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PSD Permitting Process. Nancy Mayer EPA OAQPS. Topics. Find technical resources for permit review Describe how permits are constructed Describe what to look for when reviewing a permit. Useful Areas of Expertise. Air pollution modeling Air pollution control Equipment Practices - PowerPoint PPT Presentation
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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
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Useful Areas of Expertise
Air pollution modeling Air pollution control
– Equipment – Practices
Law
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Typical Permit Format
General source identification Source location Emissions information Control technology analysis - BACT
– Top-down approach
Air Quality Impact Analysis
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General Source Information
Name Source classification –
– On list to count fugitive emissions?
Generally what construction/modification is being proposed – Reason for construction
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Source ID–what to look for
Is source classification correct? Does reason for modification make sense?
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Source Location
Location – Attainment/nonattainment area– Nearby class I areas
Source site diagram
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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?
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Emissions Data
Existing emissions baseline Change in emissions
– Netting calculation, if any
Stack height
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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?
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Air Quality Impact Analysis
Terrain Model name Features selected Results
– Increment– NAAQS– Class I areas
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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?
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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?
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Control technology
Proposed Best Available Control Technology (BACT) – Top-down approach
Describe other alternatives For each relevant pollutant
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Control Technology–what to look for
Reasons for not choosing best technology? Technology from BACT/LAER
Clearinghouse? Technology for all relevant pollutants?
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Public Participation/Notice
Date, time documentation Notice in readily available local newspaper Contacted Relevant Federal Land Managers Contacted nearby tribes
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Public comment–what to look for
All FLM concerns addressed? Public notice clear and well publicized? Any public comments? Public comments adequately addressed?
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Were formalities met?
Did source submit permit application before commencing construction?
Has the state been working with source? Permit easy to follow?
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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