PSD Permitting Process

Nancy Mayer

EPA OAQPS

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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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For more information

Nancy Mayer 919-541-5390

mayer.nancy@epa.gov

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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