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
                        : • •....',>,-.- >: f, v*r' */
                         •. ' -••'.

                          '..'")
                      [,  '- •.•.„,
                      F ;.,.„. ,-'i.f»
                              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


I



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                                 DETERMINATION OF PSD BASELINE DATES
•                                   WITHIN  U.S.  EPA REGION III




I


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
I
            Prepared by:


Pacific Environmental Services, Inc.
•                                      465 Fullerton Avenue
                                      Elmhurst, Illinois 60126
                                           (312) 530-7272





I



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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.
                                   1-1

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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
                                   2-1

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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.
2-2

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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
I
                                  2-3

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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      	
I
                          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
                                 2-5

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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
                                2-6

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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
                                 2-7

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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.
                                2-8

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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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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
	
_— — «.

	
	
	
	
0.7


	




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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


	
	
__ __

	
	
__ _ _
....

__ _ _

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
	

	
	
16.9




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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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3-14

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3-15

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DSLA.WAKS
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3-17

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                                                       3-19

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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)
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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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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

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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

I
I
I
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I
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

-------
1
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1
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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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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.

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                                                                                          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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               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

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       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

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                    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

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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






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                         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

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        Baseline  Area
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I Cumber!and-Keyser  Interstate AQCR
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• Central West Virginia

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                      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
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  *  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

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                         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


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• Jackson County

• Pleasants County
  Tyler County

JWetzel County
Not Triggered

Not Triggered


Not Triggered


Not Triggered

DOE-Gulf Minerals
  SRC-II

Not Triggered
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  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

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                   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

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  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
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  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
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                             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

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                       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

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                                DOE-Gulf Minerals 11/25/80  Morgantown Energy
                                  SRC-II
  Dist.  west of Highway 1-79**

- Remainder of County      DOE-Gulf Minerals
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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

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  Ritchie County
I Roane County
                       Table 6.   Baseline Determinations by County***
                                         (Continued)
    Baseline Area
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  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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•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

I

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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.
                                   1-6

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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

                                  2-1

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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
                         2-2

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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.
                                   2-3

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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.

                                   2-4

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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,

                                  3-1

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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
                                                                          3-2

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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

                                   3-3

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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
I

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                         12
                           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.
                     3-4

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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.

                                   3-5

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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
                                   3-6

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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.
                                   3-7

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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

                                  4-1

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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
                           4-2

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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.


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(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)

I

I
.*  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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                                               C-3



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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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•                                          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:


I
      (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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I                        of  receipt  of  the  application  shall be  the  date  on  which  the
                        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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                      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









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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.
                                 1-1

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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.
                                 1-2

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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
                                 1-3

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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).
1-4


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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
                                 1-5

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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
                                 1-6

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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.
                                 1-7

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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.
                                 2-1

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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.
                                 2-2

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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);
                                 2-3

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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
                             2-4

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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
                              2-5

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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
                                 2-6

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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
                                2-7

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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
                                2-8

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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
                                2-9

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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,
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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.
                              2-26

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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.
                             2-27

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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.
                              2-28

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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.
                             2-29

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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.
                              2-30

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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.
                             2-31

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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
                                2-32

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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.
                                2-33

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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
                                2-34

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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,
                                2-35

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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.
                                2-36

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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.
                                 2-37

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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.


                                 2-38

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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
                                2-39

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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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•                                             2-40
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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
                                 3-1

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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
                                 3-2

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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.
                                 3-3

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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
                                 3-4

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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.
                                 3-5

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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
                                 4-1

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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).
                                 4-2

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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)
                                 4-3

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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
                                 4-4

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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.
                                 4-5

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1
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.
                                 4-6

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1
     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.
                                                 4-7

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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


                                          -  more -

.\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.
                                      - 3 -

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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

                                       - 4 -

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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


                                       - 5 -

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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.
                                      - 7 -

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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
I

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