P.1 

OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

2) ll-A-2 

Docket Number: 

A-90-37 

Printed 11/4/2008 10:22:18 AM Sheet 2 of 147 
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PB8J-115972 •."';,tE>'..»i' 

Analysis of v£~^ 

New Source Review (NSR) ^ ^ 

Permitting Experience 

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BIBLIOGRAPHIC INFORMATION 

PB83-115972 

Analysis of New Source Review (NSR) Permitting Experience, 

Aug 8 2 

L. Hayes, w. Warren-Hicks, L. Bravo, J. Avery, and J 

Shumaker. 

PERFORMER: TRW, Inc., Durham, NC. 

Contract EPA-68-02-3174 

SPONSOR: Environmental Protection Agency, Washington, DC. 

Economic Analysis Div. 

Pursuant to the Clean Air Act Amendments of 1977 EPA, in 

1978, revised its New Source Review (NSR) regulations. The 

revised Prevention of Significant Deterioration (PSD) 

regulations were more extensive than their predecessors in 

that many more sources were subject to PSD requirements. The 

NSR regulations were again revised in 1980 as a result of 

litigation. This report deals with a sample of the 

pre-construction permits issued under EPA's post-1977 NSR 

regulations. The data and information contained in this 

report summarize results of a study directed at assessing 

the experience of EPA's New Source Review (NSR) Program. 

Information extracted from Prevention of Significant 

Deterioration (PSD) and non-attainment permit files 

augmented by data obtained from company representatives have 

been compiled, analyzed and interpreted. An automated 

(computer) data base has been constructed containing 

relevant data for each of more than 285 PSD and 

non-attainment permits issued since 1978. 

KEYWORDS: *Licenses, *Air pollution, *Regulations, *New 

source review, *Air quality. 

Available from the National Technical Information Service, 

Springfield, Va. 22161 

PRICE CODE: PC All/MF A01 

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ACKNOWLEDGEMENT 

1 #7 

This report was prepared for the Air Economics Branch, Economics 

Analysis Division, Office of Policy and Resource Management, U.S. 

Environmental Protection Agency, Washington, D.C ; by TRW Inc., 

Environmental Division, under Contract Number 68-02-3174. The EPA 

Project Officer was Mr. Alex Cristofaro. 

Data and analyses presented in this report, in many cases, were 

extracted from projects performed by TRW under Contract Number 68-02-3515, 

for which Mr. James Weigold, and Mr. Mike Trutna, Office of Air Quality 

Planning and Standards, Durham, North Carolina, were the EPA Project 

Officers. In addition, the analyses for Section 3 of this report. 

Permit Application Processing Times, were performed by TRW under 

separate Contract No. 68-01-5838, for which Mr. Scott Flamm, Office 

of Policy and Resource Management was the EPA Project Officer. 

The TRW Project Manager was Mr. L. Hayes. Principal investigators 

were Messrs. W. Warren-Hicks, L. Bravo, J. Avery, J. Shumaker, 

P. Gunthorpe, and Ms. D. Wells. 

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NOTICE 

This report is divided int o three main sections : 

• Executive Sunmary; 

• Full Report; and 

• Appendices. 

The Executive Summary is a brief summary of the highlights of the report 

findings and, in addition to being the first section (1.0) of this report, 

it has also been printed and bound separately. 

Ihe body of the report presents all analyses and explanations are 

provided, as necessary, to allow the reader to better understand tho 

significance of the results. Descriptions of analytical methods used 

and greater details of the data are contained in the respective appendices: 

A through G. 

The subsections of the Executive Summary correspond to the sections 

of the full report. For instance. Subsection 1.2 of the Executive Summary 

and Section 2.0 of the report both deal with descriptions of the data base; 

Subsection 1.3 of the Executive Sunmary and Section 3.0 of the report both 

deal with permit application processing times, and so on. 

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TABLE 01 CONTENTS 

Pag_e 

1.0 EXECUTIVE SUMMARY 1 

1 . 1 INTRODUCTION 1 

Background 1 

Project Objectives 2 

1.2 DATA BASE OF PSD PERMIT APPLICATIONS 2 

Data Base Source Types 2 

Data Base Emissions Summary 2 

PSO Application Submittals 5 

1.3 PERMIT APPLICATION PROCESSING TIMES 5 

Summary of PSD Permit Processing Times 5 

Total Processing Time 5 

Application Completeness 8 

Permit Processing Time From Receipt 

of Complete Application 11 

Effect of Source Type and Size on Processing Times .. . 11 

Effect of Pre-Application Meetings on Processing Times . 11 

Permit Processing Times for Applications Subject 

to Both PSD and Non-Attainment Review 11 

1.4 PSD AND NON-ATTAINMENT REVIEW APPLICABILITY 14 

Emissions Subject to Review 14 

Permit Applications Eliminated From Review 

at Various Thresholds 14 

1.5 ANALYSIS OF BACT AND LAER ASSOCIATED WITH 

FINAL PERMIT EMISSIONS LIMITATIONS 18 

Technology Reviews 18 

Effects of NSPS and NESHAPS on BACT and LAER 18 

Emission Units 18 

Allowable Emissions 21 

I1ACT vs. LAER 23 

Effect of Emission Unit Size on BACT-Permitted 

Emissions and Emissions Reductions Beyond NSPS 29 

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TABLE OF CONTENTS 

(Continued) 

Page 

Emission Reductions From Proposed 

BACT Emission Levels 35 

Effect of PSD on Allowable Emissions 35 

1.6 ANALYSIS OF AIR QUALITY IMPACTS 37 

Frequency of Air Quality (A/Q) Analyses 37 

Effects of Allowable PSD Increment Constraints 38 

Effects of Constraints Caused by National 

Ambient Air Quality Standards (NAAQS) 39 

Effect of A/Q Constraints on Emissions 

Reductions Beyond NSPS 40 

1.7 MISCELLANEOUS ASSOCIATED ANALYSES 40 

Effect of Class I Allowable SO- Increment 

on Power Plant Siting 40 

Effect of Alternative Class I Increment 

System on Emissions Near Class I Areas 43 

Cost to Prepare a PSD Application 43 

2.0 DATA BASE OF PSD PERMIT APPLICATIONS 47 

2.1 INTRODUCTION 47 

2.2 DATA BASE SOURCE TYPES AND PROJECT DESCRIPTIONS ... . 47 

Source Types 47 

New Major Sources and Major Modifications 49 

Project Descriptions 49 

2.3 POLLUTANT APPLICABILITY 50 

2.4 NONATTAINMENT REVIEW 50 

2.5 DATA BASE EMISSION UNITS 51 

2.6 DATA BASE EMISSIONS SUMMARY 51 

2.7 AIR QUALITY DATA 51 

2.8 PSD APPLICATION SUBMITTALS 53 

2.9 PSD REVIEW AUTHORITY 55 

iv 
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TABLE OF CONTENTS 

(Continued) 

Page 

3.0 PSD PERMIT PROCESSING TIMES 56 

3.1 INTRODUCTION 56 

3.2 SUMMARY OF PSD PERMIT PROCESSING TIMES 57 

Total Processing Time 57 

Application Completeness 57 

Permit Processing Time from Receipt of a 

Complete Application 61 

3.3 COMPONENTS OF PSD PERMIT PROCESSING TIME 

BY PERIOD OF APPLICATION SUBMITTAL 65 

3.4 EFFECT OF SOURCE SIZE AND TYPE ON PROCESSING TIMES ... 65 

3.5 EFFECT OF PRE-APPLICATION CONTACT ON PROCESSING TIMES . 69 

3.6 PERMIT PROCESSING TIMES FOR APPLICATIONS SUBJECT 

TO BOTH PSD AND NONATTAINMENT REVIEW 69 

4.0 ANALYSIS OF PSD AND NONATTAINMENT REVIEW APPLICABILITY ... 72 

4.1 INTRODUCTION 72 

4.2 DISTRIBUTION OF CRITERIA POLLUTANT EMISSIONS 72 

4.3 POLLUTANT REVIEWS AND EMISSIONS COVERAGE 

AT VARIOUS THRESHOLDS 79 

4.4 PERMIT APPLICATIONS ELIMINATED FROM 

REVIEW AT VARIOUS THRESHOLDS 85 

4.5 ELIMINATION OF NON-CRITERIA POLLUTANTS TROM 

I'SO REVIEW 09 

5.0 ANALYSIS OF BACT AND LAER ASSOCIATED WITH 

FINAL PERMIT EMISSIONS LIMITATIONS 92 

5.1 INTRODUCTION 92 

5.2 TECHNOLOGY REVIEWS 92 
1 

TABLE OF CONTENTS 

(Continued) 

5.3 EFFECTS OF NSPS AND NESHAPS ON BACT AND LAER 94 

Emission Units 94 

Allowable Emissions .. . 96 

5.4 BACT VS. LAER 99 

5.5 EFFECT OF EMISSION UNIT SIZE ON BACT-PERMITTED 

EMISSIONS AND EMISSION REDUCTIONS BEYOND A NSPS ... . 106 

5.6 PROPOSED VS. PERMITTED BACT 113 

5.7 EFFECT OF PSD ON ALLOWABLE EMISSIONS 113 

6.0 ANALYSIS OF AIR QUALITY IMPACTS 116 

6.1 INTRODUCTION 116 

6.2 FREQUENCY OF AIR QUALITY ANALYSES 116 

Source Applicability 116 

Pollutant Applicability 117 

Frequency of Required Monitoring Data 119 

6.3 ANALYSIS OF ALLOWABLE PSD INCREMENTS 120 

Increment Consumption 120 

Class II Increment Consumption Impacts 

by Source Type and EPA Region 127 

Effects of Allowable PSD Increment Constraints ... . 127 

Role of Increment Impacts Analyses 

on Specific Projects 129 

6.4 ANALYSIS OF NATIONAL AMBIENT AIR QUALITY 

STANDARDS IMPACTS 134 

NAAQS Impact Analyses .... . 134 

Effects of Constraints Caused by National 

Ambient Air Quality Standards (NAAQS) 138 

6.5 CLASS I AREA IMPACTS ANALYSES 139 

6.6 EFFECT OF A/Q CONSTRAINTS ON EMISSIONS 

REDUCTIONS BEYOND NSPS 139 

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TABLE OF CONTENTS 

(Continued) 

Page 

7.0 MISCELLANEOUS ASSOCIATED ANALYSES 142 

7.1 EFFECTS OF CLASS I SO., INCREMENT 

ON POWER PLANT SITING 142 

Introduction 142 

Results 142 

Analyses Approach 145 

7.2 EFFECT OF ALTERNATIVE CLASS I INCREMENT SYSTEM 

ON EMISSIONS NEAR CLASS 1 AREAS 149 

7.3 TIME AND COSTS TO PREPARE A PSD APPLICATION 155 

APPENDIX A - DISCUSSION OF MAJOR CHANGES IN APPLICABILITY 

OF PSD AND NON-ATTAINMENT REGULATIONS AND 

T HE EFFECT ON PERMITS IN THE DATA BASE A-l 

APPENDIX B - DATA BASE OF PSD PERMIT APPLICATIONS B-1 

APPENDIX C - PSD PERMIT PROCESSING TIMES C-1 

APPENDIX D - ANALYSIS OF PSD AND NON-ATTAINMENT 

REVIEW APPLICABILITY D-1 

APPENDIX E - ANALYSIS OF BACT AND LAER E-1 

APPENDIX F - ANALYSIS OF AIR QUALITY IMPACTS F-l 

APPENCIX G - EXAMPLE SOURCE DATA AND CODING FORMS G-1 

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1.0 EXECUTIVE SUMMARY 

1 . 1 INTRODUCTION 

Background 

Pursuant to the Clean Air Act Amendments of 1977 EPA, in 1978, reviser! 

i t s New Source Review (NSR) regulations . The revised Prevention of 

Significan t Deterioratio n (PSD) regulations were more extensive than 

their predecessors in tha t many more sources were subject to PSD 

requirements. The NSR regulations were again revised in 1980 as a resul t 

of litigation . This report deals wit h a sample of the pre-construction 

permits issued under EPA's post-1977 NSR regulations . In the years 

1978, 1979 and 1980, &1*mmmmFfmmmmMfmmmmmia*m immm* 

il ^^0HH_HP____________|___H__HH_______HH^-^^^^TO^^^^^rronThe data and information contained i n thi s report summarize result s 

of a study directed at assessing the experience o f EPA's New Source 

Review (NSR) Program. Information extracted from Prevention of 

Significan t Deterioratio n (PSD) and non-attainment permit'file s augmented 

by data obtained from company representatives have been compiled, analyzed 

and interpreted . An automated (computer) data base has been constructed 

containing relevant data fo r each of more than 285 PSD and non-attainment 

permits issued since 1978. 

The data base permits were subject to two differen t PSD Regulations 

(1978 and 1980) and one "interim " applicabilit y criterio n that being 

the post-Alabama Power "stay " of PSD Regulations in effec t between 

February 5 and August 7, 1980. These regulations are complex and 

contain differen t regulatory requirements. An understanding nf these 

regu I.i tions is extremely helpful in reading and interprotin q thi s report, 

l o r that purpose, a brie f descriptio n of the CSn and non-attainment 

regulations and the major differences between the 1978 and 19H0 versions 

is provided in Appendix A of the ful l report. 

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5 i Projec t Objectives 

The primary objectiv e of thi s projec t was to produce data that 

characterize recent experience wit h implementation of EPA's NSR 

Regulations. The data extracted and compiled was fo r the purpose 

o f representing a cross-section o f PSD and non-attainment permits 

issued pursuant to the Clean Air Act Amendment of 1977. The result s 

described in thi s report are not intended as an assessment of the 

effectivenes s (or lack thereof) of the NSR program. The analyses 

performed and the presentation o f result s are fashioned to allow the 

reader to formulate his or her own opinions . 

Stringent qualit y control procedures were used fo r each step of 

thi s project.. Accuracy checks were made by attempting to arriv e at the 

same value by two or more independent methods. I f result s of two 

methods differe d by more than 37., investigation s of the cause(s) were 

conducted unti l the difference became less than 3". 

1.2 DATA BASE OF PSD PERMIT APPLICATIONS 

Data Base Source Types 

The data base consists of HjgmjgggjangHMMagM F from the ten 

EPA regions . Table 1-1 presents a summary of the data base industria l 

source categories included in the sample by EPA region. The data boje 

application s are grouped int o the "named" 28 PSD sources and "other" PSD 

sources. The "named" 28 sources are subject to a 100 tons/year major 

source threshold as defined i n the PSD regulations . The "other" source 

categories are subject to a 250 ton per year major source threshold. 

Petrochemical and petroleum relate d sources (108) such as refineries , 

terminals , compressor stations , etc . constitut e 38." of the data base 

followed by electri c utilitie s (147). 

Dajta Base Emissions Sunmary 

Table 1-2 presents an emissions suiiinary of PM, S02> NO , CO .ind VOC 

emissions from al l data base applications . Nic emissions presented are the 

"net emissions changes" and "BACT and I.ALR permitted emissions". The net 

emissions changes of a pollutan t are calculated as the differenc e between 

the gross increases and gross decreases of the pollutan t fo r al l data base 

applications . Most emissions limitation s in PSD permits are a resul t of 

case-by-case applicatio n of eithe r Best Available Control Technology (BACT) 

f o r "attainment" pollutant s or Lowest Achievable Emission Rate (LAER) fo r 
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Table 1-1 . DATA BASE PSD APPLICATIONS 

BY EPA REGION AND SOURCE CATEGORY 

Source Category 

A. Named 28 PSD Sources 

Electric plants with greater than 

250 MH8tu/hr heat Input 

Coal cleaning plants ("H h thermal dryers) 

Kraft pulp mill s 

Portland cement plants 

Smelters 

Non-metallic mineral process plants 

Carbon black plants 

Chemical plants 

Petroletaa refinerie s 

Other - municipal Incinerator, coke oven, 

fuel conversion, secondary metal, petroleu* 

transfer and glass fibe r plants 

Subtotal 

8. Other PSO Sources 

Mining operations 

Asphalt production plants 

Natural gas and crude oi l piaaplng stations 

Natural gas processing plants 

Lumber and wood products manufacturing 

Autoootlve part manufacturing 

Food processing 

Brewery 

Glass manufacturing 

1 

1 

0 

2 

0 

0 

0 

0 

1 

0 

1 

s 

1 

3 

0 

0 

4 

0 

0 

0 

0 

11 

1 

0 

1 

0 

3 

0 

0 

8 

1 

0 

14 

3 

S 

0 

0 

0 

0 

1 

1 

0 

I I I 

4 

0 

1 

0 

2 

0 

0 

« 

2 

2 

17 

1 

4 

0 

0 

0 

0 

0 

2 

1 

EPA DECION 

IV 

6 

0 

6 

0 

3 

5 

0 

9 

} 

0 

32 

0 

0 

1 

0 

1 

t 

4 

0 

0 

V 

s 

2 

0 

0 

1 

2 

0 

3 

0 

4 

17 

1 

2 

4 

0 

1 

4 

0 

1 

1 

VI 

4 

0 

1 

2 

0 

1 

2 

7 

6 

1 

24 

0 

0 

12 

0 

1 

0 

0 

1 

1 

V I I 

5 

0 

0 

0 

1 

0 

0 

1 

3 

1 

11 

0 

0 

2 

0 

0 

2 

0 

0 

0 

VII I 

5 

0 

0 

3 

0 

0 

0 

0 

1 

0 

9 

2 

1 

11 

2 

0 

0 

0 

0 

0 

IX 

s 

0 

0 

0 

0 

0 

1 

0 

7 

0 

13 

1 

1 

2 

0 

0 

0 

1 

0 

1 

X 

3 

0 

3 

0 

1 

1 

0 

1 

3 

1 

13 

0 

0 

11 

1 

1 

0 

0 

0 

0 

Total 

39 

2 

11 

5 

11 

9 

3 

36 

26 

10 

155 

9 

16 

43 

3 

8 

7 

6 

5 

< 

Municipal Incinerators capable of charging 

less than 250 MMBtu/hr heat Input 

Miscellaneous manufacturing/production -

computers, electrodes, textiles, fertilizer, 

salt, kaolin, geothermal power, printing 

Rubber and plastic production plants 

Other - Including military bases, laboratories 

Subtotal 

0 

0 

1 

12 

17 

4 

1 

0 

16 

30 

1 

0 

4 

13 

30 

3 

2 

0 

13 

45 

1 

0 

0 

16 

32 

0 

0 

0 

IS 

39 

o o o 4 

IS 

0 

0 

1 

17 

26 

2 

0 

2 

10 

23 

0 

0 

2 

15 

28 

11 

3 

10 

130 

28S 
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Table 1-2. EMISSIONS SUMMARY OF PM, SO?, NO , CO and VOC 

EMISSIONS FROM ALL DATA BASE APPLICATIONS 

Pollutant 

PM 

so2 

NOx 

CO 

VOC 

Net Emissions Changes 

(tons/year) 

57.000 

722.000 

709,000 

-107,000a 

-13,000b 

BACT and LAER 

Permitted Emissions 

57,000 

777,000 

713,000 

162,000 

16.000 

This value includes emissions reductions of 299,000 tons/year of CO 

from two carbon black plants. 

This value includes emission reductions of 22,000 tons/year of VOC 

from one carbon black plant and one kraft pulp mill. 
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non-attainment pollutants. Those data base emissions that resulted from 

either BACT or LAER review are presented in the table as "BACT and LAER 

permitted emissions". In the case of CO, large reductions at two carbon 

black plants resulting from combustion of process gas are greater than 

the CO increases in the remainder of the data base. Similarly, VOC 

emissions indicate a net decrease for the data base. However, many PSD 

permits supply only estimated VOC emissions and in some cases, VOC 

emissions were not quantified at all. Therefore, VOC emissions data 

are not accurate and caution should be used in assessing this data. 

PSD Application Submittals 

Figure 1-1 shows a chronology of data base PSD applications by 

submittal date. It appears that "surges" of PSD application submittals 

occurred at times of actual or anticipated changes in PSD requirements. 

The first surge occurred just prior to the August 7, 1978 expiration of 

the monitoring exemption. The second and third surges occurred just 

prior to the Alabama Power decision and expiration of the "stay" of 

PSD regulations, respectively. 

Overall, the data base consists of JM___________H9__H_S____eps .wM W 

^iWW-WBEWPw l Of the 285 data base applications, 215 were reviewed 

under the 1978 regulations and 70 were subject to the 1980 (post-Alabama 

Power) regulations. 

1.3 PERMIT APPLICATION PROCESSING TIMES 

Summary of PSD Permit Processing Times 

Total Processing Time. PSD permit processing times varied widely among 

data base applications. The time between initial application submittal and 

permit issuance ranged from 1.4 to 51.3 months. 

Table 1-3 summarizes by EPA region the total processing time (from 

initial application submittal to pennit issuance) of all data base 

applications. By EPA region, processing times averaged 11.0 months and 

ranged from 8.0 to 14.6 months. As shown on Table 1-3, the average 

processing time by affiliation of the application reviewer (EPA, State or 

local agency, or contractor) varied between 10.5 months for EPA personnel 

to 12.9 months for contractors. Contractors were used by EPA and State 

agencies to assist in reviewing and processing NSR permit applications. 

Based on the limited amount of data for contractor and State agency 
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Table 1-3. SUMMARY OF PSD PERMIT PROCESSING TIME (INITIAL APPLICATION 

SUBMITTAL TO PERMIT ISSUANCE) BY EPA REGION ANO APPLICATION REVIEWER 

tPA 

Region 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

TOTAL 

EPA 

Personnel 

No. of 

Applications 

Reviewed 

17 

30 

29 

1 

32 

0 

IS 

24 

21 

28 

197 

OVERALL AVERAGE 

PROCESSING Tire (MONTHS) 

RANGE OF PROCESSING 

TIME (KWTKS) 

Average 

Processing 

Time (months) 

8.0 

9.8 

11.6 

1.6 

11.9 

N/A 

11.6 

8.9 

10.9 

9.4 

10.5 

1.4 - 51.3 

PSO AppHcatl on Reviewer 

State Agency 

Personnel 

No. of 

Applications 

Reviewed 

0 

0 

0 

33 

0 

0 

0 

0 

1 

0 

34 

Average 

Processing 

Time (months) 

N/A 

N/A 

N/A 

10.3 

N/A 

N/A 

N/A 

N/A 

26.9 

N/A 

10.8 

2.9-32.1 

Contractors 

No. of 

Applications 

Reviewed 

0 

0 

1 

11 

0 

39 

0 

2 

1 

0 

54 

Average 

Processing 

Time (months) 

N/A 

N/A 

6.5 

13.9 

N/A 

13.9 

N/A 

22.8 

9.3 

N/A 

12.9 

3.8 - 37.5 

Total 

Permits 

Issued 

17 

30 

30 

45 

32 

39 

15 

26 

23 

28 

285 

Overall 

Average 

Processing 

Time 

(months) 

8.0 

9.8 

11.4 

11.1 

11.9 

12.4 

14.6 

9.9 

11.5 

9.4 

11.0 

Range of 

Processing 

Time 

(months) 

2.9 - 15.3 

1.4 - 20.8 

3.6 - 37.7 

2.9 - 32.1 

4.9 - 24.6 

5.7 - 37.5 

2.2 - 31.6 

3.5 - 27.5 

2.6 - 51.3 

3.0 - 19.5 

1.4 - 51.3 

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reviewers, it does not appear that processing times were greatly 

influenced by reviewer affiliation. 

As can be determined from Figure 1-2, 25% of the data base permits 

were processed within 6 months; 68% within one year and 88% within 18 months 

from the time of initial submittal. It must be recognized that the sampling 

procedure itself created a potential bias that may cause results of processing time analyses to be misleading when attempting to apply these results 

to all NSR permits. Permits were selected for inclusion based on reverse 

chronological order of permit issuance. Therefore, permit applications 

submitted early and processed quickly and applications submitted late and 

not processed quickly would not have been selected. This potential bias 

is further discussed in Section 3.0 of the report. 

Application Completeness. Sixty-six (23%) data base applications 

were deemed officially "complete" upon initial application submittal. The 

remainder (219) were required to submit additional information for this 

determination. In a few cases, this required more than two years from 

the date of initial submittal. Overall, it took an average of 3.7 months 

from initial submittal to submittal of a "complete" application. 

Figure 1-3 shows the distribution of data base applications by the 

time between initial submittal and determination of "completeness." 

As shown below, the fraction of PSD applications that were deemed 

complete upon initial submittal varied from 0% of the applications in 

EPA Region I to 52% in Region IX. 

Applications Determined "Complete" 

Upon Initial Submittal 

EPA Region 

I 

II 

III 

IV 

V 

VI 

VII 

VIII 

IX 

X 

Total Number 

of Data Base 

Applications 

in Region 

17 

30 

30 

45 

32 

39 

15 

26 

23 

28 

Number 

0 

11 

1 

18 

% in Region 

0 

37 

3 

40 

32 

39 

15 

26 

23 

28 

8 

1 

5 

1 

10 

12 

7 

3 

13 

7 

37 

52 

26 
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a. 

co 

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FIGURE 1-2. DISTRIBUTION OF PERMIT PROCESSING TIMES 

BY 6 MONTH INTERVALS. 

3 

140 

130 

120 

110 

100 

90 

80 

70 

60 

50 

40 

30 

20 

71 

10 -

124 

55 

19 

10 

50 

45 

40 

35 

30 

25 

20 

15 

10 

- 5 

0-6 ' 6-12 ' 12-18 ' 18-24 ' 24-30 ' 30-36 ' 36-48 ' 

TOTAL PERMIT PROCESSING TIMC, MONTHS 

(APPLICATION SUBMITTAL TO PERMIT ISSUANCE) 

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i 

*".? y • i<n», .«»_>••;'." 

FIGURE 1-3. DISTRIBUTION OF.THE PROCESSING TIME BETWEEN INITIAL APPLICATION SUBMITTAL 

AND SUBMITTAL OF A COMPLETE APPLICATION BY 1" MONTH INTERVALS. 

a. 

< 

•x. 

=3 

IV 

60 

50 

40 

30 

20 

10 

n 

66 

-

-

27 

51 

36 

23 

9 

16 

11 

9 

-

37 

-

25 

- 20 

- 15 

- 10 

- 5 

0 ' 0-1 ' 1-2 ' 2-3 ' 3-4 " 4-5 ' 5-6 • 6-7 ' 7-8 GREATER 

THAN 8 

PROCESSING TIME. MONTHS 

(INITIAL APPLICATION SUBMITTAL TO SUBMITTAL 

OF A COMPLETE APPLICATION) 

10 

xA 

cr> 

U_ 

o 
y^fi&XtHli&Kami&m 

Permit Processing Time From Receipt of Complete Application. The 

average permit processing time from date of "completeness" to final permit 

issuance was 7.1 months. By EPA region this average ranged from 5.3 to 

9.3 months. As shown in Figure 1-3, almost 90% of the data base applications 

were processed within one year of submittal of a "complete" application. 

Effect of Source Type and Size on Processing Times 

From date of initial submittal, utility power plants applications 

took considerably longer to process than all other source types combined. 

About 50% of non-utility applications were processed (total time) in less 

than nine months whereas only 16% of utility applications were processed 

within that time. Furthermore, almost 60% of utility applications required 

more than one year to process (total time) whereas only 27% of the 

non-utility sources required more than one year. 

It appears that applications for major modifications required slightly 

more processing time than those for new major sources. An analysis showed 

that for major modifications, a direct relationship exists between the 

length of application processing time and the amounts of pollutants 

increased (tons/year). This same relationship was not found to be true 

for new major sources. 

Effect of Pre-Application Meetings on Processing Times 

For applications submitted in 1978, 1979 and 1980, those that were 

preceded by meetings between the applicant and the reviewing authority 

appeared to have experienced shorter total pennit processing times than 

those that did not. Table 1-4 shows that this difference averaged 7.5 

months in the last half of 1978 and .8 months in the first half of 1980. 

The table also shows this difference to gradually disappear in 1980. 

This may indicate that pre-application contacts were beneficial at the 

inception of the program, but as people became more aware of the 

regulations and procedures, pre-application contact diminished in value 

as far as processing times are concerned. A survey of EPA regional office 

files shows that about 30% of the data base permits involved pre-application 

contact between the applicant and the reviewing authority. 

Permit Processing Times for Applications Subject to Both PSD and 

Non-Attainment Review 

Twenty-three (23) applications were found to be subject to simultaneous 

PSD and non-attainment review. For these 24 permits, the time required to 

obtain both the PSD and non-attainment permits ranged from 3.7 to 37 

months and averaged 14.4 months from date of initial submittal to permit 

issuance. 

11 

- i . 

i • 

4 
WPMrnBanranaommiM 

K B 

FIGURE 1-3. DISTRIBUTION OF THE PROCESSING TIME BETWEEN SUBMITTAL OF A 

COMPLETE APPLICATION AND PERMIT ISSUANCE BY 6 MONTH INTERVALS. 

150 

140 

130 

XA 

Z 

o 

< 

(_) 

_J 

o. G. 

< o IA 

a. 

u. 

o 

ce 

UJ 

s? 2 

120 

110 

100 

90 

80 

70 

60 

50 

40 

30 

20 

10 

145 

109 

20 

- 30 

±=± 

50 

40 

20 

10 

0-6 ' 6-12 ' 12-18 ' 18-24 ' 24-30 ' 30-36 ' 

CJ 

CL. 

o_ 

rX 

UO 

PROCESSING TIME, MONTHS 

(SUBMITTAL OF A COMPLETE APPLICATION TO PERMIT ISSUANCE) 

12 
^?W^W*^J..«.,*WJ,PWHl*»M.iu^*wW-»*-. • 

_-»^.r^^«'r^^w^W*»*^\^lMlllWWMi 

No. of 

Permits 

With Presubmittal 

Contact 

Table 1-4. COMPARISON OF AVERAGE PERMIT PROCESSING TIMES FOR PSD PERMIT 

APPLICATIONS WITH AND WITHOUT PRE-APPLICATION MEETINGS 

Average Time Span 

Between Pre-submittal 

Contact and Final 

Permit (months) 

Average 

Permitting* 

Time (months) 

for Sources With 

Pre-submittal 

Contact 

No. of Permits 

Without Presubmittal 

Contact 

*From application submittal to final permit. 

Average Permitting 

Time* (months) for 

Sources Without 

Pre-submittal 

Contact 

^ 1st half 1978 

2nd half 1978 

1st half 1979 

2nd half 1979 

1st half 1980 

2nd half 1980 

2 

8 

14 

17 

10 

2 

14.0 

16.0 

10.5 

12.0 

12.2 

8.0 

11.0 

11.0 

7.3 

7.6 

8.6 

7.0 

7 

24 

30 

19 

43 

18 

! 

23.9 

18.5 

7.8 

9.5 

9.4 

7.0 

••-"-•"i'«iiim"ili.vW«l^ 
E"MS»V. •—MfCWf-T!—«> (Ji*!' wtfWf««<BW»««*MW , »MHaw«LJ('*!iC£,.'*T,>') 

* 

1.4 PSD AND NON-ATTAINMENT REVIEW APPLICABILITY 

Table 1-5 shows the amounts of criteria pollutant emissions reflected 

in the data base PSD and non-attainment permits. The values, shown 

in this table, consider only those data base permits that indicate 

net pollutant emission increases. This table, therefore, more closely 

depicts the applicability criteria of the 1980 NSR regulations which, 

unlike the 1978 regulations, generally do not apply to net pollutant 

decreases. This table also categorizes, by pollutant and size category, 

the permitted emissions increases for each application. As can be seen, 

most of the permitted SO-. NO , and CO emissions were caused by applications involving more than 1000 tons/yr increase of these pollutants. 

This is predominantly the influence of utility power plants and other 

very large sources. Over 90% of the utility power plants increased 

emissions of at least one pollutant by more than 1000 tons/yr. Shown 

below are the relative contributions to total permitted emissions by 

utility and non-utility (sources other than electric utility generating 

stations) sources: 

Distribution of Data Base Permitted Criteria Pollutant Emissions 

PM 

Utilit y Sources 617. 

Non-utilit y Sources 397. 

so2 

777. 

237. 

Permit Applications Eliminated From Re 

NO 

X 

787. 

227. 

mew at Va 

CO 

397. 

61% 

rious Th 

VOC 

677. 

337 

resholds 

Figure 1-4 shows the relationship between the number of data base 

permit applications that would be eliminated from review and alternative 

applicability thresholds. These thresholds assume uniform "new major 

source" (tons/year potential emissions) and "deminimis" values (tons/yr 

increase in "actual" emissions) for major modifications. Table 1-6 

shows the percentage of applications eliminated from review at uniform 

applicability thresholds of 100, 500 and 1000 TPY. Also shown on this 

table are the percentages of pollutant reviews and emissions eliminated 

from review at each threshold. These latter items should not be construed 

14 

O 

OS-
<jK»j^'jWffi^o*9>sYjrec:B^M%»y^*<^^ -,-..•—•;«*- -•»"••-

Table 1-5. DISTRIBUTION OF PERMITTED EMISSION INCREASES OF 

PM, S02, NOx, CO AND VOC AT VARIOUS APPLICATION SIZE CATEGORIES 

Emissions Size 

Cateqory 

(Permitted 

Emissions Increase, 

Tons/Yr Per PSD 

Application)a 

0 - significant level 

Significant level - 100 

100 - 500 

500 - 1000 

Greater than 1000 

TOTAL 

PM 

t/yr % of 

(lOOO's) total 

.7 

3.3 

11.0 

12.0 

35.0 

62.0 

1 

5 

18 

19 

57 

100 

SO 

t/yr 

(lOOO's) 

.6 

.8 

10.3 

13.0 

708.0 

732.7 

Pollutant (tons/year) 

h of 

total 

<1 

<1 

1 

2 

97 

100 

NOv 

t/yr % of 

(lOOO's) total 

.3 

.8 

15.9 

27.0 

665.0 

709.0 

<1 

<1 

2 

4 

94 

100 

CO 

t/yr % of 

(lOOO's) total 

2.1 

NAC 

14.0 

14.0 

218.0 

243.1 

1 

6 

6 

87 

100 

VOC 

t/yr % of 

(lOOO's) total 

1.2 

1.3 

7.0 

4.0 

9.0 

22.5 

5 

6 

31 

18 

40 

100 

aEmissions from applications with permitted net decreases are not included in the table; emissions 

are discrete values within each category. 

Significant levels as defined in the 1980 PSD regulations (tons/year): PM = 25; S02 = 40; NO = 40; 

CO = 100; VOC = 40. 

'100 tons/year emission increase is the significance level for CO emissions. 

be. 
'ml *•< 

//$fayit'MkWWIf.VV9*''WVX'*n*nxv •• xm :•»-•. 

-y.r-.r ^9Vr^rr.rVrJirnir!SVS»C^gSSe^ 

Figure 1-4. DATA BASE APPLICATIONS ELIMINATED FROM 

PSD REVIEW AT VARIOUS APPLICABILITY THRESHOLDS 

CUMULATIVE NUMBER 

OF APPLICATIONS 

(NEW MAJOR SOURCES AND 

MAJOR MODIFICATIONS) 

ELIMINATED FROM 

PSO REVIEW 

CUMULATIVE PERCENT OF 

TOTAL APPLICATIONS 

(NEW MAJOR SOURCES AND 

MAJOR MODIFICATIONS) 

ELIMINATED FROH 

PSO REVIEW 

900 1000 

APPLICABILITY THRESHOLD - MAJOR SOURCE THRESHOLD FOR NEW MAJOR SOURCES AND 

SIGNIFICANT EMISSION LEVEL FOR MAJOR MODIFICATIONS 

(tons/year of the largest pollutant emission rate for new 

major sources and the largest pollutant net emissions 

increase for major modifications) 

. . ».i.i--«ii»_«_»iin«_«_______tfcM<t>__M_'tt 
jlllpqqflBi^pwW^^ 

Table 1-6. THE NUMBER OF CRITERIA POLLUTANT REVIEWS AND AMOUNT OF ASSOCIATED 

EMISSIONS ELIMINATED AT SELECTED UNIFORM APPLICABILITY THRESHOLDS 

Emissions 

Threshold 

(TPY) Pollutant 

% of 

Pollutant Reviews 

Eliminated 

% of 

Emissions 

Eliminated 

% of 

PSD Applications 

Eliminated 

100 

500 

1000 

PM 

so2 

NO* CO* 

VOC 

PM 

so2 

N O; 

C0X 

VOC 

PM 

S0-

NO* 

C0X 

VOC 

45 

8 

7 

NA 

43 

80 

34 

40 

55 

84 

91 

47 

61 

72 

94 

6 

<1 

<1 

NA 

8 

25 

2 

2 

6 

40 

44 

3 

6 

11 

60 

7 

33 

51 

i\-&faix&^?&'i&Mt 
•Ei 

=1 

tAj1 JMWWH. 1 ' iimmup»ii_i_i>ii 

i 

to represent elimination of the complete NSR application from review. 

This simply is the elimination from review of one or more pollutants per 

application out of several pollutants that may be subject to review. For 

instance, at a uniform "deminimis" threshold of 100 tons per year, 7% of 

the applications that would otherwise be subject to PSD review would be 

exempt. At this level, 45% of the particulate matter (PM) reviews would 

be eliminated. This means that the PM emission increases subject to PSD 

review in 45% of the data base applications were less than 100 tons per 

year. The PM emissions increase associated with these applications is 

only 6% of the total data base PM emissions. 

In contrast, at a uniform 100 TPY deminimus threshold, only 8% and 

7% of the SO2 and NO reviews, respectively, would be exempt. The SO, 

and NO emissions increases associated with these reviews are each less 

than 1% of the total SO, and NO emissions in the data base. 

1.5 ANALYSIS OF BACT AND LAER ASSOCIATED WITH FINAL PERMIT EMISSIONS 

LIMITATIONS 

The emissions values presented in this section reflect only those 

that were subject to and permitted according to BACT (Best Available 

Control Technology) and where applicable, LAER (Lowest Achievable Emission 

Rate). They do not include emissions reductions resulting from equipment 

shutdowns and similar situations nor do they include permit limitations 

that were specified solely for the purpose of issuing federally enforceable 

permit conditions for exemption purposes. 

Technology Reviews 

Table 1-7 shows, by pollutant, the number of data base applications 

and emissions units that were subject to BACT or LAER. 

As can be seen, NO emissions were found to be the pollutant most 

frequently subject to BACT; VOC emissions were most frequently subject to 

LAER. Only five of the nine non-criteria pollutants were subject to BACT. 

Effects of NSPS and NESHAPS on BACT and LAER 

Emission Units. Table 1-8 shows the number of data base emission 

units that were subject to an NSPS (or NESHAP) and received emissions 

limitations: 

• At the maximum emission rate allowed by the liSPS; and 

• At an emissions rate more stringent than the maximum allowed 

by the NSPS. 

18 

HVK-.J> •".•IM11'" wm i % J_0MmM_IV tm999-9 99 _•!»•_*_*• 

gejnOTSMP-fl'nWS'^W 

II • ! - . .1 
. ...y.y-.r,-^.-...^^ya.^irp.^^t^.^ll^r^^^-l^'^V^^?^: 

f.\ mill. IUHIIIIHU.IIMUI.il i »" "*•'-

Table 1-7. DATA BASE BACT AND LAER APPLICABILITY BY SOURCE AND EMISSION UNITS 

Pollutant 

Number of 

Applications 

(Sources) 

Subject 

to BACT* 

Number of 

Applications 

(Sources) 

Subject 

to LAER* 

Number of 

Emission 

Units 

Subject 

to BACT 

Number of 

Emission 

Units 

Subject 

to LAER 

Particulate Hatter (PH) 

Sulfur Dioxide (S02) 

Nitrogen Oxides (N0X) 

Carbon Monoxide (CO) 

Volatile Organic Compounds (VOC) 

Fluorides (F) 

Vinyl Chlorides 

Total Reduced Sulfur (TRS) 

Hydrogen Sulfide (H2S) 

Sulfuric Ad d Mist 

Total Technology Reviews 

163 

157 

186 

95 

43 

9 

1 

3 

2 

3 

15 

6 

3 

6 

26 

-

-

-

-

-

589 

429 

727 

427 

144 

18 

4 

6 

2 

4 

2350 

35 

9 

6 

12 

40 

-

-

-

-

-

102 

Most applications (sources) were subject to either 8ACT and/or LAER for more than one pollutant. 

Therefore, the sum of these columns is greater than the number of data base sources. 
^HK»Hiijnmmn,_T>,wt»n|

t"i»wi«w ••Miwuitijui.wiiii • =• yr^.m .r*>M < ,..n.-yr. y,-&fTrvrr— . 

..9*,Tyr.TX^9V^9X-. 

ro 

o 

Table 1-8 . TECHNOLOGY REVIEWS SUBJECT TO NSPS (OR NESHAP) 

PERMITTED FOR BACT AT NSPS (OR NESHAP) RATE AND 

BELOW NSPS (OR NESHAP) RATE* 

NSPS ( or NESHAP) Pollutant 

Number of 

emission units 

permitted for 

BACT at NSPS 

(or NESHAP) rate 

Number of 

emission units 

permitted for 

BACT below NSPS 

(or NESHAP) rate 

X NSPS (or NESHAP) 

units subject to 

BACT permitted 

below NSPS (or 

NESHAP) rate 

Ratio of BACT 

to NSPS Allowable 

Emission Rate for 

Emission Units 

Permitted Below 

USPS Rate 

Particulate 

Hatter 

(PM) 

Total 

75 

34 

31X 

.49 

Utilities 

only 

31 

IS 

32X 

.50 

Sulfur 

Dioxide 

(so2) 

Total 

107 

51 

32X 

.45 

Utilities 

only 

35 

26 

43X 

.44 

Nitrogen 

Oxides 

(N0x) 

Total 

135 

24 

I5X 

.79 

Utilities 

only 

45 

20 

30X 

.79 

Carbon 

Monoxide 

(CO) 

lotal 

7 

2 

22X 

.52 

Utilities 

only 

0 

0 

Hydrogen 

Sulfide 

(H?S) 

Total 

1 

0 

OX 

Fluorides 

(F) 

Total 

14 

4 

22X 

.44 

Reduced 

Sulfur 

(TRS) 

Total 

3 

1 

25 X 

.84 

Vinyl 

Chloride 

Total 

4 

0 

ox 

H-S0. 

Mist* 

Total 

2 

1 

33X 

.67 

•An emission unit subject to NSPS for 2 pollutants is considered to undergo 2 technology reviews. 

Note: Most VOC NSPS (or NESHAP) are work practice or equipment standards - unable to quantify emissions. 

'__•__>_. . ruvxm-jitiM. 

* a >vt nun i, .r.Tir-i n«i afci iix'Siviiii 
UMI_UMW.lJMU.lWI 

Similar statistics specific to utility sources are also shown. For all data 

base emission units subject to NSPS (or NESHAPS), 27% were issued emission 

limits more stringent than the applicable NSPS (or NESHAP) would allow. 

This value is 36% for utility power plant sources. On a criteria pollutant 

specific basis for all data base sources, this value ranged from 15% for 

NO emissions to 32% for SO-. For utilities, this value ranged from 30% 

for NO emissions to 43% for SO- emissions. 

The bottom line on Table 1-8 shows, for emission units permitted 

more stringent than the applicable NSPS, the ratio of the average BACTpermitted emissions rates to the average of the maximum emissions rates 

allowed by the applicable NSPS (or NESHAP). 

Allowable Emissions. Table 1-9 shows a distribution of all BACTpermitted emissions by utility and non-utility sources including those 

BACT-permitted emissions subject to NSPS (or NESHAP). Also shown are 

emissions reductions beyond NSPS (or NESHAP) resulting from emissions 

limitations being more stringent than the applicable NSPS. As can be 

seen, the majority of emissions reductions beyond NSPS occurred at 

utility sources. Note, however, that the majority of BACT-permitted 

emissions subject to NSPS also occurred at utility sources. This 

relationship is shown below for PM, SO,. NO and CO emissions: 

Pollutant 

PM 

SO, 

NOE; 

c ox 

Relative Contribution 

Emission Reductions 

Beyond NSPS 

Utilit y Hon-utili 

Sources Sources 

79% 

96% 

98% 

0% 

2 1% 

4% 

2% 

100% 

to 

ty 

Relative Contribution to 

BACT-Permitted Emissions 

Subject to NSPS 

Utilit y Non-utility 

Sources Sources 

79% 

93% 

90% 

0% 

21% 

7% 

10% 

100% 

It appears that the distribution of emission reductions beyond NSPS 

is fairly consistent with the distribution of BACT-permitted emissions 

subject to NSPS for utility and non-utility sources. 

21 

_ 

. 

wmmmt-LimxLutmm i uiimumixixmmxmxmxixx «IUH»U ,»,«_»,JWiMmw^W.^f-VlE^Mff > W f \ 
>Ha_a_iMM»i in — ..- ^ _,„__.,—___. . ---'••- j

'-~"-••••- • "-^-•'••••i ^ 

•-*» / 

'•'^rT^T^ 

jm*&mv*)i***rw* •«wwn«.if......_* .•»•_•- «v ->» 

ide 

Table 1-9 . TOTAL BACT-PERMITTED POLLUTANT EMISSIONS, EMISSIONS SUBJECT TO NSPS (OR 

NESHAPS) AND EMISSIONS REDUCTIONS BEYOND NSPS (OR NESHAPS) bY UTILITY POWER PLANT SOURCES 

AND NON-UTILITY SOURCES 

PSO Pollutant 

BACT permitted 

eaissions for nonutility sources -

tons/yr 

ro BACT permitted 

eaissions for 

utility sources -

tons/yr 

Total BACT permitted eaissions -

tons/yr 

BACT permitted 

eaissions reductions beyond NSPS 

by non-utility 

sources - tons/yr 

BACT permitted 

eaissions reductions beyond NSPS 

by utility sources 

- tons/yr 

Total BACI permitted eaission reductions beyond NSPS -

tons/yr 

Particulate 

Natter (PM) 

lotal 

72.800 

11.400 

=4,200 

-

-

-

Subject 

to NSPS 

7,400 

27.800 

35.200 

1.600 

6.100 

7.700 

Sulfur 

Dioxide (SO,) 

Total 

192,400 

569.400 

761.800 

-

-

• 

Subject 

to NSPS 

41,SOO 

S61.900 

603,400 

8, SOO 

210,200 

218.700 

Nitrogen 

Oxides (NO ) 

Total 

162,SOO 

S49.900 

712,400 

-

-

-

Subject 

to NSPS 

63.700 

S42.600 

606.300 

1,200 

53.200 

54.400 

Carbon 

Monoxide (CO) 

Total 

97,600 

61,500 

159.100 

-

-

-

Subject 

to NSPS 

7,500 

0 

7,500 

2,970 

0 

2.970 

Volatile 

Organic 

Compounds 

(VOC)* 

lotal 

9,200 

4,500 

11,700 

-

-

Hydrogen 

Sulfide 

(H2S) 

lotal 

700 

0 

700 

-

-

-

Fluorides 

(F) 

Subject 

to NSP! lotal 

580 

0 

580 

0 

0 

-

300 

510 

810 

-

-

740 

Subject 

to NSPS 

300 

0 

300 

240 

0 

-

Total 

Reduced 

Sulfur (IRS) 

lotal 

1,160 

0 

1.160 

-

-

1 

Subject 

to NSPS 

60 

0 

60 

1 

0 

-

Vinyl 

Chloride 

Total 

110 

0 

110 

-

-

0 

Subject 

to 

NESHAPS 

110 

0 

UO 

0 

0 

-

H,S04 

Mist 

Total 

180 

0 

180 

-

-

2 

Subject 

to NSPS 

120 

0 

120 

2 

0 

I *V0C NSPS's are generally work practic e or equipment standards. Unable to quantil y VOC emissions subjec t t o N.PS. 
V&Wmmt»**>r!m**KiKmm rtxmmmmrm imi. 

For all pollutants, on a percentage basis, more utility emissions 

are subject to NSPS than non-utility emissions: 

BACT-Perm1tted Emissions (TPY) 

Subject to NSPS 

I of Emission Reductions 

Total Data Base Beyond NSPS (TPY) 

Total 

Oata Base 

Total •Hypothetical" 

DSPS Allowable 

Emissions (TPY) 

Utility Sources 1.220.000 

Non-utility Sources 487,000 

1.130.OOO 

121.000 

931 

251 

270.OUO 

14.SOO 

1.400,000 

135,500 

Total 1.707.000 1.251.000 -94.500 1.535,500 

For all sources, 73% of the BACT-permitted emissions were subject to 

NSPS. Twenty-five percent (25%) of non-utility source emissions are 

subject to NSPS (or NESHAP), whereas 93% of utility source emissions are 

subject to NSPS. 

BACT vs. LAER 

Of the 285 PSD applications, 35 were subject to non-attainment review 

for certain pollutants. The data were extracted from EPA files which, in 

most cases, do not contain LAER technology data since LAER reviews are 

performed by State agencies. Therefore, sufficient LAER control technology 

data are available for only 15 of the 35 PSD applications to compare with 

BACT data. The 15 applications include 26 emissions units subject to LAER 

technology review for one or more pollutants. The total number of LAER 

technology reviews in these applications, determined by counting the number 

of non-attainment pollutants reviews for each emission unit, is 54. 

Table 1-10 lists ranges of typical ranges of BACT emissions limits 

for comparison with the 54 LAER review emission limits. The upper and 

lower ends of these ranges do not represent the extremes for all BACT 

determinations made. Rather, they represent "typical" determinations 

based on BACT limits from the data base (285) PSO permits and EPA's 

Compilation of BACT/LAER Determinations. 

Comparisons of LAER allowable emission rates with BACT ranges show 

that LAER emissions are generally in the lower portions of the BACT ranges. 

However, it does not appear that LAER produces a distinguishable level of 

stringency over BACT. 

23 

'tW^WtBBfW'^rmfm* MfJWJ I* ?*<»<* fWMHH 
>(gTiy»w.>wwi"w****<1

'pas!ff'''k''*?""''''* *~ 

Table 1-10. LAER TECHNOLOGY AND EMISSIONS DATA FOR DATA BASE PSD SOURCES 

SUBJECT TO NON-ATTAINMENT REVIEW FOR ONE OR MORE POLLUTANTS3 

•te 

Application 

1. 

2. 

3. 

4. 

S. 

PPG Industry 

79 UV 06 

General 

Motors 

Corp. 

EPA-5-A-80-12 

General 

Motors 

Corp. 

EPA-5-A-80-6 

Muscatine 

Power and 

Water 

Tennessee 

East-nan 

TN-065 

Region 

4 

S 

s 

7 

4 

Emissions Unit 

Description 

Boiler - 243 MHBtu/hr 

1.7X S. 14.3X ash 

bituminous coal 

Boiler • ISO MMBtu/hr 

0.7X S fuel oi l 

2 - boilers . 1S6 

KMBtu/hr each, 0.87X 

S, 10X ash coal 

Coal storrge pil e 

fugitives 

Electri c steam 

generator - 1546 

MMBtu/hr (166MW), 

3.IX S. 8.7X ash 

coal 

2 - boilers , 780 

KKBtu/hr each, low 

sulfur coal 

Non-attainment 

Pollutant 

PM 

so2 

PM 

PM 

PM 

PM 

Selected 

LAER Control 

Technology 

Baghouse 

Low Sulfur Fuel 

Baghouse 

Surfactant 

Spray 

Suppression 

Baghouse 

ESP 

LAER 

Emissions 

Limit 

0.042 lb/MMBtu 

1.0 lb/MMBtu 

0.06 lb/MMBtu 

None 

0.03 lb/MMBtu 

(203 TPY) 

0.018 lb/MMBtu 

(123 TPY) 

Applicable 

NSPS Limit 

None 

None 

None 

None 

0.03 lb/MMBtu 

(203 TPY) 

0.1 lb/MMBtu 

(683 TPY) 

Is BACT 

Technology 

Typically 

Used 

For LAER? 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

BACT Range 

0.016 to >0J 

1b/MMBtuc 

0.5 to 1.2 

lb/MMBtu 

0.016 to >0J 

1b/MMBtuc 

N/A 

.015 to .03 

lb/MMBtue 

0.016 to 0.1 

lb/MM8tue 

Coal pile fugitives PM Chemical 

Surfactants 

None None Yes N/A 

. • . _.rfrmim_ta_.r-________H 
ilSPWIWBW^^ ' 

i..- 9yv..yvrK.'^,i^<f!!l^m*l<^'^flS!^ 

Table 1-10. LAER TECHNOLOGY AND EMISSIONS DATA FOR DATA BASE PSD SOURCES 

SUBJECT TO NON-ATTAINMENT REVIEW FOR ONE OR MORE POLLUTANTS3 

(continued) 

Application 

6. Gilman Paper 

GA-071 

7. Firestone 

Tire Co. 

GA-068 

8. Firestone 

Tire Co. 

GA-067 

9. Ashland 

Petroleun 

KY-155 

Region 

4 

4 

4 

4 

Emissions Unit 

Description 

Coal/wood/oil boiler -

587 MMBtu/hr on coal 

(1.5X S; 12X ash) and 

941 MMBtu/hr on wood 

(<0.1X S); fuel oi l 

sulfur content is 

about three percent 

Tire sealant lines (2), 

capacity Is confidential. 

Fugitives from 

warehouse ventilation 

Boiler - 96.4 MMBtu/ 

hr; 11 S oi l or gas 

fired 

Reduced crude 

conversion system 

55,000 BBL/day 

Non-attainment 

Pollutant 

PM 

so2 

VOC 

VOC 

CO 

PM 

SO, 

VOC 

Selected 

LAER Control 

Technology 

ESP 

Caustic 

Scrubber 

Carbon 

Adsorption 

Minimum 90X 

Efficiency 

No Control 

Combustion 

Controls 

LAER 

Emissions 

Limit 

0.07 lb/MMBtu 

(227 TPY) 

Wood/Coal - 1.2 lb / 

MMBtu (2143 TPY) 

Wood/011 - 0.8 lb/ 

MMBtu 

Venturi Scrubber 

Venturi Scrubber 

Waste CO Boll 

Incineration 

er 

7.4 lb/hr 

58 lb/hr 

0.08 lb/MMBtu 

0.45 lb/1000 lb 

coke burnoff 

(299 TPY) 

437 lb/MBBL 

Feed 

8 PPMV 

Applicable 

NSPS Limit 

0.1 lb/MMBtu 

(324 TPY) 

1.2 lb/MMBtu 

(2143 TPY) 

0.8 lb/MMBtu 

• None 

None 

None 

1.0 lb/1000 lb 

coke burnoff 

(644 TPY) 

None 

None 

Is BACT 

Technology 

Typically 

Used 

For LAER? 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

No 

Yes 

BACT Rangeb 

.016 to 0.1 

lb/MMBtue 

.33 to 1.2e 

lb/MMBtu 

Unable to 

find BACT 

comparison. 

Incineration 

is typical 

VOC BACT. 

N/A 

0.03 to 0.41 

lb/MMBtu" 

0.5 to 1.0 

lb/ ' 1000 l b 

coke burnoff 

500 to 1100 

lb/MBBL Feed 

Unable to 

find BACT 

comparison. 

CO boiler is 

typical. 

M M * 
"*"""' ">2HHB^^^^^ 

4 m 

4 

• 

4 

: 

• 

: 

l i B 

4ftH9______K'' 

^__B________f^ 

^_____________n 

Application Region 

10. Nevada Power 9 

Company 

NV-80-01 

ro 

11. Nevada Power 9 

Company 

NV-78-02 

•HB^ K 12. Borg Warner 5 

• H EPA-5-A-80-4 

sp AH 

^*"*"* * ii^J 

-*-—# , ^ft ^ 

:..: ^||Pm|| 

fc-^v^^^jjjg 

1 ^____.'4_ i___________________________________ 

nw 

Sl 

. _ . . • 

Tabl e 1-10 . LAER TECHNOLOGY 

SUBJECT TO NON-ATTAINMENT 

Emissions Unit 

Description 

Fugitive VOC from 

equipment leaks 

No. 8 gas turbine 

generator - 73.5 

Megawatts output, 

•800 MMBtu/hr heat 

input; 0.2SX S, low 

ash fuel oil fired 

No. 7 gas turbine 

generator - 73.5 

Megawatts output 

•800 MMBtu/hr heat 

input; 0.25X S, low 

ash fuel oil or 

natural gas fired 

Resin compounding 

facility - IS 

process vents 

Non-attainment 

Pollutant 

VOC 

PM 

CO 

VOC 

PM 

CO 

VOC 

VOC 

* • ' .'" , ' • *f 

AND EMISSIONS DATA FOR DATA BASE PSD SOURCES 

REVIEW FOR ONE OR MORE POLLUTANTS3 

(continued) 

Selected 

LAER Control 

Technology 

Leak Detection 

and Repair 

Low Ash Fuel 

No Control 

No Control 

Low Ash Fuel 

No Control 

No Control 

Waste Air Burner 

. • --y -;.. \ ' . ' 

LAER 

Emissions Applicable 

Limit NSPS Limit 

None None 

•0.03 lb/MMBtu None 

•0.13 lb/MMBtu None 

•0.006 lb/MMBtu None 

•0.03 lb/MMBtu None 

•0.13 lb/MMBtu None 

•0.006 lb/MMBtu None 

9.2 lb/hr None 

:"• . -."•' . . "•"•" . . ' '"* • "• " ** • •- ; 

. 7 • *.-•*• ' ,*'.--* * ii . ' ' , ' 

Jfi«».v»w*• ' *^.v&4w*Wftw}i.Vi$&Ji9& HswSnK " 

Is BACT 

Technology 

Typically 

Used h 

For LAER? BACT Range" 

Yes N/A 

Yes 0.04 to 0.11 

lb/MMBtu 

Yes 0.12 to 0.68 

lb/MMBtu 

Yes 0.02 to 0.11 

lb/MMBtu 

Yes 0.04 to 0.11 

lb/MMBtu 

Yes 0.12 to 0.68 

lb/MMBtu 

Yes 0.02 to 0.11 

lb/MMBtu 

Yes Similar to 

solvent 

(VOC) emissions BACT. 

Unable to 

quantify 

comparable 

BACT Units. 

m 

__________B r - u 

^^• ' "/-'•<£•', 

________K 

^ B ••-' • 

_____________?-

1 •&'. i 

m 

» - - * .-->c.irr 
iJffMjWWWWTWTWM; nwmmwifjw WWT»WW>'" W ~<' 

•„ - r ,r_l7.iy.T"i"^«nl r.«^.yWSm_W3«)!7SHf1!HWt 

Table 1-10. LAER TECHNOLOGY AND EMISSIONS DATA FOR DATA BASE PSD SOURCES 

SUBJECT TO NON-ATTAINMENT REVIEW FOR ONE OR MORE POLLUTANTS3 

(continued) 

Application Region 

Emissions Unit 

Description 

Non-attainment 

Pollutant 

Selected 

LAER Control 

Technology 

LAER 

Emissions 

Limit 

Applicable 

NSPS Limit 

Is BACT 

Technology 

Typically 

Used . 

For LAER? BACT Range" 

13. 

14. 

15. 

16. 

City of 

Coltmbus 

EPA-S-A-80-3 

Weyerhauser 

Longvlew 

PSO-Jt-81-02 

Publishers 

Paper 

PSD-X-80-03 

Modesto 

Irregation 

District 

NSR-4-4-8 

SJ 79-16 

10 

6 - refuse and coal 

fired electric steam 

generators; 246 

MMBtu/hr ea; 

coat is 0.9X S, 

and 10X ash 

Boiler - 1240 

HH8tu/hr; coal 

0.81 S; 18.71 ash 

Boiler - 552.5 

MMBtu/hr; hog fuel 

(wood and bark) 

Gas turbine 1693 

MH8tu/hr; 0.3X S 

fuel oil 

PM 

S02 

CO 

VOC 

PM 

VOC 

NO. 

ESP 0.1 lb/MMBtu None 

Low Sulfur Fuel 0.95 lb/MMBtu None 

Combustion 

Controls 

Combustion 

Controls 

0.26 lb/MMBtu None 

0.016 lb/MMBtu None 

Electro-Scrubber 0.03 lb/MMBtu 0.1 lb/MMBtu 

(165 TPY) (543 TPY) 

Combustion 

Controls 

Unknown 

0.26 lb/MMBtu None 

75 ppmv 75 ppmv 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

0.033 to 

>0.1 lb/ 

MMBtu 

0.63 to 

>1.2 lb/ 

MMBtu 

0.25 to 5.1 

lb/MMBtu 

0.043 to 

0.2S lb/ 

MMBtu 

0.016 to 0.1 

lb/MMBtu 

0.25 to 4.4 

lb/MMBtu 

Unknown 75-150 ppmv 

>*•_.*._• iiium,., fi, ii-i^^^^ay^jiyj^^^y^giii^ ^ 
jmmmB?m*mmr*i&»«^-**9 

^, ^.^.^.....^-.^.^.^-(fr'rar^^^.^ ^ 

Table 1-10. LAER TECHNOLOGY AND EMISSIONS DATA FOR DATA BASE PSD SOURCES 

SUBJECT TO NON-ATTAINMENT REVIEW FOR ONE OR MORE POLLUTANTS3 

(concluded) 

Application 

17. Refuse Fuels 

Incorporated 

Region 

1 

Emissions Unit 

Description 

Refuse Incinerator; 

960 tons/day 

Non-attainment 

Pollutant 

PM 

VOC 

Selected 

LAER Control 

Technology 

Unknown 

Unknown 

LAER 

Emissions 

Limit 

0.03 gr/dscf 

(96 TPY) 

7.99 lb/hr 

Applicable 

NSPS Limit 

0.08 gr/dscf 

(257 TPY) 

None 

Is BACT 

Technology 

Typically 

Used 

For LAER? 

Unknown 

Unknown 

BACT Range 

0.02 to 0.08 

gr/dscf 

Unknown 

'the data base contains 285 applications of which 35 required concurrent PSD and non-attainment review. LAER technology data Is 

available for only 15 of the 35 applications (table entries 1-15). Seven applications have units subject to both NSPS and 

LAER (table entries 4-6, 9, 14, 16 and 17). 

bRange of typical BACT limits as determined from the Compilation of BACT/LAER Determinations, revised (450/2-80-070, May 1980), 

data base BACT determinations and AP-42 emission factors. This range does not encompass all BACT determinations, but indicates 

the typical values specified for BACT in PSO permits. 

cThe range Is for coal fired industrial boilers with less than or equal to 250 MMBtu/hr heat input (not subject to NSPS). 

d7he range is for oil fired industrial boilers with less than 250 MMBtu/hr heat input (not subject to NSPS). 

eRange is for coal fired boilers with greater than 250 MMBtu/hr heat input (least stringent BACT or LAER is the applicable NSPS). 

••yc^ft^^^^^f^^ ^ 
.^-.tWWVM'wywPww 

Effect of Emission Unit Size on BACT-Permitted Emissions and 

Emi-ssions Reductions Beyond NSPS 

Shown in Tables 1-11 through 1-15 are distributions of BACT-permitted 

emissions, BACT-permitted emissions subject to NSPS, and emission reductions 

beyond NSPS by sizes of emission units. The size of an emission unit is 

uased on it s annual BACT-permitted emission rate in tons per year. The 

data are presented both graphically and in tabular format. 

As shown on Table 1-11, 597. of al l BACT-permitted PM emissions units 

are less than 25 tons/year in size and represent only 57 of the BACT permitted 

PM emissions in the data base. In this size range, only 87. of the PM emissions 

units were subject to NSPS. 

Only five PM emission units (1% of total) were permitted to emit 

greater than 1000 tons/year PM. Al l five of these were subject to NSPS and 

were permitted at the maximum emission rate allowed by the NSPS (therefore, 

no emissions reductions beyond NSPS were realized for this size class). The 

size class of 100-500 tons/year and 500-1000 tons/year produced the majority 

(80%) of emission reductions beyond NSPS. The NSPS emission units in these 

size categories were permitted to emit 24,400 tons/year PM (177. + 18% = 457. 

of 54,200 tons/year), some 6100 tons/year PM less than the level allowed by 

the NSPS. 

In contrast to PM, SO- emission units greater than 1000 tons/year size 

were permitted to emit the majority of SO- emissions. As shown in Table 

1-12, 26% of al l SO- emission units and 927 of al l BACT-peinitted S0-

emissions are in this size class. Furthermore, the majority of S02 

emission reductions beyond NSPS were achieved in this size class. This 

size class generally consists of utilit y and large industrial boilers. 

Some industrial boilers in this category were not subject to NSPS because 

of their heat input (less than 250 MMBtu/hr). Note that the 0-40 tons/year 

SO- size class emission units are 34% of al l SO- emission units. However, 

the corresponding allowable S02 emissions for these units are less than 

1% of the total SO- emissions in the data base. Interestingly, 47% of the 

emission units in the 0-40 ton category were subject to NSPS. These small 

NSPS emissions units consist mainly of heaters, boilers and furnaces at 

petroleum refineries burning refinery fuel gas and are generally subject 

to NSPS. 

29 

,W*|

.!4m_m.wi.Ti j»M 
••...yy .... yy.,.,*. r—. T^» r.yfy9..*ny99y9i' i^ri^»y!W'ML.»^iJiivwiv,y.8yB*feiW:l^W^f '^'' 

Table 1-11. DISTRIBUTION OF BACT-PERMITTED EMISSIONS AND 

EMISSIONS REDUCTIONS BEYOND NSPS BY SIZE OF EMISSION UNIT 

POLLUTANT: PARTICULATE MATTER (PM) 

* Total BACT-pemitted PM emission units • 589. 

*• Total BACT-pemitted PM emissions - 54.200 tons/year. 

•••Total BACT-pemitted PM eaission reductions beyond NSPS - 7.700 tons/year. 

Emission Unit 

Site Category 

(tons/year 

allowable 

emissions) 

0-2 5 

25 - 100 

100-500 

SOO - 1000 

>1000 

f of Eaission 

Units in Size 

Category 

348 

129 

80 

27 

5 

BACT-Peraltted 

PM Emission 

Units* 

X of Cua. X 

total of total 

59 59 

22 81 

14 95 

4 99 

1 100 

BACT-Peraltted 

PM Emissions** 

X of 

total 

5 

12 

33 

33 

17 

Cum. X 

of total 

S 

17 

50 

83 

100 

BACT-Permltted 

PM Emission 

Units Subject 

to NSPS 

X of size X of 

category total* 

8 5 

17 4 

39 5 

85 4 

100 1 

BACT-Peraltted 

PM Emissions 

Subject 

to NSPS 

X of size X of 

category total** 

10 1 

18 2 

52 17 

86 28 

100 17 

PH Emission Reductions 

Beyond NSPS Subject to BACT*** 

X of all PM 

emission 

reductions 

beyond NSPS 

14 

6 

3e 

42 

0 

Cum. X of all 

PM emission 

reductions 

beyond NSPS 

14 

20 

58 

100 

100 
,/^ww^w^yw^ ^ OTTPMT'W'HR rr*».-*'vf- •?>?. •ryr^rt^y.- ,i^,^j».VSM^_jv_W>» ^ 

Table 1-12- DISTRIBUTION OF BACT-PERMITTED EMISSIONS AND 

EMISSIONS REDUCTIONS BEYOND NSPS BY SIZE OF EMISSION UNIT 

POLLUTANT: SULFUR DIOXIDE (S02) 

* Total BACT-pemitted SO, 

•* Total BACT-pemitted SOi 

•"Total BACT-pemitted SOJ 

•Ission units • 429. 

•Issions • 761,800 tons/year. 

•ission reductions beyond NSPS • 218,700. 

Eaission Unit 

Size Category 

(tons/year 

allowable 

eaissions) 

0 • 40 

£ 40-10 0 

100 - SOO 

500 • 1000 

>1000 

f of Eaission 

Units In Size 

Category 

144 

30 

93 

49 

113 

BACT-Pemltted 

SO- Eaission 

Onits* 

I of Cua. X 

total of total 

34 34 

7 41 

22 63 

11 74 

26 100 

BACT-Pemltted 

SO, Eaissions** 

X of Cua. X 

total of total 

«1 <1 

<1 <1 

3 3 

S 8 

92 100 

BACT-Pemitted 

SO, Eaission 

Units Subject 

to NSPS 

X of size X of 

category total* 

47 16 

17 1 

9 2 

20 2 

59 16 

BACT-Pemitted 

SO, Eaissions 

'Subject 

to NSPS 

X of size X of 

category total** 

35 <1 

!4 <1 

8 <1 

23 1 

65 78 

SO. Eaission Reductions 

Beyonfl NSPS Subject to BACT*** 

X of all SO, 

eaission 

reductions 

beyond NSPS 

1 

<1 

<1 

13 

66 

Cxmx. X of all 

SO, emission 

reductions 

beyond NSPS 

1 

1 

1 

14 

100 

• • i|..-M-lll-il__ilJ — «h« >•*- rtiMiiiftn_h^^^;>-->tf^gti»yii 
'"^WWtf»^_WMJNW^iBy4^/!W!iw »p»—^-»" w^y.,.**. («W*^.»'V-,'f .*» *«-W*: •swwv rrjswttW^WWWS-WWTl*^^ 

• f 

t_> 

ro 

Table 1-13. DISTRIBUTION OF BACT-PERMITTED EMISSIONS AND 

EMISSIONS REDUCTIONS BEYOND NSPS BY SIZE OF EMISSION UNIT 

POLLUTANT: NITROGEN OXIDES (N0X) 

* Total BACT-pemitted NO eaission units • 727. 

•• Total BACT-pemitted NO* eaissions • 712,400 tons/year. 

•••Total BACT-pemitted NO* emission reductions beyond NSPS • 54,400 tons/year. 

Eaission Unit 

Size Category 

(tons/year 

allowable 

eaissions) 

0 - 40 

40 - 100 

100 - SOO 

500 - 1000 

>1000 

I of Eaission 

Units in Size 

Category 

189 

122 

257 

79 

80 

BACT -f emitted 

NO Eaission 

Onits* 

X of Cua. X 

total of total 

26 26 

17 43 

35 78 

11 89 

11 100 

BACT-Peraitted 

NO^ Emissions** 

X of Cua. X 

total of total 

<1 <l 

1 1 

9 10 

8 IB 

82 100 

BACT-Remitted 

NO Eaission 

Unl!s Subject 

to NSPS 

X of size X of 

category total* 

3 < l 

7 1 

13 5 

56 6 

86 9 

BACT-Pemltted 

NO Eaissions 

"Subject 

to NSPS 

X of size X of 

category total** 

5 «1 

8 <1 

16 1 

59 5 

97 » 

NO Eaission Reductions 

Beyon<TNSPS Subject to BACT*** 

X of all NO 

emission 

reductions 

beyond NSPS 

0 

0 

2 

0 

98 

Cua. X of all 

reductions 

beyond NSPS 

0 

0 

2 

2 

100 

-•r-l'n_wif----'_ltt_)_i 
^B^W^Wwn^WMWMu^^ 

*'"" "T" ^TT*^** * f!f**tflr»*lff{inw»^^ y 

i «*?pa| Wffl88 

Table 1-14. DISTRIBUTION OF BACT-PERMITTED EMISSIONS AND 

EMISSIONS REDUCTIONS BEYOND NSPS BY SIZE OF EMISSION UNIT 

POLLUTANT: CARBON MONOXIDE (CO) 

• Total BACT-pemitted CO eaission units • 427. 

** Total BACT-pemitted CO eaissions • 159.100 tons/year. 

"•Total BACT-pemitted CO eaission reductions beyond NSPS • 2,970 tons/year. 

Eaission Unit 

Size Category 

(tons/year 

allowable 

eaissions) 

0 - 100 

100 - 500 

500 • 1000 

>1000 

1 of Eaission 

Units in Size 

Category 

297 

71 

20 

39 

BACT-Pemitted 

CO Eaission 

Units* 

X of Cua. I 

total of total 

69 69 

17 86 

5 91 

9 100 

BACT-Pemitted 

CO Eaissions** 

X of Cua. X 

total of total 

4 4 

10 14 

10 24 

76 100 

BACT-Pemitted 

CO Eaission 

Units Subject 

to NSPS 

X of size X of 

category total* 

0 0 

1 <1 

20 1 

S <1 

BACT-Pemitted 

CO Eaissions 

Subject 

to NSPS 

X of size X of 

category total** 

0 0 

2 <1 

20 2 

3 3 

CO Emission Reductions 

Beyond NSPS Subject to BACT*** 

X of all CO 

eaission 

reductions 

beyond NSPS 

0 

0 

45 

55 

Cua. X of all 

CO eaission 

reductions 

beyond NSPS 

0 

0 

45 

100 

»ifiilii_lii_ir!» 
•*m r

 j^ffC¥_S!ffFRS?!Pt9J5R9W1'"4Wf tt*1 .awiMUV_|Rkea(ii.iiW'W*!.T,*ff V * rrltpxix.! .T****" ay?r ».r.^v^r-fTr.iir--'rrfwffi«^***^Wwi?^^<^w^^ 

Table 1-15. DISTRIBUTION OF BACT-PERMITTED EMISSIONS AND 

EMISSIONS REDUCTIONS BEYOND NSPS BY SIZE OF EMISSION UNIT 

POLL'-rrANT: VOLATILE ORGANIC COMPOUNDS (VOC) 

Emission Unit 

Size Category 

(tons/year 

allowable 

emissions) 

0 - 40 

40 - 100 

100 - 500 

500 - 1000 

>1000 

# of Emission 

Units In Size 

Category 

88 

16 

35 

4 

1 

BACT-Permi tted 

VOC Emission 

Units* 

% of Cum. % 

total of total 

61 61 

11 72 

24 96 

3 99 

1 100 

BACT-Permitted 

VOC Emissions** 

I of Cum. % 

total of total 

6 6 

6 12 

58 70 

18 88 

12 100 

* Total-BACT permitted VOC emission units = 144. 

** Total-BACT permitted VOC emissions = 13,700 tons/year. 

Note: VOC NSPS's are generally work practice or equipment standards. 

Unable to quantify VOC emissions subject to a NSPS. 

"^-'-.irttti^Vfcfr^qi 
r .waaitWMijui.Ujiiii.iMiwj.i r*WBa^a_K5waw_*^ap*W^5S?f??S^*r^f 

Table 1-13 for NO emissions is similar to Table 1-12 for SOo emissions 

in that the majority of permitted emissions and emissions reductions beyond 

NSPS occurred at emissions units greater than 1000 tons/year size. 

Total BACT-permitted allowable PM, SO-, NO and CO emissions and 

emissions reductions beyond NSPS are as follows: 

Pollutant 

PM 

so2 

N0X 

CO 

Total BACT-Permitted 

(tons/year) 

54,200 

761.800 

712,400 

159,100 

Reductions Beyond NSPS 

(tons/year) 

7,700 

218,700 

54,400 

2,970 

l 

Corresponding values for VOC emissions reductions beyond NSPS are not 

presented since most VOC standards are based on the type of equipment used 

and/or work practices, and quantification in terms of emissions is difficult. 

Emission Reductions From Proposed BACT Emission Levels 

In at least 63 data base applications (22%), PSD applicants received 

emissions limitations more stringent than those proposed as BACT. Factors 

such as air quality impacts, increment consumption and case-by-case evaluation 

influenced the permitting authorities' decision process. In some cases, these 

sources were subject to NSPS and the associated emissions reductions in those 

cases were accounted for in the previous subsection. 

Table 1-16 shows the (non-NSPS) data base emissions reductions caused 

by PSD permits issued with emission limits more stringent than those proposed 

by the applicant in addition to emissions reductions beyond NSPS. 

Effect of PSP on Allowable Emissions 

It is impossible to determine the levels at which the data base 

sources would have been allowed to emit in the absence of PSD 

provisions. For example, for sources not subject to NSPS, an applicant might have proposed and been allowed to emit pollutants at the 

levels prescribed in the respective State Implementation Plan (SIP). 

In other cases, however, cn emissions limiting factor may have been 

the NAAQS ceilings, or other air quality factors. Quantification of 

these "upper bounds" for non-NSPS sources was beyond the scope of this 

project. 

35 

J > -

(l!»iJ_'i!;.'U inn 

,.u,^i,liiiiii>f*irjiirr"nriffWrgiirttf 
->i!iiimwi.pwwwwrw^-.-i''.'k i **?**.*v<f-~+~,>i*-y**-"* ""•- • .. ,-W.VrV^-. • »V ^•WHW»'^^-^J«W*J^.S«Mftl!W:l 

Table 1-16. CUMULATIVE BACT PERMITTED EMISSIONS REDUCTIONS 

ASSOCIATED WITH PSD 

Pollutant 

PM SO„ NO. CO VOC H2S TRS 

Acid 

Mist 

Vinyl 

Chloride 

Emissions 

reductions 

beyond NSPS 

- tons/yr 

Non-NSPS 

emissions 

reductions 

associated with 

proposed vs. permitted 

BACT - tons/yr 

7,700 218,700 54,400 2,970 N/A 

5,100 34,200 5,100 3,000 N/A 

Total 

emissions 

reductions 

- tons/yr 

12.800 252,900 59,500 5,970 N/A 

240 

240 

Total BACTpermitted 

emissions 

- tons/yr 

54,200 761,800 712,400 159,100 13.700 700 300 1,160 180 110 

/gSpVil.XM.fxrvfjtni.tmn*. yy.yrf.-r-y9-

—il 
1

:1 ?^HyJHatM.tJ*«-<t.W*'i'» nw !•« • injip^i.^'^yyiiniiiii .__p aviAMJS 

However, some measure of the effect of the NSR program can be 

obtained by considering only: sources that were subject to NSPS; and 

sources which were not subject to NSPS but had to adopt BACT limits 

more stringent than those proposed in their original application. 

For the various pollutants, reductions from "hypothetical" NSPS levels 

(i.e., those levels at which the source would be allowed to emit if 

it were just to meet NSPS requirements) and reductions for other sources 

representing the difference between proposed and final BACT are shown 

in Table 1-16. These "reductions" expressed as a percentage of the 

hypothetical/proposed level for the criteria pollutants are: 

PM - 17% 

so? -

N 0 t • 

CO -

25% 

8% 

• 4% 

Expressed as a percentage of the final permitted BACT emissions, 

these reductions are: 

PM - 24% 

S 02 - 33% 

N0X - 8% 

CO - 4% 

That is, 1n the absence of the PSD program, PM emissions could 

have been about one-fourth higher than the permitted PM emissions and 

S 02 emissions about one-third higher than the permitted S02 emissions. 

,1.6 ANALYSIS OF AIR QUALITY IMPACTS 

Frequency of Air Quality (A/Q) Analyses 

Of the 285 data base applications, 213 were required to perform air 

quality impacts analyses. A total of 451 pollutant specific air quality 

reviews were performed distributed as shown below: 

37 
llt.UMi_iMffiingna*0t_i-)_wMna. •weawBWi^w""!*** 

Pollutant 

PM 

so2 

N0X 

CO 

VOC 

F 

H2S 

# of A/Q Revi 

90 

124 

163 

67 

3 

2 

2 

ews % of Total 

20 

27 

36 

15 

<1 

<1 

<1 

Total 451 100 

As shown, NO was the pollutant most frequently subject to air quality 

analyses. 

Site specific ambient monitoring was provided in 18% of the PSD 

applications requiring A/Q analyses. Another 25% of the cases used 

existing State or other network ambient monitoring data and 57% of the PSD 

applications requiring A/Q analyses provided no actual ambient air quality 

monitoring data. In these latter cases, existing ambient air quality 

was determined by dispersion modeling, assuming approved background 

concentrations, or some other approved method. 

Effects of Allowable PSD Increment Constraints 

The most limiting air quality factor was the allowable 24-hour SO, 

3 increment of 91 ug/m . As shown below, except for this factor, very few A/Q 

analyses predicted that more than 85% of the respective allowable PSD 

increment would result from the proposed project. 

Pollutant/Increment Averaqing Period 

PM SO, 

24-hr Annual 3-hr 24-hr Annual 

% of Cases Where 

More Than 85% Impact 

was Predicted 5% 0% 6% 19% 2% 

Based on total number of pollutant specific A/Q analyses. 

In many cases where A/Q analyses were required, the applicant did not 

perform full A/Q analyses because preliminary screening indicated the 

38 
M*W>-imiPBam'^-i __w»«i.-ii._wvy«!yg. 

impacts expected to result from the proposed project were "insignificant." 

In some of these cases, due to possible increment violations in the 

vicinity of the source, a demonstration of "insignificant" impact was 

required in order to receive a PSC permit. Therefore, those cases where 

insignificant impacts were indicated does not necessarily mean that a 

substantial amount of PSD increment was available. 

Where PM and S02 A/Q analyses were required, project alterations 

were made in at least 28 cases (13%) to avoid increment violations that 

could have precluded permit issuance. Those alterations are distributed 

as shown below: 

Alteration I of Cases 

1. More Stringent BACT 11 

2. Increase Stack Height 5 

3. Switch to Cleaner Fuel 3 

4. Emission Reductions Elsewhere 3 

5. Limit Hours of Operation 1 

6. Other 5 

Limiting Factors 

3-hr S02 (2); 24-hr S02 (7); 24-hr PM (2) 

3-hr S02 (1); 24-hr S02 (4) 

24-hr PM (1); needed insignificance (2) 

24-hr S02 (3) 

Unknown 

Unknown 

"insignificant" A/Q impact is quantified in the preamble to the 1978 NSR 

regulations. 

Effects of Constraints Caused by National Ambient Air Quality 

Standards (NAAQS) 

The A/Q analyses dealing with NAAQS compliance demonstration did not 

appear to have had much effect on PSD projects. The most limiting NAAQS 

was the 24-hour allowable ambient TSP concentration of 150 ug/m . As 

shown below, few A/Q analyses predicted that the proposed projects would 

result 1n ambient air quality concentrations that exceeded 90% of the 

respective NAAQS: 

39 
•w*^_Cf

-

,l|Jn Jiaiowtiig. 

.l.iaUU4WB"i'i.'WWW-»9 

NAAQS Pollutant/Averaging Period 

TSP SO, N0„ 

-xCO 

24-hr Annual 3-hr 24-hr Annual Annual 1-hr 8-hr 

% of Cases 

Where More 

Than 90% 

NAAQS Impacted 9% 0% 3% 3% 0% 2% 0% 0% 

Based on total number of pollutant specific A/Q analyses. 

Effect of A/Q Constraints on Emissions Reductions Beyond NSPS 

A rough screening analysis was performed to determine reasons for 

emissions reductions beyond NSPS. For those PSD permits where allowable 

emissions were below the maximums allowed by the applicable NSPS, the A/Q 

analyses were evaluated. Based on those evaluations the PM and S02 

reductions beyond NSPS were distributed among four categories: 

• As a result of NAAQS constraints; 

• As a result of Increment Constraints; 

• As a result of case-by-case BACT; and 

• Cause Unknown. 

Table 1-17 summarizes that distribution. As shown, it appears that the 

majority of S02 emissions reductions beyond NSPS resulted from increment 

constraints. Particulate matter emissions reductions beyond NSPS were 

difficult to categorize because many (about 50%) PM air quality analyses 

predicted "insignificant" ambient impacts and no estimation of PM increment availability and ambient air quality were provided. 

1.7 MISCELLANEOUS ASSOCIATED ANALYSES 

As part of this study, certain situations were studied to assess the 

general effects of existing and alternative provisions of NSR regulations. 

Presented in this section are the highlights of the more substantive studies. 

Effect of Class I Allowable SO, Increment on Power Plant Siting 

Dispersion modeling of a hypothetical 640 MWe power plant was performed 

to determine the minimum distance from a Class I area that it can locate 

without violating the Class I increment. As shown in Table 1-18, if the 

power plant was allowed to emit S02 at .3 lbs/MMBtu and located in flat 

40 

I f 

•tHWB"1*** '•""" 'iu»."«',»l'*_.,_H.!»««-iWii i«un«n ••i—niwigM 20&V&*!^W>P?. 
IJUHJW_I»".I>MUH'» < r-.-vrrn: r^w»^»*3»?Wr*?3?PvS?*:'lftS 

Table 1-17. EMISSION REDUCTIONS BEYOND NSPS AND PARTIAL 

CONTRIBUTIONS BY PROBABLE CAUSE OF THOSE REDUCTIONS 

(tons/year) 

so2 

PM 

As a Result 

of NAAQS 

Constraints 

As a Result 

of Increment 

Constraints 

As a Result 

of Case-byCase BACT 

Unable to 

Determine 

Cause* 

Total Emission 

Reductions 

Beyond NSPS 

Total Permi tted 

Emissions 

for Sources 

Subject to 

NSPS 

36,100 

0 

115,500 

200 

56,600 

2,300 

10,500 

5,200 

218,700 

7,700 

603,400 

35,200 

•Insufficient data to categorize emission reductions. 
*» 

J&QQ&lv^*1W#<***mBmtvn*m--«'~-m*z> 

Table 1-18. EFFECTS OF CLASS I SO, INCREMENT ON THE 

SITING OF A 640 MWe POWER PLANT 

Terrain 

Type 

Averaging 

Period 

Flat 

i5 Complex 

24-hour 

Annual 

24-hour 

Annual 

^Distance of Source from Class I Area Beyond Which 

SO- Increment is not Exceeded 

Case I: 

1.2 lb/MMBtu, 

90% S02 Removal 

100 

20 

>100 

91 

Case II: 

.6 

70% 

lb/MMBtu, 

SO- Removal 

42 

0 

>100 

48 

Case III: 

.3 

70% 

lb/MMBtu, 

SO, Remo 

19 

0 

>100 

26 
I 

!tfffjfl*;tf?t^,ayt_i' V"f*-' 

terrafn, it must locate at least 19 kilometers from the Class I area. 

The same power plant in complex terrain must locate at a distance of more 

than 100 kilometers from the Class I area. Higher allowable S02 emission 

rates were also evaluated and the results are shown. In each case, the 

limiting factor is the allowable 24-hour S02 Class I increment. 

Effect of Alternative Class I Increment System on Emissions Near 

Class I Areas 

One alternative cited by the National Commission on Air Quality (NCAQ) 

was to eliminate short term increment tracking in Class I areas and allow 

a source the entire short term increment. Annual increment tracking would 

still be retained. 

The allowable Class I SO- increment was evaluated under this proposal 

by studying three different cases: 

Case 1 - Remote Class I area; little or no industrial activity; 

Case 2 - Class I area of moderate industrial activity; two or more 

closely spaced sources; and 

Case 3 - Class I area of heavy industrial activity; numerous sources 

around a Class I area. 

Table 1-19 summarizes the results of this study and impacts on 

potential emissions change, potential ambient Impacts and reduction 

in air quality dispersion modeling requirements. Generally, there could 

be a moderate Increase in S02 emissions and ambient SO- concentrations 

but In some cases, S02 emissions could increase by as much as 250% in 

the area. This would occur when sources were clustered upwind of the 

impact area. 

^W-.^g^^KlJaWafaM_t^^^W»yio n 

In conjunction with EPA, a study was performed to determine the 

approximate range of cost for dispersion modeling supporting a PSD 

application. This evaluation showed that, in general, dispersion modeling 

for a PSD application wil l range from $10,000 to $130,000. However, this 

value could be as low as $3,000 and as high as $400,000 or more. 

Ten PSD permits were selected representative of data base source 

categories and locations and the applicants were asked to provide cost 

data on the preparation of their PSD applications. Table 1-20 summarizes 

the responses and the costs are broken down into the three most extensive 

parts of a PSD application: 

l J 

43 
! 

»*> M u*a*jw •. ^»w,maytgiMt5^!«nitj_ty.%^fl{|ff^ E^t***; IfflffiB 

Table 1-19. 

ESTIMATED EFFECTS OF ELIMINATING 

SHORT-TERM INCREMENT TRACKING 

Case 

1 

2 

Emissions 

Change 

None 

0-250% Incr. 

0-67% Incr. 

•Based on S02 emissions 

Air Quality" 

Impact 

None 

Reduction in 

Required 

Air Quality 

Modeling 

None 

24-hr: 0-13 ug/mJ Incr. Moderate 

annual: 0-1.4 ug/m3 Incr. 

24-hr: 0-3.6 ug/m3 Incr. Substantial 

annual: 0-.7 ug/m3 Incr. 

I 

I 

I 

44 
i 

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a. PSD AP LU 

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45 

j r FIGUR

E 3-1. DISTRIBUTION OF PERMIT PROCESSING TIMES 

DV C MTINTu inTrouni c 
IJUW ILHHUU WIII J IIW.II , jiMmmMxnummmm luwimui ^ua-wawiwwawMawa'aiWWW »|i»i»g^>.iltJI>>>iJWI>.>.ll.

lJi(M*1*;W 

• Ambient Monitoring; 

• Dispersion Modeling; and 

• BACT Analyses. 

As shown in this table, the cost of a PSD application ranged from 

about $5,000, where no ambient monitoring and little dispersion modeling 

was required, to over $1,000,000 where extensive ambient monitoring and 

dispersion modeling was required. In these cases, ambient monitoring costs 

were 80-90% of the total PSD application. However, extensive ambient 

monitoring for a single PSD application 1s infrequent. Based on Table 1-20 

in cases where extensive ambient monitoring is not required, it is probably 

fair to estimate that an average PSD application may cost between $10,000 

and $50,000. 

WjHUJ-WUMMJ -• •_ 
I gliy...MW)jUi_ ,j imi,wi_mw_ii. j. _»«Bn_*«p«rw.''j_»«icr? 

WW»»»t<WWWS'WWW8S^ 

APPENDIX A. DISCUSSION OF MAJOR CHANGES IN APPLICABILITY 

OF PSD AND NON-ATTAINMENT REGULATIONS AND THE 

EFFECT ON PERMITS IN THE DATA BASE 

This appendix contains a very general discussion of the applicability 

requirements of the 1978 and 1980 regulations. In certain cases, however, 

exemptions may apply which render the following discussion incomplete. 

However, the statements below apply to a large majority of permits issued 

under the PSD program. The reader is referred to the federal RejJ_istor_ 

notices listed in Table A-l for a complete discussion of PSD and nonattainment applicability. 

The most significant differences between the 1978 and 1980 PSD 

regulations with respect to PSD applicability are found in the definitions 

of potential to emit (PE) and major modification. Table A-l summarizes 

the key changes to these and three other related definitions. Table A-2 

gives a list of the recent PSD and nonattainment regulations history 

with the key actions taken on the specified date. 

The definition of PE was changed with the 1980.regulations to 

include emissions after application of pollution controls whereas the 

1978 regulations did rjot consider pollution controls for PE determinations. 

The effect of this change was to reduce the number of major sources subject 

to PSD. For example, a new source with one emissions unit is anticipated 

to emit particulate matter (PM) at 10 tons/year after being controlled by 

a 99 percent efficient control device. It would emit 1000 tons/year in 

the absence of such control. This source would be a major source (PE « 

1000 tons/year, before control) under the 1978 regulations and would 

undergo PSD review. However, the source would not be major (PE * 

10 tons/year after control) under the 1980 regulations and would not 

undergo PSD review. 

A-l 
^wgmwaawwwr'o^ »•_*«. •" -^»-.--- - «?s«n?KtrS:S^9^^ ^ 

Table A-l. KEY GENERALIZED DEFINITIONS WHICH CHANGED BETWEEN 1978 AND 

1980 PSO REGULATIONS 

1978 Definition 1980 Definition 

Source 

An entire plant on adjacent or contiguous 

properties under common ownership, regardless of the various types of operations 

which M y exist on the property. 

Potential to Emit (PE) 

Based upon the uncontrolled emissions 

subject to enforceable limits on type 

or amount of material processed or 

combusted. Fugitive emissions were 

considered for PE accounting. 

Major Source 

Any of 28 named sources with PE of 100 or 

more tons per year or any source with PE 

of 100 or more tons per year or any 

source with PE of 250 or more tons per 

year (100/250 threshold). 

Same as In the 1978 regulations except 

that a source would contain only those 

pollutant emitting activities belonging 

to the same two digit SIC code. Thus, 

one source under the 1978 regultions 

could be subdivided Into multiple 

sources under the 1980 regulations. 

Based upon the controlled emissions 

subject to any enforceable 1imit on 

operations. Fugitive emissions were 

considered only for certain listed 

sources with respect to PSO 

applicability. 

Same as in 1978 regulations. Note that 

the change in definitions of source and 

PE had impact upon the classification of 

a source as major. 
ttf^mn^mii mi^,x ..•-*, • 

Table A-l. Continued 

1978 Definition 1980 Definition 

Major Modification 

Any source which would Increase Its PE or 

would have accumulated increases of U s 

Pt exceeding lOQ/nQ tons/year, excluding 

any decreases in Pt 

lfKr<*fnt C»f»ttwpt1on 

••sod on illooatlf eminen t changes at 

sourcet and modifications. 

Any significant net emissions Increase 

at a major source or any modification 

which Itself would Increase emissions 

by 100/250 tons per year. This definition considered emissions changes at 

existing units based upon actual rather 

than potential emissions. 

Bated upon actual emissions changes at 

sources and modifications. 
Table A-2. BRIEF HISTORY OF NSR REGULATIONS J . 

Federal Register 

RTFerence Date Action Significant Requirements/Impacts 

41FR55S44 

43FR26388 

44FR3274 

44FR51924 

4SFR7800 

4SFR31104 

45FR31104 

45FR52676 

4SFRS2676 

December 21, 1976 1. 

June 19, 1978 

January 16, 1979 

September 5, 1979 4. 

February 5. 1980 

Nay 11. 1980 

Nay 13, 1980 

August 7. 1980 

August 7, 1980 

First Eaission Offset 

Interpretive Ruling 

PSO Regulations Pursuant 

to the Clean Air Act 

Amendments, 1977 

Second Emission Offset 

Interpretive Ruling 

Proposed Amendments to PSO 

Regulations and Emission 

Offset Interpretive Ruling 

(Pre-Oecision, Alabama 

Power) 

5. Partial Stay of PSO 

Regulations (Alabama 

Power Oeclsion) 

Partial Stay of Eaission 

Offset Interpretive Ruling 

Amendment to Emission 

Offset Interpretive Ruling 

Final Amendments for PSO 

Regulations 

Amendments to Emissions 

Offset Interpretive Ruling 

Emission offsets and LAER required in or near non-attainment areas 

BACT; NAAQS and PSO increment compliance demonstration; pre- and 

post-construction monitoring; impact analysis for soils, vegetation, 

growth, and visibility - all applied in or near attainment or 

unclassified areas. 

Expansion of sources covered by including those with "potential to 

emit" based upon uncontrolled emissions; construction moratorium in 

areas without an approved SIP. 

Definitions change: 

"Potential to emit" - include emissions after application of controls; 

"Major modification" - any significant net emissions increase for 

designated "major" pollutant, considering concurrent emission 

changes; 

"BACT"; 

"Air quality"; and 

Monitoring requirements. 

PSO review only for sources in attainment or unclassified areas for 

at least one pollutant; exempt froa review sources with uncontrolled 

emissions greater than the 100/2S0 threshold but with controlled 

emissions less than this threshold. 

Include "potential to emit" definitions of both Actions 3 and 4, 

thus fewer sources are subject to ruling. 

Elimination of review for certain sources In attainment and 

unclassified areas under offset policy. 

Applicability and monitoring requirements changed; "potential to 

emit" defined for emissions after controls; applicability of BACT; 

increment consumption, and modification defined In terms of actual 

emissions; overall effect: decrease in PSO applications but increase 

in pollutants reviewed per application. 

"Potential to emit" includes emissions after controls; and other 

definition changes as in 8. 

Acronym Glossary 

BACT Best Available Control Technology 

LAER Lowest Achievable Em'ssions Reduction 

NAAQS National Ambient Air Qualily Standards 

PSO Prevention of Significant Deterioration 

SIP State Implementation Plan 
tf*f!*A*Vm*-t i"fityt^ftf^^ v t 

I 

The second major difference between the regulations concerns the 

definition of major modification. Under the 1978 regulations, a modification was major if uncontrolled PE increased by 100/250 tons/year, not 

counting decreases in PE. The 1980 regulations considered controlled 

emissions and actual emissions decreases at the source. Further, the 

1980 definitions generally stipulated that a major modification could 

occur only at an existing major source and that a modification would be 

subject to PSO for all pollutants with a significant net emissions 

increase. The effect of this definition change was to increase the 

number of pollutants requiring review for a given source because the 

significance levels were sot well below the 100/250 ton threshold (for 

example, sulfur dioxide emissions are significant at levels of 40 or 

more tons/year). 

Figure A-l gives a generalized flow diagram of the PSD applicability 

requirements of the 1978 and 1980 regulations. Notice that under the 

1980 requirements, applicability is a two-step process: (1) is the 

source major?; (2) if major, what pollutants will be emitted at significant rates? Each significant pollutant is then subject to review consisting 

of BACT, air quality, and additional impacts analyses. 

A two tier system of review existed under the 1978 regulations. The 

first tier review was applied to sources with uncontrolled emissions of 

100/250 tons/year and controlled omissions of less than 50 tons/year not. 

counting decreases. Tor such pollutants, a source would be i.xompt from 

the I1AC1, additional impacts, and air quality requirements. The source 

would be required to meet all NSPS and SIP requirements. The tier 1 

review permit was contingent upon a demonstration of no adverse air 

quality impact and no impact upon Class I areas or known increment 

violations. This demonstration generally required less complex air 

quality analysis. 

The tier 2 review was required for sources with controlled emissions 

of 50 or more tons/year not counting decreases. This review consisted of 

BACT and if there was a net emissions increase, air quality (increments, 

NAAQS, and perhaps monitoring), and additional impacts (soils, vegetation, 

visibility, and growth) analyses were required. The source was required 

to submit dispersion modeling and in many cases, monitoring data to meet 

the air quality review requirements. A source with a net emissions 

A-5 
'"~*«<"'w*»Ttt.«.v..»._._.»_., . 

FIGURE A-l. GENERALIZED APPLICABILITY FLOW OF 1978 ANO 1980 PSO REGULATIONS. 

Under 1978 PSD Regulations 

Proposed Construction 

(A11 Pollutants Attainment) 

Under 1980 PSD Requia tions 

Proooied Construction 

(All Pollutants Attainment) 

Not 

Subject 

lo PSD 

No 

controlle 

any pollutanp 

be Increased 

more than 

100/250 T.P. 

•iS* 

redul m*/ 

Identify 

Each 

Tl>r_l 

-NSPS Onl) 

-Class I 

Area 

Impact 

Analyst_ 

_, None 

for 

pollutants 

dentify pollutant _i ' 

increased 

(after control) 

greater than 

50 T.P.r. 

(lanorina decreases) 

SUBJECT 

TO 

PSD 

• 50 TPY 

Same 

Identify emission 

units contributing 

to emissions 

increase 

JiSL 

for 

pollutants. 

r

^ 501 T>Y ^ 

Subject 

to 

BACT 

Analysis 

I__i_ 

Identlfy pollutant 

Reformulate 

control strategy 

Subject lo 

Air Quality 

and Other 

Related 

Impacts 

Analyses 

Identify emission 

units contributing 

to net pollutant 

Increase 

Reformulate 

control strategy 

lo all required analyses show: 

• no increment or NAAQS vlolat 

• BACT is applied where requi 

• no violation of Cits: I area 

requirementsT 

A-6 
decrease could be exempt from the air / review requirements provirleri 

there would be no adverse air quality ii -t or impact upon Class I areas 

or increment violations. 

A-7