PSD Permitting Process Nancy Mayer EPA OAQPS

2 Topics Find technical resources for permit review Describe how permits are constructed Describe what to look for when reviewing a permit

3 Useful Areas of Expertise Air pollution modeling Air pollution control – Equipment – Practices Law

4 Typical Permit Format General source identification Source location Emissions information Control technology analysis - BACT – Top-down approach Air Quality Impact Analysis

5 General Source Information Name Source classification – – On list to count fugitive emissions? Generally what construction/modification is being proposed – Reason for construction

6 Source ID–what to look for Is source classification correct? Does reason for modification make sense?

7 Source Location Location – Attainment/nonattainment area – Nearby class I areas Source site diagram

8 Source location–what to look for Is location accurate? Does permit ID all Class I areas and tribal lands within 100 KM? Does it ID all nearby nonattainment areas? Does site diagram clearly explain what is being proposed? Unexplained buildings in diagram?

9 Emissions Data Existing emissions baseline Change in emissions – Netting calculation, if any Stack height

10 Emissions Data–what to look for What method is used to measure emissions? – Stack tests – when, how often? – Correct emission factors? – Do assumptions make sense? – Is baseline year the correct year? – Is averaging done correctly? Is calculation for the emissions change clearly shown and explained? Is stack height measured correctly?

11 Air Quality Impact Analysis Terrain Model name Features selected Results – Increment – NAAQS – Class I areas

12 Modeling–what to look for All important terrain features identified? Correct model being used? – Pollutants – sources Assumptions reasonable? Correct meteorological data set being used? All results presented, or only summaries?

13 More modeling things to look for Increment analyses done correctly? – Baseline area? – All relevant pollutants – Any increment violations? Do emission increases cause new NAAQS violations? Do emissions impact existing nonattainment areas? – Impacts mitigated?

14 Control technology Proposed Best Available Control Technology (BACT) – Top-down approach Describe other alternatives For each relevant pollutant

15 Control Technology–what to look for Reasons for not choosing best technology? Technology from BACT/LAER Clearinghouse? Technology for all relevant pollutants?

16 Public Participation/Notice Date, time documentation Notice in readily available local newspaper Contacted Relevant Federal Land Managers Contacted nearby tribes

17 Public comment–what to look for All FLM concerns addressed? Public notice clear and well publicized? Any public comments? Public comments adequately addressed?

18 Were formalities met? Did source submit permit application before commencing construction? Has the state been working with source? Permit easy to follow?

19 For more information Nancy Mayer

20 How to submit comments States must send copy of permit to tribal governing body Public-comment period Can request public hearing and provide verbal comments Special Class I protection – Lower increment allowed – Visibility