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Notice
This is not an official policy and standards document. The opinions and selections
are those of the authors and not necessarily those of the Environmental Protection
Agency. Every attempt has been made to represent the present state of the art as
well as subject areas still under evaluation. Any mention of products or organiza-
tions does not constitute endorsement by the United States Environmental Protec-
tion Agency.
Because of the complexity of the regulations dealt with in this document, the
course material can provide only an overview. Any substantive decision on a par-
ticular case must be based on the current law and regulations and the facts of the
case.
The provisions of the Clean Air Act and of EPA regulations are subject to
change by Congress and EPA. This document reflects the law and regulations as of
the date of publication only. Persons applying the rules must determine what provi-
sions of law and regulation apply as of the. date of application.
11
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Introduction
This 15-hour self-instructional course will provide you with a comprehensive over-
view of regulations governing the prevention of significant deterioration (PSD) of
air quality. You will have an opportunity to view eleven slide/tape presentations
covering applicability determination, best available control technology (BACT)
analysis, air quality analysis, additional impacts analysis, and agency review. We
have also included, for your reference, a copy of the Workshop Manual used in the
Environmental Protection Agency's 1980 PSD workshops, a copy of Title I, Part C
of the Clean Air Act (as amended August 1977), and the EPA PSD regulations as
of July 1981.
Instructions for Successful Completion of this Course
To successfully complete this course, we recommend that you follow these five
steps.
1. Look over the questions on the examination. This will give you an idea of
what to look for as you view the slide/tape presentations. (The exam should
be included in your course materials. If it is not, please contact the Air Pollu-
tion Training Institute (APTI) at the address listed on page 3 of this
guidebook.)
2. View, in order, the eleven slide/tape presentations.
3. Read the sections in the Workshop Manual pertaining to any topic;; about
which you have questions.
4. Take the final examination.
5. Return the final examination, the slides, and the audio cassettes to APTI.
You may keep the other materials. You will receive your examination grade
by return mail. If you achieved a grade of 70 or above on your final exam,
you will receive a course certificate, and you will be awarded 1.5 continuing
education units (CEUs).
Course Materials
You should have received the following items in your package of course materials.
• Slide sets for Lessons 1 through 11.
• Audio cassettes for Lessons 1 through 11. (Note: A cassette may contain more
. than one lesson.)
• The Prevention of Significant Deterioration— Workshop Manual.
• A copy of Title I, Part C of the Clean Air Act (as amended August 1977).
If any of these items are missing, please contact the Air Pollution Training
Institute at the address listed on page 3 of this guidebook.
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Lesson number Tide Viewing time
1 Introduction and Overview 33 minutes
2 Applicability Determination
in the Application: I 20 minutes
3 Applicability Determination
in the Application: II 22 minutes
4 BACT Analysis in the Application: I 23 minutes
5 BACT Analysis in the Application: II 26 minutes
6 Air Quality Analysis: I 30 minutes
7 Air Quality Analysis: II 38 minutes
8 Additional Impacts Analysis 27 minutes
9 Application Summary
& Introduction to Agency Review 37 minutes
10 Agency Review of the Application: I 21 minutes
11 Agency Review of the Application: II 30 minutes
Using the Slides and Tapes
Each lesson has a set of 35-mm slides and an accompanying audio cassette. The
audio cassette can be used in two ways. If your cassette player has a mechanism for
synchronizing an audio cassette and 35-mm slides, you can use the side of the
cassette marked "automatic advance." This .will cause the slides to advance
automatically while you listen to the tape. If you do not have equipment that
automatically advances slides, you can use the side of the cassette marked "manual
advance." In this case you will have to advance the slides yourself.
To use automatic-advance equipment:
• Advance to the first slide (it will read "FOCUS") and focus the image. Leave
this slide on the screen; do not advance the slide tray.
• Place the cassette in the cassette player so that the side marked "automatic
advance" will play.
• Turn on the cassette player. The slides will advance automatically as the tape
plays.
To use manual-advance equipment:
• Advance to the first slide (it will read "FOCUS") and focus the image. Leave
this slide on the screen; do not yet advance the slide tray.
• Place the cassette in the cassette player so that the side marked "manual
advance" will play.
• Turn on the cassette player. Every time you hear a "beep" (tone), you should
advance to the next slide.
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Additional Information
If you have any questions about the final examination or about any other parts of
this course, please contact the Air Pollution Training Institute.
Air Pollution Training Institute
Environmental Research Center
US EPA
MD20
Research Triangle Park, NC 27711
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SI:453
Lesson 1
Introduction and Overview
Slide
1. (Focus)
2-7. (Introductory slides)
Script
Selected Visuals
FOCUS
Prevention of I
Significant ,
Deterioration j
1-1
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Slide
Script
Selected Visuals
8. This course deals with the Prevention of Significant Deteriora-
tion of air quality. We will begin by introducing the key con-
cepts and by presenting an overview of the course.
9. Our goal in this course will be to provide you with an
understanding of key concepts in programs for the prevention
of significant deterioration of air quality—known as PSD. You
will also learn how permit review requirements apply, and
what the basic steps of a review are.
10. Let's look first at the historical background of PSD as it is
dealt with in the law and in EPA regulations. If we know
something about the origins and growth of the PSD program,
it will be easier to understand its purpose and nature.
i~ " -i_ -tra
OVERVIEW'OF PSb 'REGULATION
• Key Concepts
• Permit Review
Requirements
• Basic Steps of a
Review
Hiatonj
tf
PS©
11. In 1970, Congress passed amendments to the Clean Air Act.
These amendments required States to submit State Implemen-
tation Plans—or SIPs. These plans were to ensure that the
national ambient air quality standards were both attained
and maintained.
1970 Clean Air Amendments
• required SIPs to ensure
NAAQS met and maintained
12. As the amendments were being developed, committees of the
House and Senate briefly discussed the question of how to deal
with the air quality in areas where it was already better than
the standards required it to be.
1 how to deal with air quality in areas
already better than standards
13. The Clean Air Act itself did not contain clear guidelines
about the prevention of significant deterioration of air quality.
However, those who supported a "non-degradation" policy
later argued that prevention of significant deterioration was
called for by a statement in the Act that read "to protect and
enhance the quality of the Nation's air resources..."
14. In June of 1971, EPA proposed guidelines to help States
prepare and submit their implementation plans. In these
proposed guidelines, EPA did deal with requirements for the
prevention of significant deterioration of air quality. But,
because of comments from other Federal agencies, the final
guidelines did not require States to have PSD provisions in
their implementation plans.
"to protect and enhance
the quality of the Nation's
air resources..."
1971
Proposed EPA Guidelines
• jlunnclude PSD
Final EPA Guidelines
• did not include PSD
1-2
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Slide
Script
Selected Visuals
15. So, EPA went on to review and approve State Implementation
Plans without considering whether or not they would prevent
air quality deterioration up to the ambient standards.
16. The scheduled date for EPA's final decision on State
Implementation Plans was in May of 1972. Just before that
date, Sierra Club and three other environmental groups filed
suit in the Federal District Court for the District of Columbia.
The purpose of the suit was to prevent EPA Administrator
William Ruckelshaus from approving any implementation
plan provisions that would permit significant deterioration of
air quality.
• EPA SIP review and
approval without
consideration of PSD
1972
Sierra Club
o.
Ruckelshaus
17. The District Court accepted the Sierra Club's arguments., and
ruled that EPA had to disapprove any parts of a State
Implementation Plan that would have permitted significant
deterioration of air quality. The Court did not, however,
define "significant deterioration." Therefore, EPA had to
adopt regulations which would define "significant deteriora-
tion," prevent it from occuring, and tell States what PSD pro-
visions had to be in an approvable plan.
18. When EPA appealed the case, the District of Columbia Cir-
cuit Court of Appeals agreed with the District Court. The
Supreme Court divided equally oh the question, so the opinion
originally written in the District Court became EPA's entire
guidance. The amplification and adjustment that is usually
added by higher courts was not available to help EPA frame
its regulations.
19. In response to the Court's order, EPA issued PSD regulations
in the December 5, 1974 Federal Register. These regulations
influenced the shape of the PSD program.
• court ruled In favor of Sierra Club
• EPA had to:
• define PSD
« prevent it from occurring
* tell states what provisions
Appeals Court
Supreme Court
earlier ruling
• divided equally
20. The regulations that EPA adopted declared that every State's
implementation plan was disapproved with respect to PSD
provisions.
21. In place of the missing PSD provisions, uniform Federal
requirements were made a part of each plan.
1-3
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Slide
Script
Selected Visuals
22. The regulations also stated what would be required in order
for a State's plan to be approved.
23. The only two pollutants that were dealt with in the 1974
regulations were total suspended paniculate matter—known as
TSP (T-S-P), and sulfur dioxide-or SO2 (S-oh-two).
24. "Significant deterioration" was defined in terms of a system of
area classifications and permissible concentration increases
called increments. The system covered all air quality control
regions and the two pollutants TSP and SO2.
Significant deterioration...
• area classifications
• increments
For:
• all AQCRs
• TSP and SO2
25. In Class I areas, which are the most highly protected areas,
only small increases in predicted TSP and SO2 concentrations
would be permitted. In Class II areas, larger concentration
increases would be permitted. Under the 1974 regulations,
Class III areas, which are the least protected, could have con-
centration increases up to the national secondary air quality
standards. Initially, all "clean air" areas were put in Class II,
but a State could change this designation to a I or a III.
26. The basic way that significant deterioration would be
prevented was through a case-by-case review of proposals to
construct new sources or modify existing ones. Eighteen
point-source categories were listed for review.
27. Any new source or modification in one of these categories
had to demonstrate that the best available control technology—
BACT (B-A-C-T) or "bact"-would be installed.
Class I - small Increases in
concentration
Class II - larger increases In
concentration
Class III • increases in concentration
up to the secondary
NAAQS
• case-by-case review of proposals
to construct or modify
• 18 point-source categories
28. A dispersion modeling analysis would predict how much the
new source emissions would cause ambient pollutant concen-
trations to increase.
1-4
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Slide
Script
Selected Visuals
29. These final EPA regulations on PSD left both environmen-
talists and industrial developers dissatisfied. There were
lawsuits from both sides.
30. Legislation was introduced to do away with PSD requirements.
In this atmosphere of uncertainty, States were slow to take any
action to assume responsibility for PSD or to reclassify areas.
31. By 1976, Congress was ready to take some action on PSD,
along with other troublesome areas of the Clean Air Act.
32. The Clean Air Act Amendments of 1976 were very hotly
debated in Congressional Committees and on the floor in both
houses. The controversy over prevention of significant
deterioration provisions was so strong that the bill amending
the Clean Air Act never passed.
33. When the 95th Congress convened in 1977, they began the
amending process all over again. The result was the Clean Air
Act Amendments of 1977.
1976
CAA Amendments Bills
• hotly debated
• did not pass
1977
CAA
Amendments
34. The 1977 amendments confirmed that Congress did indeed
intend PSD to be part of the national air pollution control
program. They added a new Part C, "Prevention of Significant
Deterioration of Air Quality," to Title I of the Clean Air Act.
Part C was based largely on EPA's existing regulations, but it
made some changes which we will briefly examine.
CAA
TKtol
PutC
Sferiflcam
1-5
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Slide
Script
Selected Visuals
35. All of the new language in the Act describes requirements for
State Implementation Plan provisions on PSD. EPA is
supposed to control the program only when States don't have
approvable plans. State action has been slow, however, so
EPA regulations apply in many areas. Even where the State
has an approved PSD plan, it is likely to follow EPA's model
closely.
36. The first thing States had to do under the 1977 Amendments
was to classify their Air Quality Control Regions — or
AQCRs.
Air Quality Control Regions
(AQCRs)
37. For each AQCR, they had to make a formal finding as to
whether it met National Ambient Air Quality Standards, did
not meet them, or could not be classified using available data.
With some legal complications, this classification applied to
all criteria pollutants— in other words, those pollutants listed
for ambient standards.
Air Quality Control Regions
(AQCRs)
• NAAQS met?
• for all criteria pollutants
38. An attainment area is one meeting a standard for any
pollutant; a nonattainment area is one not meeting a
standard.
Attainment Area
• meet* standard for pollutant
Nonattainment Area
• does not meet standard for
pollutant
39. For example, a region could be attainment for paniculate
matter, nonattainment for sulfur dioxide, unclassifiable for
ozone, and so forth.
40. PSD plans had to be developed for both attainment and
unclassifiable regions.
TSP
so,
o,
Attainment Nonattainment Unclassifiable
Attainment Unclassifiable
PSD Plans
Required
41. Congress used the PSD system EPA had developed in its 1974
regulations as a basis for the 1977 amendments. They made
some changes, however, in turning the regulations into law.
Specific numbers were agreed on by compromise for
permissible increment values—but still for TSP and SO2 only.
1974
EPA
Regulations
•1-6
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Slide
Script
Selected Visuals
42. The EPA regulations had allowed Class III areas to
deteriorate to secondary ambient standards, but Congress now
set Class III increments. The law did not allow any increase
that would result in pollutant concentrations that would be
higher than the ambient standard.
43. Certain areas where natural and scenic values were important
were automatically put in Class I, the most highly protected
class. These included large national parks and wilderness
areas. Certain national parks must remain Class I, and
reclassification of other Class I areas is restricted.
44. The process of reviewing proposals to construct major new
sources or modifications is the principal means of carrying out
the PSD program. It is the focus of most of the rest of this
course. Congress was aware of the importance of the review
process from EPA's experience, and made changes intended to
increase the review process's scope and effectiveness.
45. The original list of 18 source categories was later expanded to
include 28 source categories.
46. Any source in one of these categories emitting 100 tons
(or more) per year of any pollutant is subject to PSD review.
Furthermore, if a source is not on the list and emits 250 tons
(or more) per year, that source, too, is subject to review.
' PSD review required
47. A definition of "best available control technology" —
BACT (B-A-C-T) —was written into the Act.
Best Available Control
Technology
(BACT)
48. This level of emissions control is decided on a case-by-case
basis, taking all costs and impacts into account to determine
what is achievable for the proposed installation. BACT can
never be less strict than New Source Performance Standards,
and it applies to all pollutants regulated under the Clean Air
Act.
Best Available Control
Technology
(BACT)
• decided on case-by-case basis
• takes cost/impacts into account
• is never less strict than NSPS
• applies to ^pollutants regulated
under CAA
1-7
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Slide
Script
Selected Visuals
49. The 1977 amendments added several increased technical
requirements to PSD programs. One important change was
that a source owner had to monitor the ambient air for a year
before beginning construction on a new or modified source.
Another change required EPA to adopt regulations on the
pollution dispersion models used to predict ambient
concentrations.
Increased Requirements
• source owner had to monitor
ambient air for a year before
beginning construction
• EPA required to adopt
regulations on dispersion models
50. There was no experience with a PSD program for pollutants
other than TSP and SO2. Therefore, Congress directed
EPA to make a study of possible ways of preventing significant
deterioration with respect to other pollutants, referred to as
"Set II" pollutants. The study is to look at methods other than
the increment method to see if there are other ways of carrying
out PSD. As of late 1982, results of this study had not been
completed, and the increment method is used only for TSP
and SO2.
' EPA to make study of way
to prevent significant
deterioration with respect
to Set II pollutants
51. Even after the 1977 Congressional action to amend the Clean
Air Act, many aspects of the PSD program remained
controversial and ambiguous. In 1978, two major lawsuits,
involving both industry and environmentalists, were filed
against EPA. The final decision in the more complex case,
Alabama Power Co. vs. Costle, was issued by the District of
Columbia Circuit Court of Appeals in December 1979. This
decision settled many disputes about definitions and about
how the Act applied to different construction and modification
situations. EPA was required to change its regulations to agree
with the court decision. It did so on August 7, 1980.
52. As a result of these actions by Congress, the executive branch,
and the courts, we now have a mixture of statute law,
administrative regulations, and court interpretations
regulating the prevention of significant deterioration.
• Alabama Power Co. v. Costle
• EPA required to change its
regulations
• Administrative
Regulations
• Court
Interpretations
53. In the law—the Clean Air Act —we find statements of the
fundamental purposes and basic procedural requirements of
the PSD program. Although this part of the Act is detailed
and complicated, it is basically like other parts. That is, the
law mainly directs EPA to adopt and enforce administrative
regulations to carry out the program that the Act calls for.
1 Fundamental Purposes
' Basic Procedural
Requirements
1-8
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Slide
Script
Selected Visuals
54. Congress stated that the PSD provisions were written into the
Clean Air Act for several related purposes. The first of these
was to protect the public health and welfare from any adverse
effects that might occur even though national ambient air
standards were met.
• to protect the public health
and welfare
55. Another reason was to make sure that the natural and
recreational quality of parks and other scenic or historic areas
was preserved.
• to ensure preservation of the natural
and recreational quality of parks and
other scenic or historic areas
56. Congress also wanted to ensure that there was a balance
between economic growth and preservation of air quality: that
neither was neglected because of the other.
• to ensure a balance between economic
growth and preservation of air quality
57. A fourth reason for the PSD provisions was to prevent States
from interfering with one another's PSD plans. All of these
ends were to be met through a process which includes
informed public participation in decision making.
* to prevent states from interfering with
each others' PSD plans
58. As we noted above, the 1977 Amendments automatically put
certain larger areas—like national parks, monuments, and
wilderness areas—in Class I, the most highly protected
category. Some areas are "frozen" in Class I; other scenic or
recreational areas may be designated as only Class I or II, and
some areas cannot be changed from Class II to Class III.
59. All other areas where the secondary National Ambient Air
Quality Standards are met —or which cannot be classified—
are initially put in Class II, but may be redesignated by the
States to either Class I or Class III, except, as noted previ-
ously, there are some areas that cannot be redesignated from
Class II to Class III.
60. The process by which States can redesignate PSD areas is
rather complicated. While it is easy for a State to reclassify
up—to Class I — redesignation to Class III, the least restrictive
category, requires that the different branches and levels of
government within the State agree to the redesignation. If
Federal lands are included, the Federal Land Manager may
take part.
1-9
Class II
redesignation to
Class I
is easy
Class III
is difficult
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Slide
Script
Selected Visuals
61. If a State wants to reclassify an area to Class III, it must first
notify the public and hold hearings at which the public may
present comments and arguments. The comments and
arguments are to be made part of the official record on which
the reclassification is based.
62. After the State completes its action to redesignate a PSD area,
EPA reviews the record. EPA may disapprove the redesigna-
tion in only two cases: If there is an error of legal procedure,
or if the action would violate a classification that is mandatory
under the Act.
63. Changing the designation of an area can lead to
disagreements between States or with Indian tribes.
EPA may disapprove the redesignatlon -
• if there la an error of legal
procedure
• If the action would violate a
mandatory classification
Redeslgnadon
may lead to
disagreements.
F
64. The Act provides that such disagreements will be resolved by
the EPA Administrator.
Disagreements
to be resolved
by the EPA
Administrator*
65. Besides setting out the system for classifying and redesignating
PSD areas, the Clean Air Act establishes emissions increments
and ceilings for the three classes. A "baseline" concentration
is set for new or modified sources.
• emissions increments
and ceilings
66. The increment is the amount that the concentration is allowed
to increase over that baseline. There are different permissible
increments for TSP and SO2, and for area classifications and
averaging times.
Increment
• the amount that the concentration
is allowed to Increase over a
baseline concentration
67. As an example, here are the increments for TSP and SO2 in
Class I, II, and III areas. There are some other special
increments for certain exceptional cases.
ALLOWABLE PSD INCREMENTS (M9/mJ)
Pollutom n™P»nod Clou I QOJJ II Ctaji ill
annual
24JXXK
9
10
10
37
37
75
SO,
' annual
24-hour
3-hour
2 10
3 91
29 512
40
102
700
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Slide
Script
Selected Visuals
68. Remember that there is also a ceiling on increases —in no case
may a change result in concentrations that are higher than the
lowest applicable National Ambient Air Quality Standard.
Ceilings
• changes may not result In
concentrations higher than the
lowest applicable NAAQS
69. To meet the goals just set out, it is important to be able to
predict the effects of proposed construction or modifications.
For this reason, the heart of the PSD program is the process of
developing and reviewing proposals for major construction
or modification. This development and review process will be
what we concentrate on in the body of this course.
PSD Program
70. The review process leads to the issuance of a permit to
construct or modify, with Federally enforceable emission
limitations attached. The limitations help ensure that the
impact of the new operation will be no greater than was
predicted in the review, and that the agency that issued the
permit can make the source correct any violations.
71. The permit application review and analysis takes place in two
places: within the agency and by the public. Much of the
technical work must be done within the reviewing agency—
the EPA, or State or local agencies that have received author-
ity for the program from EPA. After this review, the agency
must make the review data, analyses, and impact estimates
available for public review and hearing. Comments received
from the public are taken into account in issuing, denying, or
putting conditions on the permit to construct or modify.
72. Most of the workings of the permit review system are spelled
out in EPA regulations found in 40 CFR 51.24. Before we go
on to the details of these requirements, we should look at
some basic concepts we will be using throughout the course.
• Impact will be no
greater than waa
ravlaw
• agency can make
vtolannv
Permit Application
Review and Analysis
• within the agency
• by the public
40 CFR 51.24
73. One of the major effects of the decision in Alabama Power
was that it modified certain important definitions. Among
these is the definition of potential to emit. Potential to emit is
the maximum capacity of the source to emit a pollutant under
its physical and operational design. We will look at this more
closely in Lesson 2. In assessing potential to emit, we must
consider air pollution control equipment and Federally
enforceable restrictions on operating hours or types of material
stored, burned, or processed.
Potential to Emit
• maximum capacity to emit
• given source's physical/
operational design
1-11
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Slide
Script
Selected Visuals
74. Another definition that changed was that of a stationary
source. A stationary source—subject to PSD review—is a
building, structure, facility, or installation whose units fall
within the same standard industrial grouping. The units must
be located on contiguous or adjacent properties, and under
the operating control of the same person or persons under
common control.
Stationary Source
• building, structure, facility, or
installation
• units (all within same standard
industrial grouping
• located on contiguous/adjacent
properties
• under operating control of same
person/company
75. A major stationary source is one which is on the list of 28
categories given in the Act, and which emits 100 tons (or
more) per year of any pollutant regulated under the Act. It is
also any source which emits 250 tons (or more) per year of any
regulated pollutant. If a modification to any source meets the
definition of a major source, then the modification is reviewed
as a major source.
76. A major modification —also subject to PSD review—is a
modification at a major stationary source which results in a
significant increase in emissions of any regulated pollutant.
"Significant increase" is defined in a detailed listing at
40CFR51.24(b)(23).
^Jajor Stationary Source
• on IM of 2s
• emttB 100 too* or
more per year of
any regulated
• onila 250 ton* or
own par year of
•ny regulated
pollutant
Major Modification
• modification at a major stationary
source
• results in significant Increase in
emissions of any regulated pollutant
77. Finally, construction requiring review is defined as any
physical change or change in method of operation that results
in a change in the amount of actual emissions.
Construction
• any physical change jjj change
In method of operation
• results in change In amount of
actual emissions
78. Construction is commenced when all permits have been
secured and when actual on-site construction work begins, or
when a binding agreement for construction work is signed.
Commencement of Construction
• when actual • when a binding
on-site agreement for
construction construction
work begins work is signed
79. The regulations we are studying apply geographically to all
areas classified as either attainment or unclassifiable for any
criteria pollutant.
PSD
80. If the State does not have an approved PSD implementation
plan, EPA rules apply. However, EPA may delegate some or
all authority to the State. If a State receives delegation, it
must apply Section 52.21 as if it were the Administrator of
EPA.
1-12
y_
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Slide
Script
Selected Visuals
81. When a State has an approved PSD plan, its own rules apply,
but these must follow conditions laid out in 40 CFR 51.24.
82. The sources to which PSD regulations apply are the major
stationary sources we defined a little earlier. If such a source
is constructed or modified, then a PSD review is required.
83. It is important to remember that PSD requirements apply to
all pollutants regulated under the Clean Air Act —not just to
the criteria pollutants. This means any pollutant which is
regulated under New Source Performance Standards or
National Emission Standards for Hazardous Air Pollutants
must be controlled by BACT, and its air quality impacts must
be assessed.
PSD requirements apply to all
regulated pollutants...
• NAAQS pollutants
• NSPS pollutants
• NESHAPs pollutants
84. For the criteria pollutants, the review process must predict
whether or not the proposed construction will cause pollutant
concentrations to exceed any National Ambient Air Quality
. Standard. For TSP and SO2, the reviewing agency must also
determine how much of the available increment will be used
up by the proposed operation.
85. To begin the review process, the organization proposing to
build or modify a source submits to the reviewing agency a
description of the proposal. This description includes the
location, design, and operating specifications of the source.
The construction schedule is outlined.
For criteria pollutants...
Will NAAQS be exceeded?
Description of Proposed
Construction/Modification
• location
• design
• operating specifications
• construction schedule
86. An analysis of the control technology is used to show whether
or not the technology is the best available for each applicable
pollutant.
87. The organization must also submit air quality and
meteorological data representative of the source site.
• analysis of control
technology is used to
show if it is best available
• organization must
submit air quality and
meteorological data
1-13
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Slide
Script
Selected Visuals
88. On the basis of the information submitted, the reviewing
agency verifies the BACT analysis. Generally, a reviewing
agency evaluates the applicant's predictions of source impacts
on NAAQS and on increment consumption. Further, the
agency estimates the air quality impacts of all pollutants
regulated under the Act. It also evaluates the effect of air
quality impacts on visibility, soils, vegetation, and other air
quality related values.
89. After completing its analyses, the reviewing agency makes its
information and findings available to the public. A hearing is
held, and a formal record made of all comments and
arguments.
Reviewing Agency .
• verifies BACT analysis
• evaluates Impact prediction on
NAAQS and increment
consumption
• estimates impacts of all
regulated pollutants
• evaluates effect of impacts on
visibility/soils/vegetation
90. On this basis, the agency decides whether or not to issue a
permit.
91. If it does issue a permit, conditions are attached to ensure
that increment consumption is no more than planned, that
ambient standards are not violated, and that other adverse
impacts are avoided.
• NAAQS not vtobnd
• other advene effect!
•voided
92. After a permit application has gone through agency technical
review, public hearing, and final agency action, it must
undergo one more stage of review. If the State has an approved
PSD plan, this review will be whatever State law calls for on
administrative actions of this kind —perhaps an Environmental
Board of Review. If EPA has delegated review duties to the
State, EPA will review the permit process. This EPA review
will be more or less detailed, depending on how much
authority has been delegated to the State.
93. At least one thing is clear from this background discussion: we
are dealing with a complicated subject where law,
administrative regulations, and technology interact. We shall
spend the balance of this course studying in more detail how
this PSD system works.
1-14
[>/<| Technical Review
|(X| Public Hearing
\tS\ Final Agency Action
[ | Review
-------
Slide
Script
Selected Visuals
94. Remember that our overall goal for this course is to provide
you with an understanding of key PSD concepts, and specific
guidance on determining which review requirements apply to
proposed sources and modifications, and how they are
applied.
95. Our specific objectives are to make you able to: determine
what proposed construction is subject to PSD review;
determine what analyses must be performed; understand the
procedures for required analysis; and understand review
agency responsibilities and procedures.
96. In unravelling our topic, we will first look at what goes into a
complete application to build or modify a major stationary
source. We will discuss the applicant's obligation to determine
whether or not PSD regulations apply to the source.
97. We will go on to examine how the applicant describes and
analyzes control technology to show that BACT is applied. We
will then study air quality impacts analysis and analyses of
other impacts.
98. Coming at the topic from the other direction, we will contrast
the reviewing agency's responsibilities and approach. We will
see how the agency verifies geographic and pollutant
applicability. We will look at how the agency checks the
applicant's BACT analysis. We will see how the agency examines
air quality and other impacts analyses, and whether it goes on to
do further analyses of its own.
99. We will conclude the course with a lesson reviewing and
summarizing the entire topic. When you are satisfied that you
understand the material, you may take the multiple-choice
final exam for course credit.
Goals
1 provide understanding of key
PSD concepts
• provide specific guidance on
determining review requirements
• what construction is subject to
PSD review
• what analysis must be performed
• the procedures for required
analyses
• review agency responsibilities
and procedures '
• the application
• the application
• description and analysis to show
that BACT Is applied
• Air Quality Impacts and other
analyses
• the application
• description and analysis to show
that BACT is applied
• Air Quality Impacts and other
analyses
• reviewing agency's responsibility
and approach
100. (Credit slide)
Introduction and Overview
•I Co«t«tt: John M«o*«v
IntnKthxul D**tffl: Monte* Uilt*
Gnphlci: B*m Hubvr
Ha: Dairtd Chared lit
M: Rich Pilaw*
101. (Northrop slide)
Northrop Services, Inc.
under
EPA Contract No. 68-02-3573
1-15
-------
Slide Script Selected Visuals
i f\f\ / » T Y l • 1 \ B*««d In part on the:
102. (Northrop slide) 1980 PSD Workshops
prcpuvd for (he
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
TRW. Inc.. En*4nMuo*nt*l Enfiiwrrtnt Dl*t>ion
.Nonbrop S*«vK««. toe
EPA COMTMI No. 6MU-31T4
103. (NET slide) Northrop
Enyirpnmencal
Training
1-16
-------
SI:453
Lesson 2
Applicability Determination in the Application: I
Slide
1. (Focus)
2. (Introductory slide)
Script
Selected Visuals
FOCUS
3. This is Lesson Two, "Applicability Determination in the
Application, Part One."
Applicability Determination in
the Application: I
4. In this lesson, we'll look at the beginning of the PSD
application and review process. Before anything else happens
under PSD law and regulations, someone has to decide
whether or not PSD requirements even apply to the construc-
tion or change proposed.
5. Most of the time, this determination of applicability is made
by the organization that wants permission to construct or
modify—the applicant.
Do PSD requirements apply?
6. In general, two things will determine whether PSD review
applies to a source and what has to be reviewed.
• Does PSD review apply?
• What has to be reviewed?
7. The first is geographic location, the type of area in which the
source is or will be located. The second is the size and nature
of the source itself.
In Lesson One, we saw that States had to designate all areas
in their boundaries as attainment, nonattainment, or
unclassifiable. This designation depends on whether an area
meets or does not meet a National Ambient Air Quality
Standard for any criteria pollutant.
Type of Area
• Size and Nature
of Source
• Attainment
• Nonattainment
• Unclassifiable
NAAQS met for criteria
pollutant?
2-1
-------
Slide
Script
Selected Visuals
9. The designation can be different for different pollutants and
it usually is. We will call any area that is either attainment or
unclassifiable for any pollutant a PSD area for that pollutant.
Attainment or Unclassifiable
PSD Area 4?
Possible
PSD Review
10. In general, PSD review requirements will apply to a source or
modification that is major for a pollutant if the proposed
location is a PSD area for that pollutant. We will turn to the
definition of a major source or modification in a moment. If
an area is nonattainment for a certain pollutant, special
nonattainment area plan requirements will apply. Often, a
proposed source will have to get PSD review for some
pollutants and nonattainment plan review for others.
11. Within a PSD area, new major sources and major
modifications are subject to PSD reviews. To understand what
these sources and modifications are, we must first define some
special terms—source and emissions unit. Then we'll have to
see what makes a source or a change to one, major.
12. The PSD regulations define a stationary source in a special
way. This definition can be condensed to all stationary emis-
sions units—in the same industrial grouping—on contiguous
or adjacent properties and under control of the same person
(or persons under common control).
13. An emissions unit is any part of a stationary source that
emits—or has the potential to emit—any pollutant regulated
under the Clean Air Act. Notice that this includes any
regulated pollutant, like hydrogen sulfide, regulated under
New Source Performance Standards, or vinyl chloride,
regulated under hazardous emission standards.
14. Most of the time, all the emissions units at one location will
fall into the same industrial grouping, but this is not always
so. The industrial groupings are defined as the "major groups"
in a Commerce Department reference called the Standard
Industrial Classification Manual.
15. This manual assigns 4-digit codes to different types of
industry. All activities within the same major group have
Standard Industrial Codes that begin with the same two digits.
For example, SIC 28 stands for Chemicals and Allied
Products.
2-2
PSD Review Required
• source or modification
that la major for pollutant
If in PSD area for that
pollutant
• New Major Sources
• Major Modifications
Source
All stationary emissions units-
in the same industrial grouping-
on contiguous or adjacent
properties -
and under control of the same
person (or persons under
common control).
Emissions Unit
any part of a stationary source
that emits - or has the potential
to emit •
any pollutant regulated under
theCAA
-------
Slide
Script
Selected Visuals
16. There is seldom any problem with determining if emission
units are on "contiguous or adjacent properties."
17. Also, determining if emission units are under control of the
same person (or persons under common control) isn't usually a
difficult question.
18. One thing about defining a source may require a closer look,
however. This is whether closely related activities of the same
organization on the same property fall within the same SIC
major grouping. If they are not in the same major grouping,
they are considered to be more than one source. This can
make a difference in whether PSD review is required, what
kind of review it must be, and which units need review.
activities not
In same major grouping
considered more than
one source
19. A mine-mouth coal-fired power plant, for instance, breaks
down into two sources, mining operations and electric power
generation.
Mine-mouth coal-fired power plant
Mining Electric Power
Operations Generation
20. When we want to determine if PSD review applies, our first
step is to see how the definition of source fits the proposed
construction or modification.
21. To define the source on which PSD review must be per-
formed, we check which emissions units in the same SIC
major grouping are on the same or adjacent sites, and under
the same ownership or control.
To define source subject to
PSD review...
• emission units
• major grouping
• same or adjacent sites
• ownership
22. Our second step is to decide if the stationary source is major
or not. We do this on the basis of the source's potential to
emit pollutants regulated under the Clean Air Act. It will take
us a few minutes to discuss what potential to emit is, and how
it is estimated. Then, we will see how it is used to classify a
source or modification.
Is the source major?
• Potential to Emit (PE)
2-3
-------
Slide
Script
Selected Visuals
23. A brief definition of potential to emit is: "The capability—at
maximum design capacity,
Potential to Emit
• "the capability • at
maximum capacity •
24. to emit a pollutant,
25. after the application of air pollution control equipment,
to emit a pollutant -
after the application
of air pollution control
equipment -
26. considering Federally enforceable permit restrictions." This
definition needs considerable explaining. In places, it's even
more complicated than it first sounds.
27. Let's take the critical terms of the "potential to emit"
definition one at a time. First is the capability of the
source—at maximum design capacity—to emit any pollutant
regulated under the Clean Air Act.
considering enforceable
permit restrictions"
^a«».'$k.t-:^5ft
28. This means that we must have a way of estimating the
emissions from the new source or modification. Remember,
the source may not exist yet, so its emissions can't be
measured directly.
29. The estimation is an engineering analysis; we'll look at it more
closely in a moment.
30. Next, notice that potential to emit is figured after air
pollution control equipment is applied.
31. This means that on top of emissions estimates for the new
source or modification, we must estimate how efficient the
control equipment will be.
How efficient is the
control equipment?
2-4
-------
Slide
Script
Selected Visuals
32. Last, remember we said potential to emit was figured at
maximum design capacity.
33. But most sources don't operate at their full capacity all the
time; few can. However, PSD is a program that requires
assurance that its goals will be met.
34. One of the most important things affecting those goals is the
actual potential to emit of a new source or modification. To
make sure that a source will operate somewhere under its
maximum emission rate, all day, every day, 8760 hours per
year, we need Federally enforceable permit conditions.
35. Federally enforceable permit conditions are operating rules
written into the legal document diat allows building or modi-
fying the source and then operating it.
36. If an applicant intends to run a plant for only two shifts a
day, about 16 hours, then they will have to agree to a permit
condition limiting hours of operation. Otherwise, potential to
emit has to be figured on 24-hour-a-day operation.
37. Similar limits could be written on materials burned or
processed at the source, or substances stored at it.
To base PE on
16-hour-a-day operation
Permit Condition • limiting
hours of operation
2-5
-------
Slide
Script
Selected Visuals
38. Any limit that isn't actually built into the way the source is
made has to be Federally enforceable, that is, the control
agency must be able to make the source do what the permit
condition says by legal means: an administrative order or
court order, for example.
39. We've just finished saying that we decide whether a source is
major or not by figuring its potential to emit any pollutant
controlled under the Clean Air Act.
Is the source major?
• Potential to Emit (PE)
40. The rate at which pollutants are emitted can be less than full-
time, full-capacity, "dirty" rates if we allow for air pollution
control equipment and Federally enforceable permit
conditions.
Less than full capacity rate
if:
• control equipment
• enforceable permit
conditions
41. We still need to see how the emission rates are figured and
added up, and then what we compare the rates with. The
process of calculating potential to emit for a source is an
engineering analysis.
42. Someone with a solid technical knowledge of the kind of
source we're interested in has to examine its operation unit by
unit. In most cases, the analyst will estimate the potential to
emit for each emission unit, and then add potentials for all
the units that make up the whole source.
43. There are many ways of estimating the potential to emit of an
emissions unit. The most accurate way is measurement by a
performance test.
44. If we're talking about emissions units at a source that already
exists, where a modification will be made, the test can be
done on the units we're actually concerned with.
Performance Test
2-6
-------
Slide
Script
Selected Visuals
45. Much of the time, however, we're concerned with emission
units that haven't been built. We need ways of calculating
what new emission units will do.
46. We can't always make a reliable performance test on existing
emissions units, either. It may be very difficult or physically
impossible.
47. So we may have to turn to different estimation methods for
either a brand-new source or an existing one.
48. Some of the information we need for estimating potential to
emit of an emission unit can be found in:
— Federally enforceable emission limits—regulations or
permit conditions—for that unit.
49.
50.
- Emission data and guarantees from the vendor of the
equipment.
-Data from Standards Support documents used by EPA
to back-up national emission regulations.
2-7
-------
Slide Script
51. —Data from AP-42, EPA's Compilation of Air
Pollutant Emission Factors.
Selected Visuals
52.
-Emission factors from technical articles and reference
books.
53.
-Completed questionnaires used by States to put together
their emission inventories.
54. Using these methods of measurement and estimation, we can
get at the potential to emit for "well-behaved" emissions units,
the kind we think of immediately.
55. But there are other things which we have to count as emissions
units. Some points and processes have fugitive emissions.
56. The official definition of fugitive emissions says they are "those
emissions which could not reasonably pass through a stack,
chimney, vent, or other functionally equivalent opening."
57. What this boils down to is that fugitive emissions are
substances that escape without a reasonable chance for con-
ventional kinds of controls. Particulate fugitive emissions can
come from units like coal piles, dusty roads, or quarries.
There are certain exemptions concerning fugitive emissions
that will be discussed later.
2-8
-------
Slide
Script
Selected Visuals
58. Volatile organic fugitive emissions can come from leaks in
refinery piping or chemical plant processing equipment.
59. There are ways of putting numbers on fugitive emissions
though. Some emission factors are included in AP-42,
i.:-^
60. and a lot of studies have been done for EPA and trade
organizations. The problem with using unofficial sources of"
emission factors, however, is that the applicant will have to
convince the reviewing agency that the source is reliable.
61. One type of emissions not counted in totalling up potential to
emit is secondary emissions.
62. Secondary emissions are emissions that occur ay a result of the
construction or operation of the source or modification, but
do not come from the source or modification itself. They do
not include any emissions directly from any mobile source.
63. We are finally at a point where we can talk about potential
emissions accounting — that is adding up the potential to emit
of each emissions unit to decide what size source we're dealing
with. There is more to that than it sounds like.
PE Accounting
• adding up the
PE of each unit
64. Remember that we said that different emissions units at the
same place could make up different sources—like that mine-
mouth power plant. If the emission units are different sources,
we have to be sure to count the right units for the right
source.
Mine-mouth coal-fired power plant
Mining Electric Power
Operations Generation
2-9
-------
Slide
Script
Selected Visuals
65. Another complication is that potential to emit has to be added
up for each pollutant regulated under the Clean Air Act.
66. That includes six criteria pollutants, related to national
ambient standards; nine other pollutants regulated under
National Emission Standards for Hazardous Air Pollutants or
New Source Performance Standards; and right now, five other
pollutants that are listed but don't have final regulations.
Since the list is open-ended, there may be more by the time
you see this lesson.
67. OK—what we have now is a list 15 columns wide, one for
each regulated pollutant. The list is as long as the number of
emission units at our source. We add up the potential to emit
by pollutant of all the emission units at the source, and come
up with a total potential to emit for each pollutant at the
source as a whole.
• PE accounting is
pollutantispeciflc
Pollutants
Criteria Noncriterta
Untt
Uott
Untt
IMI
U*t
Untt • V
Totato
i'
3
i
Ł
!
>
i
i
\
l
j
Ł
i
]
1
* i
68. This potential to emit for the entire source is what we use to
decide if the source is major or not. This is going to make a
difference whether we are talking about a whole new source
or a modification at an existing source.
69. There is a double-barrelled definition for "major source."
Congress made a list of 28 kinds of sources; large fossil-fuel-
fired steam electric plants;
70. Kraft pulp mills, etc., which EPA wrote into the PSD
regulations.
•PE defines
major status
28 Named Categories
2. Cod
3. Kraft
28 Named Categories
(continued)
23. Ch-N^ul
24. FovMl-FiMl
71. If a source on this list emits or has the potential to emit 100
tons per year or more of any regulated pollutant, it is major.
2-10
-------
Slide
Script
Selected Visuals
72. If a source not on the list emits or has the potential to emit
250 tons or more per year of any pollutant regulated under
the Act, then it is major.
not on list
+
250 tons/year
Major
73. Sometimes, it isn't clear what category a source falls in.
Neither Congress nor EPA gave sharp definitions to the
sources named on the list. Differences in what a power plant
burns, or what its heat input rate is, can decide whether it's
measured against the 100 or 250 tons per year yardstick. It
often helps to check the source definition in a New Source
Performance Standard regulation that would apply if the
source were on the list.
74. So far, we have discussed the basic building blocks for
determining whether PSD review applies to a proposed new
source or modification. They are:
— What is the area classification?
— What emission units make up the source or
modification?
— What is the total potential to emit of the proposed
construction?
— What does "major" mean for a new source or a
modification?
• Area Classification
• Emission Units
• Potential to Emit
• Major Source/Modification
75. In the next lesson we will use these ideas to put together tests
to determine whether PSD review applies to a proposal. And
if it does, what kind and how much.
• Does PSD review apply?
• If so, what kind and how
much?
76. (Credit slide)
Applicability Determination
In the Application: I
Technical Connnl: John M«on*v
ul D«l*ti; Monica L«lt*
Graphic*: B*nv Hubcr
Bphv. Audio O**td Choicblll
IMuTMIon: Rick P«im*r
77. (Northrop slide)
.Northrop Service*. Inc.
under
EPA Contract No. 68-02-3573
78. (Northrop slide)
(980 PSD Workshop.
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
2-11
-------
Slide Script Selected Visuals
79. (NET slide) Northrop
Environmental
Training
2-12
-------
SI:453
Lesson 3
Applicability Determination in the Application: II
Slide
1. (Focus)
2. (Introductory slide)
Script
3. This is Lesson Three, "Applicability Determination in the
Application, Part Two."
Selected Visuals
FOCUS
|
I Applicability Determination In
j the Application: II
4. In: the last lesson, we lined up the items of information we
need to determine PSD applicability for a proposed new
source or modification.
5. We looked at the classification of the area, PSD or nonattain-
ment, for different air pollutants.
Classification
• PSD
• Nonattalnment
6. We saw how to define the new source or modification in
terms of its emission units. Then we added up the potential
to emit pollutants for the whole proposed construction.
\
7. Finally, we took our first look at the general definition of
"major source."
8. Now we have the pieces from which we can build three tests
for applicability of PSD regulations.
Test One—for new or existing sources is pretty simple.
It checks whether or not the source is major.
Test Two and Test Three—are more complicated and
deal with emission changes at a source where a modifica-
tion is proposed. These tests check for significant
increases, and decide which pollutants require review.
• Emission Units
• Potential to Emit
Major Source
Test 1 Is the source major?
Test 2 Are there any
significant increases?
Test 3 Which pollutants
require review?
3-1
-------
Slide
Script
Selected Visuals
9. Test One just says: "Is the source, new or existing, major for
at least one regulated pollutant?" If the source is major by the
100- or 250-ton criterion, we have to go ahead with a PSD
review. If the source isn't major, and we aren't proposing a
change so large it's a major source in itself, then no PSD
review is needed.
10. But remember, a source that's major for any pollutant is a
major source, unless, of course, the area is nonattainment for
that pollutant. If so, the nonattainment area rules apply to
the source for that pollutant.
Testl
Is the source major?
yes
no
PSO review
no PSO review
Major for any
(Attainment) Pollutant
Major Source
...regardless for what
pollutant the area
is PSD
11. The simplest case is an entirely new major stationary source in
a PSD area. It will have to go through the rest of the PSD
review process. Things are more complicated for
modifications.
12. To deal with modifications, we need some more definitions.
The first one is "modification" itself.
13. A general definition says a modification is "any physical
change in a stationary source, or change in its method of
operation that would increase its actual emissions of any
pollutant regulated under the Act." There are some detailed
qualifications and exceptions to this general definition.
Modification
• physical change
• change In the method of
operation
• net emissions Increase
14. Modifications that might require PSD review would include
modified emissions units, new emissions units, or replacement
emissions units.
• modified emissions units
• new emissions units
• replacement emissions
"™^™"
15. But not every modification, not even at a major source, has to
receive PSD review. It is only major modifications that must
be reviewed.
Only major modifications
require review.
3-2
-------
Slide
Script
Selected Visuals
16. A "major modification" meets two conditions: it is a modifica-
tion at a major source, and it "results in a significant net
increase in emissions of any pollutant regulated under the
Act."
Major Modification
• at a major source
• significant net
emissions increase
17. By now, we have a pretty good idea of what a major source is,
so that doesn't raise much of a problem in our understanding
what a major modification is. But now we have something
new to deal with—a significant net increase in emissions. We
have to deal with two loaded words: "significant" and "net."
18. "Significant" in this context means "it makes a difference to
somebody," but how do you assign numbers to that idea?
Well, it isn't a new problem in law and regulation.
Significant Net
Increase
19. The solution is to pick a number based on the best informa-
tion available and call that "significant." This is what EPA
has had to do in its PSD regulations.
20. For each pollutant regulated under the Clean Air Act, EPA
has assigned a number of tons per year that will be treated as
a significant increase.
Significant Emiufon Rates
[extracted from 40 CFR 51.24 (23MI)]
SnUw OtaiM*: 40 toi.
PMtcaUM MMtlc 23 tpv
OKM* 441 Ipv of »J.lll. ofl
U«l:0.ttev
0.007 ipv
i; 0.0004 tpv
21. These amounts range down from 100 tons per year for carbon
monoxide to eight-tenths of a pound per year for beryllium.
Significant Emiision Rate*
(continued)
• Salfortc AcM MM: ' Ipy
• Hydraem 5«llu* (H.SI: 10 tpv
* Tout IUdMC«4 9«lto llflcladlnv H.SI: 10 tpy
22. There's one further complication we have to keep in mind in
talking about significant emission increases. It has to do with
the special protection that Class I PSD areas must get.
3-3
-------
Slide
Script
Selected Visuals
23. If a major source that plans a modification is within 10
kilometers of a Class I area, we have to do air dispersion
modeling to find out if the change is significant. Usually, we
don't get to modeling until we're evaluating all the air quality
impacts of the source.
24. For a source within 10 kilometers of a Class I area, any
emissions increase that will make the air quality model predict
an increase in pollutant concentration greater than one
microgram per cubic meter is significant.
• major source
• within 10 km of Class I area
Air Dispersion Modeling
Special Criteria for Sources within
10 kilometers of a Class I Area
1 any pollutants
regulated undei
1 any Increase which
impacts the Cass I
ana by greater than
1 u&m' (24-hour
i)
25. All right, now we have something to compare our net emission
increases to, to see if they're significant. Next we have to
decide what the net actual increase is. The process of
counting up emission changes to arrive at this number is
usually called "netting." It can be fairly involved.
26. We can define "net actual increase" by a simple-looking
formula. It is: Net increase equals actual change from new
and modified units minus creditable, contemporaneous
decreases, plus creditable contemporaneous increases. That's
like telling you all bookkeeping is just running the basic
accounting equation. The hard part is knowing what to plug
in for each of the variables.
Netting
• counting up emission
changes '
Net Actual Increase
27. Once again, let's attack the problem by taking the key words
one at a time. Contemporaneous means "in the same time
period."
Contemporaneous
• in the same tune period
28. For PSD, this doesn't necessarily mean an increase or decrease
is made at exactly the same time as a modification. They may
happen during a "window" of time. Where EPA regulations
apply, the "window" opens five years before legal commence-
ment of construction of the change. It closes when the change
actually produces emissions. An approved State PSD plan can
define a reasonable period before the emissions increase as
"contemporaneous."
29. There are quite a few conditions on what emission changes are
creditable. The idea is to make sure that we get actual, not
"paper," decreases and increases credited to the net change.
Time Window
• opens 5 years before
commencement of construction
1 closes when change actually
produces emissions
> or a reasonable period
In a State plan
Creditable Changes
> actual • not "paper" •
d*ecreases and increases
3-4
-------
Slide
Script
Selected Visuals
30. For this reason, if a decrease results from an operation cut-
back, or something else that could be turned around, the
decrease has to be Federally enforceable.
31. Along the same lines, decreases may be counted only once. If
a decrease is applied to one permit application, it can't be
used again on a later one.
32. Also, the decreases have to be the same pollutant type as the
other changes they're credited against and have similar effects
on public health and welfare.
Decrease resulting from
operation cutback must
be Federally enforceable.
Decreases
• may be counted only once
Decreases
• may be counted only once
• must be same pollutant
type —————
• must have similar effects
33. When we start talking about specific pollutants, we have to
remember that paniculate matter and sulfur dioxide are
special cases. They have air quality increments associated with
them.
TSP and SO2
Increments
34. When we tie emission changes to other PSD requirements, like
increments, we have to consider when the changes take place
with respect to the baseline date.
35. The baseline date is not connected with the construction of
the source or modification we're analyzing. It's the "trigger"
date for increment calculations that we'll be talking about
under Air Quality Analysis.
36. For now, keep in mind that the baseline date is triggered by
the first application in the area for a PSD permit involving
specific pollutants. If there's one application for just
paniculate matter on one date, and for volatile organics a
year later, your area will have baseline dates a year apan for
those two pollutants. You could wind up with about 15 dif-
ferent baseline dates in one area, but it's not very likely.
There is, however, some variability among State programs.
37. There's a difference as to whether you can credit an emission
change, depending on whether it's before or after the baseline
date. With some detailed qualifications, changes before the
baseline date are creditable only if they are directly tied to
construction, and at a major source.
38. If the change is after the baseline date, it may come from
nonconstruction causes, like operating-level changes. Again,
the regulations apply detailed qualifications to this simplified
statement.
• when changes take place
• with respect to the baseline
date ^""~~""~
Baseline Date
• "trigger" date for increment
carculatlf ns
Baseline Date
• "trigger" date for increment
calculation
• tied to specific pollutant
Before Baseline Date
Creditable only if:
• tied to construction
• at a major source
After Baseline Date
may come from
nonconstruction causes
3-5
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Slide
Script
Selected Visuals
39. The process, netting, that we just got through describing is
not simple. People generally don't do it in their heads. It
requires going over the existing source, and the proposed
change, emissions unit by emissions unit, for every regulated
pollutant.
40. You have to look at changes in the operating history of each
unit for each pollutant. When you get through you add up
the emission changes that come from modifying the source
with all the other creditable contemporaneous changes.
41. The results of those additions (remember there's one for each
pollutant) are the numbers we need for Test Two. Test Two
asks: "Are there any significant net increases?"
42. If any pollutant has a significant net increase under Test Two,
then we have to continue with PSD review. This is so even if
the source is a major source for a completely different
pollutant.
43. If we were dealing with a source that was major for hydro-
carbons, for instance, and our proposed change significantly
increased only suspended paniculate matter emissions, we'd
still have to do PSD review.
Test 2
Are there any significant
net increases?
Significant Net Increase
Continue with
PSD review.
source major for HC
+
significant increase in TSP only
PSD review
anyway
44. One thing to keep in mind about significant net changes is
this: a relatively small increase in emissions due to a modifica-
tion can trigger a full PSD review at a major source.
Relatively small increase
due to modification can
trigger full PSD review at
major source.
45. To wrap up this segment on significant net increase, let's
recall something we mentioned in passing earlier, and look at
one strange effect of the rules. Both have to do with sources
that are not major, and are proposing changes.
46. If we're looking at a proposed change at an existing non-
major source, then we aren't concerned with significant net
increases. But we still have to think about emission increases
from the modification. If the increases are big enough to meet
major source criteria by themselves, 100 or 250 tons per year
depending on category, then the modification has to be
reviewed as a major source.
• not major
• proposing changes
increases meet
major source criteria
modification must be
reviewed as major
source
3-6
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Slide
Script
Selected Visuals
47. The strange situation comes up because changes at a non-
major source can add up to create a major source that never
got PSD review, but will need it for future significant
changes. Let's look at a simplified example:
• changes at nonmajor source
• ^ddupto major source
• never got PSD review
...but will need review if future
significant changes
48. Take a source that's on the list of 28 categories. It emits only
70 tons per year of some pollutant, so it's not major.
nonmajor
•ource
49. The proposal is to add operations that would increase
emissions by 80 tons per year. The source isn't major, and the
modification isn't either, so no PSD review is called for.
nonmajor
increase
nonmajor
source
50. But when the change is complete, we've got an existing
source, on the list of 28, with 150 tons per year of emissions.
From now on, any significant net emission increase, for any
regulated pollutant, will call for PSD review.
90
| .0**,™
70
MMM/vmt
nonmajor
increase
noomajor
• now is existing
major source
• has never been
reviewed
150
tons/year
51. So far, we've described two sorts of things that call for PSD
review, new major sources and major modifications. Test
One compares the new or existing source with criteria to
decide if it's major or not. If the proposed new source is
major we go on with PSD review. If the existing source is
major, we go to Test Two, to see if there is a significant net
increase in actual emissions of any regulated pollutant. That's
the point we've reached now.
Testl
Is source major?
no PSD
review
New
Source
Existing
Source
PSD review Test 2
Significant net
increases?
52. Whether we're talking about a proposed new source or a
modification we still have to determine what and how much
PSD review will be done. Test Three will tell us that.
What and how much
PSD review?
53. Test Three looks a lot like Test Two. It goes over the totals of
emission increases from the new source or modification. But
Test Two just asks for a modification, "Is there at least one
significant net increase?" Test Three asks, "Which pollutants
have significant increases?" For each pollutant that comes out
of Test Three, that has a significant net increase we have to
do the three analyses that PSD review involves.
Test 2
Is there at least one
significant net increase?
Test3
Which pollutants have
significant net increases?
3-7
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Slide
Script
Selected Visuals
54. Those three analyses are the topics of lessons of their own in
this course. They are: Best Available Control
Technology—BACT—Analysis, Air Quality Impact Analysis,
and Additional Impacts Analysis.
Three Analyses
BACT Analysts
Air Quality Impact Analysis
Additional Impacts Analysis
55. The process we've just described—deciding on the applicabil-
ity of PSD review—is pretty complicated and time-consuming
in itself. The analyses that applicability determination can
lead to will be more complicated, time-consuming—and
expensive. To keep applicants from having to do unnecessary
and expensive work, the PSD regulations have some exemp-
tions from review.
There are some
exemptions
from PSD review.
56. A major exemption deals with the air quality monitoring
related to air quality impacts analysis. We'll discuss it when
we get to the air quality impacts lesson.
Major Exemption
• monitoring related to Air
Quality Impact Analysis
57. We mentioned another exemption in passing in Lesson One
and earlier in this lesson. It's important enough to mention
again. When the States designate an area as nonattainment,
attainment, or unclassifiable, it is for specific criteria
pollutants.
Areas may be:
• nonattainment
• attainment
• unclassifiable
for specific criteria pollutants
58. Many areas we're interested in are likely to be nonattainment
for one or more pollutants and PSD for the rest.
Areas may be mixed
• nonattainment for some
• PSD for others
59. In these "mixed" areas, PSD review has to be done for all the
pollutants that do not make the area nonattainment, if PSD
review is triggered by Test One and Test Two.
pollutants
jio^making
area
nonattainment
potential
PSD review
60. But for the pollutants that do make the area nonattainment,
special nonattainment area plan new source review applies.
That's another story, one we're not going to deal with in this
course.
pollutants
not making
area
nonattainment
potential
PSD review
pollutants
making
area
nonattainment
special new
source review
61. Another exemption keeps fugitive emissions from making some
sources major. The basic idea is that certain sources that
would be major only because quantifiable fugitive emissions
bring their potential to emit over the line are exempt from
PSD review.
If source Is major only
because of fugitive
emissions...
Then source is exempt
from PSD review
3-8
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Slide
Script
62. However, the exemption has an exemption of its own. Certain
sources can't get out of PSD review this way. They are: those
on the list of 28 categories, and those that were regulated by
New Source Performance Standards or Hazardous Pollutant
Standards as of August 7, 1980. That's the day the final PSD
regulations were issued. That narrows the field of the fugitive
emissions exemption, but some sources still qualify. There is,
however, some difference among the States as to which NSPS
or NESHAPS must be applied.
63. There is a very long and complicated list of other exemptions
in the regulations, mostly at 40 CFR 52.21(i)(4). The general
idea is to exempt from review those changes that are made to
comply with a Federal law, that are temporary and
unavoidable, or that are in the public interest.
Selected Visuals
Exemption does not apply to:
• 28 listed sources
• sources regulated under
NSPS or NESHAPs
Exemptions
[40 CFR 52.21 (l)(4) I
Changes:
• made to comply with a
Federal law
• temporary and unavoidable
• In the public Interest
64. The applicability determination process we've just gone
through is the first big step in PSD review. It's also a critical
one. Applicability determination decides */ a source or
modification will get PSD review. If it does get review, the
process decides what pollutants the review will be done on.
Applicability Determination
• Will a source get PSD review?
• What pollutants will review
deal with?
65. For every new major source or major modification, the
applicant is going to have to do three analyses. These will
need to be done for each pollutant emitted in significantly
increased amounts.
for every
new major source or
major modification
three analyses for each
pollutant emitted in
significantly increased
amounts
66. The analyses are: Best Available Control Technology
(BACT)—or bact —analysis. Air Quality Impact Analysis, for
effects on air quality increments and standards; and
Additional Impacts Analysis, for soils, vegetation, and visi-
bility effects, especially on Class I areas. We'll take these up
one by one in the following lessons.
• BACT Analysis
• Air Quality Impact Analysis
• Additional Impacts Analysis
67. (Credit slide)
68. (Northrop slide)
Applicability Determination
In the Application: If
Technical Conwm: John M«on*v
liutractloral Dv*lf.n: Monica L.miU
Guphlc*: BM*v Hubvr
Photo«i»tri>V Audio: Dnld Churchill
Narration: Rick Patmvr
Developed and
produced by:
Northrop Services. Inc.
EPA Contract No. 68-02-3573
3-9
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Slide Script Selected Visuals
69. (Northrop slide)
1980 PSD Workshop*
Agency
Office of Air Quality Planning and
Standards
70. (NET slide) Northrop
Environmental
Training
3-10
-------
SI:453
Lesson 4
BACT Analysis in the Application: I
Slide
1. (Focus)
2-3. (Introductory slides)
Script
Selected Visuals
FOCUS
4. This is Lesson Four, "BACT Analysis in the Application, Part
One."
BACT Analysis in the
Application: I
5. In Lessons Two and Three, we saw how an organization plan-
ning to build or modify an air pollutant source went about
determining if PSD review requirements apply, and if so,
what kind of review has to be done.
6. The next major step, after deciding that PSD does apply and
has to be done for specific pollutants is the Best Available
Control Technology—B-A-C-T or BACT analysis. We can
think of the BACT analysis as the real core of the whole PSD
review process.
7. This is because the BACT analysis provides the information
needed for the other two analysis steps: Air Quality Analysis
a.nd Additional Impacts Analysis.
• PSD review?
• What kind?
Best Available (Control
.Technology (BACT)
Analysis
BACT Analysis
Air Quality Analysis
Additional Impacts
Analysis
8. The BACT analysis will also line up data the corporation
needs for financial decision-making about the project. It also
pulls together some of the most important facts needed to
inform the public before the review goes to public hearing.
BACT Analysis
• financial decision
making
• public information
4-1
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Slide
Script
Selected Visuals
9. Best Available Control Technology is a very important term in
PSD programs. It's so important that it is defined at some
length in the Clean Air Act.
10. EPA regulations copy the Act's definition, with a few changes
to fit programs run by the States or EPA.
11. Legal definitions are seldom easy reading. This one certainly
isn't. It packs into a few words most of the ideas needed to
deal with a complex concept. We'll spend all of this lesson
"unpacking" what the definition means in terms of what you
really do in a BACT analysis.
12. But you should hear the whole definition just once. Just listen
for some of the key words and ideas. Don't expect to commit
it to memory.
13. The Clean Air Act says: "best available control technology"
means an emission limitation—
Best Available Control
Technology
BACT
• emission limitation
14. "based on the maximum degree of reduction of each pollutant
subject to regulation under this Act —
BACT
emission limitation
maximum reduction
pollutant
15. "emitted from or which results from any major emitting
facility, which the permitting authority,
BACT
emission limitation
maximum reduction of each
pollutant
from major source
16. "on a case-by-case basis, taking into account energy,
environmental, and economic impacts and other costs,
BACT
emission limitation
maximum reduction of each
pollutant
from major source
case-by-case basis, considering:
• encrgy/envlTonnMntal/acononiic Impacts
4-2
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Slide
Script
Selected Visuals
17. "determines is achievable for such facility through application
of production processes and available methods, systems, and
techniques, including fuel cleaning or treatment or innovative
fuel combustion techniques for control of each such pollutant.
BACT
emission limitation
maximum reduction of each
pollutant
from major source
case-by-case basis, considering:
• eMrgy/environrnental/economlc impacts
• other cost*
achievable, through:
• production processes
• available methods/systems/technlques
18. "In no event shall application of 'best available control
technology' result in emissions of any pollutant which will
exceed emissions allowed by any applicable standard
established pursuant to Section 111 or 112 of this Act."
BACT
• emission limitation
• maximum reduction of each
pollutant
• from major source
• case-bycase basis, considering:
• energy/envirorunental/econoinic impacts
• other costs
• achievable, through:
• production processes
• available methods/systcms/techniques
• emissions not to exceed standards
19. Whewl That's what happens when you put everything you
need to know in one paragraph. Let's start working on the
definition—and what it implies —a few words at a time.
20. One thing that's easy to lose sight of as soon as you start
running detailed analyses of technology, economics, and so
forth, is that BACT is an emission limitation.
BACT
' emission^ limitation
21. It's based on available control technology, but—whenever
possible—it's an emission rate. The BACT rate is what will get
written into the PSD permit as a Federally enforceable
limitation.
22. Of course, if there's no practical way to come up with a
quantifiable emission rate, BACT conditions may involve
something else. The "something else" could be specific kinds
of processes, limitations on fuels or feed stocks, or work
practice rules.
23. These can be especially important in dealing with fugitive
emissions, like leaks and storage losses.
• kinds of processes
• limitations on fuels/
feedstocks
• work practice rules
4-3
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Slide
Script
Selected Visuals
24. In some cases, BACT could be specified in terms of specific
control equipment, operated in a certain way. But the basic
idea is that the emission rate is what you want from your
BACT analysis. But, you might have to settle for something
narrower and less quantitative—a how-to-comply directive, for
instance.
Emission
Rate
25. This idea comes up often in the Clean Air Act. Whenever
possible, emission controls are to be specified in allowable
emission rates—under NSPS or NESHAPs, for instance. The
source operator should be able to decide on the best way to
achieve the allowable rates.
26. There's a difference with BACT analysis under PSD, however.
It's the applicant —the organization that wants to build or
modify a source—that works up the emission rate that's
offered as best available control technology. The reviewing
agency can approve or disapprove the analysis, but the
applicant does the analysis.
27. With that in mind, it's not hard to remember that BACT
analysis is case-by-case. What's been done at other plants can
certainly help the analysis, but BACT is the best available for
this plant, operating in its technical, economic, and so on,
situation.
BACT/PSD
plicnnt determines
approves or
'approves
BACT Analysis
• case-bycase
• this plant
• Its situation
28. What takes most of the time and effort in BACT analysis is
deciding what "best" and "available" mean for the proposed
project. The definition in the Act outlines, in a few words,
what's involved. EPA regulations and guidance expand the
definition to cover concrete cases.
• "Available"
29. Let's begin with the definition of "best." Remember that the
Act says BACT means the maximum degree of reduction of
each pollutant regulated. Once again, we have to remember
to deal with all the regulated pollutants that are emitted in
significant amounts by the source.
30. "Best" also means that the degree of control proposed goes
beyond what's routinely applied to sources of this kind.
"Best"
maximum reduction
each pollutant
"Best"
maximum reduction
each pollutant
beyond routine application
4-4
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Slide
Script
Selected Visuals
31. To keep the control tight, the Act says BACT has to require
limits at least as strict as New Source Performance Standards
or National Emission Standards for Hazardous Air
Pollutants —if any apply.
"Best"
maximum reduction
each pollutant
beyond routine application
at least as strict as NSPS/
NESHAPs
32. But BACT is best available control technology. And
"available" here means what can be achieved when you take
into account energy, environmental and economic impacts
and other costs—including social costs.
"Available"
Achievable, considering:
• Energy Impacts
• Environmental Impact*
• Economic Impacts
• Social Coats
• Other Costs
33. So besides examining control technology alternatives, a BACT
analysis requires us to evaluate what the controls will cost, in a
very broad sense.
$
What will
the controls
cost?
34. It isn't just the reasonableness of investment and operating
costs for the company we have to consider.
35. We also have to analyze what effects different control
strategies will have on society and the environment,
36. and what those effects are worth.
37. What do we want from a BACT analysis, then? Basically,
information of different kinds for making different kinds of
decisions.
BACT Analysis
Information
38. Some of these decisions will be made within the organization
making the application.
4-5
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Slide
Script
Selected Visuals
39. Some of them will be made by—or together with—the
reviewing agency. And some will be made by public
participation.
40. First of all, we want the BACT analysis to come out with the
mixture of control equipment, processes, and operations to be
used on the source. This is an important step in company
investment decision making.
41. Second, we need the emissions data after controls have been
applied. This information feeds all of the rest of the PSD
analysis, especially the air quality-modeling-analysis, and the
additional impacts analysis.
42. Third, calculating emissions after control
surprising effect.
may have a
Control
equipment
processes
opcr&tions
Emissions Data
. • after control
Emissions Data
• after control
surprising effect
43. Since potential to emit is figured on the basis of controlled
emissions, the applicant may find an appropriate mix of
controls drops the source from PSD applicability. The source
may become nonmajor, or emission increases may not be
significant. This isn't the primary goal of BACT analysis, but
it can be important in special cases.
44. Fourth, the analysis of alternative control strategies, with costs
to the company and costs and impacts that society and the
environment will bear, are vital public information. This has
value in itself, and has a practical effect when the permit
application gets to the public hearing stage.
Major
Nonmajor
45. A BACT analysis is not like filling out a tax return. The
applicant doesn't get any official form with blanks to fill in.
4-6
-------
Slide
Script •
Selected Visuals
46. Instead, engineers, accountants, and other specialists have to
line up their facts and reasoning so that company executives,
agency reviewers, and the public can check them. However,
we can break the basic approach up into manageable pieces.
47. The BACT analysis starts by lining up the basic data to be
examined. This is done in four steps that we will look at in
more detail later. They are: One, Pollutant Applicability;
Two, Emissions Unit Applicability;
48. Three, Identification of Potentially Sensitive Concerns; and
Four, Selection of Alternative Control Strategies.
Steps
1. Pollutant Applicability
2. Emissions Unit Applicability
Steps
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
49. When the sensitive concerns have been identified and the
control alternatives lined up, the applicant can turn to three
impact analyses. We'll also look at them in more detail later.
The impact analyses are: One, Economic Impacts; Two,
Energy Impacts; and Three, Environmental Impacts.
50. The applicant demonstrates compliance with the requirements
of the PSD regulations step-by-step through this process. The
"bottom line" won't be one big number adding up a BACT
score. It will be an array of control alternatives, showing con-
trol efficiencies, costs to the company, costs to society and
other effects.
51. Sometimes, one set of controls will obviously be the best in
terms of all these costs and impacts. Usually, however, it will
be necessary to pick among alternatives with advantages and
disadvantages, using two criteria for choice.
Impact Analyses
Economic Impacts
Energy Impacts
Environmental Impacts
Impacts
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52. For energy and economic costs, the criterion is
reasonableness. What is reasonable is seldom easy to define.
Energy/Economic
Costs
• reasonableness
4-7
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Slide
Script
Selected Visuals
53. But comparison with what other companies—and
communities—in similar circumstances have to pay for energy
and controls will help. Also, some control alternatives will
clearly be more reasonable than others. They'll be cheaper for
about the same results.
54. For environmental factors, the criterion is a little more
complicated. It always is for things that can't be measured
directly in dollars. The idea is to keep to a minimum
undesirable impacts and risks to all kinds of environmental
values.
Environmental
Factors
minimize undesirable
Impacts/risks
55. Some risks or impacts may be so important that they force
dropping a control alternative that looked good otherwise.
56. This sounds as though we're getting ahead of ourselves. Don't
we do Air Quality Impact and Other Impacts Analyses later,
as major components of PSD review? Yes, but we have to do
brief, screening-type checks in BACT analysis to make a
choice of a final control strategy for detailed review. You
don't expect the strategy that passes BACT analysis to fail the
later stages. But there's no way to be sure without doing the
detailed analyses.
57. The first step in BACT analysis is to consider pollutant
applicability. In other words, as we put together our list of
control alternatives, what pollutants do we have to apply
controls to?
Now
screening checks
Later
detailed analyses
1. Pollutant
Applicability
• What pollutants
do we control?
58. When dealing with a new major source, we must do BACT
analysis for any pollutant regulated under the Act that is
emitted in a significant quantity.
New Major
Sources
regulated pollutants
emitted in significant
59. At a major modification, any regulated pollutant emitted in a
significantly increased amount calls for BACT analysis.
These are the same significance levels we talked about in the
last lesson—when we discussed Tests Two and Three for PSD
review applicability.
Major
Modifications
regulated pollutants
emitted In significantly
increased amounts
4-8
-------
Slide
Script
Selected Visuals
60. Remember from Lesson Two that we have to add up all
emissions—stack and fugitive — of each regulated pollutant. If
the total for the whole source is significant, that pollutant gets
BACT analysis.
Unit 1
UnM2
Unit)
Unit 4
Units
Unit "n"
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a
i
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i
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i
61. In adding up new emissions or increases by pollutant
classification, we have to keep in mind something that isn't
obvious at first glance. This is that some substances can fall
into more than one pollutant category.
62. For example, take dimethyl sulfide, a not unusual emission.
It's a reduced sulfur compound, so it has to be totalled under
reduced sulfur. But it's also a volatile organic compound or
VOC, so it has to be totalled again with all the other VOCs.
Some Substances
• morethan^cme
pollutant category
Dimethyl
Sulfide
Reduced VOC
Sulfur
63. Closely connected with Step One— pollutant applicability—is
Step Two—emissions unit applicability. Our question here is:
which emissions units does the BACT analysis have to deal
with?
2. Emissions
Unit Applicability
• Which emissions units
must be analyzed?
64. The answer calls for close attention. For new major sources
each emissions unit that emits any amount of a regulated
pollutant has to apply BACT.
New Major
Source
• any unit that emits
Łnyamount of a
regulateTpollutant
65. For modified sources, each modified unit that has any
increase of a regulated pollutant has to apply BACT.
Major Modification
• any unit that shows
any Increase In
enussionsof a
regulated pollutant
66. Notice that we said any emissions or any increase. Because
each regulated pollutant has to be analyzed, we'll find many
emission units —like fuel burning operations—that require
BACT analysis for several pollutants.
67. Also remember that it isn't just the neat well-behaved
emissions and emissions units that need analysis. Sources of
fugitive emissions have to be dealt with, too.
Fugitive
Emissions
4-9
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Slide
Script
Selected Visuals
68. There are several important examples of fugitive emissions.
For example,
—Storage piles of coal, limestone, or other materials;
69. —Outdoor conveyor belts;
70.
— Storage tanks for volatile organic liquids; and
71. —Valves and pumps that carry volatile organic
compounds.
72. Usually, fugitive emissions from sources like these are affected
by the weather. This makes them hard to quantify.
73. Since this means that emission limits will also be hard to spell
out in definite numbers, BACT for these fugitive sources*
generally takes a special form. Where quantifiable emission
limits cannot be set, BACT is usually an equipment (design)
standard, or a work practice standard, or both.
74. Don't forget, however, that for stack emissions—where rates
are easier to quantify—BACT has two components. The
analysis will produce an equipment standard, or a process
(operation) standard, or both. Tied to what the analysis says
the devices or operations can do will be Federally enforceable
limits on allowable emissions from each unit. It is desirable to
have both an emission standard and equipment or process
standard where possible.
4-10
BACT may be:
• equipment standard
• work practice
standard
• equipment
standard
process
standard
enforceable
limits
-------
Slide
Script
Selected Visuals
75. However, there are some exemptions from counting and
analyzing emissions for BACT. Emissions units that produce
only secondary emissions are exempt from BACT analysis.
Remember that secondary emissions result from building or
running the major source or modification, but don't come
directly from it.
76. However, secondary emissions do not include:
emissions from ships, trucks, and cars not on the plant
site, taking goods or people to and from it.
Units producing only
secondary emissions
• exempt from BACT
analysis
77. And an example of secondary emissions that generally don't
require BACT analysis are:
increased emissions from a power plant due to greater
electric demand, when the power plant is not part of the
source.
78. But the applicant has to keep track of secondary emissions for
a later stage of analysis. When we get to the Air Quality
Analysis stage, we have to check whether secondary emissions
threaten air quality standards or would consume an allowable
increment. If secondary emissions present such a threat,
control will have to be applied to eliminate that threat.
79. When you put together the results of Step One —pollutant
applicability—and Step Two —emissions unit
applicability—you wind up with a lot of pieces of information.
To deal with that information in a reasonable way, you have
to put it into a form that makes sense.
80. There is no one best way to group emission units for the rest
of BACT analysis. There is a general principle, however.
Similar emissions units should be analyzed together.
Do secondary emissions
threaten air quality
standards?
Similar emissions units
should be analyzed
together.
81. They may be "similar" because they're the same type of
device, because they have similar kinds and amounts of
emissions, or because they can use the same general kind of
control.
"Similar"
same type of device
similar kinds and
amounts of emissions
can use the same
general kind of control
4-11
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Slide
Script
Selected Visuals
82. By treating similar units together, the applicant can usually
cut control costs through "economies of scale."
• grouping simitar units
• lower control costs
83. For example, a source with three boilers as separate emissions
units could plan one flue-gas desulfurization system to serve
all three. The larger system should cost less—both to build
and to operate—than three separate systems.
Boiler
No. 1
Boiler
No. 2
Ml Ull LJT
Boiler
No. 3
FGD
Scrubber
84. By applying Step One and Step Two, then grouping similar
emissions units, we have assembled one kind of basic data for
BACT analysis. This information has to do mostly with things
inside the source.
Steps
I. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
85. In the next lesson we will start looking outside the source—as
we discuss Steps Three and Four.
Steps
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
4. Selection of Alternative
Control Strategies
86. (Credit slide)
BACT AnilyiiB
in the Application: I
G»phici: BMM Hn6*r
f Ao4lo: Di*M Churchil
Rick Palwi
87. (Northrop slide)
Developed •nd
produced by:
Northrop Services. Inc.
EPA Contract No. 68-02-3573
88. (Northrop slide)
8*wd In put on (hi:
1980 PSD Workshops
prepared far the
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
und«
EPA Contract No, 6MJ.3I
89. (NET slide)
4-12
Northrop
Environmental
Training
-------
SI:453
Lesson 5
BACT Analysis in the Application: II
Slide
1. (Focus)
Script
2. This is Lesson Five, "BACT Analysis in the Application, Part
Two."
Selected Visuals
FOCUS
BACT Analysis in the
Application: II
In the previous lesson, we outlined the overall shape of the
Best Available Control Technology—BACT—Analysis. We
emphasized that BACT Analysis is a case-by-case analysis
done by the applicant, and that it leads to emission limits for
the new source or modification.
BACT
• case-bycase
••by the applicant
• emission limits
4. We talked about the four steps and three impact analyses
that make up BACT Analysis. The four steps are:
One, Pollutant Applicability
Two, Emissions Unit Applicability
Three, Identification of Potentially Sensitive Concerns,
and
Four, Selection of Alternative Control Strategies
5. The three Impact analyses are:
One, Economic Impacts
Two, Energy Impacts, and
Three, Environmental Impacts
6. The criteria for measuring alternative control strategies are
economic reasonableness and minimum undesirable impact
on the environment.
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
• Economic Impacts
• Energy Impacts
• Environmental Impacts
Alternative Control
Strategies
• economically reasonable
• minimal undesirable impacts
7. At the end of the last lesson, we had finished describing Steps
One and Two. They looked mostly at things inside the source.
Now we're going to look more outside the source itself, as we
go on to the remaining steps and the impact analyses.
land 2
3 and 4
8. Step Three is Identification of Potentially Sensitive Concerns.
This means lining up a list of areas that can be affected by
the source or modification. Estimation of the size of the
effects comes later.
3. Identification of Potentially
Sensitive Concerns
• Which areas could be
affected?
5-1
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Slide
Script
Selected Visuals
9. On the principle that "everything is connected to everything
else," there could be an endless list of things that the source
might affect. We need to narrow our list to concerns that are
sensitive to operation of this source in this area.
10. So our examination of potentially sensitive concerns is going to
be very case specific-
11. Looking at the local area, we need to ask: "what effects can
running this source have on local energy use, economics, and
environment?" Whenever possible, we want to select measures
of these effects that are quantifiable—that tell us how much
of an effect, not just "more" or "less."
12. All kinds of things could go on the potentially sensitive
concerns list. The trick is to keep the list down to a
manageable length, but count everything that's really
important. Things that might go on the list for a given area
could include:
—labor supply, skilled or unskilled,
— water availability and use, and
— availability of certain fuels.
13. At this point, we have a lot of data about the source and
about the local area. Now we need to do something with it.
That brings us to Step Four, Selection of Alternative Control
Strategies.
14. Of course, selecting control strategies is the meat of the BACT
analysis. This is where engineering knowledge of the source,
its various emissions units, and control techniques comes in.
But we're not concentrating—in this course —on how to select
appropriate control equipment.
• this source
• this area
• very case-specific
• local area
What effects can source have on:
• Energy
• Economics
• Environment
• labor supply
• water availability
and use
availability of
certain fuels
4. Selection of Alternative
Control Strategies
15. What we want to know is how the applicant—given engineer-
ing expertise—arrives at best available control technology.
And then, how the application supports the claim that the
chosen strategy is BACT.
5-2
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Slide
Script
Selected Visuals
16. The basic idea behind control strategy selection is that
alternative control technologies should be technically feasible.
In practice, technically feasible controls are those that have
been demonstrated to work. They have been tried and found
to function efficiently on emission units just like the ones
under study, or on similar units.
17. If the applicant plans to use control alternatives that haven't
been demonstrated as technically feasible, but that might be
more efficient and/or more economical than usual systems,
these are innovative alternatives. The Clean Air Act and the
regulations are set up to encourage use of innovative control
technology.
18. What we're doing here is narrowing the scope of the analysis,
trying to get a manageable set of alternatives to compare with
each other. To have a "yardstick" for these comparisons, we
need to set up a base case.
19. The base case is the control strategy that would normally be
applied to a source, if BACT were not required. The controls
normally applied might be called for by:
— other control regulations, State or Federal, or
— the company's own practices, if they're stricter than
what's required by non-PSD regulations.
20. With a base case laid out, the applicant can arrange
alternative control strategies by rank. The rank order will be
each strategy's control efficiency.
21. This sounds as though lining up control strategies will
automatically produce BACT. It won't. For one thing, there
are usually several pollutants to deal with. A control that
ranks high for, say, paniculate matter isn't likely to rank as
high for sulfur dioxide, for instance.
• technically feasible
• demonstrated to work
Base Case
Base Case
• normally used control strategy
• called for by:
• other regulations
• company's own practices
Applicant arranges
control strategies
by rank.
22. In addition, alternative control strategies still have to be
analyzed for their economic, energy, and environmental
impacts. So ranking control alternatives up from the base case
is an important step in BACT analysis, but not the whole
thing.
Environment
5-3
-------
Slide
Script
Selected Visuals
23. It if possible that control strategy selection could stop with
describing the base case. In some circumstances, the controls
routinely applied will turn out to be the best available. Of
course, the applicant will have to line up some strong
evidence to prove this in the application.
24. Most of the time, however, there will be several alternatives
for controlling regulated pollutants at the various emissions
units. Information on these alternatives has to be assembled so
that we're sure all reasonable possibilities are examined.
Sometimes routine
controls are the
best available.
25. There are four kinds of alternative strategies that can be
considered for any emissions unit. You won't always find one
of each kind for each pollutant at each emissions unit, of
course.
4 Kinds of
Alternative Strategies
26. The first —and most obvious—kind of control alternative is
existing technology. This means control methods actually used
on other units of the same type.
27. The second kind—transferable technology—is related to
existing technology. It includes control methods used on units
not exactly like the ones under analysis. These methods show
promise of working efficiently when applied to this source.
28. The third kind of control alternative is innovative technology.
As we mentioned earlier, this includes control techniques that
haven't been fully proven in routine use.
4 Kinds
• existing technology
4 Kinds
• existing technology
• transferable technology
4 Kinds
• existing technology
• transferable technology
• innovative technology
29. The fourth kind of control alternative is an important one not
to overlook. It is using a basic industrial process that is
inherently lower polluting.
4 Kinds
• existing technology
• transferable technology
• innovative technology
• inherentlvjowerjwllil^in
technology
30. An example is the dry precalcination process for
manufacturing cement. It has significantly lower nitrogen
oxide emissions than the alternative "wet" process.
Cement Manufacturing
5-4
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Slide
Script
Selected Visuals
31. In looking for various kinds of control alternatives, the
applicant has several places to look. The place that should
come first to mind is the general locality of the proposed
construction or modification. If BACT analyses have been
made on similar facilities, and have been approved, then the
earlier determinations are good guidance for a new analysis.
32. On a wider scale, EPA maintains a central "Clearinghouse" of
BACT determinations—along with Lowest Achievable
Emission Rate for nonattainment permits. Anyone putting
together a list of control alternatives should check the
BACT/LAER (lair) Clearinghouse Reports for similar cases.
33. All of this useful information is what we said it was earlier,
though—guidance. Since BACT is, by definition, determined
case-by-case, what was BACT on an emissions unit in Oshkosh
may not be on one just like it in Peoria.
EPA Clearinghouse
on
BACT/LAER
Determinations
Remember...
• Other determinations are only
guidance.
• BACT is always case-specific.
34. That gets us through the four steps of assembling the data for
the BACT Analysis. Remember, they were: Pollutant
Applicability, Emissions Unit Applicability, Identification of
Potentially Sensitive Concerns and Selection of Alternative
Control Strategies.
35. You should have noticed that a lot of work goes into these
steps. We only suggested what kind of work, not what the
details are. There's more work to be done now that the data's
assembled.
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
36. With a reasonable list of alternative control strategies lined
up, the applicant is ready to run three Impact Analyses on
the alternatives. These are for: Economic Impacts, Energy
Impacts, and Environmental Impacts.
37. This chart suggests how the impact analyses are set up. Don't
get the idea that there's some" official form like this somewhere
to fill out. You will see charts like it summarizing parts of
most applicants' BACT Analyses, of course. But also don't
forget that you- need a chart like this for each pollutant and
each emissions unit —or small group of units—in the analysis.
Analyses
• Economic Impacts
• Energy Impacts
• Environmental Impacts
COMPARISON OF
CONTROL ALTERNATIVES
5-5
-------
Slide
Script
Selected Visuals
38. The first impact analysis within the BACT Analysis is
economic. In the Economic Impacts Analysis, the applicant
makes an estimate of the approximate costs of different
emission control alternatives.
39. There is a body of widely accepted techniques for estimating
costs of engineering projects. These methods of engineering
economics are generally applied to the BACT Economic
Impacts Analysis.
Economic
Impacts Analysis
estimate of approximate costs
of different control alternatives
40. The costs considered in estimating economic impacts of
control alternatives are divided into capital costs and
operating costs.
41. The capital cost is the amount required to purchase and
install the permanent equipment required for the control
method. You can think of it as the "one-time" cost—but it
usually gets paid in installments over a long period.
• Capital Costs
• Operating Costs
Capital Costs
to purchase and
install permanent
equipment
42. The operating costs are the ones that keep occurring. They
pay for the labor, energy, and materials needed to keep the
control process operating. Operating costs include normal day-
to-day operations, routine maintenance, and some things you
might not think of right away, like insurance premiums.
Operating Costs
• keep occurring
• for labor, energy.
and material*
• normal daytoKiav
operation*/
maintenance/etc.
43. Remember that these control costs are being added up so that
different methods can be compared with one another. This
means that the costs have to be put in a format that allows
comparison. One thing that must be done is to put all the
costs on the same time basis.
44. Usually, all capital and operating costs are reduced to an
annual basis. For some operations, there may be a cycle that
makes more sense than the year. You have to use a combina-
tion of accounting methods and engineering principles based
on experience to fit the costs into one time period.
5-6
-------
Slide
Script
Selected Visuals
45. Another thing that has to be done to permit comparison of
alternatives is to break out total and incremental costs.
Costs
• Total
• Incremental
46. Total cost is easy to grasp. It's all of'the capital and operating
expenses for each emissions unit, for one regulated pollutant.
Total Cost
• _a!N:apltal and operating
expenses
• for eacl^emlssions unit
• for one regulated pollutant
47. Incremental costs measure how much is paid to reduce the
last ton—or pound—of emissions. Both total and incremental
costs can affect our judgement of what method produces more
control for a given economic impact.
48. With the various costs of control alternatives lined up on a
comparable basis, the economic impacts can be evaluated in
terms of three factors. They are:
— pollution-specific costs,
— additional product costs, and
— ability to secure financing.
49. It would be nice if costs assigned to each of these categories
could be measured against a fixed yardstick. Unfortunately,
there isn't one. However, there are ways of guiding
judgements and of justifying choices among alternatives.
Incremental Cost
• cost of reducing the last
Increment of emissions
Economic impacts
evaluated in terms of:
• Pollution-Specific Costs
• Additional Product Costs
• Ability to Secure Financing
50. In the area of pollution-specific costs, many studies have
been done on the dollar value of reducing a ton of emissions
of a specific pollutant. Most of these studies have been for
New Source Performance Standards, and are in the
Background Information Documents for the standards.
51. Studies used for pollution-specific cost appraisal will vary in
reliability and applicability to the case at hand.
Pollution-Specific Costs
• studies done on S value
• found In Background
Information Documents
Pollution-Specific Costs
• studies done on $ value
• found in Background
Information Documents
• vary In reliability and
applicability
52. The BACT Analysis should cite and justify the studies used to
develop pollution-specific costs.
BACT Analysis should
cite/justify studies used.
5-7
-------
Slide
Script
Selected Visuals
53. The "bottom line" of the pollution-specific cost appraisal will
be a comparison of estimated costs to control pollutant X with
generally accepted reasonable costs for control of X.
Cost Appraisal
Eirimatg
Sly ..........
lyll ml ll»K
R«««on«bl«
SII...K...I
• Hlll» .III <
ytilltMik I
nil > till, yl
54. The Economic Impacts Analysis looks at additional product
costs. These will be how much a control alternative adds to
the price of the plant's finished products.
Additional Product Costs
• how much a control alternative
jdds to the price of plant's
finished product
55. Additional product costs should be figured as a. percentage of
total manufacturing costs. This percentage can be used for
comparison with the costs of other firms in the same market.
If additional product costs put the applicant at a severe
competitive disadvantage, then this may justify preferring
another control option.
Additional Product Costs
• how much a control alternative
adds to the price of plant's
finished product
• percentage
56. The third item of the Economic Impacts Analysis considers
ability to secure financing. For most products, this is critical.
Dollars and cents will count on this item, but other things
will, too. The applicant will have to estimate how money
lenders would judge the firm's ability to pay back on time.
This can depend on control reliability, product markets,
money markets, and many other factors.
57. As you can see, the Economic Impacts Analysis takes into con-
sideration several different economic aspects. It adds up both
capital and operating costs of control alternatives. It lines
these costs up in terms of three factors, so the applicant can
judge the values affected. The three factors are:
— pollution-specific costs,
— additional product costs, and
— ability to secure financing.
58. The second impact analysis is for energy impacts. The form
of the Energy Impacts Analysis is a lot like the economic one,
but instead of dollars, here we're concerned with units of
energy consumption. The amounts posted to the account for •
each control alternative will be in Btu's, kilowatt-hours, or the
like.
Ability to Secure Financing
• estimate of how money lenders
would judge firm's ability
to pay back
Economic impacts
evaluated in terms of:
• Pollution-Specific Costs
• Additional Product Costs
• Ability to Secure Financing
Energy Impacts
• units of energy consumption
• BTUs/kWh
5-8
-------
Slide
Script
Selected Visuals
59. Only the direct energy impacts of a control alternative should
be figured in. These energy requirements should be figured on
a total and incremental —per ton of reduction—basis, as for
money costs.
• direct energy impacts
• total
• incremented
60. Some forms of energy are easier than others to get in a given
region. This means the Energy Impacts Analysis should look
at what forms of energy a control alternative can use, and
how much of those the region has available. For some
applications, it will help to convert energy requirements to
barrels of oil or tons of coal.
• What forms
of energy can
be used?
• How much
available
In the region?
61. We wrap up the impact analysis phase of the BACT Analysis
with the Environmental Impacts Analysis. As we said before,
this sounds like we're getting ahead of ourselves. The complete
application will include detailed Air Quality and Additional
Impacts Analyses. But right now we're looking at choices
among several alternative control strategies. They have to be
rated on the degree of their effect on the environment.
62. Detailed environmental assessment of the alternative chosen in
the BACT Analysis will come later. One important aspect of
that work will be air quality modeling. But an important part
of our BACT Environmental Impacts Analysis is brief,
comparative modeling of air quality effects of control
alternatives.
Environmental
Impacts
• degree of effect on
environment
• brief, comparative
modeling of effects
63. For each control alternative, we want to find the maximum
ground-level concentrations of pollutants emitted. We also
want to know the size of the area for which the pollutant
impact is significant. To simplify the problem, we normally
use "worst-case" meteorology in the model.
.64. This can get complicated, but look at a simple example. For a
boiler, the choice is between low-sulfur fuel and a flue-gas
desulfurization —FGD — scrubber. The FGD system produces
much lower emissions. But the FGD stack plume is relatively
cold —it reaches the ground sooner. The result is only a tiny
difference in maximum ground-level concentrations of SO2.
For each control alternative:
• maximum ground-level concentrations
• size of area of significant impact
* uae "worst-case" meteorology
for modeling
AIR QUALITY COMPARISON
Impact Impact
Control Emissions (fjg / m') Area (km)
Low
Sulfur
IOOO
ID/hour
FGD 400
Scrubber id/hour
5-9
-------
Slide
Script
Selected Visuals
65. The big difference between the two controls is the size of the
impact area. For< low-sulfur fuel, the area of significant
impact is 28 kilometers in radius. For the scrubber, the area
has a 10 kilometer radius. That's a significantly smaller real
impact, so the scrubber wins this comparison.
Low-Sulfur Fuel
66. There are other environmental impacts that need to be
accounted for. That scrubber we just discussed will produce
sludge. Disposing of the sludge can affect water quality, land
use, or both.
67. Just about any control alternative will have impacts on the
environment—-air, water, land—besides its emission reduction
effects. These impacts have to be estimated, turned into hard
numbers wherever possible, and used to rate control
alternatives.
68. That brings us to the end of the outline of the BACT .
Analysis process. What you have seen is a description of how
the applicant arranges data for the analysis, and what kinds of
analysis get done. The frustrating part of an overview like this
is that there's no one right answer, no overall BACT score.
•IT
69. The hard work in the BACT analysis is taking all the data
combined into control alternatives and comparing them with
one another.
AJtCTXt*.
3
70. The comparisons are made through the economic, energy,
and environmental impact analyses. Control alternatives can
score high on one analysis and low on another. Many com-
binations can be tried for even a medium-size source. The
applicant has to judge what is better or worse. And then
justify the judgement of what is BACT so the reviewing
agency will agree.
Ill
5-10
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Slide
Script
Selected Visuals
71. So we started Best Available Control
Technology—BACT —Analysis with four steps of lining up
data:
— pollutant applicability,
— emissions unit applicability,
— identification of potentially sensitive concerns, and,
— selection of alternative control strategies.
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
72. With the data assembled in alternative control strategies, the
applicant is ready to run three analyses:
—economic impacts,
— energy impacts, and
— environmental impacts.
Analyses
Economic Impacts
Energy Impacts
Environmental Impacts
73. By comparing the results of the analyses, pollutant by
pollutant, for all the control alternatives, the applicant arrives
at a set of controls for the whole source or modification. This
is what goes into the application as BACT.
o
74. To get an idea of how the BACT analysis might be done on a
simple case, briefly go over the example in the PSD Workshop
Manual. The example is on pages l-B-14 through 37.
75. The emission rates and other data developed in the BACT
analysis also go on to be the basis of the detailed analyses to
follow. These are the Air Quality and Additional Impacts
analyses. We will go on to them next.
PSD Workshop
Manual
• pages l-B-14 through 37
Air Quality Impacts
Analysis
Additional Impacts
Analysis
76. (Credit slide)
77. (Northrop slide)
BACT Analysis
In in* Application: II
Grlffhlci: L«lt* Whll*
PhMOfrapfc*, Audio: D.w.4 Churchill
r7«t.(l«; flick P.lnwt
Northrop Services. Inc.
EPA Contract No. 68-02-3573
78. (Northrop slide)
Btu«td In put on th«:
1980 PSD Workshops
prepared (or the
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
bv
TRW. Inc.. EjmraamtmiAl Eaqinmin? OltUion
Northrop 5*rvic*«. Inc
undu
EPA Conn-Mi .No, 68-02-3174
5-11
-------
Slide Script Selected Visuals
79. (NET slide) Northrop
Environmental
Training
5-12 '
-------
Slide
1. (Focus)
2-5. (Introductory slides)
SI:453
Lesson 6
Air Quality Analysis: I
Script
Selected Visuals
FOCUS
6. This is Lesson 6, "Air Quality Analysis, Part One."
7. In the lessons we just finished, we talked about determining
whether PSD review had to be done for a new source or
modification.
6-1
-------
Slide
Script
Selected Visuals
8. We saw how the applicant decides which pollutants the
review has to deal with.
9. Then we went on to see how the applicant arrives at a set of
emission limits which will reflect application of Best
Available Control Technology — BACT.
Emission Limits
Reflecting BACT
10. All of this analysis so far has produced a large volume of data
about the new source or modification itself. Some of the
source's impacts have been looked at, but mostly to feed back
and adjust the source control strategy.
11. Now the application has become more solid. It describes new
emission units with specific control devices—or
processes—emitting specific amounts of pollutants per hour.
If there are stacks, the stack height, exhaust gas velocity and
temperature, and so on, are described in the application.
12. It is time to do something with all the data. The "something"
has to do with the purposes of PSD programs we started out
with. The Clean Air Act —and EPA's regulations under
it—say that there are two ambient air quality measurements
to be protected.
13. First—and most general—the new construction must not result
in any violation of a National Ambient Air Quality Standard.
We are concerned with these standards—NAAQS —for six
criteria pollutants.
14. They are: total suspended paniculate matter, sulfur dioxide,
carbon monoxide, nitrogen dioxide, ozone, and lead.
Air Quality Analysis
Must demonstrate:
• no NAAQS violation
Criteria Pollutants
• TSP • NC>2
• S02 . O3
• CO • Pb
6-2
-------
Slide
Script
Selected Visuals
15. Remember that for each of these criteria pollutants, there can
be a primary —health —standard and a
secondary—welfare—standard.
Primary
Standards
Secondary
Standards
16. Every standard has an averaging time over which
measurements are taken. Any one pollutant can have both a
primary and secondary standard for each of several averaging
times.
ALLOWABLE CONCENTRATIONS (yg/m1)
PoUutom
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onnuol
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annum
UJnur
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Controlling
NAAQS
79
190
90
369
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aouo
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19
37
20
91
911
17. The second requirement is that the new construction not cause
a violation of an allowable increment. We mentioned in the
first lesson that an increment is an increase in an ambient air
quality concentration.
Air Quality Analysis
Must demonstrate:
• no NAAQS violation
• no violation of allowable
increments
18. The Clean Air Act gives allowable increments for only total
suspended paniculate matter —TSP —and sulfur dioxide —
SO2. Besides these basic requirements—to protect the ambient
standards for all criteria pollutants, and to protect
increments for TSP and SO2 —there is a more general
requirement.
19. This is to examine the effect on air quality of emissions of
any pollutant regulated under the Clean Air Act.
20. The idea of air quality analysis centers on making decisions
based on concentrations of pollutants in the ambient air.
21. We may be interested in standards reflecting the whole
amount of pollutants to which people or things may be
exposed. Or in increments, which are changes from what
existed before. We can look at different pollutants, with
concentrations averaged over different periods of time.
Increments for only:
•TSP
• SO2
General Requirement
• to examine the effect on
air quality of emissions of
any pollutant regulated
by the CAA
Decisions
• Standards
• Increments
6-3
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Slide
Script
Selected Visuals
22.
23.
24.
25.
However, to make decisions based on concentration numbers,
we have to get the numbers somehow. There are two basic
ways to come up with the numbers—measure or estimate. We
may have measurements for the past, and we can go out and
do them for present. But if we want future concentrations to
work on now, we have to estimate.
We estimate ambient air quality by using dispersion models.
EPA provides dispersion models as an accepted method for
predicting future air quality.
Both air quality monitoring and air quality modeling are
highly technical arts. The PSD regulations lay down certain
modeling and monitoring requirements for air quality
analysis. They don't,'however—in fact, they can't —tell the
applicant how to do a step-by-step analysis of a particular
proposal. Each PSD appliction is a different case.
This does not mean we can't lay down a general framework
for air quality analysis, based on the regulations and
experience. But, since a program of modeling and monitoring
can involve many hours and dollars, the applicant needs to be
careful.
Estimate
• dispersion
models
26. A company planning to build a new major source in a remote
area may have a fairly simple, straightforward air quality
analysis situation.
27. One planning a major modification in an industrialized area is
likely to find things more complicated. In either case, the
applicant should get the reviewing agency to agree on an air
quality analysis plan before spending a lot of time and money.
6-4
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Script
Selected Visuals
28. Even after giving you all these cautions about air quality
analysis being complex and case-by-case, there's still a lot that
can be said about the process in general. We will describe five
basic steps and three phases of the air quality analysis.
29. The purpose of organizing the analysis into these steps and
phases is to have a systematic approach that will save as much
time and money as possible.
Air Quality Analysis
• 5 Basic Steps
• 3 Phases
Systematic Approach
• saves time
• saves money
30. The five basic steps that we'll discuss further are:
First. Define the impact area. This is the area affected by the
new source or modification for each pollutant analyzed.
31. Second. Establish inventory of other sources. For each
pollutant analyzed, you need a quantitative listing of all
sources adding to its concentration in the impact area.
Five Steps of
Air Quality Analysis
Define impact area
Five Steps of
Air Quality Analysis
Define Impact area
Establish Inventory of other sources
32. Third. Determine existing ambient concentrations —for each
pollutant in the analysis.
Five Steps of
Air Quality'Analysis
1 Define impact area
1 Establish Invemorv of other sources
DeterraltM existing ambient
concentrations
33. Fourth. Perform screening analysis. That is, a fast and
inexpensive modeling using very conservative assumptions. If
this shows no problems, the next step can be much simpler.
Five Steps of
Air Quality Analysis
Define impact area
Establish inventory of other sources
Determine existing ambient
concentrations
Perform screening analysis
34. And fifth. Determine projected air quality level. With an air
quality dispersion model, project ambient concentrations of
each pollutant analyzed.
Five Steps of
Air Quality Analysis
Define impact area
Establish Inventory of other sources
Determine existing ambient
concentrations
Perform screening analysis
Determine projected air quality level
35. To apply these steps of analysis, we divide the whole task of
analysis into three phases. It depends on what pollutants we're
looking at whether—and how extensively—any one phase
applies. The phases don't separate out neatly, because doing
some of the steps for one phase will overlap with another.
Three
Interrelated
Phases
6-5
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Script
Selected Visuals
36. The three interrelated phases of air quality analysis are:
One. Analyze increment consumption. How much of the
available increment for TSP and SO2 will be used by the new
source or modification?
37. Two. Determine existing air quality. What are present values
for all pollutants subject to the analysis? This can involve the
use of ambient air monitoring or modeling where ambient
data are not available.
Air Quality Analysis
I 1 1
• analyze [
increment 1
consumption
Air Quality Analysis
I 1 1
1 determine
existing
atr quality
38. And three. Project future air quality. This will involve
dispersion modeling based on data from everything that went
before. The air quality will have to be predicted at least for
all the criteria pollutants involved in the analysis. The
reviewing authority may decide that concentrations of some
other pollutants have to be projected.
39. Before we go on to some of the details of air quality analysis,
we need to examine a few more terms. These have to do with
baseline concentrations and baseline areas.
Air Quality Analysis
• protect I
future I
air quality I
• Baseline Concentrations
• Baseline Areas
40. We have to deal with baselines because PSD is concerned with
significant change. Change has to be measured from
conditions at a certain point in time for a specific area.
Change
Baseline
41. Complications arise because things start from different points
for different areas with several pollutants. Scarcity of data can
add to the complexity.
42. When we talk about "significant deterioration" of air quality,
we mean an increase in the ambient concentration of some
pollutant. But an increase from what? The baseline
concentration is the ambient concentration —of TSP or
SOZ, remember —over which increment is figured for each of
these two pollutants.
43. Baseline, increment, and total ambient concentrations are
related by a simple-looking equation. In principle, it is:
increment plus baseline equals total concentration. If you
know any two, you can get the third by addition or subtrac-
tion. However, in actual practice this is almost never the case.
6-6
Conc.ntr.tKx, / Theoretical
Ambient
SO2orTSP
Concentration
Appnalmata Total Air Quality
-------
Slide
Script
Selected Visuals
44. What makes things more complicated is the special definitions
of what counts for baseline concentration and increment
consumption. Neither one is directly measured.
45. Baseline concentration is an adjusted ambient concentration.
It is the adjusted ambient concentration of TSP or SO2 in the
PSD area at a baseline date.
' Baseline Concentration
1 Increment Consumption
Baseline Concentration
• ambient concentration
• of TSP or SO,
• at the baseline date
46. That date is the first date after August 7, 1977 when the first
complete PSD application is submitted for a major source or
major modification in the area.
Baseline Date
• after August 7. 1977
• date of first complete PSD
application
47. To get the baseline concentration from existing ambient
monitoring data, adjustments have to be made. To adjust
concentration measurements, you have to do air quality
modeling—more or less sophisticated—to apply effects of
emission changes to what was measured. If ambient
measurements already reflect these changes, of course, they
aren't counted again.
48. As we go over these adjustments, you'll see that they're related
to the adding up —netting—of emissions. But keep clearly in
mind that what we're interested in now is the effect of emis-
sion changes on ambient concentrations.
49. The baseline concentration has to be adjusted for two kinds of
emission changes. The first kind is actual emission changes
that result from construction at major stationary sources. If
this construction commenced after January 6, 1975, then the
emissions consume the increment.
Emission
Changes
Actual
Construction
Commenced
• «fMr 1/6/73 and
50. The second kind of emission changes figured into baseline
concentration are projected changes. They are the allowable
emissions from major sources that commenced construction
before January 6, 1975.
Emission
Changes
Pro|ected
> Construction
Commenced
• Mora 1/6/73
6-7
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Slide
Script
Selected Visuals
51. The baseline concentration gives us a foundation for building
increment consumption. The increment—or increase—in
TSP and SO2 concentrations results from different kinds of
emissions changes. The basic idea is that what doesn't count
for adjusting baseline does count toward using up increment.
52. So, the amount of increment still available is changed by
emissions increases or decreases that result from construction
at major sources. These changes count if they occur after
January 6, 1975.
Allowabl*
PSD Incnmcnt
• Amount of
Increment
Still Available
53. Also, emissions increases and decreases from all stationary
sources increase or decrease the amount of increment
available, if the emissions changes take place after the
baseline date.
54. The basic intent of the Clean Air Act is to apply actual
increases or decreases in emissions to determine how much
increment remains available. This isn't always possible,
however. Where actual operating data just isn't available,
allowable emission rates may be used in increment
calculations.
55. We've already said that total ambient concentration is the
sum of baseline and increment concentrations. By addition or
subtraction, you can get any one from the other two. But
often, it is hard to get exact numbers for one or more of these
values.
C=
Available Increment
actual Increases/decreases
allowable emission rates
Ambient SO2 or TSP
Concentration
Total Air Quality
56. What the applicant is really interested in—and what the
reviewing agency is checking for—is whether new emissions
will result in either of two kinds of violation. Emissions from
the proposed source or modification must not cause a violation
of the allowable increment. They must also not result in a
violation of any National Ambient Air Quality Standard.
J?? Violation??
6-8
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Script
Selected Visuals
57. Very often, it's possible to check for NAAQS and allowable
increment violations without knowing the exact baseline
concentration.
PSD Increment
BaMlln*
Concentration
PSD Increment
Bueilne
Concentration
58. That brings us to the question of what these limits—the
ambient standards and allowable increments—are.
What are the limits?
59. Remember, for the moment we're talking only about
particulate matter and sulfur dioxide.
TSP,SO2
60. The National Ambient Air Quality Standards are set by EPA
for each of the criteria pollutants. They can be primary or
secondary, and be for different averaging times.
NAAQS
• set by EPA
• for criteria pollutants
• primary or secondary
• for different averaging times
61. As an absolute limit on deterioration of ambient air quality,
we're interested in the lowest ambient standard, whether it's
primary or secondary. For brevity, we'll refer to that lowest
concentration as the "controlling" NAAQS.
"Controlling" NAAQS
• lowest ambient standard
• primary or secondary
62. This table gives a quick summary of typical limiting concen-
trations. On the left, we have the "controlling"
NAAQS —whether primary or secondary—for TSP and SO2
for different averaging times. On the right, we've picked the
Class II increments as the most usual limits on increases in
ambient concentrations.
ALLOWABLE CONCENTRATIONS (|jg/nv>)
Controlling Qou H
Pollutant Tim Period NAAQJ
SO,
73
150
30
Mi
1300
19
07
20
91
312
63. Remember that we said that every PSD area in the country is
classified as Class One, Two, or Three. There are different
allowable increments for each PSD Class.
ALLOWABLE PSD INCREMENTS annual
24-hour
Claul
3
10
2
3
23
daull
19
37
20
91
312
COM III
07
73
40
in
700
64. As you can see, the smallest allowable increases are set for
Class One areas. These areas are typically national or
international parks, wilderness areas, and other areas of
natural or scenic value.
ALLOWABLE PSD INCREMENTS (M9/ma)
Pollutant Tim* Period
annual
24-hour
SO,
• annual
• 24-hour
• 3-hour
Qau II Clou 111
19
37
20
91
312
37
73
6-9
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Slide
Script
Selected Visuals
65. The Clean Air Act automatically put into Class Two those
areas that weren't on the mandatory Class One list. As you
can see, Class Two areas can accept considerably larger
increases than can Class One.
ALLOWAOLE PSD INCREMENTS )
Pollutant TlnwPwtod dan I dan I
SO,
• onnuol
• 24-hour
• 3-hour
i
(0
1
S
23
10
37
20
91
67. It's very important to remember, however, that new emissions
must not take the area over any National Ambient Air
Quality Standard.
NAAQS = 365
ISO, 24-hr.)
68. Let's look at what the dual limitations of allowable increment
and NAAQS mean in one simple case. We'll consider sulfur
dioxide limits in a Class Two PSD area.
Dual Limitations
Allowable Increment
NAAQS
69. First, suppose that the baseline concentration is 70
micrograms per cubic meter, annual average, for SO2. The
allowable annual increment for SO2 in a Class Two area is 20
micrograms per cubic meter. 70 plus 20 gives us 90. Does that
mean that we can add enough emissions to take the projected
annual ambient SO2 reading to 90 micrograms per cubic
meter? No. We have an "effective cap" at the primary
NAAQS of 80 micrograms per cubic meter. Projected annual
concentrations can't go past the controlling NAAQS.
70. Now, suppose the baseline for the same area is computed at
40 micrograms of SO2 per cubic meter, annual average. This
time, an increase of the allowable increment —20 —gives us an
SO2 concentration of 60 micrograms per cubic meter. This 60
is the "effective cap" in this case. The space between that cap
and the NAAQS is the part of the "air resource" that the
Clean Air Act is protecting from significant deterioration.
Annual SO^ Concentration
Enacnin Cap.
Allowable
PSD I
Cooccntratlon
•SOug/m'
6-10
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Slide
Script
Selected Visuals
71. The last item that we're going to discuss by way of
preliminary, before we start outlining the Air Quality Impacts
Review process, is baseline area. We were taking it for
granted, when we talked about baseline concentration and
increments, that we knew what area these concentrations were
measured or modeled over.
72. What happens when the first source after August 7, 1977
makes a complete PSD application is that it helps define the
baseline area, as well as set the baseline date.
Baseline Area
PSD
Application
helpst
define
73. The concept of baseline area starts out fairly simple. First, the
baseline area is mtrostate—it doesn't cross State lines. Second,
it's made up only of areas designated attainment or
unclassifiable. Usually, these are smaller than whole Air
Quality Control Regions.
74. Third—and this introduces some complications—the baseline
area is where the proposed source or modification is located,
or will have a significant impact.
Basel!
Ares
e
• • intrastatp
• consists of
attainment or
• location of
proposed source
area of significant
Impact
75. For this purpose, a significant impact is a concentration
increase of at least one microgram per cubic meter, annual
average.
76. To illustrate how a source creates a baseline area, let's take a
simple example. We'll look at a 5-county area at the western
end of an imaginary State. We'll talk only about SO2 status
for this example.
77. This State has —until now —designated its attainment and
nonattainment areas on a county-by-county basis. All five
western counties are PSD areas. Counties A, C, and D are
attainment, and B and Ł are unclassifiable.
Significant Impact
• concentration increase of
at least 1 ua/m3. annual
average
N \ si... li..
6-11
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Script
Selected Visuals
78. On October 6, 1978, a new major source files a complete
PSD application to the permit reviewing agency. The
application proposes construction in County C, with
significant sulfur dioxide emissions. Since County C is a PSD
area—attainment—the baseline date is triggered everywhere in
County C. But other areas also come into the baseline area.
79. Air quality dispersion modeling shows that the proposed
source will have a significant impact—at least one microgram
per cubic meter—inside the line shown on the map. This
irregular area overlaps Counties A and B, and the
neighboring State on the north.
80. The definition says the baseline area (shown in blue) is
tninzstate, so this application does not trigger the baseline
date in the State to the north. The impact of the source may
have to be accounted for, though. We'll deal with that ques-
tion later.
81. Counties A and B become part of the same baseline area as
County C. Baseline concentrations, emission changes, and
increment consumption for all three will be figured from
October 6, 1978.
Baseline Area
f \ —- Am-* SO,
N \ S*»M UlM S X1»P*«» *f«»
Baseline Area
Baseline Area
a
bMO«i
nmd
10/4/78
82. This is a good time to recall something we said in passing
earlier. We are going to count increment consumption in this
baseline area from the baseline date for, certain kinds of
emission changes.
83. These changes will include major source construction and
modification commenced after January 6, 1975, plus all other
emission changes that occurred since the baseline date.
Count increment consumption:
• in baseline area
• from baseline date
• for certain changes
major source
construction/modification
plus all other emission
changes since baseline date
6-12
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Script
Selected Visuals
84. This business of different starting dates and affected areas,
with different classes of emission changes, can get
complicated. But in real situations, the agency can set up a
tracking system which will account for what changes count
against what increments, and where.
85. Finally, look at the western part of County A. Some of it is
not inside the area where the proposed new source has a
significant SO2 impact. If the State wanted to—and there
might be good reason to want to —it could redraw the
"attainment-nonattainment" area boundaries. Our map shows
one simple change in County A. Its western half has been
made a new, separate, designated area.
Baseline Area
'. \ X—V>"~' S0«
N \ S««t« Ltn* f \liwciAtM
86. This is a new PSD area. It would probably be attainment. If
reliable air quality data had been available for only the
eastern part of the county, the new area might be
unclassifiable. At any rate, it is outside of the significance
area for the proposed new source. This means the baseline
date has not been triggered for this new area, for SOZ. It will
go along under ^rebaseline rules until a complete PSD
application triggers its baseline.
87. As usual for the topic of PSD, carefully setting out
preliminary ideas has taken a lot of explaining. We began this
lesson by talking about what the PSD program has to
protect —the National Ambient Air Quality Standards and the
allowable increments for TSP and SO2.
88. Then we went on to break the Air Quality Analysis process
into five basic steps and three phases.
PSD program protects:
• NAAQS
• allowable increments for
TSP and S02
Air Quality Analysis
• 5 Steps
• 3 Phases
89. The five steps are:
— Define the impact area,
— Establish inventory of other sources,
— Determine existing ambient concentrations,
— Perform screening analysis, and
— Determine projected air quality.
Five Steps of
Air Quality Analysis
Define Impact area
Establish Inventory of other sources
Determine existing ambient
concentrations
Perform screening analysis
Determine projected air quality level
6-13
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Script
Selected Visuals
90. The three overlapping phases are:
— Analyze increment consumption,
— Determine existing air quality, and
— Determine projected future air quality.
3 Phases
(overlapping)
• Analyze increment
coraumptjon
• Determine existing air quality
• Determine projected future
air quality
91. Then we talked about baseline concentration and how it
relates to the National Ambient Air Quality Standard and the
allowable increment.
Baseline Concentration
92. We finished this lesson with an explanation of the baseline
area. It is the area where the baseline date is triggered—for
one or more pollutants—by a complete PSD application. This
baseline area is basically administrative—it's where certain
rules for tracking emission changes and increments apply. Be
careful to keep it separate in your mind from the impact area
that we'll discuss first in the next lesson.
93. In the next lesson, we'll outline how the steps and phases of
the Air Quality Analysis are applied by the applicant in a
PSD application.
Next...
How steps/phases are
applied in a PSD
application.
94. (Credit slide)
All Qiwlltv AittlvHl: I
ZTttZ
95. (Northrop slide)
96. (Northrop slide)
Developed ind
produced by:
Northrop Services. Inc.
EPA Contract No. 68-02-3573
Baaed In put on tfa«:
1980 PSD Workshops
prepared for the
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
TRW. Inc.. Emrironmmul En*in*rring Dltltlon
ulth ihv •tUtttnc* of
Nonhrop imricn. lie
EPA Conflict ,\o. 68-02-3174
97. (NET slide)
Northrop
Environmental
Training
6-14
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Slide
1. (Focus)
2-5. (Introductory slides)
SI:453
Lesson 7
Air Quality Analysis: II
Script
Selected Visuals
FOCUS
6. This is Lesson Seven, "Air Quality Analysis, Part Two."
7. In the previous lesson, we laid out the basic ideas involved in
performing the Air Quality Analysis required in a PSD
application. Now we are going to outline the steps which
make up the analysis itself.
Air Quality
Analysis
7-1
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Script
Selected Visuals
8. The emphasis here is on outline, because the process is long,
involved, and potentially expensive. Air Quality Analysis may
involve designing, building, and operating an air quality
monitoring network. It usually involves extensive data
gathering, planning for dispersion modeling, and running
computer dispersion models at one or more levels of
complexity.
Air Quality Analysis
Maybe
• deafening, building.
and operating a
monitoring network
Usually
• d*U gathering
• lpg/mj
Then:
baseline date triggered
More than one...
• pollutant
• averaging time
Is there significant Impact?
7-2
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Slide
Script
Selected Visuals
16. What we mean by significant impacts for different pollutants
and averaging times is easiest to see in a table. For the
pollutants listed, you can see that EPA has assigned a
significance level for various averaging times. These times are
those for which a national ambient standard is set.
Significant Impacts Uo/m3)
Averaging Period
Pollutant Annual 24-hour 8*hour 3-hour t-hour
TSP 1 5 - - -
SO, 1 5 - 25 -
NO, 1 - - - -
CO — — 500 — 2000
17. The applicant gets the data on concentrations of these
pollutants from dispersion modeling. An EPA recommended
mathematical model is run, using the proposed emissions, for
each of the averaging times that applies to each pollutant.
Dispersion Modeling
using p
emission*
for each averaging
tune
for each pollutant
18. This gives an outline —usually irregular —of the area where
source emissions produce at least the significant-impact levels
of ambient concentration.
19. To simplify the rest of the Air Quality Analysis process, we
make the impact area more regular. This is done by taking
the source as a center, and drawing a circle around it with a
radius equal to the greatest distance of a significant impact.
Impact Area
Impact Area
20. This still leaves us with a different circle for each pollutant
and averaging time. When the differences are not very great,
the applicant will usually consolidate impact areas. This is
done by taking the largest of the impact-area circles that are
close to the same size, and using it as the basis for emission
inventory, modeling, monitoring, and so on.
21. We mentioned the use of dispersion modeling briefly earlier,
under BACT Analysis. But now we're talking about beginning
an extended and intensive modeling effort.
22. Before undertaking such an effort, the applicant needs to
make a plan and get the reviewing agency's agreement on it.
• extended, intensive
modeling
7-S
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Script
Selected Visuals
23. As a minimum, for the modeling that determines the impact
area, the applicant should get the reviewing agency to concur
on three things:
—selection of an appropriate dispersion model,
—use of meteorological data that are adequate and
representative, and
—which techniques and assumptions will be used in the
analysis.
24. However, determining the impact area is only one part of the
modeling effort that goes into the Air Quality Analysis. It
should be consistent with the rest of the dispersion modeling
activity. This will save effort, time, and money, and avoid
later confusion.
Reviewing agency must agree on..
• dispersion model
* meteorological data
• techniques/assumptions
IrapKtArn
Determination
25.
The best thing for the applicant to do before going ahead
with any detailed dispersion modeling is to draw up a
modeling plan or protocol, and get the reviewing agency to
agree on it.
26.
The modeling plan should be based on guidance in the latest
versions of three EPA publications:
— Guideline (revised) on Air Quality Models,
— Regional Workshops on Air Quality Modeling: A
Summary Report, and
— Volume Ten of the Guidelines for Air Quality
Maintenance Planning and Analysis Series entitled
Procedures for Evaluating Air Quality Impact of
New Stationary Sources.
27. Published guidance can't cover the different circumstances of
every new source or modification proposal. It is very
important that the applicant make clear in the dispersion
modeling plan the things that will affect how modeling will be
applied in this proposal.
7-4
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Script
Selected Visuals
28. The modeling plan should include at least the following items:
— the nature of the proposed construction,
— the pollutants to be modeled,
— the site characteristics—such as buildings,
—the topography within fifty kilometers of the site,
— the dispersion models proposed for use, and the
meteorological data to be used with them,
— the options to be used within the general dispersion
models, and
— the emissions data to be "plugged into" the dispersion
models.
• Proposed Construction
• Pollutants
• Site Characteristics
•Topography
• Dispersion Models and
Meteorological Data
•Options
• Emissions Data
29. On that last item, let's turn our attention back to impact area
determination, and finish it up. There are two things to
remember about the emission data from the proposed
construction used to determine the impact area. They are:
which emissions are included, and what rate should be used.
Emissions Data
• Which emissions?
• What rate?
30. The impact area determination must be based on all direct
emissions from the new source or modification. These include
stack emissions and quantifiable fugitive emissions. But
temporary emissions—like those from construction
activity—do not need to be included.
31. The emission rate used in impact area determination should
be the "worst case." That will usually be the maximum rate.
But the way the source operates —and things like stack velocity
or temperature, and stack height—might produce higher
concentrations at lower emission rates. An experienced
modeler can usually check for suspicious spots in a "worst
case" situation with calculations that can be done quickly by
hand.
Which emissions?
• all direct emissions
• stack
• fugitive
• no temporary emissions
What rate?
• "worst case" (usually
the maximum)
32. Meteorological data will be used in the preliminary modeling
for setting the impact area and in the later, more detailed
modeling of the Air Quality Analysis itself.
33. The data used should be both representative and typical.
Meteorological Data
• representative
• typical
7-5
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Script
Selected Visuals
34. Representative means the meteorological data should
represent the weather at or near the source. Typical means
the data should cover a period of time when conditions are
"normal" for the area—not a drought or a deluge, not a "dust
bowl" year, for instance.
35. The actual measured meteorological data should come from
one of two reliable sources, either:
—site-specific meteorological monitoring, or
— the National Weather Service station closest to the site.
Meteorological data
should come from...
site-specific monitoring
nearby NWS station
36. For on-site data, the applicant has to show that the
meteorological data they have gathered are for one year prior
to receipt of application, unless the reviewing authority deter-
mines that a shorter period is adequate.
Site-Specific Monitoring Data
1982-
• one year
(or determined period)
37. If the data are from a nearby representative National Weather
Service station, five years of data will usually be required.
Site-Specific Monitoring Data
• five years
38. That gets us through the outline of the first step in Air
Quality Analysis —defining the impact area. You should notice
things about this step that we mentioned earlier.
Impact Area
ImiwctAiu
39. The process is fairly complicated. What will happen for any
given proposal depends very much on the facts of that case.
The applicant may find no significant impacts for some
pollutants or averaging tunes. They may come up with
different areas for several different pollutants and times.
40. Things done for impact area determination overlap with other
steps. The modeling plan will cover screening analysis, air
quality projection, and possibly existing air quality. The
meteorological data will also apply to these other steps.
7-6
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Script
Selected Visuals
41. The impact area itself is basic to the remaining steps of Air
Quality Analysis. It is primarily for the impact area that the
emission inventory is assembled, and air quality is measured or
projected.
Emission
Inventory
Air Quality
42. The second step in Air Quality Analysis is to establish an
inventory of other pollutant sources.
43. The question immediately comes to mind— What other
sources? Where? For what pollutants? Somehow, the job of
emission inventory has to be kept to a reasonable size, so it
can be done adequately in the time available for a PSD
application.
44. Once again, the principle is to concentrate on things that
make a difference. The answer to the question, "what
pollutants?" is fairly straightforward. The inventory will cover
those criteria pollutants that will have significant impacts. It
may have to include non-criteria pollutants if there are —or
could be —high concentrations of them, threatening public
health or welfare.
2. Establish inventory of
other pollutant sources
• What other sources?
• Where?
• What pollutants?
Pb
O,
CO
TSP
S02
NO,
• criteria
pollutants
that have
significant
Impacts
45. This again involves preliminary dispersion modeling in the
process —mostly the modeling done to determine the impact
area. Generally, if this modeling shows no significant impact
from a criteria pollutant, that pollutant can be dropped from
emissions inventory and other analysis requirements.
46. However, there's an important exception to this dropping of
criteria pollutants from inventory and analysis. If the proposed
source or modification is located near a Class One area, a full
analysis may have to be made for any pollutant with more
than a one microgram per cubic meter impact on the Class
One area. This one-microgram impact is for a short averaging
time—twenty-four hours. That makes it a pretty sensitive
"trigger" for expanded review.
47. After deciding which pollutants to inventory, we still have
questions of where, what sources, and how. To help decide
these questions, we break the overall emissions inventory into
three types.
3 Types of Inventories
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48. The size and nature of each type of emissions inventory will
depend on the particular situation under study. The three
types of inventory are:
—increment-consuming emissions of particulate matter
and sulfur dioxide,
3 Types of Inventories
King emluloiu of TSP
49. —all existing emissions that affect air quality in the
impact area, and
3 Types of Inventories
ilng «nlMiofM of TSP
•ff«cdng air quality
•ndSO,
> nlsHitg.
In Impact araa
50. —any emissions from emission units that have permits,
but aren't operating yet, if they will affect impact-area
air quality.
3 Types of Inventories
• increnwnt-consuintna emlaaloiM of TSP
and SO,
• muting tmlulofli affactlng air quality
In Impact area
• .emlMlona from units with parmlti
51. We will discuss the requirements for the increment-consuming
inventory in a little more detail than the other two. All
emission inventories have some features in common. The most
important are identifying emissions units and getting
emission rates for them, for each pollutant covered.
52. Doing an increment-consuming inventory assumes that we've
reached the point where an air quality analysis is needed for
TSP or SOZ—or both. It also assumes that there is a signifi-
cant impact for one or both of them.
Common Features
• identification of emissions
units
• getting emission rates
Increment-Consuming
Inventory
AQ analysis needed for TSP
andSOj
significant impact
53. The increment-consuming inventory should include all
particulate matter and sulfur dioxide emissions, within the
impact area, that can consume increment.
54. It should also include emissions outside the impact area that
may have a significant impact within the area.
TSP and SO2 emissions,
within impact area, that
can consume increment
TSP and SO2 emissions.
within impact area, that
can consume increment
emissions, gjitgidg impact
area, that may have
significant impact within area
55. This can mean considering large sources as far as fifty
kilometers away from the applicant's impact area.
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56. It generally works out that for short-term increments—
24-hour and 3-hour averaging times—only increment-
consuming emissions within the impact area need counting.
However, on an annual basis, large sources up to fifty
AciJometers away can have impacts inside the applicant's
impact area.
57. To determine which sources outside the impact area need to
be counted, the applicant can set up an additional screening
area. This area is a ring that extends up to fifty fctZometers
beyond the impact area.
Short-Term
• count
emissions
within
Annual
• consider
sources
outside
Emissions
Inventory
Screening
Area
58. Only some of the sources in the screening area need to have
their increment-consuming emissions inventoried. To decide
which ones, the applicant considers:
— annual emissions of the source,
— potential ambient air quality impacts, and
— the source's distance from the impact area.
59. For example, a source that emits one hundred tons per year,
located ten kilometers from the impact area, could generally
be dropped from the inventory. Its impact on air quality
inside the area would be insignificant. But a ten thousand ton
per year source at forty kilometers would probably have to be
inventoried.
Sources in Screening Area
Consider:
• annual emissions
• potential Impacts
• distance from impact area
Emissions
Inventory
Screening
Area
60. Those two examples are not intended to be rules of thumb.
The applicant can apply a fairly simple screening model
technique to sources outside the impact area.
Screening
Model
61. The results of the simple modeling procedure will indicate
whether or not a source's emissions have to go into the emis-
sion inventory.
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62. Like any other modeling application, this calls for a written
record of assumptions, procedures, and conclusions. This
documentation lets the reviewing agency check what's been
done.
63. Within the impact area, and for the identified sources outside
the impact area, the applicant prepares a list of emission
units for the applicable pollutants. For each unit, an emission
rate is needed, since the emission rate is one of the basic
inputs to an air quality model.
AMdmptioci*
Unit
1
2
3
4
ttxu/1*"
TSP
MJ,
NO,
CO
HC
Fb
64. For the first attempt at running the increment-consumption
inventory and analysis, allowable emissions should be used. In
most cases, allowable emissions—what regulations or permit
conditions allow—will be greater than actual, sometimes
much greater.
use
allowable
emissions
65. There are two reasons for using allowable emissions on the
first try:
— it is easier to get allowable rates from State emission
files, and
— analysis based on allowable rates will give more
conservative results.
• easier to get allowable rates
from State emission files
• will give more conservative
results
66. These reasons are important because the air quality analysis
should be reliable and economical. State emission files are
the proper source for emission data in the application. If the
applicant has to go beyond these files, the data will be less
reliable and cost more time and money to get.
67. Also, a conservative analysis is usually less expensive and more
persuasive. It says, "We can show we'll be in compliance with
the regulations, even using pessimistic estimates." When this
approach works, it saves the time and effort required to get
more detailed actual information. And it indicates that there's
a "margin of safety" in the compliance demonstration based
on allowable emissions data.
An AQ analysis must be..
• reliable
• economical
A conservative analysis is...
• less expensive
• more persuasive
7-10
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68. But — applicants can't always demonstrate they won't use up
available increment, using allowable emissions data on other
sources. In that case, another try must be made, using actual
emissions data.
use actual
emissions
69. These are harder to get. Often, State engineering personnel
and employees at other sources have to be interviewed. The
applicant will have to build a reviewable record of where the
actual data came from, and how.
• harder to get
• must build reviewable record
• where data obtained
• how data obtained
70. The two other kinds of emissions inventory—existing
emissions, and expected permitted emissions —are generally
similar to the increment-consuming inventory. They are
compiled to show that no National Ambient Air Quality
Standard will be violated.
3 Types of Inventories
' IncTcnMnxonsunUng emiaetona of TSP
and SO,
existing emtaeiona affecting air quality
In impact area
' emiaalona from unit! with permita
71. In both of these emissions inventories, we have to deal wr.h all
of the criteria pollutants that would have a significant impact
from the proposed construction. This opens the list up from
the TSP and SO2 of the increment-consuming inventory. But
it limits the inventory, too. The applicant has to inventory
other sources' emissions only if the new source or modification
will have a significant impact from emissions of those
pollutants.
• all criteria pollutants that
would have significant impact
72. For the inventory of existing emissions, actual emissions
should be counted, if actual data are available. This is to tie
what is coming out of existing sources to what ambient air
monitors would measure. Of course, for emissions units that
have permits, but aren't operating yet, the only available
emissions data are-their potential to emit.
73. The third of the five steps in Air Quality Analysis is to
determine existing ambient concentrations.
74. Basically, this is a matter of monitoring ambient air quality,
but adjustments — using dispersion modeling—may be needed.
Inventory of Existing Emissions
• actua^eraiuiona.
for operating aourcea
• potential to emit.
for Murcea not yet
operating
3. Determine existing
ambient concentrations
3. Determine existing
ambient concentrations
• monitoring air quality
• but adjustments may be
needed
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75. Ambient air quality monitoring is a major component of the
art and science of air pollution control. We can't deal with it
in detail here. Despite all the complications, we want to keep
in mind that the basic purpose is to find out what is the
existing situation that will be affected by the proposed
change.
Basic Purpose
determine
existing
situation
76. The regulations require the applicant to include up to one
year of preconstruction monitoring data in the application.
The pollutants that have to be monitored are any criteria
pollutants the source would emit in significant amounts. This
doesn't include nonmethane hydrocarbons. Some noncriteria
pollutants may also have to be monitored, if the reviewing
agency determines it is necessary.
One Year of Data
(generally)
• preconstruction
• criteria pollutants
• fllgniftcam amount*
(In. NMHC)
• noncriteria pollutant!
possibly
77. The general rule is that if the proposed new source or
modification will have a significant increase in emissions of a
pollutant, continuous monitoring data will be required. This
not only includes air-quality data but may also include on-site
meteorological data collection for input to an air quality
dispersion model in the later Air Quality Analysis steps.
General Rule...
If:
proposed source/modification
will have significant increase
Then:
continuous monitoring will
be required
78. There are exceptions to keep this requirement from being too
burdensome. The regulations list a set of air quality values
and averaging times. If the source's predicted impact or the
existing air quality readings are lower than these, the
reviewing agency can say no monitoring is needed for that
pollutant.
79. This exception means that before the applicant does anything
else on monitoring, it should estimate source impacts and
total existing air quality for the area.
Exception
If predicted impact or
existing readings are lower
than listed values, reviewing
agency can say no monitoring
Is needed.
• source Impacts
total existing air
quality
80. There are two ways to satisfy the preconstruction monitoring
requirements. First, the applicant can use existing continuous
monitoring data collected by an air pollution control agency.
Second, the applicant may have to conduct its own site-
specific monitoring program. How much of each approach is
used depends on the quantity and quality of available data.
2 Ways to Satisfy
Requirements
use existing monitoring data
collect site-specific
monitoflngaata^^
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81. To decide when and where monitoring is required, what
pollutants must be monitored, and whose monitoring data
will be acceptable, the applicant must consider many factors.
The reviewing agency also has to take part in making the
monitoring decisions. These decisions will be based on the
EPA regulations and on guidance in the Ambient Monitoring
Guidelines for PSD.
82. If the applicant is going to use existing monitoring data, it
must make sure the data meet certain criteria. These criteria
are:
— One, sufficiency, or completeness,
— Two, representativeness, and
—Three, reliability.
83. Air pollution control agencies —Federal, State, and local —
have been gathering air quality data for years. But the data
on file may not meet the requirements of PSD Air Quality
Review. Using the Guideline, the applicant and reviewing
agency must check whether the data meet the criteria.
Criteria for Existing Data
• sufficiency/completeness
• representativeness
• reliability
84. Are there enough data for analysis? Do they represent the
source site and impact area? Can they be relied upon?
85. If existing data cannot be used, the applicant is going to have
to carry out a program of site-specific monitoring. In
addition to selecting, buying, and running appropriate
monitoring equipment, there are two major procedural
aspects of the requirements. They are:
— site selection and
— quality assurance.
86. Site selection involves deciding on the number and location
of monitors. It will call for dispersion modeling to decide what
points within the impact area are most appropriate. For PSD
application monitoring, the sites should represent the highest
projected concentrations in the impact area.
• Enough data for analysis?
• Do they represent site/
impact area?
• Can they be relied upon?
Site-Specific Monitoring
• selecttng/buying/running
equipment
• site selection
• quality assurance
Site Selection
• number of monitors
• location of monitors
• dispersion modeling
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87. Quality assurance is a system for making sure the air quality
data collected are consistent and reliable. The Federal
requirements for air monitoring quality assurance are spelled
out in Appendix B to 40 CFR Part 58.
88. Appendix B requires the applicant who monitors air quality to
draw up a detailed quality assurance plan. The plan has to be
approved by the permit-reviewing authority.
Quality Assurance
• making sure data are
consistent and reliable
• 40 CFR Part 58. Appendix B
Quality
Assurance
Plan
89. The monitoring program itself calls for a detailed monitoring
plan, which the reviewing authority needs to comment on and
approve. The five elements of this plan are laid out in the
EPA Ambient Monitoring Guidelines for PSD, which
describe them in detail.
90. They are:
— One, Network description,
— Two, Monitor -site description,
— Three, Monitor (equipment) description,
— Four, Sampling program description, and
— Five, Quality assurance program.
91. The preconstruction monitoring program is another point in
the PSD permit application process where large volumes of
information are gathered.
1. Network Description
2. Monitor Site Description
3. Equipment Description
4. Sampling Program
Description
5. Quality Assurance Progian
92. This information has to be used by the applicant in decision
making. The reviewing agency has to go over it. To make the
information useful, it has to be presented in a rational
format. The exact format will be specified by the reviewing
agency.
93. At a minimum, the monitoring data should be set out in a
summary format. This will arrange pollutant concentrations
by averaging time and frequency. For pollutants like SO2,
NO2, or paniculate matter, this means giving both the highest
concentration and highest second-highest concentration for
averaging times of less than one year.
Highest and Highest Second-Highest
Concentrations
Pollutant
SO,
NO,
Time Period
3-hour
24-hour
annual
annual
24-hour
Maximum Second-Highest
329 277
68 61
12 -
29 -
110 101
51 -
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94. Of course, actual monitoring data —as recent as possible —is
preferred for the Air Quality Analysis. But the analysis also
has to account for the effects of emissions that are already
permitted, but that didn't occur during the monitoring
period.
95. To do this, the actual monitoring data must be adjusted. The
applicant adjusts monitoring data by applying information
from the emissions inventory to an appropriate dispersion
model.
96. Once again, we've reached a point where the data for an
analysis have been gathered and organized. The impact
area —or areas —have been defined, emissions inventory and
existing air quality data have been compiled. The remaining
two steps of Air Quality Analysis involve applying the
assembled data to see what happens to increment consump-
tion and air quality standards with the new operation.
97. The fourth step in Air Quality Analysis is to perform a
screening model analysis. A screening air quality dispersion
model may not require extensive computer tune or
sophisticated equipment to run. It produces approximate
results, and is normally designed to be conservative. In cer-
tain circumstances, no further modeling may be required.
98. The applicant will get three pieces of essential data from the
screening analysis. They are:
— One, an approximation of the maximum impacts
downwind of the source,
— Two, a general idea of the location of the maximum
impacts, and
— Three, quick, preliminary results.
4. Perform a screening model
analysis
• doc* not require extensive
computer time or sophisticated
equipment
• produce* approximate results
• la conservative
Benefit of Screening Analysis
• approximation of maximum
downwind impact
• a general idea of the location
of maximum impact
• quick preliminary results
99. This analysis is a lot like the impact area determination.
However, here we're using the complete emissions inventory
that fits the analysis, not just the changes from the new source
or modification.
Total
Emissions
Inventory
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100. For the screening analysis, then, the applicant should count
three kinds of emissions:
—stack emissions,
—fugitive emissions that are quantifiable, and
—secondary emissions, if they are quantifiable and are
expected to affect impact-area air quality.
101. In dealing with stack emissions, we have to remember that
EPA has Good Engineering Practice—GEP—stack height
regulations. Some stacks that appear in the emissions
inventory may be taller than GEP heights. For those stacks, a
GEP height has to be figured, using procedures from the EPA
Guideline on Air Quality Models. This is the stack height that
must be used in both the screening and refined modeling
procedures.
102. The conservative and approximate results of the screening
model may indicate that no PSD increment or air quality
standard is threatened. On the other hand, the screening
analysis may show that more than the available increment will
be used up, or an ambient standard will be violated. If
screening shows any kind of violation, then a refined model-
ing analysis must be done.
103. If the screening analysis does not indicate using more than
available increment, or exceeding an ambient standard, then
the applicant can reach an agreement with the reviewing
agency. The agreement will be to accept the screening model
results as conservative projections of source impacts. In this
case, the applicant may not have to do a refined modeling
analysis.
104. In some cases, however, screening analysis may not show a
clear situation where no increment or standard is threatened.
In these cases, the applicant must go on to the fifth —
and last—step in Air Quality Analysis. That is to determine
projected air quality levels by means of a refined air quality
dispersion model:
105. The refined analysis itself is a fairly complicated procedure
involving computer use. The details are too complex to deal
with here. However, all the data-gathering steps we've talked
about so far were leading up to this point.
If:
screening predicts a violation
Then:
refined analysis must be done
If:
screening predicts jio^violation
Then:
agency may accept screening
results as projections
5. Determine projected
air quality
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106. Because no two cases of refined modeling application are
exactly alike, the applicant may find it advisable to design a
special plan, following the EPA Guideline on Air Quality
Models or any supplemental State guidance. We mentioned
this plan earlier, and remarked that it, is essential that the
applicant develop the plan, propose it to the reviewing
agency, and get agency agreement on it.
107. In specific cases, special modeling considerations may come
up. These could include:
—using some alternative model that is better suited to
this application,
— problems of modeling in complex terrain, or
—modeling pollutant sources that are not points—but
rather are lines or areas.
108. Here again, it is essential for the applicant to get agency
agreement on a detailed modeling plan before committing
itself to a complex and expensive modeling program.
Refined Modeling Analysis
• should adhere to modeling
guidelines
• work closely with
review agency modeling
contact
• alternative models
• complex terrain
• line or area sources
109. The result of refined modeling will be projected air quality
data. The exact form will depend on the model. In any case
there will be concentrations for certain averaging times at
points in the impact area. These are compared with available
increments or ambient standards to detect any violations.
110. In this lesson and the previous one, we have described one of
the most important analysis steps in the PSD application
process: Air Quality Analysis. Put simply, it is a way of seeing
what will happen to air quality if the proposed source or
modification is constructed.
111. The Air Quality Analysis can be broken down into five
analysis steps and three interrelated phases. The five steps
are:
— One, define the impact area,
—Two, establish inventory of other sources,
—Three, determine existing ambient concentrations,
— Four, perform screening analysis, and
— Five, determine projected air quality—by refined
modeling, if needed.
What will happen to air quality?
5 Steps
1. Dcfliw tlM ffflpactarf
2. Ettabtish Inggy^g?
5. OvtmniiM proi«««d air quality
7-17
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Slide Script Selected Visuals
112. The three phases are: 3Phases
— One, analyze increment consumption, L AMI«. incrementcon.un.Ddon
—Two, determine existing air quality, and 2- o««™i"««i;tin3pa,r quality
7 ;. J 3. Protect future air quality
—Three, project future air quality.
i
113. With the results of this analysis and the BACT Analysis, the
applicant has assembled, probably, a quite bulky document.
What remains to be done now is the Additional Impacts
Analysis and detailed agency review.
114. (Credit slide)
115. (Northrop slide)
Ab Qulltt Autote II
EPA Contact No. 6S-02-3573
116. (Northrop slide) i98o°*pso workshop.
U.S. Environmental Protection
Agency
Office of All Quality Planning and
Standard!
117. (NET slide)
Environmental
Training
7-18
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SI:453
Lesson 8
Additional Impacts Analysis
Slide Script
1. (Focus)
2. This is Lesson Eight, "Additional Impacts Analysis."
3. We have just gone over some very detailed and demanding
•requirements for PSD permit applications. These requirements
come from Title One, Part C of the Clean Air Act, and from
EPA regulations that carry out the Act.
6.
We have already discussed determination of applicability,
Best Available Control Technology (BACT) analysis, and air
quality analysis. The regulations spell out in considerable
detail the requirements for these analyses. EPA Guidelines go
on to show how to do these important steps.
Our last stage in the application process—Additional Impacts
Analysis—is somewhat different. These are definite
requirements in the Act to deal with effects other than
increment consumption and ambient air standards. However,
they are not very detailed.
In about seventeen and a half pages of EPA PSD regulations,
the subsection "Additional Impact Analyses" takes up about a
third of one column on one page.
7. This doesn't mean that Additional Impacts Analysis is a lot
less important than everything else, something the applicant
can toss off as an afterthought. It does mean that the analysis
has to be carefully planned to fit the situation.
Selected Visuals
FOCUS
Additional Impacts Analysis
The Clean Air Act
Title 1
PartC
• Applicability determinations
• BACT Analysis
• Air Quality Analysis
' Additional
Impacts
Analysis
• planned carefully to
fit the situation
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8. From the law and regulations, we can learn that Additional
Impacts Analysis is concerned with determining air pollution
impacts on three things—
—soils,
— vegetation, and
— visibility.
9. The air pollution that has these impacts comes from —
—emissions from the new source or modification, and
—emissions resulting from associated growth.
Additional Impacts Analysis
• soils
• vegetation
• visibility
auod>t«d growth
10. There are three basic purposes for the Additional Impacts
Analysis. They are:
One, assist Best Available Control Technology—BACT—
decision making,
Two, inform the general public of potential air quality-
related impacts, and
Three, provide the Federal Land Manager with infor-
mation on potential Class One area impacts.
11. When you take all of these considerations together, you get
something pretty broad and general. But the requirement for
Additional Impacts Analysis is more specific. It probably
wouldn't be useful to look at all the effects of everything on
everything else, even if there were enough time and money to
do it.
Purposes
1. Assist BACT decision making
2. Inform the general public
3. Provide Federal Land Manager
with Information
12. By now, this should sound familiar. We want to narrow the
scope of our analysis to where we get useful, significant infor-
mation with the time and other resources available. For this
analysis, however, there is very little in the way of required
format. A "fill in the blanks" approach won't work.
13. But the applicant can decide what kind of analysis is needed,
how to organize it, and what method to use.
• kind of analysis
' organization
• method
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14. These, decisions about the overall direction and methods of
Additional Impacts Analysis can be made easier by keeping
six basic points in mind. They are:
First, the depth of the analysis,
Second, the public information elements,
Third, what triggers review,
Fourth, the focus on concentration-impact relations,
Fifth, the need for full documentation, and
Sixth, the flexibility of possible approaches.
15. First, the depth of the analysis depends on the expected
impacts. Every applicant must do an Additional Impacts
Analysis. But the analysis does not have to be equally deep in
different cases. How deep the analysis goes in any particular
area depends on many things, most importantly:
— the quantity of emissions,
— the existing air quality, and
— the sensitivity of local soils, vegetation, and visibility
to effects of the emissions.
1. Depth
2. Public Information
3. Triggers
4. Concentration-Impact
Relations
5. Documentation
6. Flexibility
1. Depth
• quantity of emissions
• existing air quality
• sensitivity of soils.
vegetation, and visibility
16. Common sense suggests that small emission increases will not
produce major impacts. However, the applicant must survey
the impact area and make sure it can actually expect "no
significant impact." The conclusion has to be documented, so
it can be checked.
17. Second, public information is one of the primary goals of the
Additional Impacts Analysis. The general public will be
taking part in the permit process through hearings and
comments on the record. The public is most interested in how
the proposed project will effect things directly connected to
their daily lives and well-being. The analysis should address
these impacts in a way the public can understand.
18. Potential impacts on Class One areas should get special,
thorough treatment.
2. Public Information
• effect on daily lives
and well-being
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19. Third, the review may be triggered for both criteria and
noncriteria pollutants. The Additional Impacts Analysis has
to consider the effects of all pollutants under review—on soils,
vegetation and visibility.
20. Fourth, and closely related to that last point, the analysis
deals with the effect of each pollutant under review on air
quality-related values. This means the applicant has to explore
concentration-impact relations—how concentrations of these
pollutants, are related to changes in soils, vegetation, and
visibility.
21. In analyzing the effects of all the pollutants under review, the
applicant has to remember that two kinds of emissions must
be accounted for. They are:
—direct emissions from the new source or modification
itself, and
—secondary emissions from residential, commercial, or
industrial growth associated with the project.
22. Fifth, full documentation is very important to the Additional
Impacts Analysis. The analysis creates a public record of fairly
complex and tmobvious reasoning on technical topics. Both
the public and the reviewing agency need to be able to go
over the analysis point by point to check facts, assumptions,
and conclusions.
3. Triggers
• criteria pollutants
• noncriteria pollutants
4. Concentration-Impact Relations
• effect on air-quality-related values
• how concentrations are related to
changes In soils/vegelatlon/visibility
associated growth
5. Documentation
• public record of:
• facts
• assumptions
• conclusions
23. Sixth, there is considerable flexibility in doing an Additional
Impacts Analysis and documenting the results. We'll go
through one basic method for approaching the analysis here,
but it isn't the only way. There is no "cookbook" approach to
Additional Impacts Analysis. What is important is that the
applicant recognize all significant factors and their impacts,
and carefully analyze them.
24. There are three component analyses that make up the
Additional Impacts Analysis:
— a Growth Analysis
— a Soils and Vegetation Impact Analysis, and
— a Visibility Impairments Analysis.
6. Flexibility
• there is no "cookbook"
approach
• must recognize/analyze
all significant factors
Additional Impacts Analysis
• Growth Analysis
• Soils and Vegetation
Impact Analysis
• Visibility Impairments
Analysis
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Script
Selected Visuals
25. The Growth Analysis has to come first. It produces basic
information for the other two component analyses. The
growth analysis itself breaks down into three elements:
— projection of associated growth in the impact area,
—estimates of emissions caused by permanent
growth, and
— analysis of air quality resulting from these emissions.
26. To project the growth associated with building and operating
the new source or modification, we need to consider three
kinds of growth: industrial, commercial, and residential.
Growth Analysis
1 projection of associated growth
1 estimates of emissions
' analysis of air quality
27. We also need a starting place for projecting growth. We
describe the existing base in terms of two kinds of support
factors:
— Local Support Factors, and
— Industrial Support Factors.
28. Local support factors are related primarily to population and
its growth. They include:
— the existing housing supply and its ability to expand,
and
— the commercial base for supporting residential
growth—construction companies, suppliers, and so on.
29. Industrial support factors are tied more closely to the running
of the source itself. They include:
— raw materials suppliers,
— utility and power suppliers, and
— maintenance and support services.
• Local Support Factors
* Industrial Support Factors
30. There are many good sources for basic information on existing
Local and Industrial Support Factors. These include:
— State agencies (like the Department of Commerce),
— regional planning offices,
— local Chambers of Commerce,
— Environmental Impact Statements, and
— PSD applications previously prepared by other
applicants.
Sources of Information
• State agencies
• Regional planning offices
• Chambers of Commerce
• Environmental Impact
Statements
• PSD applications
8-5
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Slide
Script
Selected Visuals
31. All this information on support factors indicates what exists
now. The next step is to project how much new growth must
take place to support the new source or modification. Some of
the same organizations that provided the baseline data can
help in making this projection.
32. A new operation can result in residential growth. How much
growth depends—among other things—on:
— the work force available now,
— the number of new employees, and
— the current housing supply.
33. There is likely to be more or less industrial growth to support
the new operation. Important elements for projecting growth
in local industry and commerce include:
— the kinds and amounts of .raw materials needed,
— the water, sewer, and power needs of the source, and
—other goods, services, and maintenance requirements.
34. The different kinds of projected growth feed into the second
element of the Growth Analysis, emissions estimates. In some
ways, this is like the inventory of other sources used in the
overall Air Quality Analysis.
• current
workforce
• new employees
• housing supply
• raw materials
• water/sewer/
power needs
• goods/ services/
maintenance
requirements
35. Anywhere that specific industrial or commercial pperations, or
emissions units within them, can be identified, "hard"
engineering estimates should be used.
36. Keep in mind, however, that we're talking about projec-
tions—estimates of growth that may take place. It may be
necessary to estimate future emissions from things like popula-
tion growth. For example, there are rough rules for projecting
dry-cleaning use, and therefore volatile organic emissions,
from population figures.
8-6
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Slide
Script
Selected Visuals
37. Emission estimates can be made on the basis of many
information sources, including:
— equipment manufacturers' specifications and
guidelines,
— AP-42, the EPA Compilation of Emission
Factors
—other PSD applications, or
— comparisons with existing facilities.
38. All of these projected emissions will be those from permanent,
stationary sources. Temporary sources and mobile sources are
excluded from the analysis.
39. At this point, the applicant has a fair handful of data. It has
to be put together so some use can be made of it. The
putting-together involves adding up the projected-growth
emission estimates and the emission estimates for the source.
Together, these are inputs for the next element of the Growth
Analysis.
40. The third element of the Growth Analysis is projecting air
quality resulting from the emissions that come from the
source and associated growth.
41. This isn't doing the whole Air Quality Analysis part of the
application process all over again. For one thing, there may
be several noncriteria pollutants to be considered here. For
another thing, we have a mix of projected emissions data
ranging from "hard" to "soft."
42. Without going deep into the details, we can say that the
projected total emissions data are plugged into appropriate air
pollution dispersion models. The computer then generates
projections of ground-level concentrations of the pollutants
under review. These concentrations are part of the informa-
tion package for Additional Impacts Analysis. They also feed
the next component analysis —Soils and Vegetation.
8-7
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Slide
Script
Selected Visuals
43. This second component analysis uses the results of air quality
modeling as a basis to estimate the effects of air pollution on
soils and plants in the impact area.
Soils and Vegetation
Analysis
• estimates effects on soils
and plants
44. Different air pollutants can have a variety of effects on plants.
Some of these are caused by pollutants absorbed directly from
the air, and some indirectly, by way of water and soil. The
effects show up as things like premature bud loss, leaf necrosis
(tissue death), and plant death.
45. When ambient pollutant concentrations are high, acute
effects—short-term, possibly severe—often appear.
46. But lower levels of exposure over long periods of time can
have serious effects, even if they're usually less obvious. The
damages, in terms of loss of money or enjoyment, from long-
term, low-level exposure, can be worse than from acute
effects.
47. A suggested approach to Soils and Vegetation Analysis breaks
the task down into three elements:
— a survey of soil and vegetation types,
—projection of future ambient pollutant concentrations,
and
—correlation of concentrations with effects.
• survey of soil and vegetation
types
• projection of future ambient
concentrations
• correlation of concentrations
with effects
48. The survey of soil and vegetation types in the impact area
should include all vegetation of any value—whether
commercial or recreational value.
• survey of soil and vegetation types
• all vegetation - commercial or
recreational
49. It's not likely that the applicant will have to do the whole
survey "from scratch." Much of the information-gathering has
probably already been done by conservation groups, State
agencies, and universities. It should be readily available from
them.
Information probably available from:
• conservation groups
• State agencies
• universities
8-8
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Slide
Script
Selected Visuals
50. A summary of the soil and vegetation survey for a lowland
part of a typical southern State might look something like this.
Soil and Vegetation Survey
Soil Types
• sandy loam
• loam
• silt loam
Vegetation Types
• loblolly pine
• southern red oak
• soybeans
• corn
51. The second element of the Soils and Vegetation Analysis—
projection of future ambient pollutant concentrations —should
also come mostly from work already done. The Air Quality
Analysis of the application process and the air quality
projections of the Growth Analysis provide maximum and
time-averaged figures for criteria and noncriteria pollutants.
52. The third element of Soils and Vegetation Analysis is
correlation of ambient concentrations with effects. It will call
for the applicant to do some research. There is a lot of
scientific literature on the damage that different air pollutants
can do to various plants. There is no single, agreed-upon
method for predicting how much damage to exactly what
kinds of plants will result from certain levels of pollutants.
53. The applicant can turn to the scientific literature for
research results on relations of pollutant concentrations to
effects. Also, the same conservation groups, State agencies,
and university departments that had soil and vegetation
survey information are likely to be able to help on predicting
effects.
• projection of future ambient
concentrations
• Information usually already available
• for criteria and noncriteria pollutants
• correlation of concentrations with
effects
• will require research
• there Is no one single, agreedtipon
.method for predicting damage
• scientific literature
• conservation groups
• State agencies
• universities
54. As a general rule, criteria pollutant concentrations below the
secondary ambient standards won't have harmful effects.
However, there are exceptions to watch out for.
Criteria pollutant concentrations
below secondary NAAQS usually
are O.K.
55. Certain sensitive species of plants and types of soil can show
damage at lower levels. Examples are alfalfa and soybeans.
These sensitive items should be caught and "flagged" on the
soils and vegetation survey.
• sensitive species
can show damage
at lower levels
56. The noncriteria pollutants need to be approached more
cautiously. Some of them can cause soil or plant damage at
pretty low ambient concentrations, over a period of time.
Noncriteria pollutants may
cause damage at pretty low
concentrations.
8-9
-------
Slide
Script
Selected Visuals
57. Fluorides, for example, can cause this kind of leaf-tissue
death at levels around half a microgram per cubic meter over
a thirty-day period.
58. It's important, again, to document the Soils and Vegetation
Analysis. Its results aren't simple. Its methods are likely to be
special for this case. Both the general public and the review-
ing agency have to be able to go over data, reasoning, and
conclusions.
59. The third and last component analysis of the Additional
Impacts Analysis is the Visibility Impairments Analysis.
60. "Visibility" generally means how well people can see. It
includes ideas of how much of what there is to be seen can be
»
seen, and how far. The Clean Air Act says that "visibility
impairment" includes reduction in visual range (distance) and
atmospheric discoloration.
Visibility Impairments Analysis
• how mucli can be seen
• how far one can see
61. Visibility impairment has to be assessed for any area on which
the proposed source or modification has an impact. But the
analysis is especially concerned with visibility effects on Class
One areas. The Clean Air Act requires special plans and
procedures for protecting visibility in mandatory Federal Class
One areas.
62. A suggested approach to Visibility Impairments Analysis
breaks it down into three elements:
. One, an initial screening for possible effects of emissions
on visibility,
Two, a more refined modeling analysis, */ needed, and,
Three, a description of the area's visual quality.
• initial screening
• deeper modeling analysis
• description of visual quality
8-10
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Slide
Script
Selected Visuals
63. Class One area impacts may be estimated using EPA's
Workbook for Estimating Visibility Impairment, which is
available from NTIS as PB81 157885. The Workbook's
methods are applicable to Class One and other areas.
64. The Workbook outlines a three-level screening procedure.
Levels One and Two are preliminary screening, while Level
Three is application of a computer modeling analysis.
3 - Level Screening Procedure
I Preliminary Screening
lft) Computer Modeling
'"] An
Analysis
65. Level One visibility screening is a simplifying approach. It's
intended to screen out emission sources that have little
potential for adverse effects on visibility. For each source a
standard calculation is made that relates emissions to visibility
impact. The results are compared with a standard screening
value. If the result for a source is less than the screening
value, the source can be dropped from further visibility
analysis. A higher value indicates potential visibility impacts.
For such sources, further analysis is required.
66. Level Two visibility screening is conservative. It uses assumed
worst-case meteorological conditions. However, more informa-
tion on the source, topography, and visual range and
meteorology in the region is applied. The analysis can be done
by hand calculations, using reference tables and charts. It can
also be done as a fairly simple computer run of EPA's
PLUVUE Model.
Level I Screening
i simplifying
> standard calculation for
each source compared to a
standard value
Level II Screening
• conservative
• uses "worst-case" meteorological
conditions
• hand calculations or PLUVUE
Model run
67. Level Three of the Workbook's screening procedure
corresponds to what we've called a more refined modeling
analysis. If the Level One and Two screenings indicate a possi-
ble visibility impairment, the applicant should do a full run
of the PLUVUE Model. This will call for complete emissions,
meteorological, and other regional data. The output will be a
more accurate projection of visibility impacts, in terms of how
severe and how often.
Level III Screening
• more refined modeling
analysis
• full run of PLUVUE Model
8-11
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Slide
Script
Selected Visuals
68. To wrap up the Visibility Impairment Analysis, the applicant
should assemble a description of the area's visual quality.
This description should include any scenic vista that has
' public appeal or aesthetic value.
69. It should be obvious that there's no mechanical method for
deciding what is or isn't "scenic" or "aesthetic." But there is
an area of general agreement on what kinds of changes
definitely would or wouldn't harm an area's visual quality.
The visual quality description should, at least, address these
consensus values.
Applicant should assemble a
description of area's visualquajltv •
Including sce
• public appeal
• aesthetic value
70. If a Class One area might be affected, the applicant should
contact the Federal Land Manager. Federal agencies that
manage lands in Class One areas have formally identified
visibility values in the areas. They will also have detailed
information that will assist the applicant to prepare the
Visibility Impairments Analysis.
Federal
Land
Manager
71. The Visibility Impairments Analysis is the third and last
component of the overall Additional Impacts Analysis.
Additional Impacts Analysis
1^X1 Growth Impacts Analysis
0 Soils and Vegetation
Impacts Analysis
1^71 Visibility Impairments '
l_^_J Analysis
72. The important points to remember about the Additional
impacts analysis include:
— one major purpose is to inform the public of
environmental impacts from a proposed new source or
modification.
• provide public information
73. —the impacts to be examined are on soils, vegetation,
and visibility,
' provide public information
• examine Impacts on soils,
vegetation, and visibility
74. —the impacts can come from emissions from the new
project or from associated growth.
• provide public information
' examine impacts on soils.
vegetation, and visibility
1 impacts may be from new
sources or associated growth
8-12
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Slide
Script
Selected Visuals
75. The Additional Impacts Analysis is made up of three
component analyses:
— Growth Analysis,
— Soils and Vegetation Analysis, and
— Visibility Impairments Analysis.
Additional Impacts Analysis
• Growth Analysis
• Soils and Vegetation
Impact Analysis
• Visibility Impairments
Analysis
76. Each component analysis develops information for the next
step. Since there is no "cookbook" for doing these analyses, it
is very important that the applicant document each step. The
public and the reviewing agency should be able to see the
facts, assumptions, and reasoning that lead to each
conclusion.
Applicant must document
each step.
77. The Additional Impacts Analysis completes the PSD
application process. In the next lesson, we'll briefly review the
steps to a complete application, and discuss how the reviewing
agency takes up its responsibilities.
Reviewing Agency
Responsibilities
78. (Credit slide)
Additional Impact* Analysis
Grtp*tc»: Lnito Whit*
PhMo«p*ph«f Aodto: David Chuichlll
Narration: Rich Palwr
79. (Northrop slide)
Developed and
produced by:
Northrop Services, Inc.
under
EPA Contract No. 68-02-3573
80. (Northrop slide)
Ba**d In put on the:
1980 PSD Workshops
prtpcrad (or the
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
by
TRW. Inc.. Enrlronmvnial Enelnn-rin* Olvluon
Northrop Scnkn. Inc.
EPA Coatnct N" 6*41-3174
81. (NET slide)
Northrop
Environmental
Training
8-13
-------
SI:453
Lesson 9
Application Summary & Introduction to Agency Review
Slide
1. (Focus)
Script
2. This is Lesson Nine, "Application Summary and Introduction
to Agency Review."
3. In the previous lesson, we outlined the last step of the PSD
application process —Additional Impacts Analysis. We
discussed a suggested approach to meeting the flexible
requirements of this analysis.
4. Now that we've finished up the application process, it's time to
review the major steps and points to remember in that
process. We have spent much more time on the applicant's
work in putting together the application than we will on the
reviewing agency's work in reviewing it. We want to
understand why this is so. So this lesson will go on to contrast
the responsibilities of the applicant and the reviewing agency
in dealing with an application for a proposed new source or
modification.
Selected Visuals
FOCUS
Application Summaiy
and
Introduction to
Agency Review
^ Applicability Determination
Z Ota AnlUM* Control
Technology AnalyiU
Ł Air Quality Analvai*
E Additional Impact! Analvala
Applicant's
Responsibility
Reviewing Agency's
Responsibility
6.
We began by tracing some of the development of the concept
of Prevention of Significant Deterioration—PSD. Through
court decisions, amendments to the Clean Air Act, and
changes in EPA regulations, we have arrived at the present
system.
This system works to prevent significant increases in air
pollution in areas where the air quality is already better than
National Ambient Air Quality Standards.
7. At the same time, the system provides a margin for growth
and development.
9-1
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Slide
Script
Selected Visuals
8. The major mechanism for carrying out PSD is to require new
major sources or major modifications in PSD areas to file a
detailed application for a permit before beginning
construction.
-
Permit
Application
9. The reviewing agency checks the application to be sure it
meets PSD requirements.
10. With a complete, satisfactory application, and after a public
hearing, the agency issues a permit. The permit contains
Federally enforceable conditions to make certain the new
operation will comply with PSD requirements, and remain in
compliance.
11. The application is the key to this process. It is a detailed
engineering analysis done by the applicant.
Permit
Application
• engineering analysis
• done by the applicant
12. It examines regulatory, technical, and environmental-impact
questions raised by construction of the new source or
modification. It shows how construction and operation will be
carried out to meet legal and regulatory requirements.
I Permit
j Application
• examines
• regulatory
• technical
• environmental-Impact
questions
• shows how
construction / operation
will be carried out
13. The applicant puts the PSD application together in a step-by-
step way. Each step provides information and go —no-go
signals for the next.
{ Permit
| Application
• step-by-step
process
14. The major steps in assembling the complete application are
these four:
• Applicability Determination,
• Best Available Control Technology Analysis,
• Air Quality Analysis, and
• Additional Impacts Analysis.
4 Steps
• Applicability Determination
' Best Aullable Control
Technology Analysis
• Air Quality Analysis
• Additional Impacts Analysis
9-2
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Slide
Script
Selected Visuals
15. Each major step breaks down into smaller steps. Some of these
are directly called for by the law and regulations. Some are
simply efficient ways of getting the answers needed to meet the
law and regulations.
16. We began with the Applicability Determination. The first
thing we saw was that applicability asked two kinds of
questions. First, where will the proposed construction be?
Second, what is the proposed construction? That is, there is:
• Geographic applicability, and
• Source applicability.
17. Geographic applicability depends on the classification of the
area where the new source or modification will be built.
Under Section 107 of the Clean Air Act, the States have to
classify all of their Air Quality Control Regions. They can
break them up and classify the parts.
Applicability
• JVhm will construction be? .
• Whjtta Ih« construction?
18. The classifications—which can be different for each criteria
pollutant — are:
• Attainment—meets the National Ambient Standard,
• Nonattainment—does not meet the national standard, and
• Unclassifiable —information doesn't show whether or not it
meets the standard.
19. Attainment and unclassifiable areas are PSD areas. The PSD
regulations apply geographically within their borders. The
more complicated question is source applicability.
Attainment
• NAAQS
Nonattainment
• docs not meet
NAAQS
K
20. We saw that PSD review requirements apply to major new
stationary sources, or to major modifications to stationary
sources. The definition of major stationary source was
important for both new sources and modifications.
• IMW stattonfttv sources
• modifications
9-3
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Slide
Script
Selected Visuals
21. A major stationary source is one of two things:
• a source on the list of twenty-eight categories, with
potential to emit one hundred tons or more per year of
any regulated pollutant, or
• any unlisted source with potential to emit two hundred
fifty tons or more per year of any regulated pollutant.
22. This took us on to the definition of potential to emit. We do
accounting of potential to emit for whole sources by totalling
up emissions:
• pollutant by pollutant—for any pollutant regulated under
the Clean Air Act, and
• emissions unit by emissions unit—with control equipment
operating normally.
Major Stationary Source
•on list of 28
categories
• cmlu 100 tons or
any regulated
pollutant
• emits 250 tons or
more par yaar of
any regulated
pollutant
Potential to Emit
Total emlaUoos...
• polhitant by pollutant
23. Using the definitions of major source and potential to emit,
we can set up three applicability tests. These tell us whether
PSD review applies to proposed construction, and if it does,
what level of review.
3 Applicability Tests
To
* whether PSD reriev applies
• U «o. *hat level
24. Test One asks: "Is the source—new or existing—major for at
least one regulated pollutant?" The total potential to emit for
each pollutant is compared with the 100- or 250-ton criterion.
If the source is major for any one pollutant, it's a major
source, and the PSD review has to go on to its next steps.
25. The important exception to the rule in Test One applies only
if the area is nonattainment for a pollutant that makes the
source major. For that pollutant, the source has to undergo
the special nonattainment area plan review.
Testl
Is the source major?
• yes
• no
PSD review
no PSD review
HUIor
0
Nonattainment
Plan Review
Nofuttalnment lor SO,
26. So, if a proposed new source meets Test One—it's a major
source for an applicable pollutant —PSD review applies. Or, if
a modification all by itself would be a major source, PSD
review applies.
27. But for any other modification to have PSD review apply, it
has to be a major modification. A major modification is a
change at a major source that results in a significant net
increase in emissions of any pollutant regulated under the
Clean Air Act.
9-4
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Slide
Script
Selected Visuals
28. We examined the emission levels set by EPA as significant for
the pollutants regulated under the Act. We noted the special
case for emissions that have a one microgram per cubic meter
or greater impact on Class One areas.
29. We also went over the fairly complicated business of netting.
In netting, the emission changes from the modification are
added up with all the creditable contemporaneous emission
changes for each pollutant.
30. Test Two takes these numbers and asks, "Is there at least one
pollutant with significant net increases in actual emissions?"
If there is, we have a major modification, and PSD review
applies.
Netting
• counting up creditable.
contemporaneous
emluton changes
Test 2
Are there any significant
net Increases?
31. Test Three goes beyond the question of whether PSD review
applies to a new source or modification, to what review and
how much. It asks: "Which pollutants have significant
increases?" For each pollutant that does have a significant
increase, the applicant has to perform the three analyses of
the PSD application process.
32. As we saw, these three analyses are:
• Best Available Control Technology—BACT —Analysis,
• Air Quality Analysis, and
• Additional Impacts Analysis.
33. Any proposed new source or modification that comes through
the applicability determination with a finding that PSD review
applies goes on to the next step. That step is BACT Analysis.
34. We called the BACT Analysis the core of the PSD application
process. This isn't —as we saw —because everything is finished
when you get through with BACT. It's because BACT
Analysis lines up information for the other two analysis steps
and for corporate decision making on the project.
Test3
Which pollutants have
significant net increases?
• BM Available Control
Technology (BACT) Anaty»i»
• All Quality Anarv*!*
* AddlttoiuJ Impact* Anatinl*
Best Available Control
Technology (BACT)
Analysis
BACT Analy«ls
* Information for other anaryMS
• Information for corporate
decision making
35. Our first step in understanding BACT Analysis was to take
apart the Clean Air Act definition of Best Available Control
Technology. And the first thing we hit on there was what kind
of thing BACT is. It is an emission limitation, based on what
can be accomplished with the best available technology.
BACT
ban
emission limitation.
9-5
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Slide
Script
Selected Visuals
36. The ideas of emission limitation, best, and available shape
the way BACT is proposed in an application, and the analysis.
If possible, BACT will be an enforceable emission rate to go
into the permit. Only if something makes quantifying the rate
impractical will you find a fall-back to fuel limits, work
practice standards, or the like.
37. The question of what limits are best is settled
case-by-case. BACT is the best for the project being
considered, in its particular technical and economic situation.
BACT
• enforceable emiielon rate*
•turi llnuta
1 work practice ctandards
BACT Analysis
case-by-case
this plant
Its situation
38. It's the maximum degree of reduction of each regulated
pollutant, when availability is considered.
"Best"
• maximum reduction
• each pollutant
39. When we turn to what available means, we find that it's what
can be achieved taking into account energy, environmental,
and economic impacts, and other costs.
"Available"
Achievable, considering:
Energy Impact*
Environmental Impacts
Economic Impact*
Social Com
Other COM.
40. Keeping in mind that there's no pre-printed form—like a tax
return—to fill out, we divided the job of BACT Analysis into
four steps and three impact analyses.
41. The four steps are:
One, Pollutant Applicability,
Two, Emissions Unit Applicability,
Three, Identification of Potentially Sensitive Concerns,
and
Four, Selection of Alternative Control Strategies.
42. The three impact analyses are:
One, Economic Impacts,
Two, Energy Impacts, and
Three, Environmental Impacts.
BACT Analysis
• 4 Step*
• 3 Impact Analyses
Steps
1. Pollutant Applicability
2. Emissions Unit Applicability
3. Identification of Potentially
Sensitive Concerns
4. Selection of Alternative
Control Strategies
Impact Analyses
Economic Impacts
Energy Impacts
Environmental Impacts
43. In Step One, Pollutant Applicability, we found that for a
new source, any pollutant emitted in a significant quantity
requires BACT Analysis.
New Major
Sources
regulated pollutants
emitted in significant
9-6
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Slide
Script
Selected Visuals
44. For a modification, any pollutant emitted in significantly
increased amounts gets BACT Analysis.
Major
Modifications
• regulated pollutants
• emitted in significantly
increased amounts
45. In Step Two, Emissions Unit Applicability, the question is:
"Which emissions units get BACT review?"
2. Emissions
Unit Applicability
• Which emissions units
must be analyzed?
46. For new sources, the answer is each emissions unit that emits
any amount of a regulated pollutant.
New Major
Source
any unit that emits
; amount^of a
["pollutant
47. For modifications, each emissions unit with any increase in a
regulated pollutant has to apply BACT.
Major Modification
• any unit that shows
any Increase in
Tmtssionsot a
r jgulated pollutant
48. Remember that in Steps One and Two, fugitive emissions
have to be dealt with, but secondary emissions are generally
exempt.
49. Steps Three and Four of BACT Review take the information
from Steps One and Two and apply it to things outside the
source.
50. Step Three is Identification of Potentially Sensitive Concerns.
In Step Three, the applicant lists the specific factors in the
local area that may be affected by building and operating the
new source or modification.
Units producing only
secondary emissions
• exempt from BACT
analysis
3. Identification of Potentially
Sensitive Concerns
• Which areas could be
affected?
51. These factors include energy use, economics, and the
environment.
What effects can source have on:
• Energy
• Economics
• Environment
52. Remember that Steps One through Three gathered the
information needed for the BACT Analysis. The quantitative
evaluation and comparison comes in Step Four — Selection of
Alternative Control Strategies.
9-7
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Slide
Script
Selected Visuals
53. It is in Step Four that the applicant does an analysis of the
different methods of control that are technically feasible on
the source. The alternative control methods are compared
with the base case—the controls that would ordinarily be
used.
4. Selection of Alternative
Control Strategic*
• uwlmto at tKttaicallv
54. The applicant ranks control alternatives against the base case
and each other. The ranking is in terms of efficiency and
effectiveness of control for the pollutants under review.
55. The alternative control strategies can be based on existing
control technology or transferable technology.
Applicant rank* control
alternatives against
be*e cue and each other.
4 Kinds
• existing technology
• transferable technology
56. In some cases, the applicant might examine innovative
control methods,
4 Kinds
• existing technology
• transferable technology
• Innovative technology
57. or industrial processes that are inherently lower polluting.
Data on these alternatives can be drawn from other companies
in the area, previously approved PSD applications, or the EPA
BACT/LAER Clearinghouse.
4 Kinds
• existing technology
• transferable technology
• innovative technology
• inherently lower polluting
^^^^^^^
58. These four steps have set up a list of different mixes of
controls that might be applied to the new source or
modification. They are arranged in order of how well they
control the significant pollutants from the source.
o
o
O
59. The applicant performs three Impact Analyses to see what
effects would come from installing and operating each
alternative.
Analyses
• Economic Impacts
• Energy Impacts
• Environmental Impacts
60. In the first analysis, Economic Impacts Analysis, the
applicant rates the control alternatives against each other in
terms of their costs.
Economic
Impacts Analysis
estimate of approximate costs
of different control alternatives
9-8
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Slide
Script
Selected Visuals
61. Both capital and operating costs are reduced to a common
time base and compared.
• Capital Costs
• Operating Costs
62. Total and incremental — last-unit—costs provide bases for
comparison.
Costs
• Total
• Incremental
63. In the Economic Impacts Analysis, the applicant considers
three measures of cost for reasonableness:
• pollution-specific costs,
• additional product costs, and
• ability to secure financing.
64. In the second impacts analysis, Energy Impacts, the applicant
estimates the direct energy needs of control alternatives. These
energy needs are compared with available forms and amounts
of energy in the region.
Economic impacts
evaluated in terms of:
• Pollution-Specific Costs
• Additional Product Costs
• Ability to Secure Financing
• What forms
of energy can
be used?
• How much
available
in the region?
65. The third and final impacts analysis is for environmental
impacts. The applicant compares maximum effects—usually
under worst-case conditions—of alternative controls on
ambient air concentrations.
66. Other impacts —on land, air, and water—must be listed,
evaluated, and compared.
Environmental
Impacts
• degree of effect on
environment
67. By comparing the results of the analyses, pollutant by
pollutant, for all the control alternatives, the applicant arrives
at a set of controls for the whole source or modification. This
set of controls is what is presented in the application as
BACT.
o
o
9-9
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Slide
' Script
Selected Visuals
68. With the BACT Analysis complete, the applicant has decided
on a definite set of controls for the new source or
modification. The next thing to do is project the
environmental effects of operating with these controls. These
detailed projections are made in the next two major steps of
the PSD application process—Air Quality Analysis and
Additional Impacts Analysis.
69. The Air Quality Analysis concentrates on the impact of the
new emissions on National Ambient Air Quality Standards
and on allowable PSD increments.
Air Quality Impacts
Analysis
Additional Impacts
Analysis
• Standards
• Increments
70. In addition, the analysis will check the effect on air quality of
emissions of any applicable pollutant regulated under the
Clean Air Act.
General Requirement
• to examine the effect on
air quality of emissions of
say pollutant regulated
by the CAA
71. The Air Quality Analysis uses dispersion modeling techniques
to predict how increased emissions will affect ambient air
quality.
• dispersion
models
BQ QO[~~
sJlalJT^
72. These effects might include possible violations of primary or
secondary National Ambient Air Quality Standards for one or
more of the criteria pollutants. The possible violations might
be for averaging times from annual down to one hour.
Primary
Standards
Secondary
Standards
73. For two pollutants—paniculate matter and sulfur dioxide,
TSP and SO2 — the Air Quality Analysis also checks increment
consumption. There are maximum permissible increases —
increments —in ambient concentrations of TSP and SOZ.
Increments for only:
• TSP
• SO2
74. There are different maximum increments for each Class of
PSD area, and for each averaging time for which there is an
ambient standard.
9-10
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Slide
Script
Selected Visuals
75.' The ambient monitoring and dispersion modeling that go
into Air Quality Analysis are complex technical disciplines.
76. We noted, when we discussed the analysis process, that the
applicant should prepare detailed plans for review agency
concurrence before spending large sums on monitoring or
modeling.
77. Although the Air Quality Analysis process is quite
complicated, we were able to get some understanding of how
it works by breaking it into five basic steps and three
interrelated phases.
78. The five steps are:
First. Define the impact area — the area affected by the new
emissions for each pollutant analyzed.
79. Second. Establish inventory of other sources—a
quantitative listing of all sources adding to the
concentration of each pollutant analyzed.
Air Quality Analysis
• 5 Basic Steps
• 3 Phases
Five Steps of
Air Quality Analysis
Define impact area
Five Steps of
Air Quality Analysis
Define Impact area
Eatabllsh Inventory of other sources
80. Third. Determine existing concentrations—for each
pollutant in the analysis.
Five Steps of
Air Quality Analysis
Define Impact area
1 Establish Inventory of other sources
Determine existing ambient
concentration*
81. Fourth. Perform screening analysis.
Five Steps of
Air Quality Analysis
Define impact area
Establish inventory of other sources
Determine existing ambient
concentrations
Perform screening analysis
82. Fifth. Determine projected air quality levels —using
dispersion modeling.
9-11
Five Steps of
Air Quality Analysis
Define Impact area
Establish Inventory of other sources
Determine existing ambient
concentrations
Perform screening analysis
Determine protected air quality level
-------
Slide
Script
Selected Visuals
83. The work of applying the five steps of Air Quality Analysis
can be divided into three phases, which are interrelated and
can overlap. As we saw, for instance, a lot of the work in .
analyzing increment consumption and projecting future air
quality for TSP and SO2 overlaps.
84. The three phases are:
One. Analyze increment consumption. How much of the
available increments will be used by the new source or
modification?
Three
Interrelated
Phases
Air Quality Analysis
1
• analyze
conmmptton
85. Two. Determine existing air quality—present values for all
pollutants subject to analysis. Both monitoring and
modeling may be involved.
Air Quality Analysis
I 1 1
> determine
misting
air quality
86. Three. Project future air quality. This calls for dispersion
modeling for at least the criteria pollutants involved in the
analysis. The reviewing agency may call for projections of
some other pollutant concentrations.
Air Quality Analysis
• protect
future
•Ir quality
87. We went on to examine the relations of baseline areas,
baseline concentrations, increments, and total
concentrations.
• Baseline Areas
• Baseline Concentrations
• Increments
• Total Concentrations
88. The relation in principle to remember was: baseline plus
increment equals total concentration. But it's also very
important to remember that analysis can go ahead with some
uncertainties about the baseline data.
89. The baseline concentration is the foundation over which
increment consumption for TSP and SO2 is figured. It's an
adjusted concentration, which means both monitoring and
modeling can be involved. The adjustments are there to take
into account major source emissions that should be counted
against ambient concentrations as of the baseline date.
Co«»«T.,ion / Theoretical
Ambient
SO2 or TSP
Concentration
AppradBata Total All Quality
Baseline Concentration
• ambient concentration
• of TSP or SO2
• at the baseline date
9-12
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Slide
Script
Selected Visuals
90. The ideas of baseline date and baseline area are closely tied
together. The baseline date is a "triggering" date for counting
baseline concentrations and subsequent increment consump-
tion. The actual date is the day the first complete PSD
application is received after August 7, 1977.
91. It applies to an area within one State. The area is made up of
all designated PSD areas—attainment or unclassifiable—
touched by the first major source's line of significant annual
impact.
Baseline Date
• date of first complete PSD
application
• after August 7. 1977
Baseline Area
92. When we examined the procedures for carrying out the Air
Quality Analysis procedure, we saw that there are several
areas where the applicant has to go into considerable depth:
Dispersion modeling calls for a modeling plan, agreed on
by the reviewing agency.
Data on existing air quality, in most cases, require on-site
monitoring, described in a monitoring plan, also agreed on
by the reviewing agency.
To go with the air quality data, we need meteorological
data, which may be available from official records. But they
may have to be collected on site by the applicant.
• modeling plan
• on-site monitoring
• meteorological data
93. When the data are all pulled together, the applicant does
dispersion modeling.
94. If this fourth step, screening analysis, shows no threat to
National Ambient Air Quality Standards or available
increments, it may not be necessary to do the fifth step.
9-13
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Slide
Script
Selected Visuals
95. Generally the screening analysis will produce:
Approximate maximum concentrations downwind of the
source,
A general idea of the location of maximum concentrations,
and
Quick, preliminary results.
96. If screening results do not clearly show that there is no
problem with ambient standards or increments, the fifth
step—refined modeling analysis—will be necessary. Refined
analysis will call for careful planning, computer time, and
money.
97. Refined analysis in accordance with the EPA Guideline on Air
Quality Models will produce:
• projected concentrations,
• for specific averaging times,
• at a set of points — receptors—in the area modeled.
98. These can be compared in detail with the corresponding
ambient standards or available increments.
tratlon downwind
• general location of maximum
concentration
• quick, prdlmmary reaulta
• at a eet of polnta
99. Depending on your point of view, you could argue that either
Air Quality Analysis or BACT Analysis is the most com-
plicated stage of the application process. We won't try to settle
that here. However, the fourth and last stage we looked at is
somewhat different.
100. Additional Impacts Analysis is not spelled out in great detail
in the Clean Air Act or EPA regulations.
4 Steps
• Applicability Determination
• Beat Available Control
Technology Analyeie
• Alt Quality Analyita
• Additional Impact* Analyala
101. What kind of analysis and how much has to be done depend
greatly on the PSD Class of the area affected and on special
conditions in the area.
102. Additional Impacts Analysis looks at the effects of the new
source or modification on three things: soils, vegetation, and
visibility.
Kind of enatvala and how much
• PSD claea of die area
• •pedal condlUona In the area
Additional Impacts Analysis
• soils
• vegetation
• visibility
9-14
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Slide
Script
Selected Visuals
103. The emissions that affect these may come from the new source
or modification itself, or from associated growth.
104. The applicant makes the Additional Impacts Analysis for
three basic purposes:
One, to assist its own decision making on Best Available
Control Technology—BACT,
Two, to inform the general public of potential air-quality-
related impacts, and
Three, to provide the Federal Land Manager with infor-
mation on potential Class One area impacts.
105. Making decisions on what and how much to analyze, we saw,
could be made easier by keeping six basic points in mind.
Purposes
1. Assist BACT decision making
2. Inform the general public
3. Provide Federal Land Manager
with information
1. Depth
2. Public Information
3. Triggers
4. Concentration-Impact
Relations
5. Documentation
6. Flexibility
106. First, the depth of the analysis depends on the nature and
degree of expected impacts. They, in turn, depend on the
quantity of emissions, existing air quality, and the sensitivity
of the area.
1. Depth
• quantity of emissions
• existing air quality
• sensitivity of soils.
vegetation, and visibility
107. Second, the analysis should inform the public of things they
need to know to take part in the decision-making process.
2. Public Information
1 Information necessary for
talcing part in decision'
making process
108. Third, the analysis may be triggered for both criteria and
noncriteria pollutants.
3. Triggers
• criteria pollutants
• noncriteria pollutants
109. Fourth, the analysis deals with effects of each pollutant under
review on air-quality-related values. This involves examining
concentration-impact relations for direct and secondary
emissions resulting from the project.
110. Fifth, full documentation of all the Additional Impacts
Analysis is important for both legal and public information
reasons.
• effects on alr-qualltyretated
values
5. Documentation
• for legal Information reasons
• for public Information reasons
9-15
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Slide
Script
Selected Visuals
111. Sixth, the approach to the analysis is flexible. It has to fit
the situation.
6. Flexibility
• has to fit the situation
112. We saw that the overall task of Additional Impacts Analysis
can be broken down into three component analyses. They
are Growth Analysis, Soils and Vegetation Impact Analysis,
and Visibility Impairments Analysis.
Additional Impacts Analysis
• Growth Analysis
• Soils and Vegetation
Impact Analysis
• Visibility Impairments
Analysts
113. The Growth Analysis projects associated growth in the area,
estimates emissions caused by permanent growth, and
analyzes air quality resulting from the emissions.
Growth Analysis
• projection of associated growth
• estimates of emissions
• analysis of air quality
114. The Soils and Vegetation Impact Analysis uses the projected
air quality values to predict how soils and vegetation in the
area will be affected.
Soils and Vegetation
Analysis
• estimates effects on soils
and plants
115. Since different areas can have very different problems, this
will call for a survey of soil and vegetation types, projection
of ambient concentrations, and correlation of concentrations
with effects.
• survey of soil and vegetation
types
• projection of future ambient
concentrations
• correlation of concentrations
with effects
116. The Visibility Impairments Analysis is especially important
where a Class One area may be affected.
117. It uses special kinds of dispersion modeling to estimate the
effects of new emissions on the impacted area. It compares
these effects with existing visibility and the special value of
visibility in the area.
118. What we just finished describing—Applicability Determina-
tion, BACT Analysis, Air Quality Analysis, and Additional
Impacts Analysis—is what the applicant does. Why this focus
on the applicant?
• uses dispersion modeling to
estimate effects of raw
• existing visibility
• special value of visibility
• Applicability
Determination
• BACT Analysis
• Air Quality
Analysis
• Additional Impacts
Analysis
9-16
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Slide
Script
Selected Visuals
119. The answer to why the focus is on the applicant is found in
the Clean Air Act and supporting EPA regulations.
Clean Air Act
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120. Each of the steps we've spelled out is part of the demonstra-
tions the applicant is required to make. The law and regula-
tions repeatedly say things like: "The owner or operator of
such facility demonstrates . . . that emissions from construc-
tion or operation of such facility will not cause, or contribute
to air pollution in excess of increments, national ambient
standards, or other emission limitations.
121. The legal burden is put on the applicant —the organization
wanting to build or modify. It has to justify its possible using
up of part of a public resource—the available increment of
air quality for each pollutant that meets the significance test.
"The owner or
operator of such
facility
dempnstrates..."
122. Building and operating the new source or modification is
something we presume the applicant does, first of all, for its
own benefit. For this reason, the applicant has an incentive
to meet the requirements of PSD permit application.
123. But the new operation can benefit others, too. It can provide
jobs, goods, services, and a market that were not previously
available.
124. So getting the new operation in place and running may also
be a subject of legitimate interest to government at one or
more levels. This means that government agencies may help
the applicant with parts of the application. Sometimes the
agency that can help is the same one that will review the
application; often it is not.
9-17
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Slide
Script
Selected Visuals
125. None of this, however, takes away the basic responsibility of
the applicant. That is to prepare and defend a technically
sound, complete proposal. The application has to show how
the new source or modification will operate to comply with
the requirements of the PSD program.
126. We have seen the steps that the applicant performs to put
together a sound, complete application. In some ways., it is
like a legal brief in a law suit. It assembles the facts and
arguments which the applicant claims will show why it should
have a permit to build and run an operation as described.
127. If we don't push the comparison too hard, we can say the
applicant is like the plaintiff in a civil law suit. It has the
burden of proof'. The application has to convince an
unbiased observer that the proposed operation will comply
with the law and regulations. It also has the burden of going
forward with the action —to produce the facts and arguments
to support its case, without waiting to be asked specific
questions.
128. This is a good time to remind ourselves this is not a lawsuit.
We're talking about the administrative processing of a permit
application. With that comment in mind, we can roughly
compare the reviewing agency's role with that of a judge.
» DUTOCD of proof
1 burden of going forward
129. When the agency has a complete application in hand, it has
to become that "unbiased observer" we mentioned a moment
ago. The agency has to examine the facts and arguments
advanced by the applicant. If, after following procedures set
down by law, it decides the applicant should have its permit,
then it has to write a decision. The decision reviews why the
agency is convinced by the application, and sets out the terms
of the permit.
9-18
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Slide
Script
130. If the agency decides the applicant should not have a permit,
it has to write a justification of that decision. It may be a
denial, or it may be a requirement for more evidence and
argument.
Selected Visuals
131. In the next lesson, we will look briefly at how the reviewing
agency organizes and carries out its responsibilities in the PSD
application-review process.
132. (Credit slide)
133. (Northrop slide)
Coming up next. ..
the agency's role
Application Summary anO<
Introduction to Agency Review
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190: Momci Lnli*
Graphic*; IWt*« Hub*t
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Pholof»plr*/Audio: D».ld Churchill
.N*r»tlon: Rich Palm*!
Northrop Service*. Inc.
under
EPA Contract No. 68-02-3573
134. (Northrop slide)
Btttd In part on the:
1980 PSD Workshops
prepared for the
U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
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EPA CMHTOCI No. 44-02-3174
135. (NET slide)
Northrop
Environmental
Training
9-19
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SI:453
Lesson 10
Agency Review of the Application: I
Slide
1. (Focus)
Script
2. This is Lesson Ten, "Agency Review of the Application, Part
One."
Selected Visuals
FOCUS
l_ Agency Review _^
of the
Application :
I
3. Up to now, we've concentrated on the applicant's part in the
process that leads to a PSD permit for a proposed new source
or modification. In the last lesson, we reviewed the applicant's
steps in developing a sound, complete application.
4. The applicant carries the burden of convincing the reviewing
agency that the new source or modification should get a PSD
permit. It's the applicant who is in the best position to know
the technical and financial details of the source and possible
emission controls for it. The law and regulations say the
applicant has to demonstrate that the new operation will
comply with PSD requirements.
5. Specifically and concretely, this means the applicant must:
perform all the required analyses,
document the results clearly and concisely in the permit
application,
apply best available control technology where it's required,
and
comply with all permit conditions.
• perform analyses
• document results
• apply BACT
• comply with permit
conditions
6. However, the reviewing agency doesn't get to take it easy just
because the applicant has all this responsibility. The agency
isn't supposed to do the applicant's job, but it is supposed to
do its own job.
10-1
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Slide
Script
Selected Visuals
7. The reviewing agency is responsible for evaluating the PSD
application systematically, thoroughly, and expertly.
Reviewing Agency
• responsible for
evaluating
PSD application
8. It's also responsible for using the application and review
process to manage air quality in the region, helping to
balance economic growth and use of the air resource.
9. The Clean Air Act and EPA regulations do not spell out
detailed steps that each agency doing PSD reviews has to go
through.
10. There are several reasons for this. The most important reason
is that the PSD program is supposed to be carried out by the
States as pan of their implementation plans under the Act.
11. Over the past few years, this has worked out so that we have
four PSD review situations:
States with their own PSD permit authority,
States with full delegated authority from EPA,
States with partial delegated authority from EPA, and
States where EPA does the review and issues the permits.
States may have... .
their own penult authority under • SIP
lull delegated authority from EPA
partial delegated authority from EPA
no authority—EPA doea the review
and Imaucs the permit
12. In partial delegation, State or local agencies do most of the
review and send the package to EPA to issue the permit and
to enforce it.
10-2
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Slide
Script
Selected Visuals
13. The rules that a State agency follows in permit review have to
be compatible with the Clean Air Act.
State Rules
14. They have to get the results the Act calls for, and make sure
certain essential legal bases —like public participation —are
touched.
15. But the rules grow out of State law and practices at least as
much as out of the Clean Air Act. This means they can be
different in some ways from State to State.
16. We did say that the reviewing agency is responsible for a
systematic review. The process shouldn't have to be reinvented
every time a new application comes in. And applicants are
entitled to know what they have to do and what to expect
from the agency.
17. If you combine logical requirements of what needs to be done
with basic legal essentials, you get a suggested five-step process
for the reviewing agency. These five steps are:
The review process
should be
systematic.
— Steps in Permit Process —.
18. One, preapplication meeting,
I— Steps in Permit Process —,
• Preapplication Meeting
10-3
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Slide
Script
Selected Visuals
19. Two, completeness review,
I— Steps in Permit Process —,
• Preappllcation Meeting
• Completeness Review
20. Three, preliminary determination,
j— Steps in Permit Process —|
• Preappllcadon Meeting
• Completeness Review
• Preliminary Determination
21. Four, public review and comment, and
_ Steps in Permit Process —|
• Preappllcation Meeting
• Completeness Review
• Preliminary Determination
• Public Review and Comment
22. Five, final determination—including methods for
compliance checks.
_ Steps in Permit Process —i
Preapplication Meeting
Completeness Review
Preliminary Determination
Public Review and Comment
Final Determination
23. The preapplication meeting can shape the whole application
and review process. It should take place early in the
applicant's planning to build or modify. This meeting may be
more formal or less so, depending on agency standing rules
and policy. However, it should not be just a mechanical
acceptance or rejection of paperwork reviewed before the
meeting.
Preappllcation Meeting
• early
• formal or not
' not mechanical
acceptance or
rejection
24. The purpose of this meeting is to educate the applicant and
the agency, and to make some preliminary assessments.
• to educate applicant
and agency
• to make preliminary
assessments
10-4
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Slide
Script
Selected Visuals
25. The educating at the preapplication meeting should run in
both directions. Of course, the applicant has had an
opportunity to read agency regulations and application
instructions.
26. Agency staff has seen a written outline of the project proposal
for new construction or modification.
27. But the meeting is about whether and how these fit each
other.
28. Based on the project proposal and information exchanged at
the meeting, the agency and the applicant should come to an
agreement on a preliminary assessment.
29. This assessment is used to help decide whether PSD review is
required, and if so, which specific review requirements must
be met.
• whether PSD review Is required
• which review requirements
must be met
30. The preliminary assessment resulting from the preapplication
meeting provides essential information for both parties. It tells
the applicant, in outline, what engineering analyses have to
be done, and in what depth. It spells out for agency staff
what elements will be needed for a complete application.
10-5
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Slide
Script
Selected Visuals
31. A lot happens between the preapplication meeting and the
agency's second review step, the completeness determination.
0 Preapplication Meeting
^ D Completeness Determination
32. This is the time when the applicant does its detailed
Determination of Applicability, BACT Analysis, Air Quality
Analysis, and Additional Impacts Analysis. Of course, many
questions and answers may be exchanged between the agency
and the applicant, and perhaps with other government
agencies.
33. But when the agency receives what claims to be a complete
PSD permit application, it has to concentrate special effort
and time on reviewing that package. It also has to begin work
on involving other participants in later stages of review—for
instance, at this point the Federal Land Manager must be
notified if a Federal Class I area will be affected.
34. Completeness is a very important word in PSD permit
processing. A complete PSD application can start several
clocks running. The maximum time between the declaration
of a complete application and the issuing or denying of a per-
mit is set by the Clean Air Act as one year.
PSD
Application
35. Remember that the baseline date for each pollutant in an
area is triggered by receipt of the first complete PSD
application for that pollutant. An earlier complete application
may have priority for using available increment over a later
one. In some agencies, the permit must be issued or denied
within a rather short fixed time after receiving a complete
application.
PSD
Application
helps
define
10-6
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Slide
Script
Selected Visuals
36. The EPA regulations say a complete application "contains all
of the information necessary for processing the application."
"...all o( the information
necessary for processing
the application"
37. In talking about State agency review, the regulations say this
doesn't mean the agency can't ask for or accept additional
information.
38. But remember we said that a PSD permit application isn't a
fill-in-the-blanks sort of thing. The reviewing agency can't just
go through a form—or a bundle of forms, like a complicated
tax return —and see if all the blocks are filled in. To check an
application for completeness, the agency has to have some of
their technical staff go through it. These engineers or
technicians need to have the kind of knowledge and
experience that makes them able to judge whether an
application contains all the information necessary to process
it.
39. This gives the agency a fairly difficult job to begin with. The
idea at this stage is not to launch a detailed evaluation of the
project described by the application. What is needed is a
quick, reliable determination that the agency has enough
information in hand to proceed to its detailed analysis.
40. Much of the effort in the completeness review focuses on
evaluating the applicant's determination of applicability.
Important yes-no questions of applicability should be dealt
with in the prerapplication meeting stage.
41. But there are still questions of what review and how much
must be done for specific units within the proposed
construction or modification.
• What review?
• How much review?
10-7
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Slide
Script
Selected Visuals
42. There are five areas of concentration in the agency's
evaluation of applicability. They are:
First, identification of the source and proposed
construction,
Second, examination of emissions estimates,
1. Identification of the Source
2. Examination of Emissions
Estimates
43. Third, examination of location,
Fourth, checking of the applicability tests, and
Fifth, examination of exemptions.
1. Identification of the Source
2. Examination of Emissions
Estimate*
3. Examination of Location
4. Checking of the Applicability
Tests
5* Examination of Exemption*
44. In going over the application for completeness, the agency's
reviewer will be helped considerably by having experience with
other applications. A checklist like the one suggested in
Appendix Two of the PSD Workshop Manual is also a great
help.
45. The reviewer needs to know what common omissions and
errors to check for.
46. These happen most often in the areas of source definition
and making emissions estimates. A careful check of which
emissions units are counted and how their emissions are
estimated and netted is in order.
• Which emissions units are
counted?
• How are their emissions
estimated and netted?
10-8
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Slide
Script
Selected Visuals
47. Because completeness determination has such legal
significance, many agencies will issue a formal notice to the
applicant and the public when they decide they have a
complete application. From this point, agency review goes on
and intensifies, leading to the next step that is seen by the
applicant and public—preliminary determination.
48. Before the agency can issue a preliminary determination, it
has to review each of the applicant's engineering analyses:
—Applicability,
— Best Available Control Technology,
— Air Quality, and
— Additional Impacts.
49. All of these reviews are internal. They take place, within the
reviewing agency.
— Review of Analyses —•"
• Applicability
• BACT
• Air Quality
• Additional Impacts
50. As we have so often emphasized before, the application is a
detailed engineering analysis performed by the applicant. The
agency does not do an analysis for the applicant, and
shouldn't just re-do the various analyses in the review.
51. The completeness determination concentrated on the informa-
tion and conclusions in the applicant's applicability
determination. This is because of the important questions of
which units to include and what level of review to do on them.
A
Mlicab
i APillcabllity
^Determination.
52. But completeness review has to go on to check for data in
each of the major analysis steps.
Data Check
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Script
Selected Visuals
53. There is also an overlap from the completeness determination
into the general review. The agency has to go over the
Applicability Determination at a more stringent level of
detailed technical review before going on to review of the
BACT Analysis.
54. In reviewing the Best Available Control Technology Analysis,
the agency has to keep in mind that the applicant is
proposing a set of emissions limitations. The agency reviewer
may believe that more stringent controls can be achieved
within the BACT criteria. Any such decision must be based on
solid factual information, for example from the EPA Clear-
inghouse or technical reports.
55. Disagreements on the specific continuous emissions reduction
representing BACT may call for requests for additional
information, informal meetings, and negotiation.
P_ Review of BACT Analysis -^
* reviewer miut keep In mind that
applicant l« proposing emission
limitations
• more stringent controls may be
achievable
56. Of course, reviewing the BACT Analysis requires engineering
knowledge and experience. There are four questions that
guide the application of that knowledge and experience:
— Is the analysis complete? This applies to both pollutant
coverage and emissions units.
O I* the analysis complete?
57. —Is the analysis thorough? This deals with identifying
alternatives and looking at them deeply enough.
a
a
Is the analysis complete?
Is the analysis thorough?
58. —Are the cost estimates used reasonable?
D
D
D
Is the analysis complete?
Is the analysis thorough?
Are the cost estimates
reasonable?
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Selected Visuals
59. —Has the applicant made a good faith effort in proposing
BACT?
Q Is the analysis complete?
G Is the analysis thorough?
O Are the cost estimates
reasonable?
Q Has applicant made good-
faith effort?
60. To get a "yes" answer to these questions, the reviewer may
have to get more information from the applicant. When,
finally, all the answers are "yes," the agency can write up
BACT as Federally enforceable permit conditions specifying
a system of continuous emission reduction.
61. In moving on to reviewing the Air Quality Analysis, the
agency may have to call on reviewers with different skills and
experience—in dispersion modeling. These reviewers are
looking at six critical items in the application:
Review of
_ Air Quality Analysis —
agency may have to call on
reviewers who have knowledge
of dispersion modeling
62. — Which pollutants require air quality analysis,
1 which poUntants require analysis
63.
—A clear description of the source or modification,
1 which pollutants raquir* analysis
clear description of source or modification
64. —Dispersion model selection and use,
1 which pollutants r*qutra analysis
clear description of source or modification
disperston model selection and use
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Script
Selected Visuals
65. — Existing air quality determination,
> which poUmanta raqnin analyata
claar daaertptlon of aourca or modification
dunanloa modal Mlactlon and UM
pining «lr quality d«t«rmln«llon
66. —Class One area impacts, if any, and
•Uchpolln
matin! air quality
Oaaa I area hnpacta
67. —Compliance with National Ambient Air Quality
Standards and allowable increments.
clear description of aourca or modification
•Hating air quality datamUnanon
Clara I area Impacta
compUaoca with NAAQ3 and allowable
68. For the Air Quality Analysis review, the agency is likely to be
working with large volumes of data, on paper and in
computer files.
69. If the application is for a source of some complexity and size,
there are likely to be detailed Modeling and Monitoring
Plans. The details of these plans should have been worked out
in preapplication meetings. In the review stage, the agency is
checking to see that the plans have been carried out, and have
produced usable information.
70. As far as possible, the agency keeps its review of Air Quality
Analysis limited to checking of data and procedures. Doing
over-the applicant's calculations could be expensive and time-
consuming, especially in the area of dispersion modeling.
Checking of
Data and Procedures
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71. Since the Additional Impacts Analysis has such flexible basic
requirements, the agency also has to be flexible in its
approach to reviewing it. The professional backgrounds of the
reviewers and the amount of time and effort required will vary
with the pollutants to be dealt with and the areas that are
affected.
Review of
• Additional Impacts Analysis •
• agency should be flexible in
its approach to the review
72. Also, the Additional Impacts Analysis doesn't compare
projected impacts with fixed levels of acceptability, the way
NAAQS or increment impact analysis does. With Additional
Impacts, the idea is to present clearly the projected effects of
the source and associated activity, so informed value choices
can be made about them. So the reviewer has to ask not only,
"Is the analysis technically correct?" but, "Can the public
understand the results?"
•• Big question...
"Can the public understand
the results?"
73. For these reasons, the reviewer has four special questions to
ask in going over the steps of the applicant's Additional
Impacts Analysis:
One, is the description of soils, vegetation, and visibility
in the impact area both clear and technically accurate?
74. Two, are the projected impacts correctly estimated, and
does documentation back up the projections?
1. Is the description of the
impact area clear and
accurate ?
2. Are the projected impacts
correctly estimated and
doeii documentation back
them up?
75. Three, are the data presented logically, so the reviewer and
the public can follow the reasoning? This would include
starting with a growth analysis, then presenting an
emissions projection, and continuing with a soils and
vegetation analysis, and then a visibility analysis.
3. Is the data presented logically?
• Growth Analysis
• Emissions Projection
• Soils and Vegetation Analysis
• Visibility Analysis
76. Four, does the analysis make clear to everyone —applicant,
reviewer, and public —the potential impacts of the
proposed construction?
4. Does the analysis make
clear the potential impacts
of the proposed
construction?
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77. At this point, it isn't hard to see that the agency is getting its
internal review process set to move to the next big step. That
is the third step in the overall review process, preliminary
determination. We'll begin with that step in Lesson 11.
0 Preapplication Meeting
3 Completeness Determination
>D Preliminary Determination
78. (Credit slide)
Agency Review
f **»" Application: I •
• ot the AppU
I Titfcrtcil CoMtMti
I iMtmctloMl D«*f>:
| -^-Taag
79. (Northrop slide)
— piodncidby:'
I North
I EPA Con
Northrop Services. Inc.
under
EPA Contract No. 6*02-3573
80. (Northrop slide)
1980 PSD Worlubop*
U.S. EnvlronnicntaJ Protection
Agency
Office of Alt Quality Planning and
Standard*
81. (NET slide)
Northrop
Environmental
Training
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SI:453
Lesson 11
Agency Review of the Application: II
Slide
1. (Focus)
Script
2. This is Lesson Eleven, "Agency Review of the Application,
Part Two."
Selected Visuals
FOCUS
_ Agency Review _^
of the
Application;
II
In the previous lesson, we began to talk about the reviewing
agency's role in the PSD permit process. We emphasized the
applicant's responsibility to produce as an application a
thorough engineering analysis of the proposed new source or
modification.
• applicant to propose
a thorough engineering
analysis of proposed
new source or
modification
4. The reviewing agency, we said, is responsible for evaluating
the application through a process of thorough, expert, and
systematic review.
reviewing agency to
evaluate the applicant
through review that is:
• thorough
• expert
• systematic
5. We then examined the first two steps in this review process:
the preapplication meeting and the completeness review.
\. Preapplication Meeting
2. Completeness Review
After the agency receives an application and determines that
it's complete, it carries out the detailed internal review that
leads to the preliminary determination. In this lesson, we
will examine the last three steps of the agency review:
Three, preliminary determination,
Four, public review and comment, and
Five, final determination.
Then we will briefly review the PSD process as a whole.
3. Preliminary Determination
4. Public Review and
Comment
5. Final Determination
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7. The preliminary determination is the reviewing agency's state-
ment of its initial judgement of what to do about the proposed
new source or modification.
initial judgement
8. This judgement is based on the expert review of the applica-
tion by agency staff.
9. The determination states the agency's conclusions about
whether the applicant should get a PSD permit, or not, but it
does much more.
• states agency's
conclusions about
whether or not
applicant should get
PSD permit
10. The preliminary determination is a legal notice to those who
will be involved in the next major step —public review and
comment.
11. These participants include the applicant, other government
agencies, and the general public.
• legal notice
• to those involved In
public review and
comment
12. The notice of determination has to do more than state the
agency's preliminary conclusions. It has to summarize the
data and the reasoning leading to those conclusions.
.Notice of determination must... _,
• state preliminary
conclusions
• summarize data and
reasoning
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13. Because the preliminary determination is, among other things,
a legal notice, its exact form will be different from one
jurisdiction to another. However, there are things that need to
be covered in any notice of preliminary determination. A
simple example format is given in Appendix One of the PSD
Workshop Manual.
14. The suggested format organizes the necessary information into
five sections. Some are very short, others longer. The
sections are:
One, Applicant identification,
Two, Location of proposed source or modification,
Three, Project description,
Four, Source impact analysis, and
Five, Conclusions.
Example of format for
preliminary determination can
be found in:
PSD Workshop Manual
Appendix 1
1. Applicant Identification
2. Location of Proposed
Source or Modification
3. Project Description
4. Source Impact Analysis
5. Conclusions
15. The first section, applicant identification, is the shortest. It
just states who—corporation, partnership, persons, or
whatever —has applied for the PSD permit. It also gives the
mailing address for reaching the applicant.
1. Applicant Identification
• who has applied for the
permit
• mailing address
16. The second section is only a little longer. There is usually
more than one way to describe the location of the proposed
source or modification. These have to do with where it is
legally, where it is on the map, how you would get to it, and
what kind of mental picture you can form of it. You'll usually
find at least three methods of describing location:
• Political subdivision—county, parish, borough, or the likes,
• Map coordinates, and
• Street or road location.
2. Location of Proposed
Source or Modification
• political subdivision
• map coordinates
• street or road location
17. The third section is project description. This is not very
detailed. It aims at an overview of the proposed project, with
necessary technical data coming later. The emphasis should be
on the amount—or change in amount—of fuel burned or
product processed.
3. Project Description
• overview
• emphasis on amount - or
change in amount • of
fuel burned or product
processed
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18. The fourth section, source impact analysis, is likely to be
much longer than the others. It is a summary of the results of
the application's analysis steps and the agency's review.
Whether you're preparing one of these or trying to read it, it's
important to remember that it's a summary. The detailed
technical information that backs up the analysis is a matter of
public record, available in the application and agency records.
4. Source Impact Analysis
• summary of analysis
step* and review process
19. Exactly what goes into the source impact analysis depends on
the source and the review it received. The analysis should
begin with a short introduction describing:
• What items the application was reviewed for,
• Why these items were reviewed,
• What portions of the regulations apply to the review,
• Which pollutants make the source or modification major,
and
• What air quality standards and increments apply to the
air quality review.
20. The source impact analysis goes on to summarize each of the
analyses in the application, together with the agency's conclu-
sions from its review of the analyses.
what Items reviewed for
why
what regulations apply
which pollutants
what AQ standard*/
increments apply
• summarizes each analysis
21. At each stage, a reader should be able to tell:
• What was analyzed,.
• What method was applied,
• What data, alternatives, and so on, were used, and
• What the result was, both from the applicant's analyses
and the agency review.
• what was analyzed
• what method wa* applied
• what data. etc.. were used
• what the result was
22. This means the preliminary determination summary will boil
down Applicability, BACT Analysis, Air Quality Analysis,
and Additional Impacts Analysis to a few pages. The guiding
principle is to inform the persons who will take part in the
public review and comment process. They need to know what
the issues are, what arguments are raised about the issues,
and what facts and expert judgements back up the arguments.
inform persona involved in
public review and comment
about:
• issues
* arguments
• facts
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23. The fifth and final section of the preliminary determination
summary is conclusions. The first thing it should deal with is
whether or not the agency recommends approval of the per-
mit application. Then the agency says why it recommends
approval or disapproval, citing the specific parts of the
application and review record involved.
5. Conclusions
• does the agency
recommend approval?
• why>or why not
24. If the agency recommends approval, the conclusions go on to
spell out proposed permit conditions.
• permit conditions
25. These are legally binding means to make sure the new source
or modification does the things that keep it within the
requirements of the PSD regulations.
26. Permit conditions will include:
• Federally enforceable emission limitations reflecting
BACT,
• emission limitations reflecting
BACT
27. • Design, work practice, or other standards where quan-
titative emission limits can't be set,
• emission limitations reflecting
BACT
• design, urork practice, or other
standards
28. • A method to check emission levels after startup, and
• emission limitations reflecting
BACT
• design, work practice, or other
standards
• method to check emission levels
after startup
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29. • Methods for checking compliance with limitations during
the term of the permit.
• emission limitations reflecting
BACT
• design, work practice, or other
standards
• method to check emission levels
after startup
• methods for checking compliance
with limitations
30. From here, things move on to the fourth overall step, public
review and comment.
SPnappllci
5 PnUmlMnr Determination
*C Public Review and Comment
31. EPA has a special set of regulations dealing with this.
32. The States that process PSD permits have their own individual
laws and regulations.
EPA Regulations
State Regulations
33. Lawyers usually sum up the requirements of such rules under
the words notice and hearing. These work out to informa-
tion, opportunity to participate, and knowledge of the
outcome.
•" "Notice and Hearing"—
• information
• opportunity to participate
• knowledge of the outcome
34. Some of the routine notice is made when the application is
received and when the applicability determination is made.
When the preliminary determination is issued, very extensive
notice is required.
35. The agency has to notify the public — by advertisement in a
newspaper of general circulation where the project is —about
four items:
— the application,
— the agency's preliminary determination,
— the expected degree of increment consumption, and
— the opportunity to comment at a public hearing or in
writing.
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36. For most agencies, there will be more notice than this,
including publication in an official register and mailings to
associations and interest groups. The notice is generally brief,
summarizing the results of the preliminary determination,
increment consumption, and the opportunity to comment, in
writing or in person.
37. At the same time, the agency notifies any other parties who
might take part in the permit hearing. Of course, this includes
the applicant. It also includes EPA, government officials
responsible for the place where the project is, other State and
local air pollution control agencies, city and county chief
executives, and other concerned officials.
38. The brief notice has to be backed up by making more infor-
mation available. At a minimum, this means there is one
place in the region where the construction will take place ,
where people can go to examine the public comment package.
39. This has to include at least:
• The applicant's complete application and any other infor-
mation submitted,
• The preliminary determination, and
• Copies or summaries of any other information used by the
agency to make its preliminary determination.
40. That was notice. Hearing means that everyone who received
notice is entitled to comment on the agency's proposed action.
They can do this by submitting written testimony, or they can
appear before the hearing examiner, board or panel and give
oral testimony.
• complete application
• preliminary determination
• copies/summaries of other
Information used in
preliminary determination
41. Comments can address:
• air quality impacts,
• alternatives to the source,
• control technology, or
• anything else that relates to the PSD effects of the project.
• air quality impacts
• alternatives to the source
• control technology
• other
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Script
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42. There may be several public hearings for a major project with
extensive impacts. The comment record is always held open
for a period of time that was spelled out in the notice.
43. When the agency has received all the comments, it has to
reach a final decision by a time that was also given in the
notice.
1982 !
SEPTEMBER
15 1
2Sl W*dn»»
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Script
Selected Visuals
48. The permit is a legally binding document that spells out all of
the basic obligations the applicant has under PSD. It also con-
tains all of the conditions needed to make sure the source is
built and operated to meet the regulatory requirements.
—— Permit ———
• legally binding
document
• spell* out all basic
obligations
• contains all conditions
49. With approved permit in hand, the applicant is entitled to
commence construction on the new source or modification.
When the construction is complete, the source can legally
operate as long as it meets the conditions of the permit.
50. We've come a long way to get that permit into the applicant's
hand. We paused after talking about how the applicant builds
the application to review the major technical points of the
application process. Now, let's back off a little and review very
broadly where we've been.
51. We started out by talking about what Prevention of Signifi-
cant Deterioration is and where it came from.
prevention of
Significant
Deterioration
52. From 1970 to 1977, there was continuing controversy and
litigation over the meaning of the words, "protect and
enhance the quality of the Nation's air resources," in the
Clean Air Act.
"protect and enhance
the quality of the
Nation's air resources"
53. EPA promulgated PSD regulations in 1974 in response to a
court order in the Sierra Club versus Ruckelshaus lawsuit.
•EPA Regulations-
1974
Sierra Club v. Ruckelshaus
54. Those regulations stirred up argument, but they also laid the
groundwork for the thinking that went into the PSD provisions
of the Clean Air Act Amendments of 1977.
1977
Clean Air Act
Amendments
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55. The basic idea behind those first regulations and the Amend-
ments is fairly simple. We have National Ambient Air Quality
Standards to protect the public health and welfare from the
effects of air pollution.
National
Air
Quality
Standards
56. But there are many areas where air quality is better than
some of the ambient standards.
57. Such areas shouldn't be allowed freely to deteriorate toward
just meeting the standards without informed decisions being
made about what's being traded for the loss of superior air
quality.
58. That's where the word significant came in. It's impractical
and undesirable to try to "freeze" ambient air quality.
"significant"
59. In general, we want it to get better, or not get enough worse
to make a difference to us.
• better
or
• not enough worse
to make a difference
to us
60. Much of the complication in the law and regulation has to do
with deciding what makes that difference.
61. Congress adopted the idea of allowable increments for two
pollutants, TSP and SO2.
ISP
soz
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Script
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62. An increment is an increase in the concentration of a
pollutant.
•• Increment —
• Increase in the
concentration of a
pollutant
63. The law sets maximum allowable increases of TSP and SO2
concentrations for different averaging times and different
classes—One, Two, or Three—of PSD areas.
^—^- Increment —•—
• Increase In the
concentration of a
pollutant
• over different averaging
• for different classes of
64. The Clean Air Act requires EPA to adopt regulations to pre-
vent significant deterioration for the other criteria
pollutants—carbon monoxide, ozone, nitrogen dioxide, and
lead. EPA's system doesn't have to use increments for these
pollutants, but it can.
65. Closely tied to the increment idea is the designation of PSD
areas and area classifications.
• PSD areas
• area classifications
66. Any area that is attainment—or that cannot be classified as
attainment or nonattainment —for any National Ambient Air
Quality Standard is a PSD area for that pollutant.
Attainment Unclassifiable
PSD area
67. PSD areas come in three classes, depending on how strictly
they are protected. Class One areas have small allowable
increments and other special protections, including restrictions
on redesignation and special permit review considerations.
CUn I -tm.il .llow.&U
Increment*—and odm
protection*
68. Class Three areas have the largest available increments.
Claw I -small allowable
Increment*—and other
protection*
Clan III -largctt Increment*
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69. Class Two areas fall in between.
OBM! -
tncrnanitt-md other
OM« n -in b«tw««o
ClaM Ul -lugwt taCMUiauu
70. But no matter what an area's class is, no increase is allowed to
take the area over any ambient standard.
Ambient standards
may never
be exceeded.
71. Deciding what class an area will be is a job divided among
Congress, Federal agencies, and the States.
Classification,
72. ^classification requires public participation and agreement
from certain important parties, like Federal Land Managers.
Reclassification
73. The method for ensuring that the ambient standards,
increments, and other values are protected is case-by-case
review of proposed new sources of air pollutants or modifica-
tions to them.
74. The Clean Air Act lays down some of the basic features of this
new source review process for PSD.
§ * ^-^fti
I °— «• I
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75. EPA describes its review procedures in its regulations at 40
CFR52.21.
76. State Implementation Plans must provide for prevention of
significant deterioration of air quality. The regulatory
requirements for PSD SIPs are at 40 CFR 51.24.
©
77. To understand generally how this process for reviewing pro-
posed new sources or modifications works, we broke it down
into several parts. First, we concentrated on how the
applicant—the organization that wants to build the
project—puts together its permit application.
78. Second, we turned to how the government agency responsible
for issuing the permit reviews that application.
79. In fact, we spent most of our time on the application process.
The reason for this emphasis is straightforward. The applica-
tion is a detailed engineering analysis by the applicant. Its
purpose is to demonstrate that the proposed construction can
meet all PSD requirements. If the application can persuade
the reviewing agency and public, the applicant gets a permit.
If not, no permit.
80. The application, we saw, is made up of four major steps:
One, Applicability Determination,
Two, Best Available Control Technology Analysis,
Three, Air Quality Analysis, and
Four, Additional Impacts Analysis.
.The Application. . ..
a detailed engineering
analysis
1. Applicability
Determination
2. BACT Analysis
3. AQ Analysis
4. AI Analysis
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81. The first major step, Applicability determination, is con-
cerned with whether PSD review applies to the project, and if
it does, how much. The key questions had to do with
geographic applicability—is the area attainment or
unclassifiable? — and source applicability—is the source or
modification major?
82. To answer these questions, we saw that the applicant had to
deal with a number of topics. The most important of these
were:
• Source definition,
• Potential to emit pollutants regulated under the Clean Air
Act,
• Major source and modification definitions, and
• Three applicability tests.
83. The second major step, BACT Analysis, is concerned with
designing an emission control strategy for the new emission
units. The analysis arrives at a set of emission limits that
reflect the maximum degree of reduction of each pollutant
regulated under the Clean Air Act. To decide whether a
reduction is achievable, the analysis considers energy,
environmental, and economic impacts. You should note that
BACT applied to new applications does change over time, as
technology advances.
1. Applicability
Determination
• doea PSD review apply?
• how much?
• geographic applicability
• eourca applicability
• potential to emit
• three applicability ton
2. BACT Analysis
• designing an emtMlofl
• maximum reduction of
each pollutant
• energy, environmental.
and economic Impact!
84. The BACT Analysis is organized into four steps for assem-
bling the data, and three impact analyses.
4 Steps
3 Impact Analyses
85. The four steps of BACT Analysis are:
One, Pollutant Applicability,
Two, Emissions Unit Applicability,
Three, Identification of Potentially Sensitive Concerns, and
Four, Selection of Alternative Control Strategies.
86. The alternative control strategies are tested and ranked by
three Impact Analyses:
• Economic,
• Energy, and
• Environmental.
•Slepa-
•Stepa-
PMCMUllv
MCo
of Alur-
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Script
Selected Visuals
87. The product of the BACT Analysis is a decision on a set of
controls to apply on the emission units of the new source or
modification.
BACT
Controls
88. Projecting the operation of the source with these controls pro-
duces a set of emission rates for the pollutants under study.
These emission rates are proposed permit conditions, and
they are also the basis of the two following analyses, Air
Quality and Additional Impacts.
emission rates
• permit conditions
• basis of AQ and AI
analyses
'IP
89. The third major step in the application process is Air Quality
Analysis. It aims at making sure that emissions from the new
operation will not violate any National Ambient Air Quality
Standards or allowable increments. It also examines the
effects on air quality of emissions of any pollutant regulated
under the Clean Air Act.
3. AQ Analysis
not vlolat* NAAQS Of
> •unlna eff«cti of ill CAA-
nguUtod pollutant*
90. Data on air quality can be obtained by measurement or
estimation.
91. Some measured data that goes into the baseline air quality
may be available from government monitoring, but the appli-
cant may have to actually monitor air quality.
92. Estimated air quality—present or future —is obtained from
dispersion modeling.
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93. This means that, generally, the applicant has to put together
two plans for Air Quality Analysis: a Monitoring Plan and a
Modeling Plan.
Monitoring
Modeling
94. The complicated work of measuring and estimating air quality
data is organized into five basic steps and three interrelated
phases.
• 5 Basic Steps
• 3 Phases
95. The five steps are:
One, Impact area definition,
Two, Emission inventory compilation.
Three, Existing concentration determination,
Four, Screening analysis, and
Five, Air quality projections.
96. The three interrelated phases are:
One, Increment consumption analysis,
Two, Existing air quality determination, and
Three, Projected air quality analysis.
1. Impact Area Definition
2. Emission Inventory
Compilation
3. Existing Concentration
Determination
4. Screening Analysis
5. Air Quality Projections
1. Increment Consumption
Analysis
2. Existing Air Quality
Determination
3. Projected Air Quality
Analysis
97. The Air Quality Analysis produces a detailed description of
present and future ambient concentrations of the pollutants
studied. This is important for showing that the proposed
project will not exceed any standards or increments. It is also
important for the final step of the application process.
detailed description of
present and future
ambient concentrations
of pollutants
98. The fourth major step in the application, Additional Impacts
Analysis, is concerned with the effects of the source on air-
quality-related values. These are: soils, vegetation, and
visibility.
4.
AI Analysis
• effects on atrKnialUvreuued
values
• soils, vegetation, and
visibility
99. The Additional Impacts Analysis is put together from three
component analyses:
• Growth Analysis,
• Soils and Vegetation Impact Analysis, and
• Visibility Impairment Analysis.
* Growth Analyst*
• Solla and Vegetation Impact
Analysis
• Visibility Imi
Analysis
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100. The Additional Impacts Analysis produces a description of
how the proposed project's operation will affect values — both
economic and esthetic —in the impact area.
• how proposed project
will affect values:
• economic
• utlMtlc
101. This provides needed data for BACT decision-making, public
information, and Federal Land Managers' decisions.
> provides needed data
for:
• BACT dtcUlom
• public Information
• Fxtanl Und Mnugv'i
dcclilom
102. We moved on from the completed application to the reviewing
agency's role in the PSD application and review process. The
emphasis was again on the applicant's responsibility to pro-
duce a complete engineering analysis in the application.
103. We began the last lesson with a general description of the
agency review process, and concluded that description at the
beginning of this lesson.
104. Actually, the agency's work begins before it receives an
application. However, the heavy work conies after the applica-
tion is received.
105. We broke the review down into five steps:
One, Preapplication meeting,
Two, Completeness review,
Three, Preliminary determination,
Four, Public review and comment, and
Five, Final determination.
G Preapplicatlon Meeting
D Completeness Review
Q Preliminary Determination
O Public Review and Comment
D Final Determination
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106. The agency review results in a legally binding administrative
decision.
107. The agency may decide to disapprove the permit. If it does,
the applicant will have to decide whether to change its plans
for the proposed source or modification, or pursue some alter-
native plan.
108. An approved permit will carry conditions to make sure the
project is built and operated in accordance with PSD program
requirements.
109. This completes what we have to say about the PSD law and
regulations in this course. It's been pretty long and com-
plicated. You may feel you've learned more than you ever
wanted to know about the subject.
110. But in fact, we've really only done what we promised in the
course title—we've given you an overview. Behind every
paragraph of what we've said here, there are chapters of
greater detail. >
111. There's no denying the PSD program is complicated. If you're
going to work with it, you'll have to read guidelines, journal
articles, official notices, applications, and even court cases.
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Script
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112. The best way to pick up some information will be to talk with
people who work with PSD every day.
113. And one last thing—be ready for the program to change.
Some changes may be big and sweeping; you should see
something about them in the news.
114. But some may seem small and technical, and still have a
major effect on what you're interested in. Those, you may
have to watch the Federal Register for. Good luck with your
continued learning.
115. (Credit slide)
Agency Review
•of the Application
••^••of the Application: U^^MM
I T*chMc4 COMMI: Johe MWOM* ' I
I (oMracllMMl Dml«ai Monk* Umlto I
I Grapfcki: KMftvWcrd I
I Phot»»M*H» iWto Oi*M Churchill I
I Narnnoa: Rick P*l«w» I
116. (Northrop slide)
• Developed and
produced by:
Northrop Services. Inc.
EPA Contract No. 68-02-3573
117. (Northrop slide)
1980 PSD Work.hop.
( j U.S. Environmental Protection
Agency
Office of Air Quality Planning and
Standards
118. (NET slide)
Northrop
Environmental
Training
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