1 air quality impact analysis and other psd requirements donald law u.s. epa region 8
TRANSCRIPT
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• Main requirements1. Install Best Available Control Technology (BACT)2. Perform air quality analysis to assess impacts on
air quality3. Perform Class I Area analysis to assess impacts
on national parks and wilderness areas or other Class I Areas
4. Perform additional impacts analysis5. Provide opportunities for public involvement
Review: PSD Program Requirements
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• Pollutant-specific analysis that involves • An assessment of existing air quality and • Modeling estimate of ambient concentrations from
proposed project and future growth associated with project
• Purpose is to determine if new plus existing emissions will cause or contribute to a violation of a• NAAQS and/or • PSD increment
Air Quality Impact Analysis (AQIA)
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• A new source or modification cannot cause or contribute to significant deterioration of air quality in attainment areas• Maximum amount of deterioration allowed is called an
increment• Increments exist for• 3 pollutants (PM, PM10 and PM2.5; SO2 and NO2)• Various averaging periods (annual, 1-hour)• 3 area classifications (Class I, Class II, Class III)
AQIA for Increment Compliance
PM2.5 Increments by Area Classification (g/m3) NAAQS (g/m3) Averaging Period Class I Class II Class III
Annual 1 4 8 1524-hr 2 9 18 35
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• Change in air quality measured against a certain baseline• Not all sources consume increment• Two important concepts• Baseline area• All portions of attainment area in which PSD applicant proposes to
locate and/or would have significant ambient impact (i.e. higher than Significant Impact Level)
• Limited to intrastate areas: baseline areas not triggered across state lines
• Baseline date• When increment consumption starts, pollutant specific
AQIA for Increment Compliance (cont.)
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• Baseline Date(s) - when increment consumption starts, pollutant specific
AQIA for Increment Compliance (cont.)
Major Source Baseline Date
Minor Source Baseline Date
SO2 and PM - Jan. 6, 1975 NO2 - Feb. 8, 1988
Date of first complete permit application for a major source
or major modification
when actual emission changes from all sources affect the available increment
when actual emissions associated with construction at a major source affect increment
Start
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• A new source or modification cannot cause or contribute to a violation of any NAAQS in any area• Compliance with any NAAQS is based on proposed
source and all other sources in baseline area• No baseline dates exist• Analysis requirements similar to increment analysis
• NAAQS analysis is independent from increment analysis
AQIA for NAAQS Compliance
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• Compliance determined by using air quality models• Preliminary analysis (significant impact analysis)• Screening approach• Representative meteorology• Only proposed source or modification emissions • Refined receptor grids
• Full impact analysis (cumulative impact analysis)• Refined model• Representative meteorology• All applicable increment affecting sources• More refined receptor grids (smaller grid spacing)
AQIA Steps
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• Evaluation of NAAQS, Class I increments and Air Quality Related Values (AQRVs) when a major source’s emissions may affect a Class I area• Class I Area – areas reserved for special air quality protection, usually national
parks and wilderness areas• Class I Areas have stringent increments
• AQRVs – feature or property of a Class I Area that may be affected by a change in air quality (such as scenic, cultural, physical, biological, ecological, or recreational resources
• Generally for sources within 100 km of Class I area, not always• Federal Land Manager (FLM) must be notified of potential impacts on
Federal Class I Areas • Determines data and analyses needed
• http://www.epa.gov/visibility/class1.html
Class I Area Impact Analysis
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• Role of FLM: evaluates a source’s projected impact on AQRVs, makes recommendations to permitting agency• FLM may recommend that permit application be denied if FLM
determines a source will adversely impact AQRV’s, even where applicable increments are not exceeded
• FLM may suggest permit conditions
• FLM definition of adverse impact: an impact that• Diminishes area’s national significance• Impairs structure or functioning of ecosystems, or• Impairs quality of visitor experience
Class I Area Impact Analysis (cont.)
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AQRV Potential Air Pollution-Caused Changes
Flora and fauna Growth, mortality, reproduction, diversity, visible injury, succession, productivity, abundance
Water Total alkalinity, metals concentration, pH, anion and cation concentration, dissolved oxygen
Visibility Contrast, visual range, colorationCultural-archeological and paleontological
Decomposition rate
Odor Odor
Examples of AQRV’s for Class I Area Impact Analysis and Potential Air Pollution-Caused Changes
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• State or Indian governing body is responsible• Can define AQRV’s at own discretion• Establishes criteria for determining an adverse
impact on AQRV’s• EPA may be asked to resolve permit disputes
Managing Air Quality and Protecting AQRV’s in non-federal Class I areas
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• Assesses potential effects of increased air, ground and water pollution from proposed source and associated growth on:• Soils and vegetation• Visibility• Pollutant-specific• Performed within impact area of proposed
source
Additional Impact Analysis
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• Criteria for evaluating completeness and adequacy of applicant’s analyses
• Whether applicant has presented a clear and accurate portrait of soils, vegetation, and visibility in proposed impacted area• Whether applicant has provided adequate
documentation of potential emissions impacts on soils, vegetation, and visibility• Whether data and conclusions are presented in a
logical manner understandable by the affected community and interested public
Additional Impacts Analysis (cont.)
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• CAA section 165(a)(2) provides that a PSD permit cannot be issued unless there is an opportunity for a public hearing at which the public can appear and provide comment on the proposed source, including “alternatives thereto” and “other appropriate considerations.” • CAA allows EPA to consider environmental justice
issues in issuing PSD permits
Public Involvement
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• If your tribe has satisfied requirements for TAS for purposes of CAA sections 126(a) and (b), your tribe is entitled to 60-days notice prior to PSD source’s construction, and your tribe may petition EPA Administrator for a finding that the transported emissions from a proposed PSD source would contribute to nonattainment or interfere with maintenance of NAAQS in area covered by your TIP• Technical Support Document (TSD), generally including
responses to comments, may also be available with final permit
Public Involvement (cont.)
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• To obtain a PSD permit, an applicant must• Apply best available air control technology (BACT)• Conduct an ambient air quality analysis to
demonstrate that its new emissions would not cause or contribute to a violation of the NAAQS and/or PSD increment• Analyze whether its proposed emissions increases
would impair visibility or adversely affect soils or vegetation • Not adversely impact a Class I Area
• Public and tribes may comment on impacts of the proposed project, including environmental justice aspects
Summary