WORKSHOP ON IMPLEMENTING
THE
DECEMBER 2, 1980 VISIBILITY
REGULATIONS
MARCH 10-11, 1981
RALEIGH, NORTH CAROLINA
MARCH 16-17, 1981
DENVER, COLORADO
MARCH 19-20,1981
SEATTLE, WASHINGTON
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WORKSHOP ON IMPLEMENTING
THE
DECEMBER 2, 1980 VISIBILITY
REGULATIONS
Prepared by
PEDCo Environmental, Inc.
505 South Duke Street
Durham, North Carolina 27701
CONTROL PROGRAMS DEVELOPMENT DIVISION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
MARCH 1981
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CONTENTS
Page
Workshop Agenda and Speakers
1.0 Introduction 1
2.0 Scope of the Regulations 7
3.0 SIP Requirements 21
3.1 BART 21
3.2 FLM/State/EPA Coordination 23
3.3 Integral Vistas 24
3.4 Long-Term Strategies 25
3.5 New Source Review 27
4.0 Monitoring Requirements 53
5.0 Phase II 59
6.0 Preparation of the SIP 62
7.0 Modeling Requirements 67
8.0 Monitoring Guidance 72
9.0 FLM Responsibility 76
ii
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AGENDA
WORKSHOP ON IMPLEMENTING THE
DECEMBER 2, 1980 VISIBILITY REGULATIONS
TIME
TOPIC
SPEAKER
DAY 1
8:30 Registration
9:00 Welcome
Introduction
Scope of the Regulations
10:15 BREAK
10:30 BART
Open Discussion
FLM/State/EPA Coordination
Open Discussion
12:00 LUNCH
1:30 Integral Vistas
Open Discussion
Long-Term Strategies
New Source Review
Open Discussion
3:00 BREAK
3:15 Monitoring Requirements
Phase II
Preparation of SIP Submittal
Panel Discussion
Darryl Tyler
Robert DeSpain
Richard Thiel
David Dunbar .
Johnnie Pearson
Julie Home
Julie Home
Julie Home
Johnnie Pearson
Johnnie Pearson
David Dunbar
David Dunbar
John Pratapas
Regional Office
Representatives
5:00
ADJOURN
i i i
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AGENDA (continued)
TIME
TOPIC
SPEAKER
DAY 2
8:30 Group Discussion
Modeling Requirements
Technical Aspects of Modeling
10:00 BREAK
10:30 Monitoring Guidance
Technical Aspects of Monitoring
Open Discussion
12:00 LUNCH
1:30 Federal Land Manager Responsibilities
Open Discussion
3:30 ADJOURN
Johnnie Pearson
David Dunbar
Doug Latimer
David Dunbar
William Malm
Victoria Evans
iv
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SPEAKERS
Darryl Tyler
Acting Director
Control Programs Development Division
U.S. Environmental Protection Agency, MD-15
Research Triangle Park, North Carolina 27711
Robert DeSpain
Air Branch Chief, RO VIII
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Richard Thiel
Air Branch Chief, RO X
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
David Dunbar
Associate Branch Manager
PEDCo Environmental, Inc.
505 South Duke Street, Suite 503
Durham, North Carolina 27701
Johnnie Pearson
Environmental Engineer
Control Programs Development Division
U.S. Environmental Protection Agency, MD-15
Research Triangle Park, North Carolina 27711
Julie Home
Environmental Engineer
Control Programs Development Division
U.S. Environmental Protection Agency, MD-15
Research Triangle Park, North Carolina 27711
John Paratpas
Environmental Engineer
Control Programs Development Division
U.S. Environmental Protection Agency, MD-15
Research Triangle Park, North Carolina 27711
v
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SPEAKERS (continued)
Doug Latimer
Systems Applications, Inc.
950 Northgate Drive
San Rafael, California 94903
VJi 11 iam Malm
Environmental Monitoring and Support Laboratory
U.S. Environmental Protection Agency
Post Office Box 15027
Las Vegas, Nevada 89114
Victoria Evans
National Park Service
Air Quality Programs (492)
Room 3021, Main Interior Building
Washington, D. C. 20240
vi
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1.0 INTRODUCTION
I. History of Promulgation
A. Friends of the Earth, Inc. v. Costle No. 80-3081 - Inability
of the Agency to promulgate within statutory deadline.
B. ANPRM - November 30, 1979 (44 FR 69116) purpose - (1) provide
background information on the key components of the regulatory
program, (2) outline tentative positions, and (3) solicit
public comment.
C. Designation of mandatory Class I Federal Areas where visibil-
ity is an important value (44 FR 69122).
D. Proposed Rulemaking - May 22, 1980 (45 FR 34762) - (1) purpose
to publish proposed language for the regulatory program and
(2) solicit comment.
E. Public Hearing - January 30, 1980 (Washington, D.C.), July 2,
1980 (Salt Lake City) - purpose - to hear oral presentation of
comments.
F. Notice of Guideline Availability - July 23, 1980 (45 FR 49110)
purpose - to announce document availability and solicit com-
ments.
G. Extension of comment period July 23, 1980 (45 FR 50825).
H. Notice of Final Rulemaking - December 2, 1980 (45 FR 80084).
II. Guideline Documents
A. Protecting Visibility: An EPA Report to Congress (EPA-450/
5-79-008).
B. The Development of Mathematical Models for the Prediction of
Anthropogenic Visibility Impairment (EPA-450-3-78-110,a,b,c).
1
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C. Guidelines for Determining Best Available Retrofit Technology
for Coal-fired Power Plants and Other Existing Stationary
Facilities (EPA-450/3-80-009B).
D. Assessment of Economic Impacts of Visibility Regulations
(EPA-450/2-80-084).
E. User's Manual for the Plume Visibility Model (PLUVUE) (EPA-
450/5-80-032).
F. Workbook for Estimating Visibility Impairment (EPA-450/5-80-
031).
G. Interim Guideline for Visibility Monitoring (EPA-450/2-80-
082).
2
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[-2SS5I
Visibility
i anna
NOTES
NOV 197V
History of Promulgation
of Visibility Regulations
Friends of the Earth, Inc
vs.
Costle
3
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NOTES
AIMPRM
November 30, 1979
Designation of mandatory Class I Areas where
visibility is an important value . . . November 30,
1979
"Proposed
Rulemaking May 22, 1980
• Public
Hearing June 30 and
July 2, 1980
• Notice of Availability of Guidelines
July 23, 1980
• Extension of Comment Period
July 23, 1980
4
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GUIDELINE DOCUMENTS
Protecting Visibility: An EPA Report to Congres^.
EPA-450/5-79-008
Mathematical Models for the Prediction of
Anthropogenic Visibility Impairment.
EPA-450/3-78-110a, b, c
BART. EPA-450/3-80-009b
MORE GUIDELINE DOCUMENTS
• Assessment of Economic Impacts.
EPA-450/2-80-084
• PLUVUE. User's Manual. EPA-450/5-80-032
• Workbook for Estimating Visibility Impairment
EPA-450/5-80-031
• Interim Guideline for Visibility Monitoring.
EPA-450/2-80-082
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-fpSBggBBHBEHSg 1 ™=
\ AVAILABILITY
GUIDELINE
DOCUMENTS
NOTES
6
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2.0 SCOPE OF THE REGULATIONS
I. Pending Litigation
Utah Association of Counties
Kerr-McGee Chemical Corporation
American Paper Institute
Commonwealth of Virginia
Chevron, Inc.
Stillwater PGM Resources
Utiliites Air Regulatory Group
Magma Copper
West Associates
II. The national goal - "the prevention of any future, and the remedy-
ing of any existing impairment of visibility in mandatory Class I
Federal areas which impairment results from man-made air pollu-
tion. "
III. Applicability
A. Phased Program
B. Phase I deals with "reasonably attributable" visibility im-
pairment.
C. "REASONABLY ATTRIBUTABLE" means attributable by visual obser-
vation or other techniques the State deems appropriate.
D.. Regulations apply to 36 States all of which have mandatory
Class I Federal areas within their boundaries.
IV. Other Key Terms
A. Best Available Retorfit Technology - based on the degree of
reduction achievable through the application of the best
system of continuous emission reduction. Determination takes
into account technology available, cost of compliance, energy
7
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and nonair quality environmental impacts, existing pollution
control equipment, remaining useful life of the source, and
degree of improvement to be achieved.
B. Existing Stationary Facility - large, greater than 250tpy,
sources in existence on August 7, 1977, but not in operation
prior to August 7, 1962. Sources reconstructed between these
dates must be analyzed for BART.
C. Federal Land Manager - Secretary of Interior, Secretary of
Agriculture.
D. Natural Conditions - Includes naturally occurring phenomena
that reduce visibility.
E. Significant Impairment - Impairment which interferes with the
management, protection, preservation or enjoyment of the
visitor's visual experience of the area.
F. Adverse Impact - Impairment which interferes with the manage-
ment, protection, preservation or enjoyment of the visitor's
visual experience of the area.
G. Significant Impairment and Adverse Impact - considers the
geographic extent, intensity, duration, frequency and time of
visibility impairment, and how these factors correlate with
times of visitor use and the frequency and timing of natural
conditions.
Mandatory vs. Nonmandatory Class I Areas
A. Section 162 of the Clean Air Act defines mandatory Class I
Federal areas as all:
(1) international parks,
(2) national wilderness areas which exceed 5,000 acres in
size,
(3) national memorial parks which exceed 5,000 acres in size,
and
(4) national parks which exceed 6,000 acres.
8
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B. There are 158 such areas.
C. On November 30, 1979, EPA identified, in accordance with Sec-
tion 169A(a)(2), 156 of these areas as having visibility as an
important value.
D. Two areas excluded.
(1) Rainbow Lake, Wisconsin
(2) Bradwell Bay, Florida
E. Visibility Provisions Under Section 169A apply only to these
156 areas.
F. Visibility protection provisions for new sources comes under
the provisions of Section 162 of the Act and applies to all
Federal Class I areas which are defined as "any Federal land
that has been classified or reclassified Class I."
G. State Class I areas are not required to be afforded visibility
protection under the Clean Air Act. However, the State may
do so if it desires such protection.
Under Section 165(e)(3J all new sources must analyze their
impact on visibility on the area particularly affected.
Anticipated Impact of the Regulations
A. Three primary pollutants of concern:
(1) Particulate Matter (TSP)
(2) Sulfur Dioxide (S02)
(3) Oxides of Nitrogen (N0x)
B. Existing Sources
(1) S02 is primarily a contributor to regional haze through
atmospheric conversion of S02 to ,S04 (sulfate) forming
light-scattering areosols.
(2) N0x creates a brown plume which in some cases can be
"reasonably attributed" to a single source. However,
current controls generally can not reduce the impact of
these emissions on visibility. Sources should be ana-
lyzed but probably no control at this time.
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(3) TSP was found to be a problem at only one source. That
source has committed to clean up, which is predicted to
considerably reduce the problem.
C. New Sources
(1) Most of the new source requirements are procedural in
nature
(2) little impact is expected beyond the impact of the PSD
rules.
VII. Timetable
A. December 2, 1980 - Publication of final rules.
B. January 2, 1981 - State notifies Federal Land Managers of
State contact.
C. March 2, 1981 - Identification of impairment by Federal Land
Manager to be considered by State in preparing SIP.
D. March 2, 1981 - Identification of Integral Vistas by Federal
Land Managers to be protected in SIP.
E. September 2, 1981 - Visibility SIP due to Regional Office.
F. December 2, 1981 - EPA approval/disapproval of SIP.
G. December 1984 - First report on long-term strategy.
H. December 31, 1985 - Cutoff date for identification of integral
vistas by Federal Land Manager.
I. December 1986 - BART must be installed and operational on all
sources identified in 1981 plan.
10
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"Prevention of any future
and remedying of any
existing impairment..
11
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Applicability
• Phase I
• Mandatory vs. nonmandatory Class I areas
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Established
1963
Existing Stationary
Facility
August 7, 1962, to
August 7, 1977
NOTES
Federal Land Manager
Natural Conditions
13
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Significant
Impairment
BMW—
Significant and Adverse Considerations
- Geographic extent
- Intensity
- Duration
" Frequency
- Time
- Factors correlate with use
and natural conditions
14
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NOTES
CLASS I AREAS
INTERNATIONAL PARKS
NATIONAL WILDERNESS AREAS - 5,000 ACRES
NATIONAL MEMORIAL PARKS - 5,000 ACRES
NATIONAL PARKS - 6,000 ACRES
Visibility identified as important
value in all areas except
- Rainbow Lake, Wisconsin
- Bradwell Bay, Florida
15
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, aaa»aB—
NOTES
Section 169A Regulations
apply only
in these 156 areas
NSR Visibility Requirements
. .any Federal land classified or
reclassified Class I."
165 (d)
Anticipated
< Impact of
j Regulations
rtrV1*^ / -
- « -
itiww:
16
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¦—
EXISTING SOURCES
Regional Haze
NOTES
EXISTING SOURCES
Regional Haze
Brown Plume
S02
NOx
TSP
EXISTING SOURCES
Regional Hazo
Brown Plume
One-Source Problem
17
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j'— •
NOTES
New
Sources
Dec. 1986
Dec. 1985
Dec. 1984
Dec. 2, 1981
Sept. 2, 1981
Mar. 2,
Jan. 2, 1981
Dec. 2, 1980
kitties
)ecember 2, 1980 Final regulations published
^January 2, 1981 State notifies FLM of state
contact
I— FLM identifies integral vistas
[March 2, 1981 —
'— FLM identifies impairment t
be considered in SIP
18
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NOTES
September 2, 1981 SIP's due
September 2, 1981 SIP's due
December 2, 1981 Approval/disapproval
"f
19
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September 2, 1981
December 2, 1981
December 1984
SIP's due
Approval/disapproval
First report on long-term
strategy
L
sbebhescthsshse
ess
S5Ł9
September 2,1981
)ecember 2, 1981
lecember 1984
December 1985
SIP's due
Approval/disapproval
First report on long-term
strategy
Cutoff date for identification
integral vistas
September 2, 1981
December 2, 1981
I '
December 1984
)ecember 1985
)ecember 1986
SIP's due
Approval/disapproval
First report on long-term
strategy
Cutoff date for identification
integral vistas
BART installed and operating
on 1981 SIP sources
20
NOTES
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3.0 SIP REQUIREMENTS
3.1 Best Available Retrofit Technology (BART)
I. Applicability: Any existing stationary facility (as defined in the
Act). In existence as of August 7, 1977. In operation after
August 7, 1963.
II. The BART Analyses
A. The Federal Land Manager identifies visibility impairment in a
mandatory Class I area.
B. The visibility impairment is "reasonably attributable" to an
existing stationary facility.
Reasonably Attributable - Attributable by visual observa-
tion or any other technique the State deems appropriate.
Basically this means the impairment can be physically traced
to a source. Monitoring techniques such as visual observa-
tion, tracing the plume with an aircraft or any other appro-
priate technique.
C. Determine if the maximum achievable control will result in a
perceptible reduction in the visibility impairment.
Perceptibi1ity - A comparison should be made between the
source's existing emissions' contributions to the visibility
and that expected from imposition of the maximum achievable
control. Maximum achievable control is generally represented
by the NSPS. If this comparison shows a perceptible improve-
ment in visibility - the analysis continues. Both analytical
techniques and empirical methods can be used to determine the
degree of improvement anticipated. These include modeling and
comparison photographic techniques.
D. An engineering analysis is done to analyze the impacts of
alternative retrofit systems.
21
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Except - If a State chooses an emission limitation which
represents the NSPS this analysis need not be done.
E. If a level of control other than NSPS is chosen, it must be
demonstrated that the emission limitation chosen reflects a
reasonable balance of the BART factors.
F. After assessing all alternative retrofit systems, an emission
limitation representing BART is determined. This emission
limitation is incorporated into the SIP.
III. Exemptions from BART
A. The Administrator may exempt from BART requirements those
existing stationary facilities which:
(1) do not cause or contribute to significant visibility
impairment
(2) the exemption is effective only upon concurrence of all
affected Federal Land Managers.
IV. Reanalysis
A. Purpose - to ensure new.technology is considered as it becomes
reasonably available.
(1) The Administrator determines new technology is reasonably
available.
(2) Pollutants, for which BART has not been previously ap-
plied, are analyzed for their impact on visibility.
(3) The analysis would follow the previous BART procedures.
V. Control of TSP, NO , and SO
' x' x
A. TSP - most controllable at present. If an uncontrolled source
produces a primary particulate plume the results of con-
trolling it are fairly obvious.
B. N0x - can cause a traceable plume, but present techniques do
not result in a perceptible amount of improvement. Advances
in NO^ control technology are excepted, within the next few
years.
22
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C. SO^ - primary contributor to regional haze which will be dealt
with in Phase II.
3.2 FLM/State/EPA Coordination
I. Coordination with Respect to BART
A. The Federal Land Manager identifies visibility impairment in
the mandatory Class I area which starts the process.
B. The Federal Land Manager may identify potential BART sources
to the State.
C. Most coordination would take place within the consultation of
§ 51.302(b)(2).
II. Consultation Procedures
A. Consultation, in person, between the FLM and the State.
B. Opportunity must be made for discussion of the FLM's assess-
ment of impairment in the Class I area.
C. Opportunity to discuss FLM recommendations on elements of the
long-term strategy.
D. State must identify to FLM the official to who certain infor-
mation is submitted.
III. Continuing Consultation
A. Plan must include procedures for continuing consultation be-
tween the State and FLM.
Exchange of Information - This requirement is to ensure
continued input from both sides. The FLM has valuable infor-
mation on the conditions of the Class I areas which is
important to informed decisionmaking by the States. These
provisions need to allow for maximum information flow.
B. Some examples of this continuing process:
(1) Early notification of the FLM of any action the State
takes concerning Class I areas.
23
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(2) Handling requests for information from either party.
IV. Coordination Between States
A. There will need to be some effort between States to deal with
some visibility impairment.
B. Each State is responsible for controlling the industry in that
State, however, sometimes that industry may pollute a park in
another State. Therefore, some communication must take place
between all affected parties to remedy the situation.
V. EPA's Role
A. Continuing visibility research.
B. Consultant to State.
C. Consultant to FLM.
D. Approval/disapproval SIP.
Integral Vistas
I. Regulatory Definition
II. Identification Procedures
A. FLM input:
(1) FLM identify integral vistas according to criteria he
develops
(2) FLM notifies State of any integral vistas and the reasons
they were selected.
B. State requirements
^(1) State must list in its SIP any integral vista identified
at least six months prior to plan submission.
(2) For integral vistas identified after that the State must
list them in its SIP at earliest opportunity and in no
case, later than at the time of the periodic review.
(3) The State does not have to list an integral vista if it
demonstrates the identification was not made in accord-
ance to criteria.
24
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III. State Responsibilities
A. When a source impacts, or is anticipated to impact, an inte-
gral vista, the State must evaluate the source in terms of
making reasonable progress towards the national goal. This
means the State may allow a balancing of interests when deter-
mining the measure of protection if that balancing is within
the definition of reasonable progress.
3.4 Long-term Strategy
I. Purpose to assure reasonable progress toward the national goal (10
to 15 years).
What is reasonable progress - reasonable progress is not defined by
the regulations, it is to be defined by the State with impact from
the Federal Land Manager.
II. Two basic parts of the long-term strategy.
A. Existing problems.
B. Future problems.
Strategy must address not only areas within the State but areas
outside the State that may be affected by sources in the State.
III. Existing Problems
A. BART is intended to only address the largest sources.
B. The long-term strategy must address non-BART sources which may
also be reasonably attributable.
C. State must consider any land management plans to protect or
enhance visibility in the mandatory Class I area.
D. State should first consider any existing air quality manage-
ment programs because current control efforts around the
mandatory Class I Federal area may improve visibility.
E. State should consider encouraging the retirement of older,
less well controlled facilities by providing opportunity for
25
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newer, well controlled facilities to construct. Some degra-
dation in visibility may be acceptable over the short-term in
order to make long-term gains.
F. The State should consider smoke management programs which can
reduce the impact of forestry and agricultural burning. This
does not mean that forestry and agricultural burning must be
eliminated but rather consideration is to be given the various
ways and alternatives available to reduce the impact.
G. The State must demonstrate that measures, including emission
limitations, are enforceable.
Future Problems
A. The review of new sources will be a key component of the
long-term strategy.
(1) Replacement of old sources by new, well-controlled
sources will help eliminate existing problems.
(2) Problems created by new sources will be longer in dura-
tion and be considerable more difficult to solve.
Review of the Long-term Strategy
A. Must be accomplished at least every three years.
B. Purpose - to provide a periodic assessment of the ability of
the long-term strategy to make reasonable progress.
C. Report to the public and the Administrator must include:
(1) As assessment of the progress achieved in remedying
existing impairment.
(2) An evaluation of any change, improvement or degradation
in visibility.
(3) An assessment of the ability of the long-term strategy to
prevent future impairment.
(4) Identification of additional measures necessary to remedy
or prevent impairment.
26
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(5) An assessment of the progress achieved in implementing
BART.
(6) An assessment of the impact of any exception from BART.
3.5 New Source Review
I. Overview
A. New source review is imperative in order to assure reasonable
progress toward preventing future visibility impairment.
B. The requirements of the PSD program if incorporated into the
visibility program will provide many of the review require-
ments necessary to satisfy this requirement.
II. Visibility Provisions of PSD
A. PSD program requires that all PSD sources must be reviewed for
their potential impact on all Federal Class I areas.
B. PSD provisions provide the opportunity for the Federal Land
Manager to demonstrate that an adverse impact on visibility
would occur even though air quality increments are not vio-
lated.
C. If the Federal Land Manager demonstrates to the satisfaction
of the State that an adverse impact would occur the State may
not issue the permit.
D. The source may attempt to demonstrate to the Federal Land
Manager that even though air quality increments are violated
no adverse impact will occur.
E. If the Federal Land Manager agrees with the demonstration, the
State may under certain conditions issue the permit.
F. If the Federal Land Manager provides an analysis of adverse
impact and the State does not find in favor of the demonstra-
tion, the State must explain its decision.
-IIJ Additiona 1 No" Source Visibil ity
A. "-5D' does not require the review of new sources locating in
nonattainment areas.
27
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B. Section 307 requires that all "major stationary sources" be
reviewed if they potentially impact visibility in a mandatory
Class I Federal area.
C. Sources locating in nonattainment areas are not subject to the
adverse impact test, rather the State must ensure permitting
of the source is consistent with the long-term strategy.
D. Notifications.
E. The State must notify the Federal Land Manager within 30 days
of receipt of an application from a source that may affect
visibility in any Federal Class I area.
F. Notification of Federal Land Manager must be at least 60 days
before any public hearing on the permit.
G. Notification must include all relevant information including
an analysis of the anticipated impact of the source on visi-
bility.
H. While advance notification is received the State must notify
the Federal Land Manager within 30 days of the advance notifi-
cation.
Integral Vistas and New Source Review
A. New source permit applications must address the potential
impact on integral vistas if identified at least one year
before submission of a complete permit application.
B. Integral vistas subjected to public review and comment must be
addressed, if identified, at least 6 months prior to permit
application.
C. The State in permitting sources with an impact on integral
vistas shall ensure that permitting the source will be con-
sistent with the long-term strategy.
28
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NOTES
Best
Available
Retrofit
Technology
o.
¦?\m
X 4>i:
1
8
CLEAN AIR
ACT
Applicability
169 A(b) (2)
Definition
169 A(g) (2)
?q
-------
Applicability
• 28 categorical sources
• Potential to emit 250 tons/year
• < 1 5 years old as of August 7, 1977
• "Reconstructed" after August 7, 1962
—a——
BART ANALYSIS
wmmrnmmmmmmmmwmw'
FLM IDENTIFIES IMPAIRMENT
minuiiM
REASONABLY ATTRIBUTABLE
FLM IDENTIFIES IMPAIRMENT
30
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Reasonably Attributable
BART ANALYSIS
WILL MAX. CONTROL 0
IMPROVE VISIBILITY?
„
REASONABLY
ATTRIBUTABLE
FLM IDENTIFIES
IMPAIRMENT
Perceptibility
AFTER
BEFORE
NOTES
31
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BART ANALYSIS
'J.*"JJV' V i • V * " i V V' •
•"¦•¦i.iii»i,«iinifuimiiitiiiiiin^ii^
WILL MAX. CONTROL0
IMPROVE VISIBILITY?
REASONABLY ATTRIBUTABLE
FLM IDENTIFIES IMPAIRMENT
NOTES
EXCEPTION:
lfAiimit = NSPS no
analysis is needed.
BART ANALYSIS
FLM IDENTIFIES IMPAIRMENT
WILL MAX, CONTROL0
IMPROVE VISIBILITY?
REASONABLY ATTRIBUTABLE
ENGINEERING ANALYSIS
DEMO' REFLECTS BALANCE
OF FACTORS
32
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BART ANALYSIS
EMISSION LIMIT INTO SIP
DEMO REFLECTS BALANCE
OF FACTORS
ENGINEERING ANALYSIS
WILL MAX. CONTROL0
IMPROVE VISIBILITY?
REASONABLY ATTRIBUTABLE
IFLM IDENTIFIES IMPAIRMENT
Exemptions from BART
Do not contribute to significant
visibility impairment
Only effective upon concurrence
of affected FLM
33
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BART
Reanalysis
New technology is
reasonably available.
Pollutants for which
BART not previously
applied.
Follow BART procedures
34
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NOTES
JKs M
II IM
Consultation Procsdurss
Impairment
Long-Term Strategy
Inteyi^l Vfstas
-------
waawifflS
1
Opportunity to Discuss
FLM's assessment of impairment
FLM's recommendations on elements
of long-term strategy
BART Coordination
FLM identifies impairment
FLM may identify potential sources
Most coordination under 51.302 (b) (2)
L
I'm the one
to get the
information.
Integral Vistas
Impairment
Monitoring
36
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Continuing Consultation
EXCHANGE
Examples:
Z3S8
Early notification
Handling requests
• Periodic meetings
& P • Seminars
* *A *
37
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Ml
¦¦¦in., i
J HELP!
Coordination Between States
Visibility Research
STATE
Consultant to State
Consultant to FLM
Review/Approval SIP
-------
Identification Procedures
f >
&
§ —
T) • I
~
\3f
&
v j
-------
FLM Input
Identify according to criteria developed.
Notify state of integral vistas, along with reasons
for selection.
I
State Requirements
List in SIP any integral vista identified at least 6
months prior to plan submission.
List integral vistas identified after plan submission
soon as possible, never later than time of periodic
review.
Not necessary to list an Integral vista if state
demonstrates the identification is not in
accordance with criteria.
State Responsibilities
to Protect Integral Vistas
Vista
40
-------
Reasonable
Progress
Measure of
Protection
NOTES
Time Table
September 2, 1981 Date by which SIP's that
include integral vistas must
be submitted
March 2, 1981
6 months
Time Table
identification of integral
vistas
September 2, 1981 SIPs due
41
-------
n mbmbm aoaz
Time Table
September 2, 1981 SIPs due
3 years
September 2, 1984 Period review must include
vistas since SIP submitted.
J
September 2,1981
September 2, 1984
December 1985
Time Table
SIP's due
Periodic review must include
vistas since SIP submitted.
Cutoff date for identification
of integral vistas.
J
32=
SS
NSR Impact on Integral Vistas
— June
Integral vistas identified
6 months
with public hearing
December
Complete permit
application submitted
42
-------
SEZJE
NOTES
NSR Impact on Integral Vistas
— Last integral vista to be
considered
12 months —
Submission of complete
application
J
Assure reasonable progress
toward the national goal
(10-15 years)
at
-------
Long-Term Strategy
* Existing
* Future
Existing Problems
Address non-BART sources that are reasonably
attributable.
Consider any land management plans.
Consider any existing air quality management
programs.
Existing Problems (Cont.)
Consider encouraging retirement of older, less-well-
controlled facilities.
Consider smoke management programs.
Demonstrate measures and limitations are
enforceable.
44
-------
FUTURE PROBLEMS
\
n
9E
Problems created by new sources
will be longer in duration and
more difficult to solve.
-------
W78cjni»clHK*iiiireji|>iona^iuicjuloau«jp*^vo cjiu icJebon uir-j ij M*Cfiui_>cj i ii *j uloau goc*|)0< hIj h no< k v
REVIEW OF LONG-TERM STRATEGY
l'Jiii (^mc4i4x^najnDaprciiui^cjiurjiil3au«^D#>epobcnmrai|ircniincj mtj uloau ""CM-jK^K'tCiKnCMlw
mKCjimcW^iurcaiM^uiy^iuicjulcttu^^KXM'tciHAOdec
l9«vcjarciHK^nuroa|)iOMU^uncjulouugC>t'|)00ctCiiwic*k*c
i,)v«cjaiiCcjiu*^uIoimj53t»
-------
NOTES
NSR is imperative to assure reasonable
progress toward preventing future
isibility impairment.
Visibility
-------
All PSD sources must be reviewed for
I their potential impact on all Federal
Class I Areas.
Adverse Impact
Demonstrations
-------
BBS!
If state disagrees with FLM
demonstration, state must
provide explanation.
r DEMO->
NO
ADVERSE
IMPACT
^ J
1
NOTES
"
r\S° A \°
6® p-Ue
-------
Additional NSR/Visibility Provisions
iiili
Subject to
Adverse Impact Test
if/,.
PSD Applies
State Notification to FLM
ANALYSIS
OF
IMPACT
ON
VISIBILITY
Time Table
Within 30 days of receipt
of application
At least 60 days before
public hearing
nn
-------
If advance notice
is received, State
must notify FLM
within 30 days of
such notice.
Integral Vistas
and
NSR
Must ensure that permitting sources with impact]
|on integral vistas will be consistent with
long-term strategy
mm
-------
Exception
52
-------
4.0 MONITORING
I. Needs
A. Correct conditions.
B. Extent of contribution.
C. Identify specific sources.
D. Effectiveness of program.
II. Objectives
A. Optical parameters.
B. Pollutants.
C. Meteorological variables.
III. Data Needs
A. Identify impact of existing sources.
B. NSR.
C. Evaluate long-term strategy.
IV. SIP Requirements
A. Strategy.
B. Use of available data.
V. NSR
A. Case-by-case.
B. Available techniques.
53
-------
&SS3S2SBE3X
MONITORING
NOTES
Monitoring is used to:
• Establish current visibility conditions
• Determine extent of contribution from
manmade and natural conditions
ass
Identify specific sources that contribute
protection program
54
-------
Meeting monitoring objectives will
require measurement of:
• Optical parameters
• Pollutants
Meteorlogical variables.
Visibility Data
Needed for
Three Aspects of
Visibility Program
mBm
-------
SIP must include
strategy for
evaluating
visibility in
Class I areas.
NOTES
P Outlining monitoring needs
ft and areas needed
ff
f: Evaluation of current data
[J
It Schedule for intended actions
— or —
Will evaluate
monitoring as it progresses and
implement it when reference method
is developed.
56
-------
1
Strategy should take into consideration
• Availability of forthcoming techniques
• Current research
• Guidelines
NOTES
EPA 450/2-80-082
r
>EPA
Interim Guidance
for
Visibility Monitoring
Plan must consider
available data
in decision making.
R7
-------
Current Data Uses
• Identify BART sources
• NSR
• Determine protection afforded integral vistas
NOTES
New Source Monitoring
as part of
NSR Process
V-WI pw, u -- I w 'jam
Assess need for new source monitoring on a
case-by-case basis.
• Available data
• Adequacy of available monitoring techniques.
¦ J-ViMiTrviirrr
58
-------
5.0 PHASE II
I. Visibility impairment to be addressed as regional haze.
II. Timing dependent upon research into cause/effect relationships.
III. Will deal primarily with aerosols formed as a result of atmospheric
chemical reactions.
IV. Pollutant of major concern will be S02.
V. May attempt' to address the impact of urban pollutant mixes on
visibility.
59
-------
111
5? !» > *» >•
I"""/
'1 z
Phase II
S 5 5 " -
~ S : : >
.^>5- -
+&&Ł%&
NOTES
Visibility Impairment
Addressed As
Timing
depends on research
into cause/effect
relationship.
-------
NOTES
PHASE II
Phase II may address
impact of urban plume
on visibility.
61
-------
6.0 PREPARATION OF SIP
I. Major Elements
A. Listing/Identifications
B. BART Analysis
C. Monitoring Plan
D. NSR
E. FLM/State coordination procedures
F. Long-term Strategy
G. Commitments
II. Listing
A. Responsible Individuals
B. Visibility Impairment
C. Suspected Sources
D. Integral Vistas
E. Mandatory Class I areas'.
III. Monitoring
A. Data Analysis
B. Decisionmaking
IV. Long-term Strategy
A. Tracking Progress
B. Additional Controls
C. Overall Assessment
D. PSD
62
-------
E. Incentives.
V. NSR
A. 51.18
B. 51.24
C. Integral Vistas
D. FLM/State coordination.
VI.. Commitments
A. Periodic Review
B. Monitoring Strategy
C. FLM/State coordination
D. Resources.
VII. Checklist
63
-------
SIP
PREPARATION
aSUBMI
MAJOR ELEMENTS OF SIP
• Listings/Identifications
• BART Analysis (if required)
• Monitoring and Analysis Plan
• NSR
• FLM/State Coordination Procedures
• Long-Term Strategy
• Commitments
LISTINGS/IDENTIFICATIONS
•Responsible Individuals (Names)
• Visibility Impairments (Areas)
• Suspected Sources
• Integral Vistas
• Mandatory Class I Areas
I .mu.im .i
64
-------
BART ANALYSIS
Visibility Impairment:
Yes
No
Yes
Suspected Stationary
Sources:
No
Yes
SIP Requirements:
Nonappll-
None
Emission
cabillty
Limit
Assessment
Compliance
Schedule
Technical
Support
BBS!
HUlWJAUgCT
NOTES
ONITORING AND ANALYSIS,
USEES
• Data Analysis
• Decision Making
— BART
— NSR
!All.«-UIWMWIJUIJIJ»W»mL-H*HIUW«»g
LONG-TERM STRATEGY
• Tracking Reasonable Progress
• Additional Control Measures
• Overall SIP Assessment
• PSD Reviews
• Incentives
c c
-------
NEW SOURCE REVIEW
Part 51.18 Requirements
plus
Part 51.24 Requirements
plus
Integral Vistas
plus
FLM/State Coordination
1
!
Adverse
Impact
Assess-
ment
aass
COMMITMENTS
• Periodic Review and Revision
• Development of Monitoring Strategy
• FLM/State Coordination
• Resources
¦iSSBSESZSSS
!imu
CHECK LIST
~ Class I Areas
~ Names of State Contacts
~ Names of FLMs
~ Areas With Visibility Impairment
~ Integral Vistas
~ Suspected Stationary Sources
~ Other Sources
~ BART Analysis or Nonappllcability
Assessment
~ Monitoring Plan
~ Data Analysis
~ NSR Rules
~ Long-Term Strategy
~ Reporting Commitment
~ Periodic Review Commitment
asaaassizzs
66
-------
7.0 MODELING
I. Regulatory Requirement
II. Uses in Phase I
A. Reductions Achieved
B. NSR
III. Application
A. Not Absolute
B. Real world.
IV. Guidance
A. Workbook for Estimating Visibility Impairment
B. PLUVUE
V- Technical Aspects.
67
-------
MODELING
NOTES
December 2,1980, Regulations
Do Not
Require Modeling
Models are available for
estimating Phase I impacts.
68
-------
Determine Reductions
Achieved by
Retrofit of Existing Sources
Models should not
be used in an
absolute sense.
fiQ
-------
WORKBOOK FOR S
ESTIMATING I
VISIBILITY
IMPAIRMENT |
450/4-80-031 4
-------
TECHNICAL
ASPECTS
MODELING
NOTES
ffflwawwrnaaE;
a^swwr.yifmi
5SE
71
-------
8.0 MONITORING GUIDANCE
I.
Regulatory Requirements
II.
Interim Guidance
III.
Detail Procedures
IV.
Reference Method
V.
Monitoring Program Development
VI.
Technical Aspects
72
-------
*255
1
MONITORING
GUIDANCE
S5EBH9HB&
sesszssEBSsaai
r".*n^»wi iH.mm
miuowmHimuw
mss
Regulations Consider Monitoring Data
¦ Identify existing source impact
¦ NSR
¦ Evaluate long-term strategy
:a*auswrsB3
Interim Guidance
for
Visibility Monitoring
EPA-450/2-80-082
NOTES
73
-------
NOTES
-X- Instrumentation
* Program Design Considerations
-X-Nonroutine Monitoring
* Quality Assurance
Data Management/Reporting
More detailed procedures manual
will be available on:
¦ O/M
- Data handling
- Calibration
> - 1 ' T«.W *
7/1
-------
| STEPS IN |
J MONITORING PROGRAM
m
reference method
detailed procedures
a
interim guidance
monitoring workshop-1978
NOTES
TECHNICAL
ASPECTS OF
MONITORING
1
Hi
75
-------
9.0 FLM RESPONSIBILITY
I. Federal Land Manager
A. Affirmative responsibi1ities-to protect visibility values of
lands within Class I areas and not limited to mandatory Class
I areas Section 165(d)(2)(B)
B. Consideration of integral vistas Section 169A
II. Status of Class I Areas
A. Existing Impairment
B. Preventing Future Impairment
C. NPS List of Integral Vistas
D. Monitoring - Cooperative network
III. FLM Role in State Visibility Programs
A. Contact Points - Visibility Program Coordinator-Vicki Evans
(202)343-4911, State SIP Liaison-Phil Wondra (303)234-6419,
and Monitoring-Jim Littlejohn (303)234-6419
B. Coordination/Cooperation - Within SIP and State Measures
Outside of SIP, too
IV. Integral Vistas
A. Criteria - Based on merits of resource
B. Notice and Comment by FLM
C. NPS Integral Vista Process
D. State review during SIP process
E. Establish Vista Sensitivity for vistas
V. FLM Role in New Source Permit Review
A. Contact points
76
-------
B. Early notification/coordination of FLM by state and applicant
(1) Establish scope of analysis needed
(2) Monitoring needs and sites
C. Review limited to direct effects on visibility values - plume
blight or layered haze from stacks
D. Impact Analysis Considerations
(1) Case-by-case review
(2) Establish more certainty with more experience
(3) Adverse factors - Impact within Class I boundary
(a) Geographic extent, intensity, duration, frequency,
and time of visibility impairment
(b) Correlation with (1) time of impairment and (2)
frequency and timing of natural conditions that
reduce visibility
(c) Interference with the management, protection, pre-
servation or enjoyment of the visitor's visual
experience
(d) No consideration of energy and economics
(e) Does not include effects of integral vistas
Impacts on Integral Vistas
A. Based on consideration of similar factors, including
importance of vista
B. FLM not to consider energy and economics, State can, as long
as makes reasonable progress
Summary of Requirements of the Federal Land Managers
A. Within 90 days of promulgation (by March 2, 1981)
(1) Identify integral vistas and publish notice of identi-
fication criteria and list of integral vistas in the
Federal Reqister for public comment.
(2) Provide list of integral vistas to. EPA and the States for
incorporation into the visibility SIP.
77
-------
(3) Identify existing impairment of Class I areas and con-
tributing sources for State consideration under BART.
(4) Provide list of Class I areas with existing impairment
and contributing sources to EPA and the States for in-
corporation into the visibility SIP.
Within 6 months of promulgation (June 2, 1981):
(1) Consult with the States on the incorporation of integral
vistas in the visibility SIP.
(2) Consult with the States on the consideration of remedying
existing impairment for Class I areas identified.
(3) Identify elements for inclusion in the visibility moni-
toring strategy.
(4) Provide recommendations on the development of the long-
term strategy.
(5) Work with the States on procedures for continuing con-
sultation on implementation on the visibility SIP.
After adoption of acceptable visibility SIP:
(1) Participate with States and applicants in assessing
visibility impacts from proposed major new stationary
sources of pollution locating in the vicinity of any of
the 48 NPS Class I areas. Ensure that visibility assess-
ment includes impacts on integral vistas identified by
NPS Federal Register notice within 6 months of submission
of a complete permit application.
(2) Participate with States in their BART analyses for
sources affecting NPS Class I areas.
(3) Work with States on carrying out long term strategy to
make reasonable progress toward remedying existing
visibility impairment and preventing future impairment
(i.e., other measures may include monitoring compliance
schedules, prescribed burning policy and permits, and
cumulative effects of new sources).
78
-------
FEDERAL
LAND
MANAGERS'
RESPONSIBILITIES
NOTES
FEDERAL LAND MANAGERS' RESPONSIBILITIES
• TO PROTECT AIR QUALITY RELATED VALUES
(INCLUDING VISIBILITY)
• TO CONSIDER IMPACT OF PROPOSED SOURCE
(WITH EPA CONSULTATION)
9S3B
S3S
EE2
H55
FLM also responsible for
• Identifying impairment
• Identifying integral vistas
79
-------
NOTES
FLM's Role
SIP Development
Status
Class I Areas
Adverse
Impact
Test
an
-------
Integral Vistas
Identification Criteria
Integral Vistas
81
------- |