Nonattainment NSR
Permitting Process
Nancy Mayer
EPA–OAQPS
Topics
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Find technical resources for permit review
Describe how permits are constructe.
Describe what to look for when reviewing a
permit
Useful Areas of Expertise
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Air pollution modeling
Air pollution control
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Equipment
Practices
Law
Typical Permit Format
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General source identification
Source location
Emissions information
Offsets obtained from existing sources
Control technology analysis
Alternative Site Analysis
General Source Information
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Name
Source classification
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Generally what construction/modification is
being proposed?
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On list to count fugitive emissions?
Reason for construction
Other sources with same owner in state?
Source ID– Things to look for
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Is source classification correct?
Is list of other sources owned by same owner
in state complete?
Are other sources owned by same owner in
compliance?
Source Location
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Location
Source site diagram (not all permit
applications have site diagrams)
Source location–what to look for
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Is location accurate?
Does permit application ID all nonattainment
areas for all pollutants?
Does site diagram clearly explain what is
being proposed?
Are there unexplained buildings in the
diagram?
Emissions Data
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Existing emissions baseline
Change in emissions
Netting calculation, if any
Emissions Data–what to look for
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What method is used to measure emissions?
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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?
Emissions offsets
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Identification of all sources providing
emission offsets
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Amount and location
Calculations for emission decreases
Every relevant pollutant
How reduction is federally enforceable
Emissions Offsets–what to look
for
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Are all emissions increases offset with emission
reductions?
Were offsets calculated correctly?
Were they real or “paper” reductions?
Are all emission changes reflected in emissions
inventory used for attainment demonstration?
Will not slow down the attainment progress
Are reductions enforceable against source providing
offsets?
Control technology
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Proposed Lowest Achievable Emission Rate
How decision was made
Describe other alternatives
For each relevant pollutant
Control Technology–what to look for
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Has source researched for best?
Does the application propose using the best
technology? (For LAER – must use best
technology; no exceptions)
Does it have the technology from the
BACT/LAER Clearinghouse?
Does it have technology for all relevant
pollutants?
Public Participation/Notice
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Date, time documentation
Notice in readily available local newspaper
Contacted nearby tribes
Public comment–what to look for
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Was the public notice clear and well
publicized?
Were there any public comments? Were
these addressed?
Formalities
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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?
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30-day public comment period
Send to issuing party
Can request hearing and provide verbal
comments at hearing