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Air Quality Impact Analysis and Other PSD Requirements

Air Quality Impact Analysis and Other PSD Requirements. Donald Law U.S. EPA Region 8. Review: PSD Program Requirements. Main requirements Install Best Available Control Technology (BACT) Perform air quality analysis to assess impacts on air quality

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Air Quality Impact Analysis and Other PSD Requirements

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  1. Air Quality Impact Analysis and Other PSD Requirements Donald Law U.S. EPA Region 8

  2. Review: PSD Program Requirements • Main requirements • Install Best Available Control Technology (BACT) • Perform air quality analysisto assess impacts on air quality • PerformClass I Area analysis toassess impacts onnational parks and wilderness areas or other Class I Areas • Perform additional impacts analysis • Provide opportunities for public involvement

  3. Air Quality Impact Analysis (AQIA) • 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 existingemissions will cause or contribute to a violation of a • NAAQS and/or • PSD increment

  4. AQIA for Increment Compliance • 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)

  5. AQIA for Increment Compliance (cont.) • 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

  6. AQIA for Increment Compliance (cont.) Minor Source Baseline Date when actual emission changes from all sources affect the available increment Date of first complete permit application for a major source or major modification when actual emissions associated with construction at a major source affect increment Major Source Baseline Date SO2 and PM - Jan. 6, 1975 NO2- Feb. 8, 1988 Start • Baseline Date(s) - when increment consumption starts, pollutant specific

  7. AQIA for NAAQS Compliance • 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

  8. AQIA Steps • 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)

  9. Class I Area Impact Analysis • 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

  10. Map of Class I Areas

  11. Class I Area Impact Analysis (cont.) • 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

  12. Examples of AQRV’s for Class I Area Impact Analysis and Potential Air Pollution-Caused Changes

  13. Managing Air Quality and Protecting AQRV’s in non-federal Class I areas • 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

  14. Additional Impact Analysis • 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

  15. Additional Impacts Analysis (cont.) • 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

  16. Public Involvement • 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

  17. Public Involvement (cont.) 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

  18. Summary • 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

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