PSD Permitting Process

Tribal NSR training 

Nancy Mayer
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 

 Law 
Typical Permit Format

 General source identification

 Source location

 Emissions information due to:

– Control technology analysis

 Top-down BACT

– Air Quality Impact Analysis 

– Class I Area Analysis (if applicable)

– Additional Impacts Analysis (mainly visibility)
General Source Information

 Name

 Source classification 

– On list to count fugitive emissions?

 Generally what construction/modification is 

being proposed 

– Reason for construction 
Source ID– Things to look for

 Is source classification correct?

 Does reason for modification make sense? 
Source Location

 Location 

– Attainment/nonattainment area

– Nearby Class I areas

 Source site diagram (not all permit 

applications have site diagrams)
Source location what to look for

 Is the location accurate?

 Does it ID all Class I areas and tribal lands 

that are within 100 KM?

 Does it ID all nearby nonattainment areas?

 Does the site diagram (if available) clearly 

explain what is being proposed? 
Emissions Data

 Existing emissions baseline

 Change in Emissions

– Netting calculation, if any

 Stack Height
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 the calculation for the emissions change clearly 

shown and explained? 

 Is stack height measured correctly? 
Air Quality Impact Analysis

 Terrain

 Model selected

 Features selected

 Results 

– Increment

– NAAQS

– Class I areas
Modeling things to look for

 Are all important terrain features identified?

 Is the correct model being used?

– Pollutants – sources 

 Are assumptions reasonable? 

 Is correct meteorological data set being 

used? 

 Are all results presented or only summaries?
More modeling things to look for

 Are increment analyses done correctly?

– Baseline area 

– All relevant pollutants 

– Any increment violations?

 Do emission increases cause any new NAAQS 

violations?

 Do emissions impact existing nonattainment areas?

– Are these impacts mitigated? 
Control technology

 Proposed Best Available Control Technology 

– Top-down BACT approach 

 Describe other alternatives 

 For each relevant pollutant 
Control Technology what to look for

 Does it have reasons for not choosing the 

best technology?

 Does it have the technology from the 

RACT/BACT/LAER Clearinghouse? 

 Does it have technology for all relevant 

pollutants?
Public Participation/Notice

 Date, time documentation 

 Notice generally in available local newspaper

 Contacted Relevant Federal Land Managers

 Contacted nearby Tribes 

 Contacted nearby States (if applicable)
Public comment what to look for

 Have all concerns from FLM been 

addressed? 

 Was the public notice clear and well 

publicized? 

 Special Class I protection 

– Lower increment allowed

– Visibility 
Formalities

 Did source submit the permit application 

before commencing construction?

 Has the state been working with the source? 

 Is the permit easy to follow? 
How to submit comments? 

 States must send copy of draft permit to tribal 

governing body and EPA regional office 

working on their behalf

 30 day public comment period

 Can request public hearing and provide 

verbal comments