## 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