumption could be processed together with the temporary emis-
sions plan revision. In the second instance, a source requesting a
"temporary emissions" plan revision would be prevented from having it
granted because the source itself would cause an increment violation
(but still satisfy NAAQS). In this case also, the exemption from
increment consumption can be requested simultaneously with the plan
revision.
In both cases, the state retains substantial control in granting any
exemptions from increment consumption and can require the source to
demonstrate that they qualify for the exemption.
If you have any further questions concerning this matter, please feel
free to call me.
Sincerely yours,
Charles J. Mackus
Environmental Engineer
CJM/cs/453
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APPENDIX X
PSD Review Process Flowchart
X-l
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APPENDIX Y
Procedures Manual and Checklist for PSD
Review in the State of Delaware
Y-l
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EPA Contract No. 68-02-2536
Work Assignment No. 14
PROCEDURES MANUAL AND CHECKLIST FOR
PSD REVIEW IN THE STATE OF DELAWARE
Robert Blaszczak - U.S. EPA Project Officer
Robert French - Delaware Project Officer
Thomas Blaszak - Project Manager
Charles Mackus - Principal Investigator
December, 1980
Prepared for:
State of Delaware
Department of Natural Resources and Environmental Control
Edward Tatnall Building
Dover, Delaware 19901
and
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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STEP-BY-STEP OVERVIEW PROCEDURES FOR PSD REVIEW
PSD review, for the purposes of this discussion, is divided into
four independent sections: (1) Applicability; (2) Emissions Regula-
tions and BACT Review; (3) Air Quality Review, and (4) Public Partici-
pation Process. An overview flowchart of the entire PSD review pro-
cess depicting each of these sections and how they interrelate is
shown in Figure 1. In most applications, each of the first three PSD
sections can be reviewed independently of the other sections, with one
central reviewer incorporating the conclusions of each review into a
comprehensive review. It should be noted that conclusions from any
section can affect another section, especially if they do not agree
with those of the applicant. It is a good procedural policy that a
cursory review of all Sections 1, 2, and 3 be performed for complete-
ness of the application simultaneously to minimize, to the extent
possible, multiple requests for additional information. The following
checklist and discussion suggests the method by which the Delaware
agency can complete an application in a timely and efficient manner. (A
composite checklist is assembled in the Appendix).
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1.0 APPLICABILITY
Each new construction permit application should be reviewed for
PSD applicability. This review is necessary since some sources may be
subject to the PSD provisions, yet may not address the PSD require-
ments in their permit applications. This initial review should be
completed in the agency's permit section. The results of this review
will reveal the extent of agency activity that is required (i.e., PSD,
EOP, or standard NSR reviews). The overall flow diagram (see Figure
1.1) outlines the necessary review steps upon receipt of the construc-
tion permit application. The first step is to itemize and characterize
each air pollutant generated by the proposed construction. Each pollu-
tant must be quantified on a "ton per year" basis for each of the
following areas:
(1) Existing Sources - all existing air pollution points located
at the facility;
(2) Modification - all new air pollution sources (both "grass
roots" plants and modifications to existing facilities)
created as a direct result of the proposed construction
(excluding pollutants due solely to construction activities);
(3) Claimed Offsets - all internal offsets claimed by the source;
(4) Creditable Offsets - all claimed internal offsets which are
creditable and contemporaneous. Emissions are considered
creditable and contemporaneous if (a) a change in ACTUAL
EMISSIONS occurred after January 6, 1975; (b) a change
occurred within five years of actual construction; (c) the
reduction is enforceable; (d) the reductions must be qualita-
tively equivalent in their effects on public health and wel-
fare; and (e) the reduction has not been previously claimed.
(Note: When calculating offsets, increases as well as
decreases must be tabulated.)
(5) Net Increase - all of the above emission rates must be com-
bined to yield a net increase for the proposed construction
(Note: the net increase will be equal to the increase in
emissions associated with a new facility or major modifica-
tion of a non-major facility since no credits are allowed in
this case).
Note: The terms source, facility, and installation, as used in PSD,
are all synomonous. In general, these terms refer to all activities
which belong to the same industrial grouping, are located on one or
•ore contiguous or adjacent properties, and are under the control of
the same person.
1-1
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SUBMIT APPLiCATKDN
FOR NEW
STATtON*RY SOURCE
OR MODIFICATION
OF EXISTING SOURCE
DETCBMINE ALL
POLLUTANTS
GENERATED BY
FACILITY
AND MODIFICATION
REVIEW FOR
EOP
FOR ALL
SIGNIFICANT
POLLUTANTS
IS
EXISTING
SOURCE
MAJOR
IS THE
SOURCE
LOCATED
IN AN
-ATTAINME
AREA
FOR THIS
POLLUTAN
IS
NEW
SOURCE OR
MODIFICATION
MAJOR
IS
EMISSIONS
INCREASE
SIGNIFICANT
PSD
AND
EOP
DOES NOT
APPLY
PERFORM
STANDARD
NSR
. POTENTIAL EMISSIONS OF ANr
POLLUTANT £ IOO TPY FOR
NAMED SOURCES OR S 250 TPY
FOR ALL OTHERS.
PERFORM
FOR EACH
POLLUTANT
Figure 1.1 PSD APPLICABILITY DETERMINATION FLOW CHART
1-2
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Once each of the source's pollutants have been quantified as
above, the source can be characterized as major or non-major. The
first question which must be asked is whether the type of existing or
new source is one of the categories named in the regulations. If it
is one of the named sources (see Table 1-1), the 100 tons per year
potential to emit criteria applies, rather than the 250 tons per year
criteria. Potential to emit for the purposes of PSD means the Maximum
capacity of a stationary source to emit a pollutant under its physical
design (this includes air pollution equipment, restrictions in hours
of operation, etc. if those emission limitations are enforceable).
Once the source has been characterized as major, the table developed
for each pollutant must be scanned. From this point on, there are two
parallel courses which can be taken; one for existing sources and one
for new sources or major modifications.
For existing sources, a determination must be made as to whether
tne EXISTING source is major for ANY pollutant. If at least one pol-
lutant is major, it must be determined whether the NET emission
increase is significant for ANY pollutant (see Table 1-2 for levels of
significant emissions). If the answers to both questions is yes, the
attainment status of the area in which the source is located must be
determined for each significant pollutant.
For new sources or modifications, it must be determined if the new
source or modification itself is major for ANY pollutant. If at least
one pollutant is major, it must be determined if there is a signifi-
cant emission increase for ANY OTHER pollutant. For each pollutant
emitted from a major modification which answers yes to the signifi-
cance questions, the attainment status of the areas in the source's
location must be determined for those pollutants. Alternatively
speaking, for each pollutant considered major and for each pollutant
which is significant (when at least one pollutant is major), the area
attainment status must be determined.
1-3
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Table 1-1. LIST OF NAMED SOURCES
Fossil Fuel Fired Steam Electric Plants greater than or equal
to 250 million Btu/hour Heat Input
Coal Cleaning Plants (with thermal dryers)
Kraft Pulp Mills
Portland Cement Plants
Primary Zinc Smelters
Iron and Steel Mill Plants
Primary Aluminum Ore Reduction Plants
Primary Copper Smelters
Municipal Incinerators Capable of Charging greater than or
equal to 250 tons of refuse/day
Hydrofluoric, Sulfuric, and 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
250 million Btu/hour Heat Input or more
Petroleum Storage and Transfer Units with a Total Storage
Capacity Exceeding 300,000 barrels
Taconite Ore Processing Plants
61 ass Fiber Processing Plants
Charcoal Production Plants
1-4
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Table 1-2. SIGNIFICANT POLLUTANT EMISSION RATES
Carbon Monoxide: 100 TPY
Nitrogen Oxides: 40 TPY
Sulfur Dioxide: 40 TPY
Particulate Matter: 25 TPY
Ozone: 40 TPY of volatile organic compounds
Lead: 0.6 TPY
Asbestos: 0.007 TPY
Beryllium: 0.0004 TPY
Mercury: 0.1 TPY
Vinyl Chloride: 1 TPY
Fluorides: 3 TPY
Sulfuric Acid Mist: 7 TPY
Hydrogen Sulfide (H2S): 10 TPY
Total Reduced Sulfur Compounds (including H2S): 10 TPY
TPY = Tons Per Year
1-5
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If the attainment status for any of the significant pollutants is
considered "attainment" or "unclassified," each significant pollutant
must undergo the complete PSD review. In the case of pollutants which
do not have Section 107 attainment designations, attainment is assumed.
Whenever a pollutant is significant and is designated as non-attain-
ment, PSD review does not apply for that pollutant. The agency's
emission offset policy must be carefully reviewed for possible appli-
cability for that pollutant. (If neither PSD nor EOP apply, only NSR
for that pollutant is required.) If none of the source's new pollu-
tants are considered significant after all of the previous determina-
tions, the agency should perform their standard New Source Review
(NSR) for the source.
All of the information necessary for the applicability review
should be contained in the facility's application to construct and, in
the case of existing sources, by reference in Delaware's existing
permit file. The state reviewer should confirm the engineering
assumptions made in the application with respect to overall emissions.
Special consideration should be given to sources who fall just below
the size criteria set for PSD and EOP review.
The PSD, EOP, and NSR Applicability Review checklist which follows
should serve as a tool to the review agency in applying the applica-
bility criteria. This checklist (pages A-l and A-2) should be used
for each new construction/operating permit request received by the
agency, since some sources may not realize that the PSD or EOP require-
ments may apply to their application.
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2.0 REGULATION AND BACT REVIEW
Once a source has been screened and the PSD review is deemed to be
applicable, a list of all pollutants which are significant should be
assembled. Along with this compilation, each federal and state regu-
lation which applies to each pollutant must be identified. The pro-
jected compliance status with each of these regulations should be
determined (see Checklist Page B-l). Also, non-significant pollutants
should be reviewed in the same manner. If any regulation is projected
to be violated for any pollutant, a preliminary determination to deny
the application is mandated (see Figure 2.1).
Since annual emission rates determine if PSD review applies, all
control methods must be scrutinized as to practicability and enforce-
ability. Emission estimates which are based on unsubstantiated facts
or are deemed unenforceable at any level must be identified. In the
case of incomplete information or unsubstantiated claims, the agency
must request that the missing information be supplied. If an emission
reduction/estimate is due in part (or solely) to an unenforceable
condition, the agency must determine if the permit can be altered to
make the emission limitation enforceable. An example of this case is
a limitation of hours of operation. Emission reductions claimed by a
reduction of hours of operation can be made enforceable by placing an
hours of operation restriction in the operating permit and providing
for a monitoring mechanism. If the emission limitation cannot be made
enforceable it cannot be considered in the PSD review. Applicability
must be re-reviewed for that pollutant, and the source notified if
additional information is required.
Once the source has been projected to be in compliance with all
applicable regulations, the agency must determine if BACT is proposed
for all significant pollutants. The reviewing engineer should deter-
mine the type of control and the efficiency proposed for each pollu-
tant and e«ch emission point. It is noted here that each BACT
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MUST UNDERGO
PSD REVIEW
FOR ALL
SIGNIFICANT
POLLUTANTS
DEMONSTRATE
THAT LEVEL OF
CONTROL MEETS
STATE EMISSION
STANDARDS
DOES
FACILITY
DEMONSTRATE
BACT
AS THE
LEVEL
OF
NTROL
P
PRELIMINARY
DETERMINATION
TO DENY
MANDATED
Figure 2.1 REGULATION AND BACT REVIEW FLOW CHART
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analysis must be conducted on a case-by-case basis since different
locations or situations way determine that different control strate-
gies should be applied due to site-specific factors.
The reviewer should assemble a control strategy matrix for each
pollutant and emission point at which BACT is applicable. This matrix
(see Checklist page B-2) would consist of a list of potential control
strategies for the pollutant in the first column (including the stra-
tegy selected by the applicant). The other columns of the matrix
would list the results of an analysis of the following three factors:
(1) economic factors; (2) environmental impacts; and (3) energy
impacts (see Checklist page B-2).
Control strategies which can be included in the matrix are:
• existing technology
• transferable technology
t innovative technology
t process change
The review engineer should be familiar with the possible control
strategies for the proposed source. Possible helpful sources of
information are:
• BACT/LAER clearinghouse (EPA)
• local industrial sources
• industry standards
• technical literature (JAPCA, etc.)
• previously granted agency permits
Once the matrix has been assembled, the engineer must determine if
the proposed control strategy is indeed BACT. In some cases, two or
three matrices must be made since more than one significant pollutant
is emitted from a single point. The reviewer must weigh each of the
*NOTE: The matrix method described may, in some cases, be incorporated
by reference and not necessarily recreated for each applica-
tion. For example, a recent NSPS standard can be considered
BACT without an elaborate demonstration.
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BACT review criteria for each pollutant and determine the best approach
considering each BACT review factor. It should be emphasized that the
demonstration that BACT has been selected for implementation is
supplied and justified by the applicant. The State should review
thoroughly this matrix scheme. Note that more than one control strat-
egy or combination of control strategies can be considered to be BACT,
depending on the individual circumstances. The BACT review should
also include an analysis of control equipment to insure proper design.
If the reviewer notes that alternative control strategies appear
to control emissions better than the proposed methods with all other
BACT factors being approximately equal, the agency should request an
explanation from the source as to why that strategy was not chosen.
Upon receipt of the facility's explanation, the agency must determine
if the applicant's original BACT proposal remains valid. The reviewer
must also identify pollutants which are significant and have no con-
trol strategy proposed. In some instances, control technologies may
create a secondary pollutant which, in itself, may be either signifi-
cant or impact the public welfare or health. If any significant pol-
lutant does not satisfy the agency's BACT criteria, a preliminary
determination to deny would be mandated.
If an applicant changes his control strategy approach to satisfy
BACT requirements, the reviewer should return to the applicability
review. This is necessary since pollutant emission estimates may
change for different control strategies and other pollutants may
increase or decrease. The resultant changes in pollutant emissions
may affect individual pollutant significance levels and thereby affect
PSD/EOP applicability.
The Regulation and BACT Review checklist (pages B-l and B-2)
should help the review engineer answer each of the regulation and BACT
questions. A sample matrix form is also included to illustrate the
types of economic and environmental concerns which must be weighed in
order to determine BACT for a particular installation.
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3.0 AIR QUALITY REVIEW
The air quality review portion of the permit review is probably
the most complex and time intensive of the four review areas. The
order of elements suggested by the PSD flow diagram is only one pos-
sible route. In actuality, portions of the review can be done simul-
taneously or in a different order. The Air Quality Checklist must be
completely filled out for each significant PSD pollutant. For the
purposes of this discussion, the review order outlined in the PSD flow
diagram (see Figure 3.1) and permit checklist (pages C-l to C-3) which
follows this discussion is observed.
In the applicability section of the review process, the attainment
status of the source location is determined. In the air quality
review section, baseline air quality must be determined to quantify
the available increment on the baseline date. The baseline date
determination is the first step. The baseline date is that date after
August 7, 1977 upon which the first complete PSD application is
received by the applicable agency. Presently, baseline date is appli-
cable only to TSP and S02 since these are the only pollutants which
have increments associated with them. Therefore, for sources with
significant emissions of either TSP or SCL, the agency must deter-
mine the baseline air quality for each pollutant. This concentration
determines the amount of increment available to sources from that
date. Since increment consumption review is limited to TSP and SO^,
it will be discussed separately.
In the case of pollutants other than TSP and SO,,, air quality
for the area of source location at the time of the application must be
determined. This determination is to assure that present air quality
does not exceed any National Ambient Air Quality Standard (NAAQS). If
any NAAQS is shown to be exceeded, the agency must declare the area a
newly discovered non-attainment area. The agency is required to
revise their SIP to attain the NAAQS and the federal EOP, not PSD,
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DETERMINE
BASELINE AIR
QUALITY FOR THE
AREA OP SOURCE
LOCATION
DETERMINE
//HAT PORTDN OF
THE INCREMENTS
HAVE BEEN CON-
SUMED FOR EACH
CLASS AREA
ARE
ALL
MISSION
BELOW
4* MINIMUS
AND
EXEMPT-
RAN
REVIEW ONE
YEAR OF
AMBIENT
MONITORING
DATA
UODEL THE
SOURCES AIR
QUALITY IMPACT
ON EACH CLASS
AREA
ES
THE
DELING'
SHOW
AVAILABLE
INCREMENTS
OR NAAQS
ARE
EXCEEDED
DETERMINE THE
SOURCES IMPACT
ON AIR QUALITY
RELATED VALUES
(j*. visibility, soils}
PRELIMINARY
DETERMINATION
TO DENY
MANDATED
THE ORDER OF ELEMENTS
OF AIR QUALItr HE VIEW
MAY VARY ON A CASE
BY CASE BASIS.
ARE
CLASS
I
REQUIRE
MENTS
SATISFIED
mcremtnts.
lint manaqtr)
ES
THE
SOURCE
HAVE A
SIGNIFICANT
IMPACT ON
ANY
CLASS 1
AREAS
ARE
ANY
NON-
ATTAINMENT
AREAS
IGNIFICANTLX
IMPACTED
MUST
UNDERGO
OFFSET
REVIEW
Fiaure 3.1 AIR QUALITY REVIEW FLOW CHART
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applies (for nine months) for that pollutant. Once the agency has
determined that no NAAQS has been violated, and that the total avail-
able increment will not be violated, (presently, increments have been
established for participates and SCL only) the reviewer should con-
tinue the application review process.
In some instances, a significant pollutant(s) may have an emission
impact below the de minimus levels (see Table 3-1) outlined in the PSD
regulations. If this is the case, the applicant may request an exemp-
tion from the Air Quality monitoring requirements. In evaluating such
a request, the agency must determine if the impact is indeed below the
de minimus levels specified. This usually can be done by relatively
simple screening methods. If the agency does not grant an exemption
of the monitoring requirements, one year of ambient monitoring data is
necessary. Note that an air quality analysis must be conducted for
each regulated pollutant subject to PSD review that is expected to be
emitted from, or whose emissions are expected to significantly
increase in conjunction with, proposed construction, (e.g., a source
may be required to monitor for a pollutant which it does not emit such
as ozone created by increased vehicular traffic resulting from the
source's employees).
The monitoring program must conform with the procedures outlined
in Ambient Monitoring Guidelines for Prevention of Significant Deter-
ioration. In general, the following criteria must be met:
• data sufficiency
• data reliability
3 areas of monitoring program
• data representativeness
The ambient monitoring data may be acquired by the source itself,
by setting up site-specific ambient monitoring program. In cases
where ambient monitoring data is available from the state or other
sources, the applicant must show that the three criteria mentioned
above are met. In all cases, the review agency and the applicant
should discuss the ambient monitoring program procedures prior to
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• Table 3.1 De MINIMIS LEVELS
• Carbon monoxide - 575 yg/m3, 8-hour average
• Nitrogen dioxide - 14 yg/m3, annual average
Total suspended particulate - 10 yg/m3, 24-hour average
I Sulfur dioxide - 13 yg/m3, 24-hour average
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2
Ozone
Lead - 0.1 yg/m3, 24-hour average
Mercury - 0.25 yg/m3, 24-hour average
Beryllium - 0.0005 yg/m3 , 24-hour average
I Fluorides - 0.25 yg/m3 , 24-hour average
Vinyl chloride - 15 yg/m3, 24-hour average
I Total reduced sulfur - 10 yg/m3, 1-hour average
• Hydrogen sulfide - 0.04 yg/m3, 1-hour average
Reduced sulfur compounds - 10 yg/m3, 1-hour average
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No de minimis air quality level is provided for ozone.
However, any net increase of 100 tons per year or more
_ of volatile organic compounds subject to PSD would be
I required to perform an ambient impact analysis including
™ the gathering of ambient air quality data.
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actual monitoring. This discussion of the pre-construction monitoring
program should eliminate program inadequacies and resolve debatable
issues prior to data collection and will ease the PSD review process
when the application is finally submitted.
The review of the modeling presentation will usually be different
for each PSD application that the agency reviews. Since no two air
quality analyses are identical, the agency must tailor their review to
each specific application. In general, the following review elements
are common to all applications:
• definition of impact area
• selection of appropriate models
• detailed and representative meteorological data
• engineering input (i.e., stack height, emission rates, etc.)
Each of the above elements «tist be reviewed individually to assure
the modeling results will provide an accurate forecast of ambient air
quality. The latest revisions of the EPA documents Guideline on Air
Quality Models and the Guidelines for Air Quality Maintenance Planning
and Analysis, Volume X serve as helpful guidelines for acceptable
dispersion modeling procedures. In all cases, the review agency and
the applicant should discuss the dispersion modeling procedures prior
to actual modeling, since unacceptable/questionable techniques may
result in permit approval delays and wasted funds.
The analysis of additional impacts may be performed at any time
during the air quality review. In essence, this analysis determines
the proposed source's air pollution impact on soils, vegetation, and
visibility, along with emissions associated with predicted emissions
resulting from associated growth. The reviewer should make sure the
applicant made a complete analysis of each review area (growth, soils,
vegetation, and visibility). General statements such as "impact on
soils is minimal" must be substantiated. The application should cite
appropriate references used to substantiate impact analysis claims.
In general, there is no "cookbook" or specific method by which an
agency can review an application for additional impacts.
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The agency should confirm that the source has no significant
impact on any Class I area. If the source will not be located within
100 ton of any Class I area, confirmation of that fact is sufficient.
If the source impacts or is located within 100 km of any Class I area,
Class I requirements may be applicable. (In the State of Delaware, no
such condition presently exists. If, in the future, an area is redes-
ignated as Class I, refer to 40 CFR 52.21 (p) for all additional
requirements.)
Finally, the agency must ascertain if any non-attainment areas are
significantly impacted. If a non-attainment area is significantly
impacted by the non-attainment pollutant, the agency must review the
State's emission offset policy (EOP) for applicability and additional
requirements, if needed.
3.1 INCREMENT CONSUMPTION AND TRACKING
As stated previously, current increment consumption/tracking is
linked only to TSP and SO^. In general, it is the source's respon-
sibility to prove two points in its air quality analysis. The source
must first show that no National Air Quality Standard will be violated
due to the proposed construction. Secondly (in the case of TSP and
SOp), the source must show that the available increment will not be
exceeded. Depending on the application, there are many ways of ade-
quately fulfilling each of the above criteria. The accompanying Air
Quality Review Checklist suggests a "delta method" for defining incre-
ment consumption.
In this method, the source should define the following three
figures:
§ Available increment as of the baseline date
t Increment consumption by others to date
• Increment consumption by proposed source
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The difference between the total increment consumption (by others
*IK! the proposed source) and th* available increment as of the base-
line data must be greater than zero. Note that the total Increment
consumption can be a negative number through various mechanisms such
as plant shut downs, negative area growth, etc.. Because of the vari-
ables involved in determining increment consumption, each determina-
tion should be made on a case-by-case basis. Both the source and the
agency must realize that air quality is dependent on both time and
space, and that the increment delta must reflect these variables.
As stated previously, the accompanying Air Quality Review Check-
list (pages C-l to C-3) should serve as guide to the reviewer to check
for application completeness and adequacy. It is stressed that the
application should contain all of the information needed to analyze
the air quality criteria. The reviewer should check the applicant's
assumptions and calculations and comment on them accordingly.
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4.0 PUBLIC PARTICIPATION PROCESS
The entire PSD process must include public participation process
(see Figure 4.1). The public participation process can be divided
into three phases:
• Preliminary determination
t Public/source response
t Final determination
The agency must prepare a complete preliminary determination
package. This package should include a technical support document
supporting the preliminary determination and all permit conditions
associated with the decision. The three checklists—Applicability,
Regulation and BACT Review (pages B-l and B-2), and Air Quality Review
(pages C-l to r.-3)--can serve as the basis of the technical support
document. Once the preliminary determination package is complete, the
agency should send the notice to all interested public officials, the
source itself, and any known interested individuals.
In addition to individual notices, the agency must prepare a news-
paper notice which should be published in all of the areas affected by
the proposed source. The notice should at least contain the following
elements:
• Complete description of the decision
• Degree of increment consumption
• Address for receipt of public comments
• Final date for public input
• Opportunity for a public hearing
The public hearing, if held, must be in the area of the proposed
source and should be announced in the newspaper at least 30 days in
advance of the actual hearing. The public hearing is meant to provide
an opportunity for interested persons to appear and submit written or
oral comments on the preliminary determination. All comments should
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PWELIMNARY
DETERMINATION
PUBLIC
COMMENTS
PUBLIC
HEARINGS
APPROVAL
OR
DENIAL
OF PSD
PERMIT
REDESIGN
AND
RESUBMIT
NEW
APPLICATION
PERMIT
TO
CONSTRUCT
APPROVAL
Figure 4.1 PUBLIC PARTICIPATION PROCESS FLOW CHART
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be received by the close of the public comment period (usually ten
days after the hearing) The applicant has ten days after the close of
the public comment period to submit a "rebuttal response" to the com-
ments received. The agency should inform the applicant as comments
are received.
The timing of the public participation process is of extreme
importance to both the agency and the applicant. Delays in this pro-
cess will cost both parties valuable time and resources. A calendar
of events should be set up by the review agency to assure a timely
public participation period.
Once all comments have been received, the agency should assemble
all pertinent information into an application docket and prepare a
response to the comments received. The response to all comments
should be made available to the public at the same locations the pre-
liminary determination information were made available by the Depart-
ment.
Finally, the agency must notify the applicant in writing of the
final determination and make such notification available for public
inspection. The Public Participation Process Checklist (D-l) can
serve as a tracking mechanism for this process.
4-3
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APPENDIX
I COMPOSITE PSD REVIEW CHECKLIST
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Source Name
Date of Appl icatlon
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PSD, EOP, AND NSR APPLICABILITY REVIEW
1. Quantify and Characterize the Fallowing Pollutants:
1
11. Particulate Matter
2. Sulfur Oxides
1 3. Carbon Monoxide
4. Nitrogen Oxides
• 5. Ozone (regulate VOC)
" 6. Lead
17. Asbestos
8. Beryllium
9. Mercury
( 10. Vinyl Chloride
11. Fluoride
Il2. Sulfuric Acid Mist
™13. Hydrogen Sulfide (H0S)
114. Total Reduced Sulfur
(including H0S)
c.
15. Reduced Sulfur Compounds
•(including H0S)
EXISTING
SOURCE
ton/yr
MODIFICATION
ton/yr
CLAIMED
OFFSETS
ton/yr
i-
| 2. Is the Source One of Named Categories? (See Appendix Table 1)
IYes - (100 ton/yr for ma;
No - (250 ton/yr for ma jo
13. Is the Source Major for Any of the Above Pollutants? Yes
CREDITABLE
OFFSET
ton/yr
NET
INCREASE
ton/yr
or applies)
r appl ies)
No
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A-l
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Source Name
- Is Existing Source Major? Yes
No
(if "No", go to line 5)
• 4a. Is Net Emission Increase Significant (see Appendix Table 2) for Any PollutantU)?
YesNo(if "No", go to line 8)
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5. Is New Source or Modification Major? Yes
(if "No", go to line 8)
No
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5a. Is this Emission Increase Significant for Any Pollutant?
Yes No (if "No", go to line 8)
6. List Each Pollutant Answering "YES" to Questions 4a and 5a, and Determine
Attainment Status for Each. (For non-criteria pollutants - attainment is assumed.)
POLLUTANT
1.
2.
3.
4.
5.
ATTAINMENT/UNCLASSIFIED
NON-ATTAINMENT
7. Are Any of the Pollutants Listed in Question 6 Non-Attainment?
YES - EOP Review may be Required for these Pollutants.
_NO - PSD Review Required for these Pollutants - go to Regulation and BACT
Review, and Air Quality Review Sections.
8. Perform Standard New Source Review.
A-2
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"(B)
1
1
1. List All Pollutants Which
Iand Perform Evaluation of
POLLUTANT
1 '•
•
2.
13.
4.
15.
APPLICABLE
STATE REGS
Source Name
Date of Appl ication
REGULATION AND BACT REVIEW
Were Significant and Located in Attainment/Unclassified Areas.
Emission Data for Source Versus All Applicable Regulations.
STATE FEDERAL PROJECTED
EMISSION APPLICABLE EMISSION COMPLIANCE
LIMITATION FEDERAL REG LIMITATION STATUS
^ la. Are All Proposed Control Methods (including hours of operation) Enforceable?
1 Yes
12. Determine if
No
BACT is Proposed for All Applicable Pollutants.
••
POLLUTANT
1 l
2.
13.
4.
15.
— 3. Will Each Non-Significant
1 Federal Regul
TYPE OF CONTROL BACT CONTROL
AND EFFICIENCY EFFICIENCY
PROPOSED AND REFERENCE* DETERMINATION
Pollutant be in Compliance with All State and
ations? Yes No
1 4. Are All Regulations and BACT Determinations Satisfied? Yes No
(If "No", preliminary determination to deny mandated.)
1
• * i.e., BACT/LAER Clearing House, industry standard, etc.
-------
(B)
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(C)
Source Name
Date of Appl icatlon
AIR QUALITY REVIEW
1. Determine Baseline Air Quality for the Area of Source Location.
BASELINE
- Baseline Date
Annual Arithmetic Mean
Maximum 24-hour Concentration
Maximum 3-hour Concentration
TSP - Baseline Date
_ug/irT
ug/nf
*•
ug/nf
Annual Geometric Mean
Maximum 24-hour Concentration
Maximum 24-hour Concentration
(secondary)
_ug/nf
ug/nf
™~ ^
ug/nf
80 ug/m°
365 ug/m3*
1300 ug/m3*
75 ug/m
260 ug/n3*
150 ug/m *
2. Determine Air Quality for the Area of Source Location at Time of Application.
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PRESENT
N0>
CO
Pb
_ug/nf
_ug/nf
_ug/nf
03 (VOC)
_ug/m /ppm
100 ug/m Annual Arithmetic Mean
3
10 ug/m Maximum 8-hour Concentration*
40 ug/m Maximum 1-hour Concentration*
3
1.5 ug/m Maximum Arithmetic Mean Quarterly
Average
235 ug/m3* 0.12 ppm
. Determine What Portion of the Available Increments have been Consumed for Each Class Area,
PT
SO
iu2
AVAILABLE
INCREMENT
inuKcntix i
CONSUMPTION
TO DATE
SOURCE
CONSUMPTION
REMAINING
INCREMENT
Rot to be exceeded more than once/year.
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1
,r. Source Name
1
4. Are Emissions Impacts Below de Minimus for Any Applicable Polluta
nt (See Appendix Table 3]
• and Exemption Requested? Yes No
a) If Yes, refer to administrator
_ for affected pollutants.
| b) Is exemption granted? Yes
(department) for possible exemption of monitoring
No Which Pollutants?
15. Review Monitoring and Meteorological Data for
, . «*
a) Were monitoring sites represent
1 b) Were quality assurance procedur
c) Is data submitted complete? Ye
». Review Modelling Presentation.
a) Was impa
• b) Were app
c) Was mete
Id) Were mod
modelled
e) Were -mod
• f) Were fug
ml. If Monitori
I
1 POLLUTANT
1
1
1
1
1
ct area defined for eac
ropriate models chosen
orology representative
el inputs from other so
? Yes No
el inputs consistent wi
itive emissions conside
ng and Modelling Tasks
POLLUTANT
AVERAGING
TIME
All Poll
jtants not Granted Exemption.
ative? Yes No
es followed? Yes
s No
h applicable pollutai
for each pollutant?
_ No
it? Yes
No
Yes No
and of sufficient duration? Yes No
urces correct and appropriate for averaging times
th rest of application?* Yes No
red in models? Yes No
were Deemed Acceptable, Complete the Following
MAXIMUM INCREMENT CONSUMED
BY SOURCE
BY OTHERS
TOTAL
ALLOWABLE '
INCREMENT
TOTAL
PROJECTED
AIR QUALITY
Table.
NAAQS
*i.e., stack heights, emission rates, etc.
I C-2
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,r. Source Name
^m ^ ^ J "m*""™T"'1'"
•8. Perform/Review Additional Impacts Analysis.
a) Growth analysis
• b) Soils and vegetation impact
™ c) Visibility impairment analysis
•9. Does the Source have a Significant* Impact on Any Class 1 Area?
Yes No (if "No" go to line 10)
' a) Are Class 1 requirements satisfied?
_ 1) increment consumption Yes No
• 2) land manager approval Yes No
•o. Are Any Non-Attainment Areas Significantly*Impacted? Yes No
(if "Yes", HOP review may apply)
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.* Significant impact determined as follows:
I POLLUTANT ANNUAL 24-HOUR 8-HOUR 3-HOUR 1-HOUR
S0? 1 ug/m3 5 ug/m3 - 25 ug/m3
13 3
TSP 1 ug/m0 5 ug/rn
- N02 1 ug/m3
CO — — 0.5 ug/m3 — 2 ug/m3
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(D) Source Name
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Date of Appl ication_
PUBLIC PARTICIPATION PROCESS
Prepare Preliminary Determination Documents.
a) Itemize necessary permit conditions.
b) Assemble technical support document.
c) Send the preliminary determination to interested officials/public.
Prepare Newspaper Notice.
Is the Notice Published in the Area of the Proposed Source? Yes No
Does the Notice Contain All of the Following Elements?
a) Description of decision -
b) Availability of pertinent documents -
c) Address for receipt of public comments -
d) Final date for public input -
I. Public Hearing.
a) Is meeting in area of proposed source? Yes No
b) Announce Hearing in paper 30 days in advance.
c) Is court reporter available? Yes No
d) Announce final date for Hearing comments (usually 10 days after hearing).
e) Once comments are received, send to applicant with 10 day deadline for their response.
•4. Review All Comments and Prepare Response. _
•5. Announce Final Decision and Implement (i.e., issue or deny permit)
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CHECKLIST APPENDIX
Appendix Table 1. LIST OF NAMED SOURCES
Fossil Fuel Fired Steam Electric Plants greater than or equal
to 250 million Btu/hour Heat Input
Coal Cleaning Plants (with thermal dryers)
Kraft Pulp Mills
Portland Cement Plants
Primary Zinc Smelters
Iron and Steel Mill Plants
Primary Alumirwm Ore Reduction Plants
Primary Copper Smelters
Municipal Incinerators Capable of Charging greater than or
equal to 250 tons of refuse/day
Hydrofluoric, Sulfuric, and 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
250 million Btu/hour Heat Input or more
Petroleum Storage and Transfer Units with a Total Storage
Capacity Exceeding 300,000 barrels
Taconite Ore Processing Plants
Glass Fiber Processing Plants
Charcoal Production Plants
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APPENDIX TABLE 2. SIGNIFICANT .POLLUTANT EMISSION RATES
Carbon Monoxide: 100 TPY
Nitrogen Oxides: 40 TPY
Sulfur Dioxide: 40 TPY
Particulate Matter: 25 TPY
Ozone: 40 TPY of volatile organic compounds
Lead: 0.6 TPY
Asbestos: 0.007 TPY
Beryllium: 0.0004 TPY
Mercury: 0.1 TPY
Vinyl Chloride: 1 TPY
Fluorides: 3 TPY
Sulfuric Acid Mist: 7 TPY
Hydrogen Sulfide (H2S): 10 TPY
Total Reduced Sulfur Compounds (including hLS): 10 TPY
TPY = Tons Per Year
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Appendix Table 3. De MINIMIS LEVELS
• Carbon monoxide - 575 yg/m3 , 8-hour average
• Nitrogen dioxide - 14 yg/m3, annual average
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Total suspended particulate - 10 yg/m3, 24-hour average
Sulfur dioxide - 13 yg/m3, 24-hour average
2
Ozone
Lead - 0.1 yg/m3, 24-hour average
Mercury - 0.25 yg/m3, 24-hour average
Beryllium - 0.0005 yg/m3 , 24-hour average
Fluorides - 0.25 yg/m3 , 24-hour average
Vinyl chloride - 15 yg/m3, 24-hour average
_
' Total reduced sulfur - 10 yg/m3, 1-hour average
• Hydrogen sulfide - 0.04 yg/m3, 1-hour average
Reduced sulfur compounds - 10 yg/m3, 1-hour average
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No de mlnimis air quality level is provided for ozone.
However, any net increase of 100 tons per year or more
required to perform an ambient impact analysis including
the gathering of ambient air quality data.
• of volatile organic compounds subject to PSD would be
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APPENDIX Z
PSD Regulations for the State of West Virginia
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I OS ANGCLL'S CA
CHICAGO. ILL
RESEARCH THIANGLt. PARK NC
WASHINGTON DC
PACIFIC ENVIRONMENTAL SERVICES. INC.
March 17, 1981
Mr. Carl G. Beard, Director
West Virginia Air Pollution Control Commission
1558 Washington Street, East
Charleston, West Virginia 25311
Dear Mr. Beard:
As a result of the meeting held at your offices on February 20, 1981,
Pacific Environmental Services, Inc. (PES) has prepared a draft PSD
regulation in the "style" of the West Virginia rules and regulations.
Consistent with the discussions during that meeting, two draft versions
of the PSD regulation were prepared. First, a draft PSD regulation
was prepared which includes all options permittable in 40 CFR 51.24.
This long version is contained in Attachment A. A second version of
the regulations is a rule which would be minimally acceptable to U.S.
EPA. This version removes all optional sections and may, in some
cases, be considered more stringent than 40 CFR 52.21. However, this
stringency is real only if there is likely to be an affected source.
For example, a non-profit health institution may be exempted from PSD
review. However, if such an institution in West Virginia .is
"major" nor is it likely for one to be "major" in the future,
elimination of this exemption does
gent than 40 CFR 52.21. The short
not
the
not make the draft rule more strin-
version of the draft PSD rule is con
tained in Attachment
sistency).
B (This rule has been renumbered for internal con-
Lastly, differences between the two versions is itemized in Table 1.
This will enable you to make a decision on each item and would enable
PES to prepare a "hybrid" regulation between the two "extremes"
presented.
I look forward to discussing these materials with you in the near
future. Should there be any more immediate questions concerning these
materials, please call me at (312) 530-7272.
Sincerely yours, .
Thomas P.^Blaszafc'
Midwest Operations Division
TPB/cs/453
Attachments
MIDWEST OPERATIONS 465 Fullerlon Ave. Elmhurst, ILL 60126 (312) 530-7272
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Table 1.
MODIFICATIONS TO THE LONG PSD REGULATION (ATTACHMENT A)
(1) The baseline area has been defined in terms of Section 107
non-attainment areas. The Commission could utilize a different
geographic unit (i.e., counties, census districts, etc.) for
these areas. This modification would apply to any PSD rule.
(2) For the offsetting portion of the rule, any reasonable time
period for contemporaneous can be used. Five (5) years has been
used since it is the time period used in 40 CFR 52.21. This
choice would apply to any PSD rule containing the offset
provisions.
(3) References are made to existing PSD permits which have been
issued by U.S. EPA, Region III under 40 CFR 52.21. This could be
eliminated by requiring sources who hold such a permit to
register under the West Virginia PSD rule and to obtain a state
PSD permit which would duplicate the 40 CFR 52.21 permit and make
it a state permit. A new section would be required to implement
this and could be done to any PSD rule.
(4) References are made to U.S. EPA requirements (i.e., Section 111
and 112 of the Clean Air Act, etc.). These references can be
eliminated by citing the equivalent West Virginia rule or include
the Federal language explicitly in the PSD rule rather than by
reference. This change would apply to any version of the PSD
rule.
(5) Section 2.06 contains the definition of "Net Emissions Increase"
and has been dropped for the "short PSD rule." This may require
additional sources to be subject to PSD and may be more stringent
than 40 CFR 52.21. The provision would also be needed if any
banking program would be desired. In addition to dropping this
section, modification of the following other sections have been
made (usually the elimination of the word net or equivalent
phrase).
o Section 2.03
o Section 2.16(2)
o Section 2.24
o Section 2.25
o Section 2.26
(6) The entire redesignation procedures of Section 5 can be
eliminated. Section 4 contains the area classifications for the
entire state. The ability to change these classifications is not
required, but optional. Parts of Section 4 have been amended as
appropriate.
(7) In Section 11.05, the Commission may permit less than one year of
monitoring data to be submitted on a case-by-case review basis.
This may be more stringent if there are any affected sources. In
general, only ozone monitoring during ozone season (suwner) would
meet this requirement.
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(8) In Sections 13.03, 13.04, 13.05, and 13.06, the source may
petition for a variance from the Class I Increment undtr certain
circumstances. The allowance for this variance is optional with
the state. Sections 2.26 and 2.27 defining high and low terrain
have been dropped.
(9) Section 16 concerning Innovative Control Technology is optional.
Section 2.20 defining innovative control technology has also been
eliminated.
(10) Section 17 concerning exclusions from increment consumption is
optional. These exclusions from increment consumption are of
only two to five years in duration and any affect they may have
would be temporary.
(11) The following parts of Section 18 excludes certain sources from
parts of the regulation and are all optional:
o Section 18.01 excludes non-profit health and educational
institutions from the entire PSD process.
o Section 18.02 excludes adding fugitive emissions from
non-named sources to determine PSD applicability. In
general, this has a potential effect on non-named sources
with mostly fugitive emissions (i.e., materials handling,
quarries, etc.). Section 2.21 defining "Fugitive Emissions"
has also been eliminated.
o Section 18.03 exempts portable sources from undergoing PSD
review each time it is moved (after the first PSD review).
o Section 18.04 exempts review of temporary pollutant
emissions.
o Section 18.05 exempts a source from modeling, monitoring,
and other impact analyses if, after BACT, the emissions are
less than 50 TPY (This is the "old Tier I" review of PSD
sources).
o Section 18.06 exempts monitoring requirements if the air
quality impacts are less than the de Minimis levels listed.
o Section 18.07 allows mandatory post-construction ozone
monitoring in lieu of pre-application monitoring if specific
conditions are met.
(12) The following section is added to Section 18 since exemption from
PSD review is optional for sources located in non-attainment
areas.
18.01 Any person proposing to construct, modify, or relocate may
petition the Director for an exemption from the
requirements of Section 7 through 11 if the major
stationary source or major modification would be
constructed in an area which is designated as
non-attainment under Section 107(d)(l)(D) or (E).
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I ATTACHMENT A
• LONG PSD RULE
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SUBJECT: Regulation - Permits for Construction wid
Modification of Stationary Sources of Air Pollution for the
Prevention of Significant Deterioration.
Section 1: INTENT AND PURPOSE
1.01 To insure that economic growth will occur in harmony with
the preservation of existing clean air resources; to prevent
the development of any new non-attainment problems; to pro-
tect the public health and welfare from any adverse effects
which might occur even at air quality levels better than the
West Virginia and national ambient air quality standards;
and to preserve, protect, and enhance the air quality in
areas of special natural recreational, scenic, or historic
value, it is the intent of the Commission to register and
evaluate sources of air pollutants and to preclude the
construction, modification, or relocation of any major sta-
tionary source or major modification in any locality in
which the establishment of such source or modification may
interfere with the goals of the prevention of significant
deterioration of air quality levels.
The purpose of this regulation is to quantitatively define
significant deterioration of air quality with respect to the
desired degree of preservation of air quality for various
areas and to set forth procedures for registration and
reporting, and the criteria for obtaining a permit to con-
struct, modify, or relocate a major stationary source or
major modification within the State of West Virginia. Such
construction, modification, or relocation without such a
permit is a violation of this regulation.
Section 2: DEFINITIONS
2.01 "Major Stationary Source" shall mean:
(1) any stationary source which emits or has the potential
to emit, 100 tons per year or more of any regulated
pollutant and is one of the stationary sources named in
Table 1.
(2) any stationary source which emits or has the potential
to emit, 250 tons per year or more of any regulated
pollutant and is not one of the stationary sources
named in Table 1.
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Table 1. STATIONARY SOURCES OF AIR POLLUTANTS
o Fossil Fuel Fired Steam Electric Plants greater than or tqaal to
250 million Btu/hour Heat Input
o Coal Cleaning Plants (with thermal dryers)
o Kraft Pulp Mills
o Portland Cement Plants
o Primary Zinc Smelters
o Iron and Steel Mill Plants
o Primary Aluminum Ore Reduction Plants
o Primary Hopper Smelters
o Municipal Incinerators Capable of Charging greater than or equal to
250 tons of refuse/day
o Hydrofluoric, Sulfuric, and Nitric Acid Plants
o Petroleum Refineries
o Lime Plants
o Phosphate Rock Processing Plants
o Coke Oven Batteries
o Sulfur Recovery Plants
o Carbon Black Plants (furnace process)
o Primary Lead Smelters
o Fuel Conversion Plants
o Sintering Plants
o Secondary Metal Production Plants
o Chemical Process Plants
o Fossil Fuel Boilers (or combinations thereof) Totaling 250 million
Btu/hour Heat Input or more
o Petroleum Storage and Transfer Units with a Total Storage Capacity
Exceeding 300,000 barrels
o Taconite Ore Processing Plants
o Glass Fiber Processing Plants
o Charcoal Production Plants
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(3) any physical change at a stationary source 1f the
change itself would constitute a major stationary
source.
2.02 "Major Stationary Sewrce for Ozone" shall mean a major
stationary source of volatile organic compounds.
2.03 "Major Modification" means any physical change in or change
in the method of operation of a major stationary source
which results in a significant net emission increase of any
regulated pollutant. However, the foil wing actions shall
not constitute a modification of a affected source:
(1) Routine maintenance, repair, and replacement.
(2) Use of an alternative fuel or raw material by reason of
any order under Sections 2(a) and (b) of the Energy
Supply and Environmental Coordination Act of 1974 (or
any superceding legislation) or by reason of a natural
gas curtailment plant pursuant to the Federal Power Act.
(3) Use of an alternative fuel by reason of an order or
rule under Section 125 of the Clean Air Act.
(4) Use of municipal solid waste as an alternative fuel at
a steam generating unit.
(5) Use of an alternative fuel or raw material, provided
that prior to the effective date of this regulation,
the affect source is designed to accomodate such alter-
native fuel use unless such change would be prohibited
by a Federal permit issued pursuant to 40 CFR 52.21 or
by any permit issued pursuant to this regulation.
(6) An increase in the hours of operations unless such
increase would be prohibited by a Federal permit issued
pursuant to 40 CFR 52.21 or by any permit issued pur-
suant to this regulation.
(7) An increase in the production rate unless such increase
would be prohibited by a Federal permit issued pursuant
to 40 CFR 52.21 or by any permit issued pursuant to
this regulation.
(8) Any change in ownership at a stationary source.
2.04 "Major Modification for Ozone" shall mean a major modifi-
cation for volatile organic compounds.
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2.05 "Net Emissions Increase" means the amount of emissions by
which the sum of the following exceeds zero:
(1) Any Increase in actual emissions from a particular
physical change or change in the method of operation at
a stationary source; and
(2) Any other increases and decreases in actual emissions
at the source that is both contemporaneous with the
particular change and is otherwise creditable.
(a) An increase or decrease in actual emissions is
contemporaneous with the increase from the parti-
cular change only if it occurs not more than five
(5) years prior to the date on which the increase
in emissions from the particular change occurs.
(b) An increase or decrease in actual emissions is
creditable only if all of the following conditions
are satisfied:
(i) The increase or decrease in actual emis-
sions has not been relied upon by the U.S.
Environmental Protection Agency in issuing
a permit pursuant to 40 CFR 52.21 or by the
Commission in issuing a permit pursuant to
this regulation and such permit is in effect
on the date on which the increase in emis-
sions from the particular change occurs.
(ii) The increase or decrease in actual emis-
sions of particulate matter or sulfur
dioxide which occurred prior to the appli-
cable baseline date was used in determining
the amount of maximum allowable increases
remaining available.
(iii) The decrease in actual emissions is credit-
able only to the extent that the old actual
emissions or old allowable emissions
(whichever is lower) exceeds the new actual
emissions.
(iv) The decrease in actual emissions must be
enforceable by the Commission at and after
the time that the actual construction of a
particular change begins.
(v) The decrease in actual emissions oust have
approximately the same qualitative signifi-
cance for public health and welfare as that
attributed to the increase from the parti-
cular change.
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(c) An increase that results from a physical change at
a source occurs when the emissions unit on which
construction occurred becomes operational and
begins to emit a particular pollutant. Any re-
placement unit that requires shakedown becomes
operational only after a reasonable shakedown
period, not to exceed 180 days.
2.06 "Potential To Emit" means the maximum capacity of a station-
ary source to emit a pollutant under its physical and opera-
tional design. Any physical or operational limitation on
the capacity of the source to emit a pollutant, including
air pollution control equipment and restrictuions on hours
of operation or on the type or amount of material cou&usted,
stored, or processed, shall be treated as part of its design
if the limitation or the effect it would have on emissions
is enforceable in any permit and/or consent order issued by
U.S. Environmental Protection Agency or by the Coninission.
Secondary emissions do not count in determining the poten-
tial to emit of a stationary source.
2.07 "Stationary Source" means any building, structure, facility,
or installation which emits or may emit any regulated air
pollutant.
2.08 "Building, Structure, Facility, or Installation" means all
of the pollutant-emitting activities which belong to the
same industrial grouping, are located on one or more
contiguous or adjacent properties, and are under the control
of the same person (or persons under common control).
Pollutant-emitting activities shall be considered as part of
the same industrial grouping if they belong to the same
"Major Group" (i.e., which have the same two-digit code) as
described in the Standard Industrial Classification Manual,
1972, as amended by the 1977 Supplement (U.S. Government
Printing Office stock numbers 4101-0066 and 003-005-00176-0,
respectively).
2.09 "Emissions Unit" means any part of a stationary source which
emits or would have the potential to emit any regulated
pollutant.
2.10 "Construction" means any physical change or change in the
method of operation (including fabrication, erection,
installation, demolition, or modification of an emissions
unit) which would result in a change in actual emissions.
2.11 "Commence" as applied to construction of a major staionary
source or major modification means that the owner or opera-
tor has all necessary preconstruction approvals or permits
and either has:
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(1) begun, or caused to begin, a continuous program of
actual on-site construction of the source, to be
completed within a reasonable time; or
(2) entered in-to bifldimj agreements or contractual obliga-
tions, which cannot be cancelled or modified without
substantial loss to the owner or operator, to undertake
a program of actual construction of the source to be
completed within a reasonable time.
2.12 "Necessary Preconstructiofi Approvals or Permits" means those
permits or approvals required under Federal air quality
control laws and regulations and air quality control rules
and regulations of the State of West Virginia.
2.13 "Begin Actual Construction" means, in general, initiation of
physical on-site construction activities on an emissions
unit which are of a permanent nature. Such activities
include, but are not limited to, installation of building
supports and foundations, laying of underground pipework,
and construction of permanent storage structures. With
respect to a change in method of operation, this term refers
to those on-site activities, other than preparatory activi-
ties, which mark the initiation of the change.
2.14 "Best Available Control Technology" means an emissions limi-
tation (including a visible emissions standard) based on the
maximum degree of reduction for each regulated pollutant
which would be emitted from any proposed major stationary
source or major modification which the Commission, on a
case-by-case basis, taking into account energy, environ-
mental, and economic impacts and other costs, determines is
achievable for such source or modification through applica-
tion of production processes or available methods, systems,
and techniques, including fuel cleaning or treatment or
innovative fuel combination techniques for control of such
pollutant. In no event shall application of best available
control technology result in emissions of any pollutant
which would exceed the emissions allowed by any applicable
standard under 40 CFR Parts 60 and 61. If the Commission
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 pre-
scribed instead to satisfy the requirement for the applica-
tion of best available control technology. Such standard
shall, to the degree possible, set forth the emissions
reduction achievable by implementation of such design,
equipment, work practice or operation, and shall povide for
compliance by means which achieve equivalent results.
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2.15 "Baseline Concentration" means that ambient concentration
level which exists in the baseline area at the time of the
applicable baseline date. A baseline concentration is
determined for each pollutant for which a baseline date is
established and shall include:
(1) The allowable emissions of major staionary sources
which commenced construction before January 6, 1975,
but were not in operation by the applicable baseline
date.
(2) The actual emissions representative of sources in
existence on the applicable baseline date. However,
the following will not be included in the baseline
concentration and will affect the applicable maximum
allowable increase(s):
(a) actual emissions from any major stationary source
on which construction commenced after January 6,
1975; and
(b) actual emissions increases and decreases at any
stationary source occurring after the baseline
date.
J 2.16 "Baseline Date" means the earliest date after August 7, 1977,
on which the first complete application under 40 CFR 52.21
is submitted by a major stationary source or major modifica-
• tion subject to the requirements of 40 CFR 52.21 or the date
• of the first complete application required by this regula-
tion, whichever is earlier. The baseline date is estab-
Ilished for each pollutant for which increments or other
equivalent measures have been established if:
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(1) The area in which the proposed source or modification
would construct is designated as attainment or
unclassifiable under Section 107(d)(l)(D) or (E) of the
Clean Air Act for the pollutant on the date of its
complete application under 40 CFR 52.21 or this regu-
lation; and
(2) In the case of a major stationary source, the pollutant
would be emitted in signficant amounts, or in the case
of a major modification, there would be a significant
net emissions increase of the pollutant.
2.17 "Baseline Area" means any intrastate area (and every part
thereof) designated as attainment or unclassifiable under
Section 107(d)(l)(D) or (E) of the Clean A1r Act in which
the major source or major modification establishing the
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baseline date would construct or would have an air quality
impact equal to or greater than 1 ug/m3 (annual average)
of the pollutant for which the baseline date is established.
Area redesignation under Section 107(d)(l)(D) or (E) of the
Clean Air Act cannot intersect or be smaller than the *re,a
of impact of any major stationary source or major modifica-
tion which:
(1) establishes a baseline date; or
(2) is subject to 40 CFR 52.21; or
(3) is subject to this regulation.
2.18 "Allowable Emissions" means the emissions rate of a station-
ary source calculated using the maximum rated capacity of
the source (unless the source is subject to Federally
enforceable limits or limits enforceable by the Commission
which restrict the operating rate, or hours of operation, or
both) and the most stringent of the following:
(1) The applicable standards as set forth in 40 CFR Parts
60 and 61;
(2) The applicable State of West Virginia emissions limi-
tations, including those with a future compliance date;
or
(3) The emissiorrs rate specified as a Federally enforceable
permit condition or permit condition enforceable by the
Commission, including those with a future compliance
date.
2.19 "Federally Enforceable" means all limitations and conditions
which are enforceable by the Administrator of the U.S. EPA
including those requirements developed pursuant to 40 CFR
Parts 60 and 61 requirements, rules and regulations of the
approved State Implementation Plan of the State of West
Virginia, and any permit requirements established pursuant
to 40 CFR 52.21 or this regulation.
2.20 "Secondary Emissions" means emissions which would occur as a
result of the construction or operation of a major station-
ary source or major modification, but do not come from the
major stationary source or major modification itself. For
the purpose of this section, secondary emissions must be
specific, well defined, quantifiable, and impact the same
general area as the stationary source or modification which
causes the secondary emissions. Secondary emissions may
include, but are not limited to:
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(1) Emissions from ships or trains coming to or from the
new or modified stationary source; and
(2) Emissions from any off-site support facility which
would not otherwise be constructed or increase its
emissions as a result of the construction or operation
of the major stationary source or major modification.
2.21 "Innovative Control Technology" means any system of air
pollution control that has not been adequately demonstrated
in practice, but would have a substantial likelihood of
achieving greater continuous emissions reduction than any
control system in current practice or of achieving at least
comparable reductions at lower cost in terms of energy,
economics, or non-air quality environmental impacts.
2.22 "Fugitive Emissions" means those emissions which would not
reasonably pass through a stack, chimney, vent, or other
functionally equivalent opening.
2.23 "Actual Emissions" means the actual rate of emissions of a
pollutant'from an emissions unit, as described below:
(1) In general, actual emissions as of a particular date
shall equal the average rate, in tons per year, at
which the unit actually emitted the pollutant during a
two-year period which precedes the particular date and
which is representative of normal source operation.
The Director shall allow the use of a different time
period upon a determination that it is more representa-
tive of normal source operation. Actual emissions
shall be calculated using the unit's actual operating
hours, production rates, and types of materials pro-
cessed, stored, or combusted during the selected time
period.
(2) The Director may presume that source-specific allowable
emissions for the unit are equivalent to the actual
emissions of the unit.
(3) For any emissions unit which has not begun normal
operations on the particular date, actual emissions
shall equal the potential to emit of the unit on that
date.
2.24 "Complete" means, in reference to an application for a
permit, that the application contains all of the information
necessary for processing the application. Designating an
application complete for purposes of permit processing does
not preclude the reviewing authority from requesting or
accepting any additional information.
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2.25 "Significant" means, in reference to a net emission increase
or the potential of a source to emit any of the following
pollutants, a rate of emissions that would equal or exceed
any of the following rates:
Pollutant and Emissions Rate
Carbon monoxide: 100 tons per year (TPY)
Nitrogen oxides: 40 TPY
Sulfur dioxide: 40 TPY
Particulate matter: 25 TPY
Ozone: 40 TPY of volatile organic compounds
Lead: 0.6 TPY
Asbestos: 0.007 TPY
Beryl Hi urn: 0.0004 TPY
Mercury: 0.1 TPY
Vinyl chloride: 1 TPY
Fluorides: 3 TPY
Sulfuric acid mist: 7 TPY
Hydrogen sulfide (H2S): 10 TPY
Total reduced sulfur (including H2S): 10 TPY
Reduced sulfur compounds (including h^S): 10 TPY
2.26 "Significant" means, in reference to a net emissions
increase or the potential of a source to emit a pollutant
subject to regulation for which the Commission has promul-
gated an emission or air quality standard that is not listed
in Section 2.25 of this regulation, any emissions rate.
2.27 "Significant" means any emissions rate or any net emissions
increase associated with a major stationary source or major
modification, which would construct within ten (10)
kilometers of any Class I area, and have an impact on such
area equal to or greater than 1 ug/rrv^ (24-hour average).
2.28 "Federal Land Manager" means, with respect to any lands in
the United States, the Secretary of the department with
authority over such lands.
2.29 "High Terrain" means any area having an elevation 900 feet
or more above the base of the stack of a source.
2.30 "Low Terrain" means any area other than high terrain.
2.31 "Air Pollutants" shall mean solids, liquids, or gases which,
if discharged into the air, may result in a statutory air
pollution.
2.32 "Emission" shall refer to the release, escape, or emission
of air pollutants into the air.
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2.33 "Air Pollution", 'statutory air pollution', shall have the
meaning ascribed to it in Section 2 of Chapter 16, Article
20 of the Code of West Virginia, as amended.
2.34 "Commission" shall mean the West Virginia Air Pollution
Control Commission.
2.35 "Director" shall mean the Director of the West Virginia Air
Pollution Control Commission.
2.36 "Person" shall mean any and all persons, natural or artifi-
cial, including any municipal , public, or private corpora-
tion organized or existing under the laws of this or any
other state or country, and any firm, partnership, or
association of whatever nature.
2.37 "Relocation" shall mean the physical movement of a source
outside its. existing plant boundaries.
2.38 "Regulated Pollutant" or "Regulated Air Pollutant" means,
for the purposes of this regulation, any of the following
pollutants:
o Carbon Monoxide
o Nitrogen Oxides
o P articulate Matter
o Ozone (volatile organic compounds)
o Lead
o Asbestos
o Beryllium
o Mercury
o Vinyl Chloride
o Fluorides
o Sulfuric Acid Mist
o Hydrogen Sulfide (h^S)
o Total Reduced Sulfur Compounds (including
o Reduced Sulfur Compounds (including
2.38 "Administrator" shall mean the Administrator of the U.S.
Environmental Protection Agency.
Section 3: AMBIENT AIR QUALITY CEILINGS
3.01 No increases in pollutant concentrations over the baseline
concentrations are allowed in excess of those listed below.
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Maximum Allowable
Pollutant Increase (ug/m3)
Class I
Particulate matter:
Annual geometric mean 5
24-hour maximum 10
Sulfur dioxide:
Annual arithmetic mean 2
24-hour maximum 5
3-hour maximum 25
Class II
Particulate matter:
Annual geometric mean 19
24-hour maximum 37
Sulfur diox.ide:
Annual arithmetic mean 20
24-hour maximum 91
3-hour maximum 512
Class III
Particulate matter:
Annual geometric mean 37
24-hour maximum 75
Sulfur dioxide:
Annual arithmetic mean 40
24-hour maximum 182
3-hour maximum 700
For any period other than an annual period, the applicable
maximum allowable increase may be exceeded during one such
period per year at any one location.
3.02 No pollutant concentration shall exceed any air quality
standard promulgated:
(1) by the Commission; or
(2) by the U.S. Environmental Protection Agency
Section 4: AREA CLASSIFICATION
4.01 Dolly Sods Wilderness Area and Otter Creek Wilderness Area
are designated as Class I and may not be redesignated.
4.02 The Spruce Knob-Seneca Rock National Recreational Area, the
Cranberry National Wilderness, and the New River Gorge
National Scenic River are designated as Class II and may be
redesignated to Class I only.
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4.03 Any national park or national wilderness area exceeding
10,000 acres in size established after the effective date of
this regulation can only be redesignated as Class I.
4.04 The remainder of the State of West Virginia is designated as
Class II and may be redesignated.
Section 5: PROCEDURES FOR REDESIGNATING AREA CLASSIFICATIONS
5.01 At least thirty (30) days prior to the issuance of notice
respecting the redesignation of an area that includes any
Federal lands, the Commission shall provide written notice
to the appropriate Federal Land Manager to confer with the
Commission respecting the redesignation and to request his
submittal of written comments and recommendations.
5.02 At least thirty (30) days prior to the issuance of notice
respecting the redesignation of an area, the Commission
shall consult with the elected leadership of local and other
substate general purpose governments in the area covered by
the proposed redesignation.
5.03 At least thirty (30) days prior to the holding of a public
hearing, the Director shall place a legal advertisement in a
paper of general circulation in the area where the redesig-
nation is proposed. This advertisement shall contain, as a
minimum, the time, date, and location of the public hearing,
the area to be redesignated, and to what classification a
summary of the reasons for redesignation, the availability
and location of more detailed information available for
public inspection, and shall notify the public of its
opportunity to comment on the proposed designation, either
in person or in writing.
5.04 The Director, at the time of notifying the public of its
opportunity to comment on the proposed redesignation, shall
make available for public review in at least one location in
the affected area, a discussion of the reasons for the pro-
posed redesignation, including a satisfactory description
and analysis of the health, environmental, economic, social,
and energy effects of the proposed redesignation.
5.05 The Commission shall consider all comments received during
the public comment period and shall make available its
response to those comments and its final decision at the
same location that the Commission made available the
proposed redesignation materials. Additionally, if in
redesignating any area with respect to which any Federal
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Land Manager had submitted written comments and recommenda-
tions, the Commission shall publish a list of any inconsis-
tency between such redesignation and such comments and
recommendations (together with the reasons for making such
redesignation against the recommendation of the Federal Land
Manager).
5.06 For any area proposed to be redesignated as Class III, the
Commission shall demonstrate that the redesignation would
not cause, or contribute to, a concentration of any air
pollutant which would exceed any maximum allowable increase
permitted under the classification of any other area or any
West Virginia and National Ambient Air Quality Standard.
5.07 For any area proposed for redesignation as Class III in
which a permit application for any major stationary source
or major modification subject to provisions of this regula-
tion has been received by the Commission and that source or
modification could receive a permit only if the area in
question were redesignated as Class III, then any material
submitted as part of that application shall be made avail-
able, insofar as is practicable, for public inspection prior
to any public hearing on redesignation of any area as Class
III.
5.08 The Commission shall not redesignate any areas as Class III
unless concurred with by the Governor after consultation
with the appropriate committees or leadership of the legis-
lature.
5.09 The Commission shall not redesignate any area as Class III
unless the general purpose units of local government
representing a majority of the residents of the area to be
redesignated enact legislation (including resolutions where
appropriate) concurring in the redesignation.
Section 6: PROHIBITION OF DISPERSION ENHANCEMENT TECHNIQUES
6.01 The use of stack heights which exceed good engineering
practice or any dispersion techniques to reduce the con-
centration of any air pollutant and thereby, affect the
degree of emission limitation required is prohibited.
Section 7: REGISTRATION AND REPORT REQUIREMENTS FOR MAJOR STATIONARY
SOURCES AND MAJOR MODIFICATIONS
7.01 No person shall cause, suffer, allow, or permit the con-
struction, modification, or relocation of any major sta-
tionary source or major modification to be commenced after
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the effective date of this regulation without notifying the
Director of such intent and obtaining a permit(s) to so
construct, modify, or relocate the major stationary source
or major modification as herein provided.
7.02 Not later than ninety (90) days, for construction, modifica-
tion, or relocation of a major stationary source or major
modification, prior to the time that such construction,
modification, or relocation is proposed to commence, the
owner or operator of the source shall file with the Director
permit application forms available from the Director. These
applications shall contain sufficient information as, in the
judgment of the Director, will enable him to determine
whether such source construction, modification, or reloca-
tion will be in conformance with the provisions of any rules
and regulations promulgated by the Commission in general and
with the requirements of Sections 8 through 13 of this regu-
lation. Such information may include, but not be limited to:
(1) A description of the nature, location, design capacity,
and typical operating schedule of the source or modifi-
cation, including specifications and drawings showing
its design and plant layout;
(2) A detailed schedule for construction of the source or
modification;
(3) A detailed description as to what system of continuous
emission reduction is planned by the source or modifi-
cation, emission estimates, and any other information
as necessary to determine that best available control
technology as applicable would be applied;
(4) The air quality impact of the source or modification,
including meteorological and topographical data neces-
sary to estimate such impact; and
(5) The air quality impacts and the nature and extent of
any or all general commercial, residential, industrial,
and other growth which has occurred since August 7,
1977, in the area the source or modification would
affect.
7.03 Each permit application shall be signed by the owner or
operator of the major stationary source or major modifica-
tion, and such signature shall constitute an agreement that
the applicant will assume responsibility for the construc-
tion, modification, relocation, or operation of the major
stationary source or major modification in accordance with
applicable rules and regulations of the Commission.
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7.04 Within thirty (30) days of the receipt of a permit applica-
Ition for construction, modification, or relocation of a
major stationary source or major modification, the Commis-
sion shall determine if the application is complete or if
there exists any deficiency in the application or informa-
tion submitted. In the event of such a deficiency, the date
of receipt of the application shall be the date on which the
reviewing authority received all required information.
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7.05 Within one year of the receipt of a permit application for
construction, modification, or relocation of a major
stationary source or major modification, the Director shall
issue such a permit unless he determines that the proposed
major stationary source or major modification has not
satisfied the requirements of Sections 8 through 13 of this
regulation, will violate applicable emission standards, will
interfere with the attainment or maintenance of applicable
ambient air quality standards, or will be inconsistent with
the intent and purpose of this regulation, in which case he
shall issue an order for the prevention of such construc-
tion, modification, or relocation. Failure to issue the
permit or'such order within the time prescribed shall not be
deemed a determination that such construction, modification,
or relocation may proceed.
7.06 When the Director denies a permit application for the pro-
posed construction, modification, or relocation of any major
stationary source or major modification, the order shall set
forth his reasons with reasonable specificity.
7.07 The Director may impose any reasonable conditions as part of
a granted construction, modification, or relocation permit.
Such conditions may include, but not be limited to, the
submission of periodic progress or operation reports, the
provisions of a suitable sampling site, the installation of
pollutant monitoring devices, and the maintenance of ambient
air quality monitoring stations.
Section 8: REQUIREMENTS RELATING TO CONTROL TECHNOLOGY
8.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall meet
each applicable emissions limitation promulgated by the
Commission and each applicable emission standard and
standard of performance under 40 CFR Parts 60 and 61.
8.02 Any person proposing to construct a new major stationary
source shall apply best available control technology for
each regulated pollutant that it would have the potential to
emit in significant amounts.
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8.03 Any person proposing a major modification or relocation of a
major stationary source shall apply best available control
technology for each regulated pollutant which it would be a
significant net emissions increase at the source. This
requirement applies to each proposed emissions unit at which
a net emissions increase in the pollutant would occur as a
result of a physical change or change in the method of
operation in the unit.
8.04 For any proposed construction, modification, or relocation
of a major stationary source or major modification which is
a phased construction project, the determination of best
available control technology shall be reviewed and modified
as appropriate at the least reasonable time which occurs no
later than eighteen (18) months prior to commencement of
construction of each independent phase of the project. At
such time, the owner or operator of the applicable station-
ary source may be required to demonstrate the adequacy of
any previous determination of best available control tech-
nology for the source.
Section 9: REQUIREMENTS RELATING TO THE SOURCE'S IMPACT ON AIR QUALITY
9.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall demon-
strate that allowable emission increases from the proposed
source or modification, in conjunction with all other appli-
cable emissions increases or reduction (including secondary
emissions) would not cause or contribute to air pollution in
violation of:
(1) Any National or West Virginia Ambient Air Quality
Standard; or
(2) Any applicable maximum allowable increase over the
baseline concentration in any area.
Section 10: REQUIREMENTS FOR AIR QUALITY MODELS
10.01 All estimates of ambient concentrations required under
Section 9 of this regulation shall be based on the appli-
cable air quality models, data bases, and other require-
ments specificied in the Guideline on Air Quality Models
(OAQPS 1.2-080, U.S. EPA, Office of Air Quality Planning
and Standards, Research Triangle Park, N.C. 27711, April,
1978).
10.02 Where an air quality impact model specified in the Guide-
line on Air Quality Models is inappropriate, the model may
be modified or another model substituted, provided that:
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(1) The substitution or modification of a model shall be
subject to public comment procedures developed in
accordance with Section 14 of this regulation; and
(2) The Director approves of any substitution or modifica-
tion of a model.
Section 11. REQUIREMENTS FOR AIR QUALITY MONITORING
11.01 Any person proposing to construct or relocate a major sta-
tionary source shall provide an analysis of the ambient air
quality in the area that the major stationary source would
affect for each pollutant that it would have the potential
to emit in a signficant amount.
11.02 Any person proposing to construct a major modification to a
stationary source shall provide an analysis of the ambient
air quality in the area that the major modification would
affect for each pollutant for which there would result in a
significant net emissions increase.
11.03 For those pollutants for which no National or West Virginia
Ambient Air Quality Standard exists, the analysis shall
contain such air quality monitoring data as the Commission
determines is necessary to assess ambient air quality for
that pollutant in any area that the emissions of that
pollutant would affect.
11.04 For those pollutants (other than non-methane hydrocarbons)
for which such an ambient air quality standard does exist,
the analysis shall contain continuous air quality moni-
toring data gathered for purposes of determining whether
emissions of that pollutant would cause or contribute to a
violation of the standard or any maximum allowable increase.
11.05 All ambient air quality monitoring data that is required
shall have been gathered over a period of one year and
shall represent the year preceding receipt of the applica-
tion, except that, if the Commission determines that a
complete and adequate analysis can be accomplished with
monitoring data gathered over a period shorter than one
year (but not to be less than four months), the data that
is required shall have been gathered over at least that
shorter period.
11.06 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall, after
construction of the stationary source or modification,
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conduct such ambient monitoring as the Commission deter-
mines is necessary to determine the effect emissions from
the stationary source or modification may have, or are
having, on air quality in any area.
11.07 Operation of monitoring stations required by this Section
shall meet the requirements of Appendix B of 40 CFR 58
during the operation of the monitoring stations.
Section 12: REQUIREMENTS FOR ADDITIONAL IMPACTS ANALYSIS
12.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall provide:
(1) An analysis of the impairment to visibility, soils,
and vegetation that would occur as a result of the
source or modification and general commercial, resi-
dential, industrial, and other growth associated with
the source or modification. The owner or operator
need not provide an analysis of the impact on vegeta-
tion having no signficant commercial or recreational
value; and
(2) An analysis of the air quality impact projected for
the area as a result of general commercial, residen-
tial, industrial, and other growth associated with the
source or modification.
Section 13: ADDITIONAL REQUIREMENTS FOR SOURCES IMPACTING FEDERAL
CLASS I AREAS
13.01 The Director shall transmit to the Adminstrator a copy of
each permit application relating to a major stationary
source or major modification impacting a Federal Class I
area and provide notice to the Administrator of every
action related to the consideration of such permit.
13.02 The Federal Land Manager of the affected Class I area may
present to the Director during the public review process
developed in Section 14 of this regulation a demonstration
that the emissions from the proposed major stationary
source of major modification would have an adverse impact
on the air quality-related values (including visibility) of
any Federal Class I lands, notwithstanding that the change
in air quality resulting from emissions from such source or
modification would not cause or contribute to concentra-
tions which would exceed the maximum allowable increases
for a Class I area. If the Director concurs with such
demonstration, the Commission shall deny the permit to
construct.
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13.03 Any person proposing to construct, modify, or relocate a
major stationary source or major modification may demon-
strate to the Federal Land Manager that the emissions from
such source would have no adverse impact on the air quality
related values of such lands (including visibility), not-
withstanding that the change in air quality resulting from
emissions from such source or modification would cause or
contribute to concentrations which would exceed the maximum
allowable increases for a Class I area. If the Federal
Land Manager concurs with such demonstration and so certi-
fies to the Director, the Commission may, provided that the
requirements of this regulation are otherwise met, issue
the permit with such emission limitations as may be neces-
sary to assure that emissions of sulfur dioxide and parti-
culate matter would not exceed the following maximum allow-
able increases over baseline concentration for such pollu-
tants:
Maximum Allowable
Pollutant Increase (ug/rn^)
Particulate matter:
Annual geometric mean 19
24-hour maximum 37
Sulfur dioxide:
Annual arithmetic mean 20
24-hour maximum 91
3-hour maximum 325
13.04 Any person proposing to construct, modify, or relocate a
major stationary source or major modification affecting a
Class I area which cannot be approved under Section 13.03
of this regulation may demonstrate to the Governor that the
source or modification cannot be constructed by reason of
any maximum allowable increase for sulfur dioxide for
periods of 24 hours or less applicable to any Class I area
and, in the case of Federal Class I areas, that a variance
under this clause would not adversely affect the air
quality related values of the area (including visibility);
(1) The Governor, after consideration of the Federal Land
Manager's recommendation (if any) and subject to his
concurrence, may grant, after notice and an oppor-
tunity for a public hearing, a variance from such
maximum allowable increase; and
(2) If such variance is granted, the Commission may issue
a permit to such source or modification in accordance
with provisions of Section 13.06 of this regulation,
provided that the requirements of this regulation are
otherwise met.
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13.05 Whenever the Federal Land Manager does not concur with the
Governor to grant a variance under Section 13.04 of this
regulation, the recommendations of the Governor and the
Federal Land Manager shall be transferred to the President.
(1) The President may approve the Governor's recommenda-
tion if he finds that such variance is in the national
interest; and
(2) If such a variance is approved, the Commission may
issue a permit in accordance with the requirements of
Section 13.06 of this regulation, provided that the
requirements of this regulation are otherwise met.
13.06 Any permit issued by the Commission pursuant to Section
13.04 or 13.05 of this regulation shall contain such emis-
sion limitations as may be necessary to assure that emis-
sions of sulfur dioxide from the major stationary source or
major modification would not (during any day on which the
otherwise applicable maximum allowable increases are
exceeded) cause or contribute to concentrations which would
exceed the following maximum allowable increases over the
baseline concentration and to assure that such emissions
would not cause or contribute to concentrations which
exceed the otherwise applicable maximum allowable increases
for periods of exposure of 24 hours or less for more than
eighteen (18) days, not necessarily consecutive, during any
annual period:
Maximum Allowable Increase (ug/rrr)
Terrain Areas
Period of Exposure Low High
24-hour maximum 36 62
3-hour maximum 130 221
Section 14: PUBLIC REVIEW PROCEDURES
14.01 After finishing its review of the complete application, the
Commission shall make a preliminary determination whether
the permit should be approved, approved with conditions, or
disapproved.
14.02 The Commission shall make available in at least one loca-
tion in each region in which the proposed source would be
constructed a copy of all materials the applicant sub-
mitted, a copy of the preliminary determination, and a copy
or summary of other materials, if any, considered in making
the preliminary determination.
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14.03 The Director shall place a legal advertisement in a paper
of general circulation in the area where the proposed
source would be constructed, modified, or relocated. The
advertisement shall contain, as a minimum, the name of the
applicant, the type and location of the source, the pro-
posed startup date, the preliminary determination, the
degree of increment consumption that is expected from the
source or modification, and of the opportunity for comment
at a public hearing as well as written public comment. The
public comment period of thirty (30) days or longer will be
stated in this notice.
14.04 The Commission shall send a copy of the notice of public
comment to the applicant, the Administrator and to offi-
cials and agencies having cognizance over the location
where the proposed construction would occur as follows:
any other State or local air pollution control agencies,
the chief executives of the city and county where the
source would be located; any comprehensive regional land
use planning agency, and any State, Federal Land Manager,
whose lands may be affected by emissions from the source or
modification.
14.05 The Commission shall provide opportunity for a public
hearing for interested persons to appear and submit written
or oral comments on the air quality impact of the source,
alternatives to it, the control technology required, and
other appropriate considerations.
14.06 Public comments submitted within thirty (30) days (or longer
if stated in the notice of public comment) after the Direc-
tor's public notification of an opportunity for comment
upon a proposed construction, modification, or relocation
of a major stationary source or major modification shall be
considered by the Director before making a final decision
on the approvability of the application. The Commission
shall make all comments available for public inspection in
the same locations where the Commission made available pre-
construction information relating to the proposed source or
modification.
14.07 The Commission shall make a final determination whether
construction should be approved, approved with conditions,
or disapproved.
I 14.08 The Commission shall notify the applicant in writing of the
final determination and make such notification available
_ for public inspection at the same location where the Commis-
I sion made available preconstruction information and public
H rnmmonfc volal-irm tn thp nrnrmcorl cnnrr-o nr mnrli f i rat i r\n
comments relating to the proposed source or modification.
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Section 15: PUBLIC MEETINGS
15.01 Public meetings to receive comments on direct and/or in-
direct permit applications will be held when the Director
deems it appropriate or when substantial interest is ex-
pressed, in writing, by persons who might reasonably be
expected to be affected by the proposed source or modifi-
cation.
15.02 The Director, the Commission, or a duly authorized employee
of the Commission shall preside over such meetings and
insure that all interested parties have ample opportunity
to present comments. Such meetings shall be held at a
convenient place as near as practicable to the location of
the proposed source or modification.
15.03 At a reasonable time prior to such meetings, the Director
shall provide appropriate information to news media in the
area where the proposed source or modification is to be
located.
Section 16: PROCEDURES FOR SOURCES EMPLOYING INNOVATIVE CONTROL
TECHNOLOGY
16.01 Any person proposing to construct or modify a major sta-
tionary source or major modification may demonstrate to the
Commission that the proposed construction or modification
would employ Innovative Control Technology. The proposed
Innovative Control Technology shall meet the following
conditions:
(1) The proposed control system would not cause or con-
tribute to an unreasonable risk to public health,
welfare, or safety in its operation or function;
(2) The proposed source or modification must achieve a
level of continuous emissions reduction equivalent to
that which would have been required under Section 8 of
this regulation by a date specified by the Commission.
(3) The source or modification would meet the requirements
equivalent to those in Section 8 through 13 of this
regulation, based on the emissions rate that the
stationary source employing the system of best avail-
able control technology would be required to meet on
the date specified by the Commission.
(4) The source or modification would not before the date
specified by the Commission:
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(a) cause or contribute to any violation of an appli-
cable national ambient air quality standard; or
(b) impact any Class I area; or
(c) impact any area where an applicable increment is
known to be violated.
16.02 The Commission shall consult with the governor(s) of other
state(s) and the Federal Land Manager(s) of areas impacted
by the proposed source or modification.
16.03 The Commission, with the concurrence of the governor(s) of
other state(s) and the Federal Land Manager(s), may make a
determination that the source or modification would be
employing innovative control technology.
16.04 The Commission shall specify a date by which the source or
modification must meet the requirements of Section 16.01 of
this regulation. Such date shall not be later than four-
years from the time of startup or seven years from permit
issuance'.
16.05 The Commission shall withdraw any approval to employ a
system of innovative control technology made under this
section of the regulation of:
(1) The proposed system fails by the specified date to
achieve the required continuous emissions reduction
rate; or
(2) The proposed system fails before the specified date so
as to contribute to an unreasonable risk to public
health, welfare, or safety; or
(3) The Commission decides at any time that the proposed
system is unlikely to achieve the required level of
control or to protect the public health, welfare, or
safety.
16.06 If the source or modification fails to meet the required
level of continuous emissions reduction within the speci-
fied time period, or if the approval is withdrawn in
accordance with Section 16.05 of this regulation, the
Commission shall specify a date by which the source or
modification shall meet the requirement for the application
of best available control technology through use of a
demonstrated system of control. This date shall not exceed
three years from the date that the end of the specified
time period or the date that the approval is withdrawn,
whichever is earlier.
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Section 17: EXCLUSIONS FROM INCREMENT CONSUMPTION
17.01 The following concentrations shall be excluded in deter-
mining compliance with a maximum allowable increase:
(1) Concentrations attributable to the increase in emis-
sions from stationary sources which have converted
from the use of petroleum products, natural gas, or
both by reason of an order in effect under Sections
2(a) and (b) of the Energy Supply and Environmental
Coordination Act of 1974 (or any superseding legisla-
tion) over the emissions from such sources before the
effective date of such an order;
(2) Concentrations attributable to the increase in emis-
sions from sources which have converted from using
natural gas by reason of natural gas curtailment plan
in effect pursuant to the Federal Power Act over the
emissions from such sources before the effective date
of such plan;
(3) Concentrations of particulate matter attributable to
the increase in emissions from construction or other
temporary emission-related activities of new or modi-
fied sources;
(4) Concentrations attributable to the temporary increase
in emissions of sulfur dioxide or particulate matter
from stationary sources which result from a revision
to any rule or regulation of the State of West Virginia
provided that the following conditions are met:
(a) The time over which the temporary emissions in-
crease of sulfur dioxide or particulate matter
would occur shall be specified by the Director
and shall not exceed two years unless the Director
specifies that a longer time is more appropriate.
(b) The time period specified in Section 17.01 (4)(a)
shall not be extended.
(c) The emissions increase from the source or modifi-
cation would not
(i) impact a Class I area;
(ii) impact an area where an applicable incre-
ment is known to be violated; or
(iii) cause or contribute to the violation of a
national ambient air quality standard.
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(d) The emission limitations required to be in effect
at the end of the time period specified in
Section 17.01 (4)(a) must ensure that the emis-
sion levels from stationary sources affected by
the revision to the West Virginia rule or regula-
tion would not exceed those levels occurring from
such sources before the revision was promulgated
by the Commission.
17.02 No exclusion of such concentrations shall apply more than
five (5) years after the effective date of the order to
which Section **.01 (1) of the regulation refers or the
plan to which Section 17.01 (2) of this regulation refers,
whichever is applicable. If both such order and plan are
applicable, no such exclusion shall apply more than five
(5) years after the later of such effective dates.
Section 18: PROCEDURES FOR EXEMPTIONS FROM SPECIFIC SECTIONS OF
THIS REGULATION
18.01 A non-profit health or non-profit educational institution
proposed to construct, modify, or relocate a major sta-
tionary source or major modification may petition the
Director for an exemption from the requirements of Sections
8 through 13 of this regulation.
18.02 Any person proposing to construct, modify, or relocate a
source which does not belong to any category listed in
Table 2 may petition the Director to exclude fugitive
emissions, to the extent quantifiable, in the calculation
of potential to emit.
18.03 Any person proposing to relocate a source or modification
that is a portable stationary source which has previously
received a permit under this regulation may petition the
Director for an exemption from the requirements of Sections
8 through 13 of this regulation. The Commission may grant
this exemption if the following conditions are met:
(1) The source proposes to relocate and emissions of the
source at the new location would be temporary; and
(2) The emissions from the source would not exceed its
allowable emissions; and
(3) The emissions from the source would impact no Class I
area and no area where an applicable increment is
known to be violated; and
(4) The source identifies the proposed new location and
the probable duration of operation at the new location.
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18.04 Any person proposing to construct, modify, or relocate a
major stationary source or major modification may petition
the Director for an exemption from the requirements of
Sections 8 through 13 of this regulation with respect to a
particular pollutant, if the allowable emissions of that
pollutant from a new source, or the net emissions increase
of that pollutant from a modification, would be temporary
and impact no Class I area and no area where an applicable
increment is know to be violated.
18.05 Any person proposing to modify a major stationary source
that was in existence prior to March 1, 1978 may petition
the Director for an exemption from the requirements of
Sections 9, 11, and 12 of this regulation with respect to a
particular pollutant, if the net increase in allowable
emissions of each pollutant for which the Commission has
promulgated an emission or air quality standard from the
modification after the application of best available
control technology would be less than 50 tons per year.
18.06 Any person proposing to construct, modify, or relocate a
major stationary source or major modification may petition
the Director for an exemption from the requirements of
Section 11 of this regulation with respect to a particular
pollutant if:
(1) The applicant demonstrates that the emissions increase
of the pollutant from a new stationary source or the
net emissions increase of the pollutant from a modi-
fication would cause, in any area, an air quality
impact less than that listed in Table 3; or
(2) The applicant demonstrates that the existing concen-
trations of the pollutant in the area that the source
or modification would affect are less than that listed
in Table 3; or
(3) The applicant's request is for any pollutant which is
not listed in Table 3.
18.07 Any person proposing to construct, modify, or relocate a
major stationary source or major modification of volatile
organic compounds may petition the Director for an exemp-
tion from the requirements of Section 11.05 of this regula-
tion that the continuous air monitoring data be representa-
tive of the year preceding the receipt of the application.
The Director may grant such an exemption if the following
conditions are met:
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Table 2.
SOURCE CATEGORIES WHICH MUST INCLUDE FUGITIVE EMISSIONS
o Coal cleaning plants (with thermal dryers)
o Kraft pulp mills
o Portland cement plants
o Primary zinc smelters
o Iron and steel mills
o Primary aluminum ore reduction plants
o Primary copper smelters
o Municipal incinerators capable of charging more than 250 tons
of refuse per day
o Hydrofluoric, sulfuric, or nitric acid plants
o Petroleum refineries
o Lime plants
o Phosphate rock processing plants
o Coke oven batteries
o Sulfur recovery plants
o Carbon black plants (furnace process)
o Primary lead smelters
o Fuel conversion plants
o Sintering plants
o Secondary metal production plants
o Chemical process plants
o Fossil-fuel boilers (or combination thereof) totaling more than
250 million British thermal units per hour heat input
o Petroleum storage and transfer units with a total storage
capacity exceeding 300,000 barrels
o Taconite ore processing plants
o Glass fiber processing plants
o Charcoal production plants
o Fossil-fuel-fired steam electric plants of more than 250
million British thermal units per our heat input
o Any other stationary source category which, as of August 7,
1980, is being regulated under Section 111 or 112 of the Clean
Air Act.
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Table 3. DE MINIMIS AIR QUALITY IMPACTS
o Carbon monoxide - 575 ug/m , 8-hour average
o Nitrogen dioxide - 14 ug/m , annual average
o Total suspended particulate - 10 ug/m , 24-hour average
o Sulfur dioxide - 13 ug/m , 24-hour average
o Ozone - no minimum air quality value
o Lead - 0.1 ug/m , 24-hour average
3
o Mercury - 0.25 ug/m , 24-hour average
3
o Beryllium - 0.0005 ug/m , 24-hour average
3
o Fluorides - 0.-25 ug/m , 24-hour average
o Vinyl chloride - 15 ug/m , 24-hour average
o Total reduced sulfur - 10 ug/m , 1-hour average
o Hydrogen sulfide - 0.04 ug/m , 1-hour average
o Reduced sulfur compounds - 10 ug/m , 1-hour average
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(1) The proposed major stationary source or major modifi-
cation for volatile organic compounds satisfies all
conditions of 40 CFR Part 51, Appendix S, Section IV.
(2) The continuous air monitoring data for ozone must be
gathered for a period of one year and shall represent
the year following the issuance of the permit, except
that, if the Commission determines that a complete and
adequate analysis can be accomplished with monitoring
data gathered over a period shorter than one year (but
not to be less than four months), the data that is
required shall have been gathered over at least that
shorter period.
Section 19: PERMIT TRANSFER, CANCELLATION, AND RESPONSIBILITY
19.01 A permit shall not be transferable.
19.02 The Director will cancel or suspend a permit if, after six
(6) months from the date of issuance the holder of the
permit cannot provide the Director, at the Director's
request,'with written proof of a good faith effort that
such construction, modification, or relocation has com-
menced. Such proof shall be provided not later than thirty
(30) days after the Director's request.
19.03 The Director may cancel or suspend the permit if the plans
and specifications upon which the approval was based and/or
the conditions established in the permit are not adhered to.
19.04 Any person who owns and operates any particular source or
modification which becomes a major stationary source or
major modification solely by virtue of a relaxation in any
limitation, enforceable by the U.S. Environmental Protec-
tion Agency or the State of West Virginia, on the capacity
of the source or modification otherwise to emit a pollutant
restriction on hours of operation, shall become subject to
the requirements of this regulation as though construction
had not yet commenced on the source or modification.
Section 20: CONFLICT WITH OTHER RULES OR REGULATIONS
20.01 When a provision of this regulation conflicts with a similar
portion(s) of any rule or regulation previously adopted by
the Commission, the provision(s) of this regulation shall
apply.
Section 21: EFFECTIVE DATE
21.01 Regulation
shall become effective on
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ATTACHMENT B
SHORT PSD RULE
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SUBJECT: Regulation - Permits for Construction and
Modification of Stationary Sources of Air Pollution for the
Prevention of Significant Deterioration.
Section 1: INTENT AND PURPOSE
1.01 To insure that economic growth will occur in harmony with
the preservation of existing clean air resources; to prevent
the development of any new non-attainment problems; to pro-
tect the public health and welfare from any adverse effects
which might occur even at air quality levels better than the
West Virginia and national ambient air quality standards;
and to preserve, protect, and enhance the air quality in
areas of special natural recreational, scenic, or historic
value, it is the intent of the Commission to register and
evaluate sources of air pollutants and to preclude the
construction, modification, or relocation of any major sta-
tionary source or major modification in any locality in
which the' establishment of such source or modification may
interfere with the goals of the prevention of significant
deterioration of air quality levels.
The purpose of this regulation is to quantitatively define
significant deterioration of air quality with respect to the
desired degree of preservation of air quality for various
areas and to set forth procedures for registration and
reporting, and the criteria for obtaining a permit to con-
struct, modify, or relocate a major stationary source or
major modification within the State of West Virginia. Such
construction, modification, or relocation without such a
permit is a violation of this regulation.
Section 2: DEFINITIONS
2.01 "Major Stationary Source" shall mean:
(1) any stationary source which emits or has the potential
to emit, 100 tons per year or more of any regulated
pollutant and is one of the stationary sources named in
Table 1.
(2) any stationary source which emits or has the potential
to emit, 250 tons per year or more of any regulated
pollutant and is not one of the stationary sources
named in Table 1.
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Table 1. STATIONARY SOURCES OF AIR POLLUTANTS
o Fossil Fuel Fired Steam Electric Plants greater than or equal to
250 million Btu/hour Heat Input
o Coal Cleaning Plants (with thermal dryers)
o Kraft Pulp Mills
o Portland Cement Plants
o Primary Zinc Smelters
o Iron and Steel Mill Plants
o Primary Aluminum Ore Reduction Plants
o Primary Copper Smelters
o Municipal Incinerators Capable of Charging greater than or equal to
250 tons of refuse/day
o Hydrofluoric, Sulfuric, and Nitric Acid Plants
o Petroleum Refineries
o Lime Plants
o Phosphate Rock Processing Plants
o Coke Oven Batteries
o Sulfur Recovery Plants
o Carbon Black Plants (furnace process)
o Primary Lead Smelters
o Fuel Conversion Plants
o Sintering Plants
o Secondary Metal Production Plants
o Chemical Process Plants
o Fossil Fuel Boilers (or combinations thereof) Totaling 250 million
Btu/hour Heat Input or more
o Petroleum Storage and Transfer Units with a Total Storage Capacity
Exceeding 300,000 barrels
o Taconite Ore Processing Plants
o Glass Fiber Processing Plants
o Charcoal Production Plants
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(3) any physical change at a stationary source if the
•change itself would constitute a major stationary
source.
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2.02 "Major Stationary Source for Ozone" shall mean a major
stationary source of volatile organic compounds.
2.03 "Major Modification" means any physical change in or change
in the method of operation of a major stationary source
which results in a significant emission increase of any
regulated pollutant. However, the following actions shall
not constitute a modification of a affected source:
(1) Routine maintenance, repair, and replacement.
(2) Use of an alternative fuel or raw material by reason of
any order under Sections 2(a) and (b) of the Energy
Supply and Environmental Coordination Act of 1974 (or
any su'perceding legislation) or by reason of a natural
gas curtailment plant pursuant to the Federal Power Act.
(3) Use of an alternative fuel by reason of an order or
rule under Section 125 of the Clean Air Act.
(4) Use of municipal solid waste as an alternative fuel at
a steam generating unit.
(5) Use of an alternative fuel or raw material, provided
that prior to the effective date of this regulation,
the affect source is designed to accomodate such alter-
native fuel use unless such change would be prohibited
by a Federal permit issued pursuant to 40 CFR 52.21 or
by any permit issued pursuant to this regulation.
(6) An increase in the hours of operations unless such
increase would be prohibited by a Federal permit issued
pursuant to 40 CFR 52.21 or by any permit issued pur-
suant to this regulation.
(7) An increase in the production rate unless such increase
would be prohibited by a Federal permit issued pursuant
to 40 CFR 52.21 or by any permit issued pursuant to
this regulation.
(8) Any change in ownership at a stationary source.
2.04 "Major Modification for Ozone" shall mean a major modifi-
cation for volatile organic compounds.
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2.05 "Potential To Emit" means the maximum capacity of a station-
ary source to emit a pollutant under its physical and opera-
tional design. Any physical or operational limitation on
the capacity of the source to emit a pollutant, including
air pollution control equipment and restrictuions on hours
of operation or on the type or amount of material combusted,
stored, or processed, shall be treated as part of its design
if the limitation or the effect it would have on emissions
is enforceable in any permit and/or consent order issued by
U.S. Environmental Protection Agency or by the Commission.
Secondary emissions do not count in determining the poten-
tial to emit of a stationary source.
2.06 "Stationary Source" means any building, structure, facility,
or installation which emits or may emit any regulated air
pollutant.
2.07 "Building, .Structure, Facility, or Installation" means all
of the pollutant-emitting activities which belong to the
same industrial grouping, are located on one or more
contiguous or adjacent properties, and are under the control
of the same person (or persons under common control).
Pollutant-emitting activities shall be considered as part of
the same industrial grouping if they belong to the same
"Major Group" (i.e., which have the same two-digit code) as
described in the Standard Industrial Classification Manual,
1972, as amended by the 1977 Supplement (U.S. Government
Printing Office stock numbers 4101-0066 and 003-005-00176-0,
respectively).
2.08 "Emissions Unit" means any part of a stationary source which
emits or would have the potential to emit any regulated
pollutant.
2.09 "Construction" means any physical change or change in the
method of operation (including fabrication, erection,
installation, demolition, or modification of an emissions
unit) which would result in a change in actual emissions.
2.10 "Commence" as applied to construction of a major staionary
source or major modification means that the owner or opera-
tor has all necessary preconstruction approvals or permits
and either has:
(1) begun, or caused to begin, a continuous program of
actual on-site construction of the source, to be
completed within a reasonable time; or
(2) entered into binding agreements or contractual obliga-
tions, which cannot be cancelled or modified without
substantial loss to the owner or operator, to undertake
a program of actual construction of the source to be
completed within a reasonable time.
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2.11 "Necessary Preconstruction Approvals or Permits" means those
permits or approvals required under Federal air quality
control laws and regulations and air quality control laws
and regulations of the State of West Virginia.
2.12 "Begin Actual Construction" means, in general, initiation of
physical on-site construction activities on an emissions
unit which are of a permanent nature. Such activities
include, but are not limited to, installation of building
supports and foundations, laying of underground pipework,
and construction of permanent storage structures. With
respect to a change in method of operation, this term refers
to those on-site activities, other than preparatory activi-
ties, which mark the initiation of the change.
2.13 "Best Available Control Technology" means an emissions limi-
tation (including a visible emissions standard) based on the
maximum degree of reduction for each regulated pollutant
which would be emitted from any proposed major stationary
source or major modification which the Commission, on a
case-by-case basis, taking into account energy, environ-
mental, and economic impacts and other costs, determines is
achievable for such source or modification through applica-
tion of production processes or available methods, systems,
and techniques, including fuel cleaning or treatment or
innovative fuel combination techniques for control of such
pollutant. In no event shall application of best available
control technology result in emissions of any pollutant
which would exceed the emissions allowed by any applicable
standard under 40 CFR Parts 60 and 61. If the Commission
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 pre-
scribed instead to satisfy the requirement for the applica-
tion of best available control technology. Such standard
shall, to the degree possible, set forth the emissions
reduction achievable by implementation of such design,
equipment, work practice or operation, and shall povide for
compliance by means which achieve equivalent results.
2.14 "Baseline Concentration" means that ambient concentration
level which exists in the baseline area at the time of the
applicable baseline date. A baseline concentration is
determined for each pollutant for which a baseline date is
established and shall include:
(1) The allowable emissions of major staionary sources
which commenced construction before January 6, 1975,
but were not in operation by the applicable baseline
date.
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(2) The actual emissions representative of sources in
existence on the applicable baseline date. However,
the following will not be included in the baseline
concentration and will affect the applicable maximum
allowable increase(s):
(a) actual emissions from any major stationary source
on which construction commenced after January 6,
1975; and
(b) actual emissions increases and decreases at any
stationary source occurring after the baseline
date.
2.15 "Baseline Date" means the earliest date after August 7, 1977,
on which the first complete application under 40 CFR 52.21
is submitted by a major stationary source or major modifica-
tion subject to the requirements of 40 CFR 52.21 or the date
of the first complete application required by this regula-
tion, whichever is earlier. The baseline date is estab-
lished for each pollutant for which increments or other
equivalent measures have been established if:
(1) The area in which the proposed source or modification
would construct is designated as attainment or
unclassifiable under Section 107(d)(l)(D) or (E) of the
Clean Air Act for the pollutant on the date of its
complete application under 40 CFR 52.21 or this regu-
lation; and
(2) The pollutant would be emitted in significant amounts.
2.16 "Baseline Area" means any intrastate area (and every part
thereof) designated as attainment or unclassifiable under
Section 107(d)(l)(D) or (E) of the Clean Air Act in which
the major source or major modification establishing the
baseline date would construct or would have an air quality
impact equal to or greater than 1 ug/m^ (annual average)
of the pollutant for which the baseline date is established.
Area redesignation under Section 107(d)(l)(D) or (E) of the
Clean Air Act cannot intersect or be smaller than the area
of impact of any major stationary source or major modifica-
tion which:
(1) establishes a baseline date; or
(2) is subject to 40 CFR 52.21; or
(3) is subject to this regulation.
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2.17 "Allowable Emissions" means the emissions rate of a station-
ary source calculated using the maximum rated capacity of
the source (unless the source is subject to Federally
enforceable limits or limits enforceable by the Commission
which restrict the operating rate, or hours of operation, or
both) and the most stringent of the following:
(1) The applicable standards as set forth in 40 CFR Parts
60 and 61;
(2) The applicable State of West Virginia emissions limi-
tations, including those with a future compliance date;
or
(3) The emissions rate specified as a Federally enforceable
permit condition or permit condition enforceable by the
Commission, including those with a future compliance
date.
2.18 "Federally Enforceable" means all limitations and conditions
which are enforceable by the Administrator of the U.S. EPA
including'those requirements developed pursuant to 40 CFR
Parts 60 and 61 requirements, rules and regulations of the
approved State Implementation Plan of the State of West
Virginia, and any permit requirements established pursuant
to 40 CFR 52.21 or this regulation.
2.19 "Secondary Emissions" means emissions which would occur as a
result of the construction or operation of a major station-
ary source or major modification, but do not come from the
major stationary source or major modification itself. For
the purpose of this section, secondary emissions must be
specific, well defined, quantifiable, and impact the same
general area as the stationary source or modification which
causes the secondary emissions. Secondary emissions may
include, but are not limited to:
(1) Emissions from ships or trains coming to or from the
new or modified stationary source; and
(2) Emissions from any off-site support facility which
would not otherwise be constructed or increase its
emissions as a result of the construction or operation
of the major stationary source or major modification.
2.20 "Actual Emissions" means the actual rate of emissions of a
pollutant from an emissions unit, as described below:
(1) In general, actual emissions as of a particular date
shall equal the average rate, in tons per year, at
which the unit actually emitted the pollutant during a
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two-year period which precedes the particular date and
which is representative of normal source operation.
The Director shall allow the use of a different time
period upon a determination that it is more representa-
tive of normal source operation. Actual emissions
shall be calculated using the unit's actual operating
hours, production rates, and types of materials pro-
cessed, stored, or combusted during the selected time
period.
(2) The Director may presume that source-specific allowable
emissions for the unit are equivalent to the actual
emissions of the unit.
(3) For any emissions unit which has not begun normal
operations on the particular date, actual emissions
shall equal the potential to emit of the unit on that
date.
2.21 "Complete" means, in reference to an application for a
permit, that the application contains all of the information
necessary'for processing the application. Designating an
application complete for purposes of permit processing does
not preclude the reviewing authority from requesting or
accepting any additional information.
2.22 "Significant" means, in reference to an emission increase or
the potential of a source to emit any of the following
pollutants, a rate of emissions that would equal or exceed
any of the following rates:
Pollutant and Emissions Rate
Carbon monoxide: 100 tons per year (TPY)
Nitrogen oxides: 40 TPY
Sulfur dioxide: 40 TPY
Particulate matter: 25 TPY
Ozone: 40 TPY of volatile organic compounds
Lead: 0.6 TPY
Asbestos: 0.007 TPY
Beryl!Hum: 0.0004 TPY
Mercury: 0.1 TPY
Vinyl chloride: 1 TPY
Fluorides: 3 TPY
Sulfuric acid mist: 7 TPY
Hydrogen sulfide (H2S): 10 TPY
Total reduced sulfur (including H2S): 10 TPY
Reduced sulfur compounds (including h^S): 10 TPY
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2.23 "Significant" means the potential of a source to emit a
pollutant subject to regulation for which the Commission has
promulgated an emission or air quality standard that is not
listed in Section 2.22 of this regulation, any emissions
rate.
2.24 "Significant" means any emissions rate associated with a
major stationary source or major modification, which would
construct within ten (10) kilometers of any Class I area,
and have an impact on such area equal to or greater than 1
ug/m-3 (24-hour average).
2.25 "Federal Land Manager" means, with respect to any lands in
the United States, the Secretary of the department with
authority over such lands.
2.26 "Air Pollutants" shall mean solids, liquids, or gases which,
if discharged into the air, may result in a statutory air
pollution.
2.27 "Emission" shall refer to the release, escape, or emission
of air pollutants into the air.
2.38 "Air Pollution", 'statutory air pollution', shall have the
meaning ascribed to it in Section 2 of Chapter 16, Article
20 of the Code of West Virginia, as amended.
2.29 "Commission" shall mean the West Virginia Air Pollution
Control Commission.
2.30 "Director" shall mean the Director of the West Virginia Air
Pollution Control Commission.
2.31 "Person" shall mean any and all persons, natural or artifi-
cial, including any municipal, public, or private corpora-
tion organized or existing under the laws of this or any
other state or country, and any firm, partnership, or
association of whatever nature.
2.32 "Relocation" shall mean the physical movement of a source
outside its existing plant boundaries.
2.33 "Regulated Pollutant" or "Regulated Air Pollutant" means,
for the purposes of this regulation, any of the following
pollutants:
o Carbon Monoxide
o Nitrogen Oxides
o Particulate Matter
o Ozone (volatile organic compounds)
o Lead
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o Asbestos
o Beryllium
o Mercury
o Vinyl Chloride
o Fluorides
o Sulfuric Acid Mist
o Hydrogen Sulfide (H2S)
o Total Reduced Sulfur Compounds (including H2S)
o Reduced Sulfur Compounds (including
2.34 "Administrator" shall mean the Administrator of the U.S.
Environmental Protection Agency.
Section 3: AMBIENT AIR QUALITY CEILINGS
3.01 No increases in pollutant concentrations over the baseline
concentrations are allowed in excess of those listed below.
Maximum Allowable
Pollutant- Increase (ug/m3)
Class I
Particulate matter:
Annual geometric mean 5
24-hour maximum 10
Sulfur dioxide:
Annual arithmetic mean 2
24-hour maximum 5
3-hour maximum 25
Class II
Particulate matter:
Annual geometric mean 19
24-hour maximum 37
Sulfur dioxide:
Annual arithmetic mean 20
24-hour maximum 91
3-hour maximum 512
Class III
Particulate matter:
Annual geometric mean 37
24-hour maximum 75
Sulfur dioxide:
Annual arithmetic mean 40
24-hour maximum 182
3-hour maximum 700
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For any period other than an annual period, the applicable
maximum allowable increase may be exceeded during one such
period per year at any one location.
3.02 No pollutant concentration shall exceed any air quality
standard promulgated:
(1) by the Commission; or
(2) by the U.S. Environmental Protection Agency
Section 4: AREA CLASSIFICATION
4.01 Dolly Sods Wilderness Area and Otter Creek Wilderness Area
are designated as Class I.
4.02 The Spruce Knob-Seneca Rock National Recreational Area, the
Cranberry National Wilderness, and the New River Gorge
National Scenic River are designated as Class II.
4.03 The remainder of the State of West Virginia is designated as
Class II."
Section 5: PROHIBITION OF DISPERSION ENHANCEMENT TECHNIQUES
5.01 The use of stack heights which exceed good engineering
practice or any dispersion techniques to reduce the con-
centration of any air pollutant and thereby, affect the
degree of emission limitation required is prohibited.
Section 6: REGISTRATION AND REPORT REQUIREMENTS FOR MAJOR STATIONARY
SOURCES AND MAJOR MODIFICATIONS
6.01 No person shall cause, suffer, allow, or permit the con-
struction, modification, or relocation of any major sta-
tionary source or major modification to be commenced after
the effective date of this regulation without notifying the
Director of such intent and obtaining a permit(s) to so
construct, modify, or relocate the major stationary source
or major modification as herein provided.
6.02 Not later than ninety (90) days, for construction, modifica-
tion, or relocation of a major stationary source or major
modification, prior to the time that such construction,
modification, or relocation is proposed to commence, the
owner or operator of the source shall file with the Director
permit application forms available from the Director. These
applications shall contain sufficient information as, in the
judgment of the Director, will enable him to determine
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reviewing authority received all required information.
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whether such source construction, modification, or reloca-
tion will be in conformance with the provisions of any rules
and regulations promulgated by the Commission in general and
with the requirements of Sections 7 through 11 of this regu-
lation. Such information may include, but not be limited to:
(1) A description of the nature, location, design capacity,
and typical operating schedule of the source or modifi-
cation, including specifications and drawings showing
its design and plant layout;
(2) A detailed schedule for construction of the source or
modification;
(3) A detailed description as to what system of continuous
emission reduction is planned by the source or modifi-
cation, emission estimates, and any other information
as necessary to determine that best available control
technology as applicable would be applied;
(4) The air quality impact of the source or modification,
including meteorological and topographical data neces-
sary to estimate such impact; and
(5) The air quality impacts and the nature and extent of
any or all general commercial, residential, industrial,
and other growth which has occurred since August 7,
1977, in the area the source or modification would
affect.
6.03 Each permit application shall be signed by the owner or
operator of the major stationary source or major modifica-
tion, and such signature shall constitute an agreement that
the applicant will assume responsibility for the construc-
tion, modification, relocation, or operation of the major
stationary source or major modification in accordance with
applicable rules and regulations of the Commission.
6.04 Within thirty (30) days of the receipt of a permit applica-
tion for construction, modification, or relocation of a
major stationary source or major modification, the Commis-
sion shall determine if the application is complete or if
there exists any deficiency in the application or informa-
tion submitted. In the event of such a deficiency, the date
6.05 Within one year of the receipt of a permit application for
construction, modification, or relocation of a major
stationary source or major modification, the Director shall
issue such a permit unless he determines that the proposed
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major stationary source or major modification has not
satisfied the requirements of Sections 7 through 11 of this
regulation, will violate applicable emission standards, will
interfere with the attainment or maintenance of applicable
ambient air quality standards, or will be inconsistent with
the intent and purpose of this regulation, in which case he
shall issue an order for the prevention of such construc-
tion, modification, or relocation. Failure to issue the
permit or such order within the time prescribed shall not be
deemed a determination that such construction, modification,
or relocation may proceed.
6.06 When the Director denies a permit application for the pro-
posed construction, modification, or relocation of any major
stationary source or major modification, the order shall set
forth his reasons with reasonable specificity.
6.07 The Director may impose any reasonable conditions as part of
a granted construction, modification, or relocation permit.
Such conditions may include, but not be limited to, the
submission of periodic progress or operation reports, the
provisions of a suitable sampling site, the installation of
pollutant monitoring devices, and the maintenance of ambient
air quality monitoring stations.
Section 7: REQUIREMENTS RELATING TO CONTROL TECHNOLOGY
7.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall meet
each applicable emissions limitation promulgated by the
Commission and each applicable emission standard and
standard of performance under 40 CFR Parts 60 and 61.
7.02 Any person proposing to construct a new major stationary
source shall apply best available control technology for
each regulated pollutant that it would have the potential to
emit in significant amounts.
7.03 Any person proposing a major modification or relocation of a
major stationary source shall apply best available control
technology for each regulated pollutant which it would be a
significant net emissions increase at the source. This
requirement applies to each proposed emissions unit at which
a net emissions increase in the pollutant would occur as a
result of a physical change or change in the method of
operation in the unit.
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7.04 For any proposed construction, modification, or relocation
of a major stationary source or major modification which is
a phased construction project, the determination of best
available control technology shall be reviewed and modified
as appropriate at the least reasonable time which occurs no
later than eighteen (18) months prior to commencement of
construction of each independent phase of the project. At
such time, the owner or operator of the applicable station-
ary source may be required to demonstrate the adequacy of
any previous determination of best available control tech-
nology for the source.
Section 8: REQUIREMENTS RELATING TO THE SOURCE'S IMPACT ON AIR QUALITY
8.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall demon-
strate that allowable emission increases from the proposed
source or modification, in conjunction with all other appli-
cable emissions increases or reduction (including secondary
emissions) would not cause or contribute to air pollution in
viol ation' of:
(1) Any National or West Virginia Ambient Air Quality
Standard; or
(2) Any applicable maximum allowable increase over the
baseline concentration in any area.
Section 9: REQUIREMENTS FOR AIR QUALITY MODELS
9.01 All estimates of ambient concentrations required under
Section 8 of this regulation shall be based on the appli-
cable air quality models, data bases, and other require-
ments specificied in the Guideline on Air Quality Models
(OAQPS 1.2-080, U.S. EPA, Office of Air Quality Planning and
Standards, Research Triangle Park, N.C. 27711, April, 1978).
9.02 Where an air quality impact model specified in the Guide-
line on Air Quality Models is inappropriate, the model may
be modified or another model substituted, provided that:
(1) The substitution or modification of a model shall be
subject to public comment procedures developed in
accordance with Section 13 of this regulation; and
(2) The Director approves of any substitution or modifica-
tion of a model.
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Section 10. REQUIREMENTS FOR AIR QUALITY MONITORING
10.01 Any person proposing to construct or relocate a major sta-
tionary source shall provide an analysis of the ambient air
quality in the area that the major stationary source would
affect for each pollutant that it would have the potential
to emit in a signficant amount.
10.02 Any person proposing to construct a major modification to a
stationary source shall provide an analysis of the ambient
air quality in the area that the major modification would
affect for each pollutant for which there would result in a
significant net emissions increase.
10.03 For those pollutants for which no National or West Virginia
Ambient Air Quality Standard exists, the analysis shall
contain such air quality monitoring data as the Commission
determines, is necessary to assess ambient air quality for
that pollutant in any area that the emissions of that
pollutant would affect.
10.04 For those pollutants (other than non-methane hydrocarbons)
for which such an ambient air quality standard does exist,
the analysis shall contain continuous air quality moni-
toring data gathered for purposes of determining whether
emissions of that pollutant would cause or contribute to a
violation of the standard or any maximum allowable increase.
10.05 All ambient air quality monitoring data that is required
shall have been gathered over a period of one year and
shall represent the year preceding receipt of the appli-
cation.
10.06 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall, after
construction of the stationary source or modification,
conduct such ambient monitoring as the Commission deter-
mines is necessary to determine the effect emissions from
the stationary source or modification may have, or are
having, on air quality in any area.
10.07 Operation of monitoring stations required by this Section
shall meet the requirements of Appendix B of 40 CFR 58
during the operation of the monitoring stations.
Section 11: REQUIREMENTS FOR ADDITIONAL IMPACTS ANALYSIS
11.01 Any person proposing to construct, modify, or relocate a
major stationary source or major modification shall provide:
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(1) An analysis of the impairment to visibility, soils,
and vegetation that would occur as a result of the
source or modification and general commercial, resi-
dential, industrial, and other growth associated with
the source or modification. The owner or operator
need not provide an analysis of the impact on vegeta-
tion having no signficant commercial or recreational
value; and
(2) An analysis of the air quality impact projected for
the area as a result of general commercial, residen-
tial, industrial, and other growth associated with the
source or modification.
Section 12: ADDITIONAL REQUIREMENTS FOR SOURCES IMPACTING FEDERAL
CLASS I AREAS
12.01 The Director shall transmit to the Adminstrator a copy of
each permit application relating to a major stationary
source or major modification impacting a Federal Class I
area and'provide notice to the Administrator of every
action related to the consideration of such permit.
12.02 The Federal Land Manager of the affected Class I area may
present to the Director during the public review process
developed in Section 13 of this regulation a demonstration
that the emissions from the proposed major stationary
source of major modification would have an adverse impact
on the air quality-related values (including visibility) of
any Federal Class I lands, notwithstanding that the change
in air quality resulting from emissions from such source or
modification would not cause or contribute to concentra-
tions which would exceed the maximum allowable increases
for a Class I area. If the Director concurs with such
demonstration, the Commission shall deny the permit to
construct.
Section 13: PUBLIC REVIEW PROCEDURES
13.01 After finishing its review of the complete application, the
Commission shall make a preliminary determination whether
the permit should be approved, approved rfith conditions, or
disapproved.
13.02 The Commission shall make available in at least one loca-
tion in each region in which the proposed source would be
constructed a copy of all materials the applicant sub-
mitted, a copy of the preliminary determination, and a copy
or summary of other materials, if any, considered in making
the preliminary determination.
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13.03 The Director shall place a legal advertisement in a paper
of general circulation in the area where the proposed
source would be constructed, modified, or relocated. The
advertisement shall contain, as a minimum, the name of the
applicant, the type and location of the source, the pro-
posed startup date, the preliminary determination, the
degree of increment consumption that is expected from the
source or modification, and of the opportunity for comment
at a public hearing as well as written public comment. The
public comment period of thirty (30) days or longer will be
stated in this notice.
13.04 The Commission shall send a copy of the notice of public
comment to the applicant, the Administrator and to offi-
cials and agencies having cognizance over the location
where the proposed construction would occur as follows:
any other State or local air pollution control agencies,
the chief executives of the city and county where the
source would be located; any comprehensive regional land
use planning agency, and any State, Federal Land Manager,
whose lands may be affected by emissions from the source or
modification.
13.05 The Commission shall provide opportunity for a public
hearing for interested persons to appear and submit written
or oral comments on the air quality impact of the source,
alternatives to it, the control technology required, and
other appropriate considerations.
13.06 Public comments submitted within thirty (30) days (or longer
if stated in the notice of public comment) after the Direc-
tor's public notification of an opportunity for comment
upon a proposed construction, modification, or relocation
of a major stationary source or major modification shall be
considered by the Director before making a final decision
on the approvability of the application. The Commission
shall make all comments available for public inspection in
the same locations where the Commission made available pre-
construction information relating to the proposed source or
modification.
13.07 The Commission shall make a final determination whether
construction should be approved, approved with conditions,
or disapproved.
13.08 The Commission shall notify the applicant in writing of the
final determination and make such notification available
for public inspection at the same location where the Commis-
sion made available preconstruction information and public
comments relating to the proposed source or modification.
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Section 14: PUBLIC MEETINGS
14.01 Public meetings to receive comments on direct and/or in-
direct permit applications will be held when the Director
deems it appropriate or when substantial interest is ex-
pressed, in writing, by persons who might reasonably be
expected to be affected by the proposed source or modifi-
cation.
14.02 The Director, the Commission, or a duly authorized employee
of the Commission shall preside over such meetings and
insure that all interested parties have ample opportunity
to present comments. Such meetings shall be held at a
convenient place as near as practicable to the location of
the proposed source or modification.
14.03 At a reasonable time prior to such meetings, the Director
shall provide appropriate information to news media in the
area where the proposed source or modification is to be
located.
Section 15: PERMIT TRANSFER, CANCELLATION, AND RESPONSIBILITY
15.01 A permit shall not be transferable.
15.02 The Director will cancel or suspend a permit if, after six
(6) months from the date of issuance the holder of the
permit cannot provide the Director, at the Director's
request, with written proof of a good faith effort that
such construction, modification, or relocation has com-
menced. Such proof shall be provided not later than thirty
(30) days after the Director's request.
15.03 The Director may cancel or suspend the permit if the plans
and specifications upon which the approval was based and/or
the conditions established in the permit are not adhered to.
15.04 Any person who owns and operates any particular source or
modification which becomes a major stationary source or
major modification solely by virtue of a relaxation in any
limitation, enforceable by the U.S. Environmental Protec-
tion Agency or the State of West Virginia, on the capacity
of the source or modification otherwise to emit a pollutant
restriction on hours of operation, shall become subject to
the requirements of this regulation as though construction
had not yet commenced on the source or modification.
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Section 16: CONFLICT WITH OTHER RULES OR REGULATIONS
I 16.01 When a provision of this regulation conflicts with a
similar portion(s) of any rule or regulation previously
•adopted by the Commission, the provision(s) of this regula-
tion shall apply.
Section 17: EFFECTIVE DATE
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17.01 Regulation shall become effective on
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• Baseline Emission Inventory for the
APPENDIX AA
ission Invenl
Washington, D. C. Metropolitan Area
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• AA-1
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FINAL REPORT
EPA Contract No. 68-02-2536
Work Assignment No. 14
(incorporating information from Contract No. 68-02-3511,
Work Assignment No. 10)
QUALITY ASSURANCE REVIEW OF
SIP AND NECRMP EMISSION INVENTORIES
NATIONAL CAPITAL INTERSTATE AIR
QUALITY CONTROL REGION (AQCR 047)
Prepared by:
Lowell G. Wayne
PACIFIC ENVIRONMENTAL SERVICES, INC.
1930 14th Street
Santa Monica, CA 90404
(213) 450-1800
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania
Project Officer: Robert Blaszczak
May 1982
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• TABLE OF CONTENTS
• Section Page
™ 1.0 INTRODUCTION 1-1
• 2.0 POINT SOURCE DATA QUALITY 2-1
2.1 Indicators of Completeness 2-1
| 2.1.1 Comparisons With RACT Directory 2-1
2.1.2 Comparison With Other Specialized
• Lists 2-1
2.1.3 Comparison With State Industrial
Di rectori es 2-3
I 2.2 Consistency of Data on Boilers 2-6
2.2.1 Completeness of Boiler Records 2-6
• 2.2.2- Internal Consistency of Boiler Data 2-8
2.3 Review of Emissions by State, Facility Type,
I and Source Classification 2-13
2.4 Specific Discrepancies Found in the Data Base. 2-32
2.4.1 Discrepancies in Emission Factors for
• Boilers 2-32
• 2.4.2 Exhaust Gases From Turbines 2-34
2.4.3 Boiler Capacity 2-34
12.4.4 Sludge Incineration 2-34
2.4.5 Boiler Design Rate 2-35
2.4.6 Printing Plants 2-35
_ 2.4.7 Distillery Emissions 2-36
• 2.4.8 Bulk Terminals for Gasoline
• Distribution 2-37
2.4.9 Review of Memos Related to Point
I Source Inventory 2-37
3.0 AREA SOURCE DATA QUALITY 3-1
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3.1 Area Source Methodologies 3-1
3.2 Area Source EIS File 3-4
4.0 CONCLUSIONS AND RECOMMENDATIONS 4-1
4.1 Conclusions 4-1
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Section Page
4.1.1 Completeness of the Point Source File
in Relation to the RACT Directory 4-1
4.1.2 Completeness of the Point Source File
in Relation to Industrial Directories
and Other Lists 4-2
4.1.3 Consistency of Data on Boilers 4-3
4.1.4 Emissions by State, Facility Type,
and Source Classification 4-3
4.1.5 Specific Discrepancies at Individual
Plants 4-4
4.1.6 Review of Memos Related to Point Source
Inventory 4-5
417 Area Source Methodologies 4-5
4.1.8 Area Source EIS File 4-6
4.2 Recommendations 4-6
ii
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1.0 INTRODUCTION
The Clean Air Act Amendments of 1977 required that states
submit in 1979 plans for attainment of the National Ambient Air
Quality Standard (NAAQS) for ozone by 1982. The Act allowed states
that could not meet the 1982 attainment date for ozone to receive
an extension of the attainment date to 1987. States that received
an extension are required to submit attainment plans by July 1,
1982.
Important components of the 1982 plan submission are accurate
emission inventories for volatile organic compounds (VOC) and
oxides of nitrogen (NOx). These inventories are needed for use in
mathematical models to determine the levels of control needed for
attainment for ozone, and they will also be used in the Northeast
Corridor Regional Modeling Project (NECRMP).
Pacific Environmental Services, Inc., contracted to provide
to the U.S. Environmental Protection Agency, Region III, a quality
assurance audit of the point and nonhighway vehicle area source
inventories in the Washington, D.C. nonattainment area. This area
is formally known as AQCR 047, the National Capital Interstate
Air Quality Control Region. It consists of the entire District of
Columbia, together with two counties of Maryland (Montgomery and
Prince Georges) and four counties of Virginia (Arlington, Fairfax,
Loudoun, and Prince William), as well as the separate Virginia
cities of Alexandria, Fairfax, and Falls Church.
Data to be provided to PES by state and local inventory
agencies were the following:
1. Point source listings and/or permit file data on all
major sources of VOC.
2. Point source listings of all major sources of NOx.
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3. Any documentation available describing how emissions
were determined for each point source or source category.
4. Area source listings and documentation showing the activity
levels, emission factors, control efficiencies, etc., used to
determine emissions for each VOC/NOx category for each county.
5. Socioeconomic or other projection data used in the point
and area source inventories to reflect growth.
6. Presumed RACT (and other) control efficiencies used in
the point and area source inventories to reflect existing and
proposed control measures.
The scope of work for this project, as described in the Work
Assignment dated 31 March 1981, may be summarized as follows.
TASK 1: POINT-SOURCE DATA QUALITY AUDITS
a. Compare point sources listed in the VOC emissions inven-
tories supplied by Maryland, Virginia, and the District
of Columbia with those firms listed in EPA's Directory of
Volatile Organic Compound Sources Covered by Reasonably
Available Control Technology (RACT) Requirements, Volumes
I-III, EPA 450/4-80-007a,b,c, and identify any sources in
the RACT list which appear to be missing from the
inventories.
b. Compare point-source listings in the VOC and NOx inven-
tories with other directories of industries available from
local sources, and list any presumable sources which appear
to be missing from the inventories.
c. Review methodologies used by Maryland, Virginia, and the
District of Columbia in creating area source files to
account for VOC and NOx emissions from minor industrial
sources.
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d. Compile total indicated point-source employment, by county
and by 4-digit SIC code, and compare with totals in County
Business Patterns or State Industrial Directories.
e. Manually review Maryland's VOC emissions estimates for
up to 100 of the largest individual point sources,
including all facilities having total VOC emissions
exceeding 1,000 tons per year (TRY).
f. Review the documentation furnished by Maryland, Virginia,
and the District of Columbia regarding methodology for
estimating emissions, including estimation of activity
levels, fraction of nonreactive VOC components, seasonal
and weekday adjustments, and efficiencies of control
equipment.
g. Apply the data-quality edit-check program, EPADAS, to
emission inventory data for major point sources of VOC
and NOx when furnished in EIS/P&R format.
TASK 2: AREA-SOURCE DATA QUALITY AUDITS
a. Check area-source narrative documentation to confirm that
all categories identified in EPA-450/2-77-028 (Procedures
for the Preparation of Emission Inventories for Volatile
Organic Compounds) have been adequately evaluated for
each county in the inventories.
b. Review the area-source documentation to assure that
appropriate methodology and plausible activity levels,
apportioning factors, emission factors and control
efficiencies have been applied.
TASK 3: QUALITY AUDIT OF PROJECTION DATA
a. Review point-source projection methodologies used to
estimate emissions for future years, to assure that
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reasonable methods and plausible assumptions have been
applied.
b. Review area-source projection methodologies for con-
sistency with EPA-450/4-80-016, Final Emission Inventory
Requirements for 1982 Ozone SIPs, and check tabulated
growth factors, abatement factors and projected emission
factors for plausibility in the context of baseline inven-
tories and control -strategy scenarios.
The time initially allotted to the technical effort for the
performance of this quality assurance audit was 3 months, with a
completion date of September, 1981. However, as PES encountered
some difficulty in obtaining necessary information for the audit,
the duration of work was later increased from 3 to 8 months.
Nevertheless, much of the information required for completion
of the specified work continued to be unavailable. This report,
therefore, does not provide a completed quality assurance audit
of these inventories for the nonattainment area, AQCR 047, but
rather a discussion of the data quality implications of the infor-
mation that was available.
The information reviewed by PES was furnished entirely by
Metropolitan Washington Council of Governments (MWCOG). It con-
sisted mainly of three computer printouts showing point-source
emissions data in EPA's Emission Inventory System (EIS) format, and
a magnetic tape described as representing the gridded area source
inventory. The three computer printouts reflected the jurisdic-
tional division of AQCR 047 by states, and were labeled as follows:
1. District of Columbia Point Sources Emitting 25 Tons or
More of Either Hydrocarbons or Nitrogen Oxides (07/18/31).
2. 1980 Maryland Point Source File (09/04/81).
3. 1980 Virginia Point Source File (09/17/81).
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A note accompanying the latter two printouts (R. Kaufman,
September 17, 1981) informed PES that the Virginia inventory was
in final form, but that the Maryland inventory might be updated in
the near future.
Also received were copies of two letters, with attachments,
from Frederick M. Sellars of GCA/Technology Division, Bedford,
Massachusetts. The first, dated September 10, 1981, was addressed
initially to Mr. Mario Jorquera of the Maryland Department of
Health and Mental Hygiene and enclosed a copy of notes on the
Maryland 1980 Point Source Inventory. The second, dated November
17, 1981, was addressed to Ms. Kathy Bailey of MWCOG and enclosed
notes on the "D.C. 1980 Point Source Inventory"; these notes also
referred to some of the point sources in AQCR 047 but in Maryland
and Virginia rather than the District of Columbia.
Finally, PES received a copy of a 7-page MWCOG interoffice
memorandum, dated October 29, 1981, from R. Kaufman to A. Librach
on the subject, "1980/1987 Area and Point Source Inventory
Assumptions." A copy of this memorandum is included in this report
as Appendix A.
Progress toward the goals established in the contract and
in the work plan discussed above is described in the following
sections of this report. In Section 2.0, the point-source data
quality is reviewed.
Section 2.1 describes the results of comparisons of the list
of point sources found in the point source inventory printouts
with other lists of facilities identified as, or suspected of
being, important sources of VOC or NOx. Section 2.1.1 reviews
findings on comparing the inventory list with the "RACT list,"
found in EPA's "Directory of Volatile Organic Compound Sources
Covered by Reasonably Available Control Technology Requirements,"
EPA 450/4-80-007. Section 2.1.2 reviews findings on comparing
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the inventory lists with the list of firms mentioned in the notes
forwarded by P.M. Sellars, mentioned above. Finally, in Section
2.1.3, results of a comparison are described in which PES
generated a list of candidate firms for further screening as
possible VOC emitters, starting with the Virginia Industrial
Directory for 1981 and 1982 (published by the Virginia State
Chamber of Commerce). In view of the possibly imminent revision
of the Maryland 1980 Point Source Inventory, no similar effort
was made for the Maryland counties of AQCR 047.
Section 2.2 describes the results of the manual review of
point source records (Task le). It was decided to confine this
review to a scrutiny' of information included in the EIS printouts,
since there were no VOC sources approaching the level of 1,000
tons per year, which might have required more intensive review
and a site visit. Section 2.2.1 reviews the level of completeness
of the EIS information needed in order to execute the principal
self-consistency tests for combustion sources of NOX and VOC.
Section 2.2.2 reviews, in more detail, the various self-consistency
tests that were applied to these combustion sources, and their
results.
Section 2.3 deals with the character and the highlights of the
information contained in the emission inventories, and presents a
number of tables showing the distribution of emissions by state,
by industry type (standard industrial classification, SIC), and
by process (source classification category, SCC). This information
is expected to be useful to the ultimate data quality auditor by
indicating which types of emitting facilities and processes are
quantitatively important in relation to the overall emissions
encountered in the nonattainment area.
Section 2.4 deals with the details of specific discrepancies
encountered in the manual review of point source records. In
this section, particular records having apparent inconsistencies
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of any appreciable magnitude for inventory purposes are identified
and the discrepancies are discussed so that necessary and desirable
changes can be formulated and implemented with the least possible
confusion and delay.
In the absence of documentation regarding methodology for
estimating point source emissions, Task If had to be abandoned.
Task Ig, application of EPADAS, was also not undertaken, since the
files were relatively short and the necessary tests could be done
more economically without accessing EPADAS.
Task Id, which involved compiling the indicated totals for
employment in various industry groups, could not be completed
because the available information on employment in the facilities
listed in the printouts was too fragmentary.
In Section 3.0, area source data quality is reviewed.
Section 3.1 presents a review of the area source methodologies
as described in the MWCOG Memo of October 29, 1981. Section 3.2
reviews the status of the area source file, based on a computer
printout derived by PES from the magnetic tape supplied by MWCOG.
The plausibility of activity levels, apportioning factors,
emission factors, and control efficiencies, called for in Task 2b,
could not be established because available information was too
cursory.
Inasmuch as projection data were not available before the
project termination date, PES could not carry out Task 3. Projec-
tion methodologies for some area source categories were mentioned
in the MWCOG Memo of October 29, 1981, but with no details or
tabulations of growth factors, abatement factors, or projected
emission factors. Task 3, therefore is not further discussed in
this report.
Conclusions and Recommendations are set forth in Section 4.0.
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2.0 POINT SOURCE DATA QUALITY
2.1 INDICATORS OF COMPLETENESS
2.1.1 COMPARISONS WITH RACT DIRECTORY
As a partial check on the completeness of the point source
inventories (as shown in the printouts furnished by MWCOG), PES
reviewed "Volatile Organic Compound RACT Sources Missing From
NEDS," EPA-450/4-81-018 (February 1981) to determine whether such
sources existed within AQCR 047. Five such listings were found,
of which three were in the District of Columbia and two in Fairfax
County, Virginia. None of these facilities (which are listed below)
were included in the point source inventory EIS printouts.
• B.P. Oil Corp., 401 Farragut Street, N.E. (a bulk gasoline
terminal);
• Rhode Island Cleaners, 4235 Wisconsin Avenue, N.W. (an
industrial perchloroethylene drycleaner)
• Solon Automated Services I, 115 L Street, S.E. (an industrial
perchloroethylene drycleaner);
• Atlantic Richfield Co., Belvoir Terminal, Newington 22122
(a bulk gasoline terminal); and
• Shell Oil Co., Springfield 22150 (a bulk gasoline terminal)
MWCOG staff told PES that the three named plants in the District of
Columbia either were no longer in operation or were emitting less
VOC than the point-source cutoff level.
2.1.2 COMPARISON WITH OTHER SPECIALIZED LISTS
Independent of PES, another contractor reviewed an earlier
version of the point source inventory for AQCR 047, listing apparent
deficiencies in the data associated with each record. A copy of
these notes was forwarded to PES.
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This memo, dated November 17, 1981, provided a list of 25
plants in the "1980 Point Source Inventory for the Northeast
Corridor Regional Modeling Project." The plants listed were
those for which the data base appeared to be incomplete or to
contain internal inconsistencies. On comparison with the point
source inventory printouts received from MWCOG, PES found the
following facilities named in the memo but not in the EIS
printouts; all were listed as in the District of Columbia.
A.P. Woodson Co.
Gralladet College
Marine Corps Barracks
Tyroc Construction Co.
American University
IBM Card Manufacturing Plant
WGL Co. E. Gas Manufacturing Station
Crestwood Apartments 3900
Apparently these sources were deliberately deleted from the EIS
file which yielded the printouts. Perhaps they did not meet the
point source criterion, which required annual emissions of at
least 25 tons of either VOC or NOx.
In a different context, the memo cited above indicates that
B.P. Oil Corp. was listed as a source in the "1980 Point Source
Inventory," although, as mentioned in Section 2.1, it was not
included in the EIS printouts. This is consistent with MWCOG's
explanation of reasons for deletion (or nonoccurrence) of three
facilities in the District of Columbia point source inventory.
In an earlier memo, the same contractor reported on a compari-
son of a Maryland point source inventory with the "Organic
Chemical Producers Data Base," as well as the RACT directory.
Although various plants were found in these lists which were not in
the inventory, none of these were in AQCR 047.
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2.1.3 COMPARISON WITH STATE INDUSTRIAL DIRECTORIES
To explore the possibility that manufacturing firms which
could be potential point sources of VOC or NOx were missed in the
preparation of the EIS point source inventory, PES compared the
names of firms listed in the EIS printout with the alphabetical
list of manufacturing and mining firms in the Virginia Industrial
Directory for 1981 and 1982, 15th Edition, published by the
Virginia State Chamber of Commerce.
To generate a list of firms which should be queried as to
possible emissions of VOC and NOx, PES extracted from the Virginia
Industrial Directory the names of all manufacturing companies
located in AQCR 047 and having reported employment of 100 or more,
as well as firms with 50 to 99 employees in major industrial
SIC groups 26 (paper and allied products), 27 (printing, publishing
and allied products), 28 (chemicals and allied products), and 30
(rubber and miscellaneous plastic products).
Table 1 shows the list of 56 names retrieved under this
procedure. Codes used for employment are those given in the
Directory: C, 50 to 99; D, 100 to 299; E, 300 to 599; F, 600 to
999; G, 1,000 or above.
In addition to the firms listed in Table 1, the Virginia
Industrial Directory lists a Municipal Power System in Manassas,
which does not appear in the Virginia EIS printout.
It is clear that the list of facilities thus retrieved from
the Virginia Industrial Directory is much more extensive than the
corresponding list from the EIS printout. However, it is evident
that the Directory is not complete; of the five facilities shown
by the EIS printout as having SIC numbers in the manufacturing range
(2000 to 3999), only three were identifiable by name in the Directory.
These were (1) a distillery in County 1060, shown in the Directory as
SIC 2085, having employment category E (25 to 49 employees);
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Table 1. LARGER MANUFACTURING FIRMS IN THE NATIONAL CAPITAL
INTERSTATE AQCR, AS FOUND IN THE VIRGINIA INDUSTRIAL DIRECTORY
Alexandria City (p. 52-54)
Atlantic Research Corp., Pine Ridge
Plant
Time-Life Books, Inc.
Arlington County (P. 55-56)
Hollinger Corporation, Shirlington
Keuffel and Esser Co.
Pandick Press
Sheltered Occupational Center of
N. Virginia
Fairfax City_ (p. 73)
Comsat General Telesystems
NEC America, Inc.
Sperry Corporation
Fairfax County_ (p. 73-77)
APCA-Virginia, Inc.
Acuity Systems, Inc.
Automata, Inc.
Braceland Brothers, Inc.
Byrd Pre-Press Division
C3, Inc.
Cascio-Wolf, Inc.
Davenport Insulation
Eurotherm Corp.
Faraday National Corp.
Finley Sam Co.
Flow Laboratories, Inc.
Goodway Graphics, Inc.
Gray Concrete Pipe Co.
Hoppman Corp.
Hunter Associates Laboratory, Inc.
Journal Newspapers, Inc.
Logentronics
Master Print, Inc.
Multi-List/McGraw Hill
RC-Nehi Bottling Co.
Reston Publishing Co.
Richards Corporation
Roubin and Janeiro, Inc.
Major Group
35,37
27
27,30
39
27
27
36
36
36
29
35
36
27
27
35
27
26
38
30
29
28,38
27
37
35
38
27
38
27
27
20
27
38
14
Employment
G
E
C
D
C
D
D
D
E
D
E
D
C
D
D
C
D
D
C
D
E
D
D
D
D
D
D
C
C
D
C
D
E
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Table 1. LARGER MANUFACTURING FIRMS IN THE NATIONAL CAPITAL
INTERSTATE AQCR, AS FOUND IN THE VIRGINIA INDUSTRIAL DIRECTORY
(CONCLUDED)
Shenandoah's Pride Dairy
Sperry Systems Management
Valley of Virginia Co-op Milk
Products Association
Vega Precision Laboratories, Inc.
Versar, Inc.
Virginia Concrete Co.
Washington Post Co.
Falls Church City (p. 77)
E-Systems Inc., Melpar Division
Hubbell Harvey Inc.
Trans/Circuits, Inc.
United Lithographic Services
Loudoun County (p. 94)
Airline Tariff Publishers, Inc.
Barber and Rose Co.
Dowty Corp.
Dowty Rotol , Inc.
Loudoun Times Publishing Co., Inc.
Metro Printing and Mailing
Radiation Systems, Inc.
Rehau, Inc.
Manassas City_ (p. 99)
International Business Machines
Prince William County (p. 115-116)
Herndon Lumber and Millwork, Inc.
Potomac News
Vulcan Materials Co.
Major Group
20
36
20
36
36
32
27
38
36
36
27
27
24
35
37
27
27
36
30
36
24
27
14
Employment
D
D
D
E
D
D
E
F
E
D
C
D
D
D
D
C
D
D
C
G
D
C
D
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(2) a manufacturer of polystyrene foam and packaging, shown as
SIC 3079, employment category C (50 to 99 employees); (3) a
fabricator of steel plant work, SIC 3443, employment category E
(300 to 599 employees). The two facilities which could not be so
identified were a manufacturer of railroad equipment, SIC 3743, and
a manufacturer of copying machines, SIC 3861, with employment
listed as 147 (category D).
PES wishes to emphasize that Table 1 represents only a pre-
liminary screening of all firms listed in the Directory. The list
is based solely on employment and industrial classification, and
not on any direct information about air pollutant emissions. If
the State of Virginia has already reviewed the operations of these
firms from the standpoint of their air pollution emissions, it
might be superfluous to do so again. On the other hand, concern
for completeness suggests that inquiries be made regarding any of
these firms that have not been contacted within the last 5 years
(or other reasonable period).
2.2 CONSISTENCY OF DATA ON BOILERS
2.2.1 COMPLETENESS OF BOILER RECORDS
Since a large fraction of the NOx emissions in the file
originates in the operation of boilers, PES examined the file
information on boilers for possible internal inconsistencies
or ambiguities which might have a bearing on the accuracy of
emissions estimates.
In Maryland, of 26 facilities listed in the file, 18 contained
processes represented by source classification codes pertaining to
boilers.
In a few cases, an SCC corresponding to a commercial or
institutional boiler is used to account for auxiliary fuel used for
a brick kiln or incinerator. Although this attribution is
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evidently erroneous, the associated emissions as estimated are
clearly negligible, so no harm will be done by ignoring the
error (County 1300, plant 0565).
In the remaining 17 facilities, over 100 boiler-fuel combina-
tions are represented by individual process records. Eight of
these facilities have no emitting processes except boilers, while
two (which are major power plants) have only boilers and turbines.
The total number of boilers shown is greater than 90; the
exact number cannot be specified because some records refer to
multiple boilers without indicating the number of boilers repre-
sented. Most of these boilers are used mainly for space heating.
In Virginia, of 24 facilities listed in the file, 12 contained
records indicating boilers used. These 12 facilities contained 87
or more boilers.
In the District of Columbia, of 23 facilities, 20 included one
or more boilers. The total number of records for boilers was 67;
they represented at least 84 boilers.
Completeness of these files was checked, in reference to
boiler-related information, by counting cases in which data fields
were blank or filled with zeroes. In the Maryland file, boiler
capacity, fuel usage, and heat content were almost always given;
there were only two or three exceptions in a total of 105 records.
For Virginia, boiler capacity and heat content were always present,
while there were two exceptions on fuel usage, of a total of 91
records. For other data fields, the following table shows
percent missing or zero.
Maryland Virginia D.C.
Space heat 11 12 27
Stack height 34 1 4
Stack diameter 49 1 3
Stack temperature 48 18 11
Exhaust flow rate 62 37 26
Exhaust velocity 100 34 45
Maximum design rate 35 18 33
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2.2.2 INTERNAL CONSISTENCY OF BOILER DATA
Internal consistency checks involved the following comparisons
and calculations.
2.2.2.1 Extent of Boiler Utilization
The extent of boiler utilization is obtained by calculating
the number of hours of operation at full boiler capacity which
would be required in order to consume the listed annual fuel
usage. Table 2 shows these results, in terms of the frequency
distribution of indicated hours of use for both states. Most
records showed equivalent full-capacity usage of 500 to 7,000
hours, and those with lower indicated use were primarily space
heaters, for the most part. However, in the Maryland file, 10
boilers showed indicated usage less than 250 hours. These were
in three plants for which the maximum design rate had evidently
been entered, in error, as equivalent to the boiler capacity.
(These boilers belong to County 1300, plants 581, 667, and 884).
Since the values entered for boiler capacity are in the same range
as those for other boilers of the same SCC class, it appears
probable that the entries for maximum design rate, being out of
line, need correction.
Table 2. DISTRIBUTION OF INDICATED HOURS OF BOILER USE
Indicated Hours
<7,000
<5,000
<3,000
<2,000
< 1,000
< 500
< 250
< 100
Maryland
n %
34 97
33 94
30 86
24 69
14 40
11 31
10 29
10 29
Virginia
n %
58 100
52 90
43 74
36 62
26 45
14 24
8 14
1 2
D.C.
n %
60 100
60 100
57 95
36 60
11 18
6 10
3 5
0 0
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In another record, County 1300, plant 012, point 2, the
equivalent full-capacity usage is calculated to be 28,000 hours,
which is clearly impossible. The maximum design rate for this
boiler is given as 0.003, which may be too small by a factor of 10.
Fortunately, all the records affected by these errors pertain
to boilers with relatively low capacity and practically negligible
emissions, so that correction of the errors is not especially
urgent.
2.2.2.2 Relation of Exhaust Flow to Boiler Capacity
The ratio of exhaust gas flow rate, corrected to scfm (standard
cubic feet per minute), to boiler capacity provides a test for good
engineering practice in relation to the air-fuel ratio used in
combustion. If the ratio is much less than 200, a deficiency in
the air-fuel ratio is indicated. If it is above 400, an unusually
large air-fuel ratio is indicated. This ratio has been calculated
for the boiler records in the EIS printouts, with the results
shown in Table 3.
Table 3. RATIO OF EXHAUST FLOW RATE TO BOILER CAPACITY
(scfm/MM Btu per hour)
Ratio
>450
175 to 450
<175
Maryland
n %
10 20
30 59
11 21
V i rg i n i a
n %
19 34
30 54
7 12
D.C.
n %
2 4
30 67
13 29
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This table shows that only slightly more than half of the
boiler records checked showed the ratio to be within a somewhat
expanded range, 175 to 450, in each state. The remaining cases
are sufficiently far from the expected range so that they are
almost certainly in error due to inaccuracy in the file data.
As a case in point, we may consider County 1160, plant 008, points
01, 02, and 03. The ratio of exhaust flow rate to boiler capacity
is calculated to be 791 for each of the three points, which
exhaust through a common stack. It appears likely that the
error, in this case, was to attribute the entire flow through the
common stack to each of the boilers which feed it.
2.2.2.3 Ranges of Stack Temperature and Velocity
Stack parameters (temperature and velocity) were checked,
where possible,to determine whether file entries were within
reasonable ranges. The lowest probable temperature for boiler
exhausts is about 250 F, unless the exhaust is cooled before
discharge, by a scrubber or other pollution control device.
In the Maryland file, three boilers in one utility power plant
showed a stack temperature of 175 F, consistent with the listing
of a scrubber code under primary controls. Five points showed a
stack temperature of 2,000 F, which is clearly excessive for
boilers; these entries pertained, however, to kilns and incinerators,
to which the boiler SCCs had been erroneously attributed. Other
stack temperatures ranged from 200 to 600 F, with only two apartment
house boilers entered as less than 250 F.
In the Virginia file, all stack temperatures were in the range
of 250 to 600 F. In the District of Columbia file, all were in the
range of 250 to 650 F.
Stack velocities may vary over a wide range, but values in
excess of 5,000 fpm (feet per minute), which is equivalent to nearly
60 miles per hour, are unusual and should be confirmed. In addition,
2-10
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values less than 1,000 fpm are suspect, at least for boilers of
appreciable capacity (100 MM Btu/hr).
In the Maryland file, stack velocity was not entered. PES
therefore calculated stack velocities from the other stack
parameters, diameter and flow rate. Resulting values ranged from
250 to 5,420, except for two small boilers having an indicated
velocity of nearly 12,000.
In the Virginia file, stack velocities were entered in 59
records and PES checked these entries by calculation from diameter
and flow rate. Agreement was found in 31 cases, or 53 percent.
Values present in the file ranged from 31 to 10,700 fpm, with six
cases greater than 4,000 and 15 cases less than 1,000 fpm.
Especially questionable are values of 9,000 to 10,700 for a large
power plant (County 0080, plant 0003), where flow rates of about
0.5 million cubic feet per minute are on record as emerging from
an 8-foot stack.
Stack velocities entered in the District of Columbia file
ranged from 39 fpm to 7,620 fpm. The lowest value was for several
boilers in a single facility, used largely for space heating;
other parameters for this plant are self-consistent, suggesting
that the flue gases are exhausted through an unnecessarily large
stack. The highest value corresponds to a very large boiler in
an electric generating plant.
2.2.2.4 Relation Between Fuel and Heating Capacity
PES checked the direct relation between fuel-burning capacity
and boiler heating capacity. The file shows the fuel-burning
capacity as "maximum desing rate" (MDR); when multiplied by the
heat content of the fuel, the result (fuel heat rate) should agree
with the boiler capacity. Thus, the ratio of fuel heat rate (H)
to boiler capacity (B) should be 1.0.
2-11
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In the Maryland file, the calculated ratio (H/B) was between
0.91 and 1.04, with a few exceptions. In County 1300, plant
0001, point no. 15 yielded 0.27, while plants 0581, 0667, 0872, and
0884 yielded values near 140, the heating value of the fuel. It
appears that the MDR for the latter plants has been erroneously
set equal to the boiler capacity.
In the Virginia file, this ratio (H/B) ranges from 0.89
to 1.20, with several exceptions. One boiler (County 2520, plant
0002, point no. 4) yields 0.16. Others (County 1060, plants 0024
and 0343; County 2520, plant 0010) give values from 2.6 to 10.6.
In the District of Columbia, H/B ranges from 0.91 to 1.05,
with several exceptions. One boiler (plant 0020, point 2) gives
1.47; several others (plant 0025, point 3 and 4; plant 0040,
points 3, 4, 5, and 6) give values from 0.70 to 0.75.
From this review it appears that the engineering data in the
EIS file regarding boilers are neither complete nor reliably self-
consistent. Of course, such errors and inconsistencies as exist
may, in many cases, be irrelevant to the estimation of emissions
of pollutants from the corresponding sources, but the rather large
number of inconsistencies observed tends to diminish observer
confidence in the general quality of the EIS files considered as
detailed data bases.
2-12
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2.3 REVIEW OF EMISSIONS BY STATE, FACILITY TYPE. AND SOURCE
CLASSIFICATION
Table 4 shows the major NOx emitting facilities in the AQCR,
in order of their estimated emissions of NOx. Where the estimate
obtained using emission factors from AP-42 differs from the
estimate obtained from the EIS file, both estimates are given and
the difference is indicated. Adding all the differences thus
found, the total is nearly 3,200 tons per year. This amounts to
increasing the overall estimate of 49,100 tons per year from the
EIS file by about 6 percent.
Table 5 shows corresponding information for major VOC emitting
facilities. Changes, suggested by PES total a reduction of 93 tons
per year, which would amount to about 2 percent of the 4,420
tons per year indicated by the EIS file. However, as pointed out
in Section 2.4, a few of the VOC point source records in the EIS
file deserve further scrutiny, which might necessitate further
revisions of the same order of magnitude.
Table 6 indicates the emission totals, by state and for the
entire AQCR, from each type of facility as indicated by SIC
number, and from major divisions of facility types, as follows:
2000 to 3999, manufacturing facilities; 4000 to 4999, transporta-
tion, communications, electric, gas, and sanitary services; 5000 to
5999, wholesale trade; 6000 to 8999, finance, insurance, real
estate, and services; 9000 to 9999, public administration. The
grand total for NOx is 52,200 and for VOC 4,420 tons per year,
including 2,500 tons of NOx estimated by PES to correct the file
for an apparent underestimate of emissions from burning of fuel oil
in the utility boilers.
Further analysis of the point source files yielded summaries of
emissions as related to types of facilities. Tables 7 through 12
provide this information by state, for NOx and VOC separately,
showing also the number of facilities of each type included in
the EIS printout.
2-13
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Table 4. PLANTS IN ORDER OF NOx EMISSIONS, AND EFFECTS
OF EMISSION FACTORS, FOR PLANTS WITH EMISSIONS MORE THAN
100 TONS PER YEAR
State
1. 21
2. 21
3. 48
4. 48
5. 09
6. 09
7. 09
8. 09
9. 09
10. 48
11. 09
12. 21
13. 21
14. 48
15. 09
16. 09
17. 09
18. 09
19. 21
20. 48
County
1300
1160
0080
2520
0020
0020
0020
0020
0020 '
1060
0020
1160
1300
2520
0020
0020
0020
0020
1300
1060
Plant
0007
0008
0003
0002
0001
0024
0040
0025
0047
0281
0006
0006
0010
0010
0022
0032
0009
0033
0001
0018
NOx, TPYa
12,600
10,600
10,300
10,100
3,050
891
655
480
328
302
249
234
231
210
171
158
143
136
134
126
(File)b
12,112
10,561
10,172
10,048
847
633
Changec
488
39
128
52
2,203
258
+3,168
NOx, tons per year, based on AP-42 (rounded to three digits).
"'NOx as shown in EIS point source file, where different from "a."
'Difference, "a" minus "b."
2-14
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Table 5. PLANTS IN ORDER OF VOC EMISSIONS,
FOR PLANTS WITH EMISSIONS MORE THAN
TOO TONS PER YEAR
State
1. 21
2. 48
3. 21
4. 48
5. 48
6. 48
7. 21
8. 48
9. 48
10. 09
11. 21
12. 09
13. 48
14. 48
15. 21
16. 48
County
1160
1060
1300
1060
1060
1060
1160 '
0080
0080 -
0020
1300
0020
1060
1060
1300
1060
Plant
0012
0034
0007
0064
0063
0061
0008
0026
0003
0047
0012
0085
0069
0082
0020
0074
VOC, TPYa
312
305
213
213
199
197
177
177
169
164
162
159
159
158
139
105
(File)b
415
152
Changec
-103
10
-93
aVOC, tons per year, with revisions explained in text.
^VOC as shown in EIS point source file, where different from "a."
C0ifference, "a" minus "b."
2-15
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Table 6. FACILITY TYPES AND EMISSIONS (TONS PER YEAR)3 BY STATE
2085
2655
2721
2752
2754
2816
2815
3079
3251
3441
3743
3861
4588
4911*
4953
4961*
5171
6513
7011
7211
7216
8062
8063
8211
8221
8361
8922
9100
9199
9223
9431
9511
9651
9711
2000-3999
4000-4999*
5000-5999
6000-8999
9000-9999
All*
D.C.
NOx VOC
0 72
0 92
3,710' 58
328 164
1,760 52
26 0
6 208
76 3
143 3
286 5
60 0
158 2
108 4
0 164
5,790 274
0 0
597 219
266 6
6,650 668
Maryland
NOx VOC
5 152
0 72
2 554
28 0
0 54
44 4
23,200 390
50 8
94 3
0 118
31 0
278 0
32 0
234 4
44 0
275 70
79 836
23,300 398
0 0
335 121
553 74
24,200 1,420
Virginia
NOx VOC
0 70
4 35
0 26
2 177
0 32
69 5
20,300 358
0 1,460
52 34
45 8
302 59
375 73
6 340
20,300 358
0 1 ,460
0 0
774 174
21,400 2,330
Total
NOx VOC
0 70
5 152
0 144
2 554
0 92
28 0
0 54
4 35
44 4
0 26
2 177
0 32
69 5
47,200 806
378 172
1,760 52
0 1,460
94 3
26 0
6 208
0 118
76 3
143 3
31 0
564 5
60 0
32 0
158 2
52 34
45 8
234 4
302 59
44 0
758 147
85 1,340
49,400 1,030
0 1,460
1,030 340
1,590 254
52,200 4,420
*These tonnages incorporate changes suggested by PES to bring
estimates for emissions from burning of oil into conformity with EPA
guidance. Corresponding lines uncorrected are:
4911
4961
4000-4999
All
1,480 58
1,500 52
3,310 274
4,170 663
22,700 390
0 0
22,800 398,
23,900 1,430
20,200 358
0 0
20,200 2,330
21,000 2,330
44,400 806
1,500 52
46,300 1,030
49,100 4,420
Emission Estimates in tons per year, rounded to three digits.
2-16
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Table 7. DISTRICT OF COLUMBIA: SIC CATEGORIES
IN ORDER OF NOx EMISSIONS
Standard Industrial Classification
4911 Electric Services
4961 Steam Supply
4953 Refuse Systems
8221 Colleges, Universities, etc.
9100 General Government
8063 Pyschiatric Hospitals
9711 National Security
8062 General Hospitals
8361 Residential Care
7011 Hotels
2721 Power Laundries
2754 Periodicals: Publishing, etc.
Commercial Printing: Gravure
TOTAL
Total NOx
Emissions9
3,706
1,755
328
286
158
143
108
76
59
26
6
0
0
6,655
Plants
1,40
6,24,25,34
47
10,22,53,63
32
9
13,20
14,62
11
84
85,94
65
67
aEmission estimates (tons per year) based on AP-42 emission
factors.
Table 8. DISTRICT OF COLUMBIA: SIC CATEGORIES
IN ORDER OF VOC EMISSIONS
Standard Industrial Classification
7211
4953
2754
2721
4911
4961
8221
9711
8062
8063
9100
7011
8361
Power Laundries
Refuse Systems
Commercial Printing: Gravure
Periodicals: Publishing, etc.
Electric Services
Steam Supply
Colleges, Universities, etc.
National Security
General Hospitals
Psychiatric Hospitals
General Government
Hotels
Residential Care
TOTAL
Total VOC
Emissions3
208
164
92
72
58
52
5
4
3
3
2
0
0
663
Plants
85,94
47
67
65
1,40
6,24,25,
10,22,53
13,20
14,62
9
32
84
11
33
,63
Emission estimates
factors.
(tons per year) based on AP-42 emission
2-17
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Table 9. MARYLAND: SIC CATEGORIES IN ORDER OF
NOx EMISSIONS
Standard Industrial Classification
4911 Electric Services
8221 Colleges, Universities, etc.
9711 National Security
9431 Administration, Public Health
6513 Apartments
4953 Refuse Systems
3251 Brick and Structural Clay Tile
9651 Regulation, Licensing and Inspection
8922 Educational, Scientific and Research
8211 Elementary and Secondary Schools
2816 Inorganic Pigments
2655 Fiber Cans, Drums, etc.
2752 Commercial Printing, Lithographic
2721 Periodicals: Publishing, etc.
2851 Paints, Varnishes, etc.
7216 Drycleaning Plants
No. of
Facilities
2
2
4
1
2
1
1
1
1
1
1
1
2
1
1
4
N0xa
(TPY)
22,700
278
275
234
94
50
44
44
32
31
28
5
2
0
0
0
Emission estimates (tons per year) based on AP-42 emission
factors.
2-18
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Table 10. MARYLAND: SIC CATEGORIES IN ORDER OF
VOC EMISSIONS
Standard Industrial Classification
2752 Commercial Printing, Lithographic
4911 Electric Services
2655 Fiber Cans, Drums, etc.
7216 Drycleaning Plants
2721 Periodicals: Publishing, etc.
9711 National Security
2851 Paints, Varnishes, etc.
4953 Refuse Systems
3251 Brick and" Structural Clay Tile
9431 Administration, Public Health
6513 Apartments
Others
No. of
Facilities
2
2
1
4
1
4
1
1
1
1
2
6
VOCa
(TPY)
554
390
152
118
72
70
54
8
4
4
3
0
Emission estimates (tons per year) based on AP-42 emission
factors.
2-19
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Table 11. VIRGINIA: SIC CATEGORIES IN ORDER OF
NOx EMISSIONS
Standard Industrial Classification
4911
9711
9511
4588
9199
9223
Electric Services
National Security
Air & Water Resource and Solid Waste
Air Transportation
General Government
Correctional Institutions
Others
No. of
Facilities
3
3
1
1
1
1
34
N0xa
(TRY)
20,300
375
302
69
52
45
6
Emission estimates (tons per year) based on AP-42 emission
factors.
Table 12. VIRGINIA: SIC CATEGORIES IN ORDER OF
VOC EMISSIONS
Standard Industrial Classification
5171 Petroleum Bulk Stations and Terminals
4911 Electric Services
3743 Railroad Equipment Mfg.
9711 National Security
2085 Distilled (etc.) Liquors
9511 Air & Water Resource and Solid Waste
3079 Miscellaneous Plastic Products
9199 General Government
3861 Photographic Equipment and Supplies
3441 Fabricated Structural Metal
Others
No. of
Facilities
9
3
1
3
1
1
1
1
1
1
24
voca
(TPY)
1,460
358
177
73
70
59
35
34
32
26
13
Emission estimates (tons per year) based on AP-42 emission
factors.
2-20
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Table 13 and 14 present similar information, for NOx and
VOC emissions respectively, integrated over the entire AQCR.
Table 15 indicates emission totals, by state and for the
entire AQCR, from each source category as indicated by SCC number
and from major types of activities, viz, coal burning, oil
burning, gas burning, electric utilities, industrial processes,
commercial/institutional sources. Corresponding information
for VOC is given in Table 16. Tables 17 through 22 present this
information, organized by states, showing the source categories
in descending order of estimated emissions.
In all of these tables, NOx emissions from SCC numbers
10100405, 10100501, and 10100502 have been adjusted to reflect
an emission factor of 105.0 pounds per SCC unit, given in AP-42
Supplement 9, instead of the factor 22 pounds per SCC unit,
apparently supplied by the EIS program.
2-21
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Table 13. NATIONAL CAPITOL INTERSTATE AQCR:
SIC CATEGORIES IN ORDER OF NOX EMISSIONS
Standard Industrial Classification
4911 Electric Services
4961 Steam Supply
9711 National Security
8221 Colleges, Universities, etc.
4953 Refuse Systems
9511 Air & Water Resource and Solid Waste
9431 Administration, Public Health
9100 General Government
8063 Psychiatric Hospitals
6513 Apartments
8062 General Hospitals
4588 Air Transportation
8361 Residential Care
9199 General Government
9223 Correctional Institutions
3251 Brick and Structural Clay and Tile
9651 Regulation, Licensing & Inspection
8922 Educational, Scientific & Research
8211 Elementary and Secondary Schools
2816 Inorganic Pigments
7011 Hotels
Others
TOTAL
No. of
Facilities
7
4
9
6
2
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
27
N0xa
(TPY)
47,200
1,760
758
564
378
302
234
158
143
94
76
69
60
52
45
44
44
32
31
28
26
19
52,200
aEmission estimates (tons per year) based on AP-42 emission
factors; rounded to three digits.
2-22
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Table 14. NATIONAL CAPITOL INTERSTATE AQCR:
SIC CATEGORIES IN ORDER OF VOC EMISSIONS
Standard Industrial Classification
5171 Petroleum Bulk Stations and Terminals
4911 Electric Services
2752 Commercial Printing: Lithographic
721 1 Power Laundries
3743 Railroad Equipment Mfg.
4953 Refuse Systems
2655 Fiber Cans, Drums, etc.
9711 National Security
2721 Periodicals: ' Publishing, etc.
7216 Drycleaning Plants
2754 Commercial Printing: Gravure
2085 Distilled (etc.) Liquors
9511 Air & Water Resource and Solid Waste
2851 Paints, Varnishes, etc.
4961 Steam Supply
3079 Miscellaneous Plastic Products
9199 General Government
3861 Photographic Equipment and Supplies
3441 Fabricated Structural Metal
Others
TOTAL
No. of
Facilities
9
7
2
2
1
2
1
9
1
4
1
1
1
1
4
1
1
1
1
23
VOCa
(TPY)
1,460
806
554
208
177
172
152
147
144
118
92
70
59
54
52
35
34
32
26
37
4,430
Emission estimates (tons per year) based on AP-42 emission
factors; rounded to three digits.
2-23
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Table 15. NOx EMISSIONS'1 BY SOURCE CATEGORIES, BY STATE
sec
10100202
10100401
10100404
101005013
10100504^
10100505
10200202
10200204
10200205
10200401
10200404
10200601
10300205
10300206
10300207
10300209
10300211
10300401
10300404
10300501
10300504
10300601
10300602
10300603
20100101
20100901
30501606
50100101
50100506
All coal
All oil
All gas
All utilities
All industrial
All comm./
inst.
All other
combustion
Grand total
DC
0
31
483
95
2,130
883
0
95
322
192
0
132
516
' 0
129
47
0
908
0
180
8
0
56
0
0
135
0
327
0
1,110
5,040
188
3,750
741
1,844
327
6,660
Maryland
20,300
0
2,260
557
0
0
0
0
0
0
0
0
0
0
0
0
0
578
67
34
0
220
107
26
0
0
0
0
44
20,300
3,490
353
23,100
0
1,030
44
24,200
Virginia
10,400
5,630
4,230
235
0
0
0
0
0
0
0
0
0
132
0
0
92
88
52
64
0
0
0
0
174
0
37
0
265
10,600
10,500
0
20,400
0
428
37
21,400
Total
30,700
5,660
6,970
887
2,130
883
0
95
322
192
0
132
516
132
129
47
92
1,570
119
278
8
220
163
26
174
135
37
327
309
32,100
19,100
541
47,400
741
3,300
408
52,200
Emission estimates (tons per year) based on AP-42 emission factors;
rounded to three digits.
2-24
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Table 16. VOC EMISSIONS'3 BY SOURCE CATEGORIES, BY STATE
sec
10100202
10100204
10100401
10100404
10100501
10100504
10100505
10200204
10200205
10200401
10300205
10300206
10300207
10300209
10300211
10300401
10300404
10300501
10300602
10300603
20100101
20100901
30101401
30201003
30800799
40100103
40100104
40100201
40100299
40200101
40200601
40200701
40200901
40200918
403xxxxx
404xxxxx
405xxxxx
406xxxxx
501xxxxx
TOTAL
DC
0
6
0
10
1
20
18
6
21
3
• 5
0
3
- 3
0
15
0
8
1
0
0
11
0
0
0
194
14
0
0
0
0
0
0
0
0
0
166
0
164
668
Maryland
339
0
0
45
7
0
0
0
0
0
0
0
0
0
0
10
5
2
2
2
2
0
54
0
0
92
26
0
0
0
1
16
0
0
67
0
749
0
8
1 ,420
Virginia
175
0
51
84
2
0
0
0
0
0
0
2
0
0
46
1
3
3
0
0
12
0
0
70
35
0
32
22
42
155
26
0
22
5
73
844
34
551
53
2,330
Total
514
6
51
139
9
20
18
6
21
3
5
2
8
3
46
26
8
13
3
2
14
11
54
70
35
286
72
22
42
155
27
16
22
5
140
844
949
551
225
4,420
Emission estimates (tons per year) based on AP-42 emission
factors; rounded to three digits.
2-25
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Table 17. SOURCE CATEGORIES (SCC) IN ORDER OF
ESTIMATED NOx EMISSIONS,
DISTRICT OF COLUMBIA
Source Cl
10100504
10300401
10300205
10100505
10100404
50100101
10200205
10200401
10300501
20100901
10200601
10300207
10100501
10200204
10300602
10300209
10100401
10300504
10200202
10200404
TOTAL
assifi cation Code and Category
No. 4 oil, normal firing, SIC 4911b
No. 6 oil, commercial/institutional boilers
Pulverized coal, wet bottom c/i boilers
No. 4 oil, tangential firing, SIC 4911
No. 6 oil, tangential firing, SIC 4911
Municipal incineration, multiple chamber
Bituminous coal, indus. overfeed stokers
No. 6 oil, industrial boilers
No. 1 or 2 oil, c/i boilers
Kerosene/naphtha (jet fuel) turbines
Natural gas, indus. boilers over 100 MMC
Bituminous coal, indus. o/f stokers 10 MM
No. 1 or 2 oil, boilers, SIC 4911
Bituminous coal, indus. spreader stokers
Natural gas, c/i boilers, 10-100 MM
Bituminous coal, c/i spreader stokers
No. 6 oil, normal firing SIC 4911
No. 4 oil , c/i boilers
Bituminous coal, indus. spreader stokers
No. 5 oil, industrial boilers
Total NOx
Emissions3
2,130
908
516
883
483
327
322
192
180
135
132
129
95
95
56
47
31
8
0
0
6,660
Emission estimates (tons per year) based on AP-42 emission
factors.
b,,
SIC 4911" indicates boilers used in electric power generation.
C"MM" indicates millions of Btu's per hour.
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Table 18. SOURCE CATEGORIES (SCC) IN ORDER OF
ESTIMATED VOC EMISSIONS,
DISTRICT OF COLUMBIA
Source Cl
40100103
50100101
40500501
40500401
10200205
10100504
10100505
10300401
40100104
20100901
10100404
10300207
10300501
10200204
10300205
10200401
10300209
10100501
10300602
TOTAL
assifi cation Code and Category
Perchloroethylene drycleaning
Municipal incineration, multiple chambers
Gravure
Lithographic Printing
(Coal , industrial )
(No. 4 oil, electric generation)
(No. 4 o-il, electric generation)
(No. 6 oil, commercial/institutional)
Stoddard Solvent Drycleaning
(Kerosene/naphtha; turbines)
(No. 6 oil, electric generation)
(Coal , industrial )
(No. 1 or 2 oil , c/i )
(Coal , industrial )
(Coal, c/i)
(No. 6 oil , industrial )
(Coal, c/i)
(No. 1 or 2 oil, electric generation)
(Natural gas/ c/i )
Total VOC
Emissions9
194
164
94
72
21
20
18
15
14
11
10
8
8
6
5
3
3
1
1
668
Emission estimates (tons per year) based on AP-42 emission
factors.
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Table 19. SOURCE CATEGORIES (SCC) IN ORDER OF ESTIMATED
NOx EMISSIONS, MARYLAND
Source Cl
10100202
10100404
10300401
10100501
10300601
10300602
10300404
50100506
10300501
10301002
10300603
20100101
TOTAL
assifi cation Code and Category
Pulverized coal, dry bottom, SIC 4911
No. 6 oil, tangential firing, SIC 4911
No. 6 oil, commercial/institutional boilers
No. 1 or 2 oil, boilers, SIC 4911
Natural gas, c/i boilers over 100 MM Btu/hr
Natural gas, c/i boilers, 10-100 MM Btu/hr
No. 5 oil, c/i boilers
Sludge incinerators
No. 1 or 2 oil, c/i boilers
Liquefied petroleum gas, c/i boilers
Natural gas, c/i boilers under 10 MM Btu/hr
Distillate oil: turbines, SIC 4911
Total NOx
Emissions
20,300
2,260
578
557
220
107
61
44
34
32
26
8
24,200
aEmission estimates (tons per year) based on AP-42 emission
factors.
"SIC 4911" indicates equipment used in generating electric
power.
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Table 20. SOURCE CATEGORIES (SCC) IN ORDER OF ESTIMATED
VOC EMISSIONS, MARYLAND
Source Cl
40500401
10100202
40100103
40500599
40500304
40500201
40388801
40500506
30101401
40500301
40100104
40200701
50100506
10100501
10300401
TOTAL
assifi cation Code and Category
Printing, lithographic ,
Pulverized coal, dry bottom, SIC 4911
Drycleaning, perchloroethylene
Printing, ink thinning solvents
Printing, ethyl alcohol solvent
Printing, letter press
Petroleum storage
Printing, methyl ethyl ketone solvent
Paint manufacturing, mixing and handling
Printing, flexographic
Drycleaning, Stoddard solvent
Adhesive, general
Sludge incinerators
No. 1 or 2 oil, boilers, SIC 4911
No. 6 oil , c/i boilers
Total VOC
Emissions9
475
339
92
81
78
72
67
55
54
48
26
16
8
7
6
1,420
Emission estimates (tons per year) based on AP-42 emission
factors.
"SIC 4911" indicates equipment used in generating electric
power.
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Table 21. SOURCE CATEGORIES (SCC) IN ORDER OF ESTIMATED
NOx EMISSIONS, VIRGINIA
Source Classification Code and Category
10100202 Pulverized coal, dry bottom, SIC 4911b
10100401 No. 6 oil, normal firing, SIC 4911
10100404 No. 6 oil, tangential firing, SIC 4911
50100506 Sludge incincerators
10100501 No. 1 or 2 oil, boilers, SIC 4911
20100101 Distillate oil: turbines, SIC 4911
10300206 Pulverized coal, dry bottom, c/i boilers
10300211 Over/underfeed stokers, over 10 MM Btu/hr
10300401 No. 6 oil, c/i boilers
10300501 No. 1 or 2 oil, c/i boilers
10300404 No. 5 oil, c/i boilers
30501601 Calcimatic kiln
TOTAL
Total NOx
Emissions
10,400
5,630
4,230
265
235
174
132
92
88
64
52
37
21,400
Emission estimates (tons per year) based on AP-42 emission
factors.
)nSIC 4911" indicates equipment used in generating electric
power.
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Table 22. SOURCE CATEGORIES (SCC) IN ORDER OF ESTIMATED
VOC EMISSIONS, VIRGINIA
Source Cl
404xxxxx
406xxxxx
10100202
40200101
401xxxxx
10100404
403xxxxx
30201003
50100506
10100401
10300211
30800799
405xxxxx
40200601
40200901
40200918
TOTAL
assification Code and Category
Gasoline storage at bulk plants and
terminals
Transportation and marketing of petroleum
products ,
Pulverized coal, dry bottom, SIC 4911
Painting, general
Drycleaning and degreasing
Utility boilers, grade 6 oil, tangential
firing-
Refineries, storage of petroleum products
Whiskey permentation: aging
Sludge -incinceration
Utility boilers, grade 6 oil, normal firing
C/I boilers, less than 10 MM, over and
underfeed stokers
Fabricated plastic products, and classified
Ink thinning solvents
Surface coating: primer
Thinning solvent: acetone
Thinning solvent: methyl ethyl ketone
Total VOCa
Emissions
844
551
175
154
115
86
73
70
53
49
36
35
35
26
22
5
2,330
Emission estimates (tons per year) based on AP-42 emission
factors.
"SIC 4911" indicates equipment used in generating electric
power.
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2.4 SPECIFIC DISCREPANCIES FOUND IN THE DATA BASE
2.4.1 DISCREPANCIES IN EMISSION FACTORS FOR BOILERS
Listed emission factors were found, in a few cases, to differ
from those published in Supplement 9 to AP-42, "Compilation of Air
Pollutant Emission Factors," dated July 1979. Review showed that
these discrepancies affected four source classification code (SCC)
numbers, which were associated with a total of 13 point sources
in three facilities, as follows:
Emission Factors
File .AP-42
SCC NOx HC NOx HC Plants and Points Affected
10100501 22 1 105 1 PI. 1:5 and 6; PI. 40:2,3,4,5,6
10100502 22 1 105 1 PI. 1:1,2,3 and 6
10100504 22 1 50 1 PI. 1 ;4 and 5
10300205 15 1 30 0.3 PI. 24:1 and 2
The discrepancies reported have some important effects on the
estimated emissions of NOx in the District of Columbia. For Plant
1, a major electric generating facility, NOx emissions estimated
by AP-42 factors are 3,051 tons per year, as compared with only
847 tons per year found in the file. For Plant 24, NOx emissions
by AP-42 are 891 tons per year, as compared with 633 tons per year
found in the file. For Plant 40, the effect is negligible, since
it applies to a fuel (No. 2 oil) which constituted less than 1 per-
cent of the annual fuel consumption of the facility. (The effect
of the revision in hydrocarbon emissions at Plant 24 is to reduce
the total from 23 tons per year to 17 tons per year for that
plant.)
Thus, use of AP-42 emission factors for Plants 1 and 24 would
increase estimated NOx emissions by 260 percent at Plant 1 and by
41 percent at Plant 24. It would also increase the estimated
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total NOx emissions for the file by 2,462 tons per year, which is
37 percent of the total found in the file. It therefore appears
important to determine whether the emission factors given in the
file are supported by physical evidence, or by a plausible rationale.
If they are not so supported, the file should be revised to reflect
the AP-42 factors and the increased NOx emissions estimates those
factors would yield.
Like the District of Columbia, both Maryland and Virginia have
applied a factor of 22 pounds per ton to estimate emissions from
utility power plants when burning oil. The only source classifica-
tion category used for this type of source in the Maryland and
Virginia files is 1-01-005-01. For this SCC, Supplement 9 prescribes
a factor of 105 pounds per ton, which is 4.8 times as large as the
factor applied in the file.
Because of this discrepancy, PES estimates that VOC emissions
from this category in Maryland should be 557 tons per year, instead
of the total of 107 found in the file. Similarly, in Virginia,
the total should be 235 tons per year, instead of 51. Thus the
re-estimate adds 450 tons per year in Maryland and 184 tons per
year in Virginia. These amount to about 20 percent and 1 percent,
respectively, of the total indicated NOx emissions in the two
point source files.
In this connection, PES also calculated NOx concentrations
in the stack gases from these power plants, as indicated by the
file data. Using the factor of 22 pounds per hour as given in
the file, the concentrations were of the order of magnitude of
100 ppm; with the AP-42 factor (105 Ib/hr), they were nearer to
500 pphm. PES considers the latter result to be more nearly in
accord with general experience in relation to power plant stack
gases.
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2.4.2 EXHAUST GASES FROM TURBINES
Diesel-fueled turbines are used for electric power generation
in two power plants in Maryland and one in Virginia. In Maryland,
the total NOx emissions from these sources (SCC 2-01-001-01) amount
to 8 TRY, while in Virginia the indicated total is 174 TRY.
For the turbines in the Virginia power plant, the file
indicates a stack velocity of 1,800 feet per minute, while RES
calculates a value of about 7,800 fpm based on the stack diameter,
temperature and flow rate shown in the file. Possibly the file
entry of 1,800 is due to an erroneous transcription from an original
value of 7,800. In any event, there seems to be no reason to
question the emissions estimates as cited above.
Stack velocities have not been entered in the files for turbines
in Maryland and the District of Columbia.
2.4.3 BOILER CAPACITY
For a boiler at one power plant in Virginia, the indicated
heating capacity, 3,118 x 10 Btu per hour, is inconsistent with
the indicated maximum design rate, 49,224 gallons of oil per hour;
the latter value implies a heating capacity of 7,334 x 10^ Btu per
hour. This discrepancy suggests the possibility of an error in
recording the fuel throughput for this point (County 2520, plant
0002, point 05). Since NOx emissions from this source are very
large -- 4,300 TRY -- RES recommends that the engineering data for
the boiler be rechecked.
2.4.4 SLUDGE INCINERATION
At a waste-disposal plant in Virginia, the indicated maximum
design rate of a sludge incinerator is inconsistent with the
indicated process rate, which is about 100 times larger. The
indicated NOx emissions (265 TRY) correspond to the indicated
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process rate of 106,000 tons of sludge burned per year, or about
300 tons per average day. If the maximum design rate (0.118 tons
per hour) is correct, the NOx emissions would be limited to about
2.6 TRY. The engineering data for this facility (County 1060,
plant 0281, point 05) should be rechecked.
2.4.5 BOILER DESIGN RATE
For County 2520, plant 0002, point 04 (a power plant in
Virginia), the maximum design rate for pulverized coal is entered
as the same value, in tons per hour, as that given for oil in
thousands of gallons per hour. This is probably an error, but there
is no reason to suppose that the emission estimates are incorrect
because of it.
2.4.6 PRINTING PLANTS
Emissions estimates for two printing plants in Maryland
are indicated as having been derived from mass-balance calculations.
The results cannot be confirmed by PES, because the basic data
have not been provided. However, the estimates provided are, in
some cases, inconsistent with other information in the file.
In at least two instances, the numbers entered in the file
imply that the process emitted VOC at a rate greater than the rate
of use of VOC in the process. Thus, in County 1160, plant 0012,
point 04, the file shows HC emissions of 68 TPY emerging from a
direct-flame afterburner with a control efficiency of 90 percent;
this implies 10 x 68 or 680 TPY of HC entering the afterburner.
However, the process rate is entered as only 326 TPY. For point
05 of the same plant, 97 TPY are estimated after 90 percent control,
implying 970 TPY from the process, whereas the process rate is
given as 394 TPY.
At other points (01, 02, 03, 06), HC control is indicated as
being accomplished by means of an electrostatic precipitator,
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although precipitators are ordinarily effective only for control of
participate matter. Resultant emissions for this plant, calculated
from AP-42 factors and throughput values indicated in the file,
assuming 65 percent control efficiency by the afterburner and 0 by
the precipitators, total 312 TRY, as compared with 415 TPY found
in the file.
For County 1300, plant 0020, total VOC used at two emission
points appears to be 72 TPY of ink solvents and 104 TPY of ethyl
alcohol. Control efficiency, by an electrostatic precipitator, is
said to be 25 percent. This gives total emissions equal to 75
percent of 176, or 132 TPY, while the file shows 91 + 48, or 139.
Here, again, is a problem concerning the efficiency of a precipi-
tator for controlling hydrocarbons. If the efficiency is assumed to
be zero, the emisstons would be 72 + 104, or 176 TPY. However,
there is a possibility that the control equipment existing at the
plant may actually be a scrubber, which should have been coded as
013, instead of 012 which indicates a precipitator.
For County 1300, plant 0012, point 04, an ink dryer is
indicated as receiving 178 TPY of solvent, controlled by a scrubber
at 50 percent efficiency. From these figures, the emissions should
be half of 178, or 89 TPY; but the file shows 79 TPY. At the same
time, 50 percent is likely to be an overestimate of scrubber
efficiency, so the emissions may actually correspond to 100 TPY or
more, rather than the 79 given in the file.
Because of these inconsistencies and uncertainties, the
engineering data for these and other printing plants in the
Maryland file should be reviewed and corrected.
2.4.7 DISTILLERY EMISSIONS
For a distillery in Virginia (County 1060, plant 0059), HC
emissions calculated from AP-42 emission factors would be 150 TPY.
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The file shows 70 TRY, citing a material balance calculation.
There are no internal inconsistencies in the data cited.
2.4.8 BULK TERMINALS FOR GASOLINE DISTRIBUTION
The Virginia point source file lists nine bulk terminals,
with total HC emissions of 1,455 TPY. AP-42 provides different
emission factors for petroleum storage tanks, depending on whether
the tanks are "new" or old." It appears that the Virginia file
utilizes factors which are halfway between the "new" and "old"
factors given in AP-42. This corresponds to an assumption that
half the tanks at each terminal are new and half are old. Lacking
more specific information, this seems to be a reasonable compromise.
However, the uncertainty involved is substantial. For example, at
one point source, the emission estimate in the file is 180 TPY,
while if the emission factor for old tanks were used, the result
would be 250 TPY.
PES reviewed the major emission point files for these bulk
terminals thoroughly and found no obvious errors or internal
inconsistencies. Each point record refers to several tanks.
The number of tanks included is not recorded in the file, but
can be inferred, approximately, from the SCC number (which
identifies the size of each tank) and the total capacity listed
in the appropriate point record. Apparently, two to six tanks
are usually represented in one record.
2.4.9 REVIEW OF MEMOS RELATED TO POINT SOURCE INVENTORY
PES received, from the Project Officer, a copy of notes from
another contractor's review of the 1980 Point Source Inventory of
AQCR 047. These notes were in the form of a list of questionable
entries found in data formatted for input into the EIS data base.
A similar memo, received in September, listed questionable
entries in the Maryland 1980 Point Source Inventory.
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After reviewing these memos, PES has the following comments.
In the Maryland list, four of the plants listed as having
questionable entries were located in AQCR 047. Two of these
were in Montgomery County (County 1160) and two in Prince Georges
County (1300). Data questioned related to a total of 18 points
within these plants. PES checked the Maryland point-source
printout and found that most of the missing data noted in the memo
had been supplied, but that previously existing data which were
questioned in the memo had not been changed.
Specifically, the contractor questioned indicated heights
of 703 and 712 feet for two power plant stacks, a plume height of
6 feet for a painting operation, and specific stack parameters for
two stacks exhausting utility turbines. These entries are apparently
retained without change in the Maryland point-source printout.
PES assumes they have been reconsidered and accepted by the
Mayland agency.
The specific items, which were apparently left unchanged by
the Maryland agency, were the following (listed with PES comments):
County 1160 (Montgomery County)
Plant 0008, Point 5. The contractor suggested checking stack
parameters. Parameters in the printout are: stack height
30, diameter 10, temperature 900, flow rate 350,000. These
numbers seem reasonable, for a turbine installation.
Plant 0008, Points 6 and 7. The contractor asked to have the
6 foot plume height verified and the stack temperature supplied.
The printout shows plume height 6 feet and does not supply
temperature. However, since the process is evaporation
from liquid storage, the temperature is not needed, as no
heat is supplied.
Plant 0013, Point 4. The contractor reports "common stack
error." The common stack field in the printout is blank, as
it should be.
Plant 0013, Point 7. Stack parameters are missing in the
printout.
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County 1300 (Prince Georges County)
Plant 0007, Point 6. The contractor suggested checking stack
parameters. Parameters in the printout are stack height 30,
diameter 11, temperature 900, flow rate 385,000. These
numbers are reasonable, for a turbine installation.
The later memo also provides a list of 25 plants in AQCR 047,
with questions and comments about specific data entries in each.
Of the 25, 13 plants are in the DC file, four in Maryland, and
eight in Virginia. Only two of the four Maryland plants cited
in the earlier memo occur in this list; PES presumes that the
deletion of the other two reflects that contractor's receipt of
satisfactory answers .to the questions raised in that memo. The
data questioned in the later list relate to 31 individual emission
points in the District of Columbia, 16 in Maryland, and 68 in
Virginia.
PES checked the corresponding point-source printouts and found
that the entries contained were consistent with the questions
and comments listed, indicating that the later list was based on an
inventory which was essentially identical to the inventory found in
these point-source printouts.
For eight plants with external combustion boilers as point
sources, the memo questions the relation between calculated maximum
firing rate and indicated boiler capacity. These questions are
based on consistency checks which were also done by PES, with
essentially the same results. The plants involved are:
District of Columbia, 0024, 0025, 0040
Maryland, Montgomery Co., 0008; Prince Georges Co., 0007
Virginia, Fairfax Co., 0024; Prince William Co., 0002, 0010
For several internal combustion electric generator sources
(turbines), the memo questions stack parameters where stack heights
are 20 to 40 feet and diameters about 10 feet. Such values
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I appear reasonably conventional to PES. Plants involved are DC
0040, Montgomery County 0008, Prince William County 0002.
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3.0 AREA SOURCE DATA QUALITY
3.1 AREA SOURCE METHODOLOGIES
PES received, from R. Kaufmann of Metropolitan Washington
Council of Governments, a copy of a memorandum dated October 29,
1981, on the subject of area and point source inventory assump-
tions. This memo, shown in Appendix A, listed 20 area source
categories, discussing in each case the methods proposed for
estimating the corresponding emissions. The area source
categories thus discussed are:
Animal wastes •
Forest fires
Pesticides
Off-highway vehicles
Evaporative losses from service stations
Gasoline losses in transit
Printing and miscellaneous solvents
Small shop auto painting
Degreasing
Open/controlled burning
Incineration
Vessels
Commercial airports
Military airports
General aviation airports
Commercial/consumer solvents
Architectural surface coatings
Drycleaning
Residential/commercial/institutional fuel use
Railroads
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This list includes almost all of the categories named in the
EPA document, "Procedures for the Preparation of Emission Inven-
tories for Volatile Organic Compounds, Volume I, Second Edition,"
hereinafter referred to as "Procedures." Categories or sub-
categories listed in Procedures but not covered in the memorandum
are:
Surface coatings, other small industrial
Cutback asphalt
Highway mobile sources
Structural fires
One category, animal wastes, is included in the memo but not in
Procedures.
PES reviewed the assumptions and methodologies presented in
the memo, to judge whether these were plausible and explicit enough
to serve as documentation for a SIP or air quality modeling
inventory.
The descriptions furnished in the memo are, in general, not
directed toward the preparation of a gridded emissions inventory,
but only to disaggregation of emissions and activities to the
county level. Further, in many instances, specific emission
factors are not listed, and the methods are described only to the
extent of citing AP-42 as the source for appropriate emission
factors. Since the descriptions are, for the most part, not very
detailed, PES reviewed them principally from the standpoint of
plausibility and consistency with EPA guidance as expressed in
Procedures.
More specific comments and questions resulting from review of
the memo, as of December 31, are as follows.
1. Animal Wastes. Nothing appears in AP-42 relating to this,
except for section 6.15 on Beef Cattle Feedlots. This gives no
information on VOCs, except for a figure of 0.5 pounds of amines
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per day per 1,000 head capacity. The source of the information
presented by MWCOG is not known; however, it is plausible to
assume that both VOC and NOx emissions are insignificant.
2. Pesticides. AP-42 contains nothing relating to this.
Perhaps COG used the number, 0.25, cited in "Procedures."
3. Off-Highway Vehicles. (1) Construction Equipment: AP-42
gives emission factors in 3.2.7, but these are for specific types
of equipment. Did MWCOG estimate the amount of equipment in
these categories, or use a composite factor: If the latter, how
was it arrived at?
(2) Farm Equipment: 1980 figures were used for 1987, on the
premise that no significant change in sales is expected. Is it
assumed that the existing rate of sales is just balanced by
retirement through obsolescence? Or is it assumed that continued
sales will not affect the total fuel used?
(3) Lawn and Garden Equipment: the formula given by MWCOG
is not equivalent to the formula given in "Procedures." To get
the correct result, the value "the number of days used per year"
should appear in the denominator instead of the numerator. (This
gives emissions per day, assuming the national consumption is on an
annual basis.)
4. Evaporative Losses From Service Stations. For unloading
of tank trucks, MWCOG assumes a 3 to 1 ratio of submerged filling
to splash filling. We would like to know whether there are local
data to support this assumption.
5. Gasoline Losses in Transit. MWCOG assumes a 1 to 1 ratio
of submerged to splah filling; is this arbitrary? Again, MWCOG
reports that, in order to correct for losses in transit, gas
sale figures were multiplied by "the 1.25 growth factor." It
appears, however, that the factor (1.25) accounts for extra transit
due to deliveries to bulk plants and is not associated with projections
of growth.
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3.2 AREA SOURCE EIS FILE
During January 1982 PES received (from Metropolitan Washington
Council of Governments) a magnetic tape said to represent the
gridded area source inventory of the National Capital Interstate
AQCR, in EIS input format. PES prepared a computer listing of
the contents of the area source tape and tabulated and interpreted
the records found in that listing.
The listing was found to cover only a few of the area source
categories which would be needed for a complete area source
inventory. Types of records in the listing were identified by
their area-source SCC numbers, as follows:
SCC Code
90501200
90702400
90803100
90803200
90803300
90904430
91005200
Source
Type
E
J
M
N
P
F
R
Interpretation
fuel burning
railroads
military aviation
civil aviation
commercial aviation
vessels, gasoline powered
gasoline marketing
No. of
Grid
Squares
266
169
8
9
6
34
258
Totals
NOx
979
1,350
219
13
1,230
4,280
0
VOC
5,110
347
398
82
1,010
7,730
469
TOTALS 8,070 15,200
Area sources discussed in the WASHCOG memorandum of October
1981, included the following categories not found on the area
source tape:
Animal wastes
Forest fires
Pesticides
Off-highway vehicles
Printing and miscellaneous solvents
Small shop auto painting
Degreasing
Open/controlled burning
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Incineration
Commercial/consumer solvents
Architectural surface coatings
Drycleaning
It therefore appears that the tape received represents only a
fraction of the complete area source file.
Since none of the information used to generate the records on
the tape was made available, PES was unable to check these
estimates for internal consistency. However, we note that there
are some rather surprising relations indicated in the table.
1. Total VOC emissions from gasoline-powered vessels are
shown to be almost 20 times as much as those from
gasoline marketing. A check of some area source inven-
tories for other locations with port facilities indicates
that gasoline-marketing emissions are usually higher
than emissions from vessels. This is true, for example,
in Tampa Bay, in Philadelphia, and even in Ocean
County, New Jersey.
2. Totals for fuel burning for both NOx and VOC appear large
relative to those reported in Philadelphia, an area with
larger population and more industrial activity. Further,
the relation of total NOx to total VOC emissions -- about
5 to 1 -- suggests that the emission factors for open
burning have been applied, rather than those for residen-
tial/commercial/institutional fuel use. The detail
provided is insufficient to allow PES to determine
whether this is an appropriate application of these emission
factors.
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4.0 CONCLUSIONS AND RECOMMENDATIONS
4.1 CONCLUSIONS
The most general conclusion that can be stated, based on the
experience gained in this study, is that the documentation avail-
able to a contractor concerning air pollutant emissions from the
National Capital Interstate Air Quality Control Region is insuf-
ficient to support a complete data quality audit.
In particular, the following types of information were
requested but not received:
1. Documentation describing the methodologies applied or
intended for application in estimating emissions from point
sources and some ar.ea source categories.
2. Complete area-source listings, together with documentation
showing activity levels, emission factors, control efficiencies,
and other factors used in estimating emissions.
3. Projection data used to reflect expected growth in point
and area source emissions.
4. Documentation of presumed control efficiencies and control
scenarios to be used in the 1987 inventories to reflect proposed
control measures.
Within the limitations of the information received, the
following specific conclusions have been reached.
4.1.1 COMPLETENESS OF THE POINT SOURCE FILE IN RELATION TO THE
RACT DIRECTORY
No more than five (5) facilities are listed in the RACT
Directory (EPA-450/4-81-018, February 1981) as existing within
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AQCR 047 and constituting possible major point sources of VOC
emissions. Three of these facilities, within the District of
Columbia, are reported by MWCOG to have been checked and found
not be major point sources of VOC emissions. The other two
facilities, listed in the RACT Directory as bulk gasoline terminals
in Fairfax County, Virginia, have not been positively excluded
as possible major point sources. (Refer to Section 2.1.1).
4.1.2 COMPLETENESS OF THE POINT SOURCE FILE IN RELATION TO
INDUSTRIAL DIRECTORIES AND OTHER LISTS
A preliminary screening of manufacturing firms, listed in the
Virginia Industrial Directory as existing within the area of
AQCR 047 and satisfying certain criteria as to employment and
industry classification, yielded a list (Table 1) of 56 candidate
firms which might be expected to have appreciable VOC emissions.
The list did not include all of the five major point sources,
identified in the Virginia EIS printout, which satisfied the same
criteria. (Refer to Section 2.1.3.) It is not known whether
the firms listed in Table 1 have already been considered and
excluded from the EIS point source listings.
In regard to point sources in Maryland, an independent updating
effort was said (by MWCOG) to be in prospect. Another contractor's
earlier report (refer to Section 2.1.2) indicated that there were
no facilities listed in the "Organic Chemical Producers Data
Base" which were missing from the EIS file.
In regard to point sources in the District of Columbia, the
same contractor's earlier report named eight firms included in the
point-source EIS file which were not among those listed in the
EIS printout provided to PES. PES presumes that these firms were
deliberately deleted as not constituting major point sources of NOx
or VOC emissions (refer to Section 2.1.2).
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4.1.3 CONSISTENCY OF DATA ON BOILERS
There are many instances of incomplete data and internal
inconsistencies in data in the point source records for boilers
as seen in the EIS printouts for AQCR 047. Most of the omissions
and inconsistencies appear to be of minor importance (refer to
Section 2.2 for further detail and discussion). However, the
existence of a high percentage of inconsistencies in addition to
an appreciable proportion of missing data on stack temperature
and exhaust flow rate indicates that the quality of data on boilers
is, at best, questionable.
4.1.4 EMISSIONS BY STATE, FACILITY TYPE, AND SOURCE CLASSIFICATION
In AQCR 047, annual point source emissions as indicated in
the EIS printouts total 49,100 tons of NOx and 4,420 tons of VOC.
Estimates made by PES based on the use of emission factors given
in EPA's "Compilation of Emission Factors," (Document AP-42,
Supplement 9, July 1979) indicate corresponding totals of 52,200
tons of NOx and 4,330 tons of VOC. This is an increase of about
6 percent in total NOx and a decrease of about 2 percent in total
VOC (refer to Section 2.3). However, some of the VOC point source
records in the EIS file deserve further scrutiny, which might
identify further discrepancies of a similar order of magnitude.
In regard to NOx emissions, there are four electric generating
plants which contribute, each, about 20 percent of the total annual
emissions (refer to Table 4). VOC emissions are more broadly
distributed (refer to Table 5), with no one facility producing
more than about 7 percent of the total. Among industries the major
contributors of VOC emissions (refer to Table 6) are SIC 5171
(petroleum bulk stations and terminals), all in Virginia, contributing
33 percent of the total; 4911 (electric services), 18 percent;
and the printing and publishing industries (2721, 2752, and 2754)
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contributing collectively 18 percent of the total. Drycleaning
and power laundries (7211 and 7216) totalled about 14 percent
of total VOC emissions, with the remaining 17 percent distributed
among 23 other SIC numbers.
Among source categories, 90 percent of NOx emissions were due
to combustion of fuels by electric utilities (refer to Table 15).
Of total combustion-related NOx, over 62 percent was produced by
the burning of coal and 37 percent by burning of oil.
4.1.5 SPECIFIC DISCREPANCIES AT INDIVIDUAL PLANTS
4.1.5.1 Discrepancies in Emission Factors for Boilers
Emission factors for NOx from certain types of boilers
(SCC 10100501, 10100502, 10100504, and 10300205), as specified in
the EIS printouts, differed from those given in AP-42 (refer to
Section 2.4.1) for a total discrepancy of almost 3,200 tons per
year. PES calculated NOx concentrations in the stack gases from
these power plants as about 100 ppm if the factors from the
printouts are assumed, as compared to 500 ppm if AP-42 factors
are used. PES considers the latter result to be more nearly in
accord with general experience in relation to power plant stack
gases.
4.1.5.2 Discrepancies in NOx and VOC Emission Estimates
Emissions estimates for some printing plants in Maryland
(refer to Section 2.4.6) are indicated as having been derived from
mass-balance calculations. In some cases the estimates provided
conflict with other information in the file. These discrepancies
involve a possible overestimation of VOC emissions in Maryland
by about 100 tons per year.
NOx emission estimates for a power plant (refer to Section 2.4.3)
and a waste-disposal plant (refer to Section 2.4.4) in Virginia are
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subject to question because of internal inconsistencies in the EIS
records shown in the Virginia printout. Information available
was insufficient to allow PES to confirm or re-estimate the
indicated emissions for these plants, whose listed emissions
of NOx were 4,300 and 265 tons per year, respectively. Similar
inconsistencies exist in records for other plants, as discussed
in Sections 2.4.2 and 2.4.6. Undocumented assumptions hindered
the checking of VOC emissions estimates in the cases of a distillery
(Section 2.4.7) and the storage tanks at petroleum bulk terminals
(Section 2.4.8).
4.1.6 REVIEW OF MEMQS RELATED TO POINT SOURCE INVENTORY
PES received notes from another contractor's review of the
1980 Point Source Inventory for AQCR 047 and additional notes
regarding the Maryland 1980 Point Source Inventory (refer to
Section 2.4.9). After reviewing these notes, PES concludes that
the EIS point-source printouts reflect changes in the emission
inventory records in response to some (but not all) of the con-
tractor's comments. PES presumes that the notes have been con-
sidered by the agencies of the states involved and that appropriate
corrections were made where possible. However, in some cases,
PES concurs with the other contractor's comments on items which
appear not to have been corrected.
4.1.7 AREA SOURCE METHODOLOGIES
PES reviewed a memorandum from MWCOG (refer to Section 3.1)
which outlined methodologies for 20 area source categories. It is
concluded that this memorandum does not constitute adequate docu-
mentation to support a data quality audit with respect to area
source categories.
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4.1.8 AREA SOURCE EIS FILE
PES received a magnetic tape said to represent the gridded
area source inventory of the National Capital Interstate AQCR,
in EIS input format. After listing, tabulating, and interpreting
the contents of that tape, PES concludes that the tape represents
only a fraction of the complete area source file. Some of the
information contained on the tape also appears highly questionable,
as discussed in Section 3.2.
4.2 RECOMMENDATIONS
PES recommends, in general, that the air pollution agencies
involved in the preparation of the EIS inventory of NOx and VOC
emissions review the specific criticisms and suggestions contained
in this report and attempt to supply missing information and resolve
apparent discrepancies in emission estimates and other data. In
so doing, highest priority should be assigned to NOx emissions
from large power plants and VOC emissions from petroleum bulk
stations and terminals, printing and publishing industries,
drycleaning and power laundry facilities.
To assure completeness of the EIS file of major point sources,
the Virginia agency should review the list of firms shown in
Table 1 and determine whether any of them are, in fact, point
sources of NOx or VOC which have not been included in the EIS file.
The Virginia agency should also make the same determination with
respect to two reported gasoline bulk terminals named in Section
2.1.1. The Maryland agency and the District of Columbia agency
should undertake similar completeness checks before finalizing
their point source lists.
Each agency should also develop appropriate documentation to
support the validity of its emission estimates. This should
include the following types of information.
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1. Documentation describing the methodologies applied or
intended for application in estimating emissions from point
sources and some area source categories.
2. Complete area-source listings, together with documenta-
tion showing activity levels, emission factors, control efficiencies,
and other factors used in estimating emissions.
3. Projection data used to reflect expected growth in point
and area source emissions.
4. Documentation of presumed control efficiencies and con-
trol scenarios to be used in the 1987 inventories to reflect
proposed control measures.
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APPENDIX
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metropolitan Washington
COUNCIL OF GOVERNMENTS
1875 Eye Street, N.W., Suite 2OO. Washington. D.C. 120006 223-G«OO
INTEROFFICE
MEMORANDUM
DATE: October 29, 1981
TO: Austan S. Librach
• ^ .' ••r'
FROM: Robert C. Kaufmann r^1""
SUBJECT: 1980/1987 Area and Point Source Inventory Assumptions
ANIMAL WASTES: State Agriculture Departments were contacted in order to
obtain latest estimates of various animal populations. Dog registrations
and estimates of cat populations were obtained from local jurisdictions.
Emissions were calculated using EPA's Compilation of Air Pollutant Emission
Factors (AP-42). Species data on VOC composition showed that emissions
were 96.75 percent non-reactive (methane and ethane), so emissions of VOC
were determined to be regionally insignificant. No NOX is emitted from
animal wastes.
FOREST FIRES: Local fire marshals were contacted through COG's Public
Safety Committees to obtain estimates of forest fires in the region. The
marshals noted that forest fires in the region were regionally insignificant,
so emissions were ignored.
PESTICIDES: Several sources (including DC DOT, DC DES, DC Recreation Dept.,
Va. Highway Dept., Va. Agriculture Dept., National Assoc. of Agricultural
Chemical Users, SCS, Md. Agriculture Depts, and local jurisdiction staffs)
were contacted for estimates of pesticide usage. No estimates were avail-
able from these sources. The Procedures for the Preparation of Emission
Inventories manual noted that pesticide usage varied from 2 to 5 Ibs/yr per
harvested acre. For lack of a better procedure, we assumed 3.5 Ibs/yr per
harvested acre. Acreages were obtained from the USDA Census of Agriculture.
Arlington, Alexandria and D.C. were zeroed out because they have no harvest-
able acreages. Home and garden usage figures are considered separately
(under commercial/consumer solvent use). AP-42 emission factors were used
to calculate yearly emissions, which were in turn divided by 250 (approxi-
mate length of the growing season) to yield typical summer day estimates.
For 1987, estimates of harvested acres were obtained from State
Agriculture departments. These new lower farm acreages (reflecting con-
sumption of farmlands for other development purposes) were used with the
3.5 Ibs/harvested acre and AP-42 emission factors.
OFF-HI GHVJAY VEHICLES; Five different types of vehicles are included in
this category, so emissions for each type were separately calculated, and
emissions from all five categories summed. Specific calculation procedures
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.\ma at Columbu • Arunfton County • Fairfai County • Loudoun ("ounry • Momeomtn• County • Pnnct Gtonr - > • <,- . • ['nn«- VV ,;iur. •'
Bow. • Coll«ftP«rii • F.,rfMCity • Fall* Church • Cjuneriburj • On.nbrlt • Rn.-kv.illr • TV.nmaPjrk
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follow: (1) Construction equipment - local associations and general con-
tractors (including George Hyman Construction, Donohoe Construction, Rufus
Lusk Construction, Volpe Construction, National Association of Homebuilders,
etc) were contacted for fuel use estimates. Though most sources were unable
to provide the requested information, two sources (George Hyman Construction
and Fuller-Griffin Construction) were able to provide us with gallons per
employee figures. To be conservative, we chose the higher of the two
figures (650 gallons of fuel per year per employee). This figure was multi-
plied by the number of employees employed in heavy construction in each
county (from 1978 County Business Patterns), and resultant total fuel figures
were multiplied by appropriate AP-42 emission factors. Because county
employment figures did not accurately represent where construction was
taking place, emissions were re-allocated according to non-single family
building permits for each jurisdiction.
For 1987, the Cooperative Forecasts (Round II) predicted that construction
employment would increase by a factor of 1.37. This growth factor was
multiplied by 1980 emissions to yield 1987 estimates.
(2) Industrial equipment - a methodology suggested in the Procedures
manual was used. County consumption = National fuel use X
County Employment for SICs 10-14, 20-39, 50-51
National Employment for SICs 10-14, 20-39, 50-51
The resultant fuel consumption figures were multiplied by AP-42 emission
factors.
1980 emissions were multiplied by a growth factor suggested in the
Cooperative Forecast Summary Report to yield 1987 emissions. (3) Farm
equipment - equipment population data was obtained from the USDA Census of
Agriculture, and estimates of annual usage (hrs/yr) and fuel consumption
rates (gals/hr) were obtained from the Procedures manual. Gas and diesel
usage figures were multiplied by appropriate AP-42 emission factors.
For 1987 emission estimates, State Agriculture departments, USDA, and
the Farm Dealers Equipment Association were contacted for estimates of farm
equipment populations. All sources noted that they expected no significant
changes in sales.' As a result 1980 figures were used for 1987. (4) Lawn
and Garden equipment - a methodology suggested in the Procedures manual
was used. County consumption = county single family units X national
national single family units
lawn and garden equipment fuel consumption X the number of days used per
year. County fuel consumption figures were multiplied by AP-42 emission
factors. Emissions from this sub-category were so small for VOC and NOX
that changes in population from 1980 to 1937 were assumed to have a
negligible effect.
(5) Motorcycles - the methodology suggested in the Procedures manual
was used. County consumption = county registrations (obtained from the
Motorcycle Industry Council) X 700 miles/yr/42.5 miles/gallon (EPA estimates).
County fuel consumption was then multiplied by appropriate AP-42 emission
factors.
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1980 motorcylce emissions were factored up using a growth figure deter-
mined by dividing 1987 intermediate population forecasts by 1980 forecasts
(from COG's Round II Cooperative Forecasts).
EVAPORATIVE LOSSES FROM SERVICE STATIONS: Monthly gas sale figures by county
were obtained from State Energy officers. To determine emissions, three
types of evaporative losses were calculated - tank truck unloading (assuming
a 3:1 ratio of submerged/splash fill), vehicle refueling displacement (we
assumed no Stage II vapor recovery regionally), and underground tank breathing.
Appropriate emission factors were taken from AP-42. Emissions were distri-
buted according to the number of service stations in each five kilometer
grid within a jurisdiction.
For 1987, staff consulted with the Federal Department of Transportation
for estimates of 1987 tax revenues to support the Highway Trust Fund.
Analysts estimated that sales would grow one percent over the seven year period.
Note that Stage II Vapor Control will be assumed to be in place when the 1987
inventory is recalculated to show emission reductions resulting from control
measure implementation.
GASOLINE LOSSES IN TRANSIT; Because some gasoline is delivered to bulk plants
rather than directly to service stations, the amount of gas transferred may
exceed actual consumption because of the extra trips involved. The Procedures
manual suggested that jurisdiction gas sale totals be multiplied by 1.25 to
estimate gasoline transported. Gas sale figures were obtained from State
Energy officers, multiplied by the 1.25 growth factor, and multiplied by a
composite emission factor based on the assumption that the ratio of submerged
to splash filling is 1:1.
For 1987, gasoline sales were assumed to have increased one percent (see
above), and were multiplied by the appropriate AP-42 emission factor.
PRINTING AND MISCELLANEOUS SOLVENTS: An emission factor of 0.8 pounds/capita/
year was recommended in the Procedures manual for estimating VOC emissions
from small graphic art facilities emitting less than 25 tons per year.
Round II Cooperative Forecast jurisdiction population estimates were multi-
plied by the per capita figure, and small sources (<100 tons/yr) found in
the point source file were subtracted to prevent double counting. The
emission totals were divided by 260 working days to obtain tons/day.
Extrapolations of 1987 population estimates were taken from the Cooperative
Forecasts and multiplied by the per capita figure to estimate 1987 emissions.
SMALL SHOP AUTO PAINTING: A per capita emission factor of 1.9 Ibs/capita/yr
was suggested in the EPA Procedures manual, and was multiplied by population
estimates from the Round II Cooperative Forecasts. Yearly emissions totals
were divided by 260 working days to get tons/day estimates.
The per capita figure was used in the same way with 1987 population
estimates to calculate daily VOC emissions for 1987.
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DEGREASING: As noted in the EPA Procedures manual, the best alternative for
estimating total areawide degreasing emissions is to apply a per capita factor
to cover small cold cleaning operations. A factor of 3 Ibs/capita/yr was
recommended for estimating degreasing emissions. Round II Cooperative
Forecast population estimates were used with the per capita factor. Degreas-
ing operatings in the point source file were subtracted to avoid double
counting, and annual emissions were divided by 260 to obtain daily emissions.
1987 emissions were calculated by multiplying the per capita figure by
1987 jurisdiction population estimates.
OPEN/CONTROLLED BURNING: Rather than use the nationally-derived per capita
approach suggested in EPA's Procedures manual, staff contacted State agricul-
ture officials and personnel at the Fairfax Air Programs and the N. Virginia
Air Pollution Control Board offices for local-specific data. Using data
supplied by these personnel, a per capita figure of .43 tons of material
burned/year/1000 people was developed, and multiplied by Round II Cooperative
Forecast population estimates. Zero emissions were assumed for D.C.,
Alexandria and Arlington where open burning is banned. Based on conversations
with VAPC3 personnel, staff assumed that material burned was almost entirely
unspecified forest residue, and appropriate AP-42 emission factors of 24 Ibs
VOC/ton burned and 4 Ibs N0x/ton burned were used.
For 1987, estimates of Round II Cooperative Forecast jurisdiction popula-
tions were used with the above mentioned per capita factor.
INCINERATION: A methodology suggested in the Procedures manual based on a
nationally-derived per capita factor was rejected as being regionally inappro-
priate. Because permits are required for incinerators, state files were
consulted for all incinerators emitting at least one pound of any pollutant.
Totals for the amount of material incinerated were computed, and a composite
emission factor was developed using AP-42. Emissions from incinerators
(<100 TPY) kept in the point source file were subtracted to avoid double
counting.
For 1987, conversation with air pollution personnel led to the assumption
that any increase in amounts of material incinerated would be counteracted by
improved combustion efficiency at new and retrofitted incinerators. Thus
1987 emissions were assumed to be equivalent to those in 1980.
VESSELS: Staff contacted D.C. Harbor Police for estimates of commercial
boat traffic, and found that such traffic was insignificant. Emissions from
this source were assumed to be zero. For pleasure boats, registrations were
obtained from local jurisdictions. A ratio of 4 inboardsrl outboard engine
was determined from conversations with local marina personnel. Coast Guard
personnel provided staff with the assumption that 50 percent of beat registrants
use their boats within the jurisdiction they are'registered in,
The following methodology (from the Procedures manual) was
used witn the above assumptions:
77 of outboard motors X 1.5 gals/hr X 13 hr/yr X T of months w/teno.
> 48° = outboard fuel consumption
4 of inboard motors X 3 gals/hr X 10 hrs/yr X = of months w/tarrp.
> 48° = inboard fuel consumption
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Fuel consumption figures were multiplied by appropriate AP-42 emission
factors, and emissions were allocated to grids adjoining bodies of water.
Staff contacted the U.S. Boat Association for estimates in growth of
boat registrations. Based on analysis of registrations between 1975 and 1980,
boat registrations increased 2.9 percent annually. This 2.9 percent increase
was applied to 1980 emissions to estimate 1987 emissions.
COMMERCIAL AIRPORTS: FAA personnel provided staff with the number of operations
at regional airports, the Fleet mix at each, and typical landing-takecff cycles.
Engine data came from the March 2, 1980 issue, of Aviation Week and Space
Technology. The above information was used in conjunction with AP-42 emission
factors to generate annual airport emissions. Emissions were assigned to grids
based on the alignment of airport runways, estimates of which runways were
most frequently utilized (from FAA Environmental Impact Statements), and the
assumption (from the Procedures manual) that emissions were important until
aircraft had reached 3000 feet.
Based on aircraft operation numbers contained in a Feb. 1981 report,
FAAls Terminal Area Forecasts. Fiscal Years 1981-1992, flights at National
will increase 5.4 percent between 1979 and 1987. Conversations with FAA
sources led to the assumption that the growth in operations would be offset
by new, cleaner engines, leading to no net growth in emissions between 1980
and 1987. The above-mentioned forecasts do not take into account current
controversies regarding possible operation ceilings at National. A multi-
scenario approach was attempted but discarded as being too cumbersome and
speculative.
For Dulles airport, FAA forecasts predicted a 35.2 percent increase in
growth between 1979 and 1987. Assuming that approximately 5 percent of the
growth was counteracted by improved engine efficiencies, net growth of emissions
at Dulles was 30 percent for 1987.
MILITARY AIRPORTS: Base commanders at Andrews Air Force Base, Quantico, and
Fort Belvoir provided data on airport operations, fleet mix, and typical
landing-takeoff cycles. Emissions were calculated using the above data
with Aviation Week and Space Technology engine data and appropriate AP-42
emission factors.
Base commanders were unable to provide estimates of increases or decreases
in operations between 1980 and 1987, and suggested that staff use 1980 emissions
for 1987.
GENERAL AVIATION AIRPORTS: Airport managers supplied data on airport operations,
FAA personnel described typical landing-takeoff cycles, and Air Transport
Association personnel provided data on typical general aviation airport fleet
mix. Engine data from Aviation Week and Space Technology was used with the
above data and appropriate AP-42 emission factors.
Staff contacted airport managers for estimates of 1987 aircraft operations.
Airport managers suggested using 1980 data for 1987, with the exception of
Manassas Airport, which will undergo significant expansion. Estimates of
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aircraft operations for Manassas Airport were taken from a consultant report
entitled Manassas Municipal Airport East Complex Development Plan, and were
used in conjunction with appropriate AP-42 emission factors and engine data to
estimate 1987 emissions.
COMMERCIAL/CONSUMER SOLVENTS: The EPA Procedures manual notes that because
of the difficulty involved in developing local consumption estimates for the
myriad products comprising these categories (household products, toiletries,
aerosols, polishes and waxes, adhesives, etc.), local agencies should not
attempt to prepare local-specific emission estimates. A per capita figure
of 6.3 Ibs of VOC/capita/yr was suggested instead. This factor was multiplied
by 1980 Cooperative Forecast jurisdiction populations to obtain emissions.
The same procedure was followed for 1987 except that 1987 population
estimates were used.
ARCHITECTURAL SURFACE COATINGS: A per capita factor of 4.6 Ibs of VOC/capita/
yr (EPA Procedures manual) was used with Round II Cooperative Forecast juris-
diction populations. 1987 population estimates were used with the per capita
factor to estimate 1987 emissions.
DRYCLEANING: Large drycleaners (>25 tons/yr of VOC) were treated as point
sources. Information from state point source files on smaller dry clearners
was out-dated, and the Procedures manual suggested that a per capita factor
of 1.5 Ibs/capita/yr should be utilized to estimate nonindustrial dry cleaning
emissions when smaller sources could not be handled as point sources. Emissions
from nonindustrial dry cleaners in the point source file were subtracted from
area source emissions to avoid double counting. The per capita factor was
multiplied by 1980 Cooperative Forecast populations to calculate 1S3C emissions,
and by 1987 Cooperative Forecast populations to calculate 1987 emissions.
RESIDENTIAL/COMMERCIAL/INSTITUTIONAL FUEL USE: Coal usage figures were obtained
from the local distributers in the area; bottled gas figures came from a Geomet
study that factored actual Montgomery and Prince George's data to other counties;
natural gas data came from Washington Gas and Light; residual (#6) oil data
came from Steuart Petroleum and the Oil Heat Institute; distillate (-2) oil
data came from actual pipeline receipts supplied by the VAPCB. Based on degree
day statistics from National Airport and conversations with Steuart Petroleum
Oil Heat Institute and other personnel, staff assumed a 95 percent space
heating application, which equates to a 1 percent summer quarter usage. Fuel
figures were multiplied by appropriate AP-42 emission factors.
For 1987, projections of fuel use changes were obtained from WG&L, Steuart
Petroleum, and the Oil Heat Institute, and used with appropriate AP-^2 emission
factors.
RAILROADS: Staff obtained regular track mileage from railroad personnel, and
where unavailable, from measurement of mileage on USGS 15 minute topographic
maps. Switchyard mileage estimates came from the Potomac Yards foremen, and
from Southern Railroad and Chessie System personnel. Operations and engine
data were obtained from the Chessie System Chief Engineer, from the Maryland
Railroad Administration, and from the Federal Railroad Administration.Appro-
priate AP-42 emission factors were used.
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Railroad personnel at the above sources were contacted for estirates of
1987 traffic. All suggested using 1980 data for 1987, as any increase in
railroad traffic would be offset by cleaner engines and the switch of some
trains to electricity from diesel fuel.
SCALING UP 1980 POINT SOURCE EMISSIONS TO 1987:
District of Columbia - On the advice of the D.C. BAWQ staff, 1987
emissions from point sources were assumed to be the same as 1980 emissions
with one exception (power plants). PEPCO will shut the Benning Road and
Buzzard Ppint Power Plants by 1987. The District will be providing staff
with 1980 and 1987 point source updates in mid-November.
Maryland - Maryland Air Programs staff suggested using 1980 point source
emission totals for 1987. One exception was noted. The PEPCO Chalk Point
Power Plant will be adding a major new boiler by 1987. After consultation
with PEPCO officials, emission estimates were scaled up for the estimated
increase in fuel consumption.
Virginia - VAPCB staff suggested using 1980 emissions for 1987 until
their staff have a chance 'to contact individual sources. 1987 updates are
expected within the next two weeks.
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TECHNICAL REPORT DATA
903/9-82-008b
2.
3. HI ClrLMT'S ACCESSION NO.
NSR and PSD Program Assistance and Development in EPA,
Region III. Volume II - Appendices Q - AA
i REPORT DATE
June 1982
6. PERFORMING ORGANIZATION CODE
7. AUTHORiS)
Thomas P. Blaszak
3. PERFORMING ORGANIZATION REPORT NO.
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc.
Midwest Operations Division
465 Fullerton Avenue
Elmhurst, IL 60126
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2536
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency, Region III
Air and Media Energy Branch
6th and Walnut Streets
Philadephia, PA 19106
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16 ABSTRACT
Report covers two major areas of implementation of the PSD/EOP programs. First for the
EPA administered PSD program, 12 specific applications were reviewed for compliance with
technical requirements of the regulation and supportive administrative documentation
was prepared. Expert technical assistance was also provided directly to the states in
Region III for assistance in EOP applications. In the second major area
assist in the transfer of the PSD programs to the states were performed.
tions for incorporation into the SIPs of West Virginia and Delaware were
baseline dates and PSD baseline areas were determined and updated as the
designation areas were changed. Data for a PSD data base developed by Region III was
prepared. A position paper on PSD tracking was written. A procedures manual and flow
chart for incorporating PSD review into the states' NSR process was developed.
Limited baseline emissions inventory data was summarized and reviewed.
activities to
PSD regula-
written. PSD
Section 107
17. KEY WORDS AND DOCUMENT ANALYSIS
3. DESCRIPTORS
Prevention of Significant Deterioration,
Emission Offset Policy, New Source Review,
Best Available Control Technology, Lowest
Achievable Emission Rate, PSD, EOP, NSR,
BACT, LAER
I'i Dl3rHi3UTiJ , STA ffeMSNT
Release to public
b. IDENTIFIERS/OPEN ENDED TERMS
19 SECURITY CLASS lillK r.envrt,
unclassified
20 ->cCURITY CLASS (fins pjg<:i
unclassified
c. COSATI Field/Group
21. NO. OF PAGES
22. PRICE
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