RE: Pio Pico PSD Permit Application-Class II Visibility Analysis

Cleveland Holladay 

to: 

Steve Hill 

03/12/2012 04:07 PM 

Cc: 

Gerardo Rios 

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From: Cleveland Holladay/R9/USEPA/US 

To: Steve Hill <SHill@sierraresearch.com>

Cc: Gerardo Rios/R9/USEPA/US@EPA 

Steve, 

Here are the CFR cites for this analysis. 

40 CFR 51.166 

(o) Additional impact analyses. The plan shall provide that— 

(1) The owner or operator shall provide an analysis of the impairment to visibility, soils, and 

vegetation that would occur as a result of the source or modification and general commercial, 

residential, industrial, and other growth associated with the source or modification. The owner or 

operator need not provide an analysis of the impact on vegetation having no significant commercial 

or recreational value. 

40 CFR 52.21 

o) Additional impact analyses. (1) The owner or operator shall provide an analysis of the 

impairment to visibility, soils and vegetation that would occur as a result of the source or 

modification and general commercial, residential, industrial and other growth associated with the 

source or modification. The owner or operator need not provide an analysis of the impact on 

vegetation having no significant commercial or recreational value. 

In addition, FYI, from the CAA: 

CAA Section 165 (e) 3. 

(3) The Administrator shall within six months after August 7, 1977, promulgate regulations 

respecting the analysis required under this subsection which regulations— 

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(A) shall not require the use of any automatic or uniform buffer zone or zones, 

(B) shall require an analysis of the ambient air quality, climate and meteorology, terrain, soils and 

vegetation, and visibility at the site of the proposed major emitting facility and in the area 

potentially affected by the emissions from such facility for each pollutant regulated under this 

chapter which will be emitted from, or which results from the construction or operation of, such 

facility, the size and nature of the proposed facility, the degree of continuous emission reduction 

which could be achieved by such facility, and such other factors as may be relevant in determining 

the effect of emissions from a proposed facility on any air quality control region, 

(C) shall require the results of such analysis shall be available at the time of the public hearing on 

the application for such permit, and 

(D) shall specify with reasonable particularity each air quality model or models to be used under 

specified sets of conditions for purposes of this part. 

If you have any further questions, let me know. 

-Cleve 

Cleve Holladay 

Phone 415-947-4140 

U.S. EPA, Region 9, Air Quality Analysis Office (AIR-7) | 75 Hawthorne St., 

San Francisco, CA 94105 

http://www.law.cornell.edu/uscode/text/42/7475

-----Steve Hill <SHill@sierraresearch.com> wrote: -----

To: Cleveland Holladay/R9/USEPA/US@EPA 

From: Steve Hill <SHill@sierraresearch.com>

Date: 03/08/2012 03:56PM 

Cc: Gerardo Rios/R9/USEPA/US@EPA 

Subject: RE: Pio Pico PSD Permit Application-Class II Visibility Analysis 

Can you please provide the CFR citation for this analysis, so I can be sure we are meeting the requirements?

Thanks,

Steve

From: Cleveland Holladay [mailto:Holladay.Cleveland@epamail.epa.gov] 

Sent: Thursday, March 08, 2012 3:48 PM 

To: Steve Hill 

Cc: Gerardo Rios 

Subject: Pio Pico PSD Permit Application-Class II Visibility Analysis

 

Steve, 

As we stated we would in our meeting with Pio Pico representatives yesterday, we had an internal EPA Region 

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9 review this morning concerning the Class II visibility analysis presented in the application. The discussion 

concerned the Level 1 analysis for Federal Land Manager Class II areas within 50 km of the Pio Pico site that 

Pio Pico conducted. The analysis showed ΔE and Cp values above the Visibility Workbook screening thresholds for 

both sites. No separate Class II threshholds have been set by EPA. Therefore, even though the results of this analysis are 

only for informational purposes, please follow the guidance in the EPA "Workbook for Plume Visual Impact Screening 

and Analysis (Revised)", EPA, EPA-454-92-023, 1992 and perform a Level 2 analysis using the VISCREEN model and 

submit the results to EPA. 

Thank you, 

Cleve 

Cleve Holladay 

Phone 415-947-4140 

U.S. EPA, Region 9, Air Quality Analysis Office (AIR-7) | 75 Hawthorne St., 

San Francisco, CA 94105 

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