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PSD Permitting Process

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

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PSD Permitting Process

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  1. 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 919-541-5390 mayer.nancy@epa.gov

  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

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