1. Nonattainment NSR Permitting Process
Nancy Mayer
EPA–OAQPS

2. Topics Find technical resources for permit review
Describe how permits are constructe.
Describe what to look for when reviewing a permit

3. Useful Areas of Expertise
Air pollution modeling
Air pollution control
Equipment
Practices
Law

4. Typical Permit Format General source identification Source location
Emissions information
Offsets obtained from existing sources
Control technology analysis
Alternative Site Analysis

5. General Source Information
Name
Source classification
On list to count fugitive emissions?
Generally what construction/modification is being proposed?
Reason for construction
Other sources with same owner in state?

6. Source ID– Things to look for
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?

7. Source Location Location
Source site diagram (not all permit applications have site diagrams)

8. Source location–what to look for
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?

9. Emissions Data Existing emissions baseline Change in emissions
Netting calculation, if any

10. 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?

11. Emissions offsets
Identification of all sources providing emission offsets
Amount and location
Calculations for emission decreases
Every relevant pollutant
How reduction is federally enforceable

12. Emissions Offsets–what to look for
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?

13. Control technology Proposed Lowest Achievable Emission Rate
How decision was made
Describe other alternatives
For each relevant pollutant

14. Control Technology–what to look for
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?

15. Public Participation/Notice
Date, time documentation
Notice in readily available local newspaper
Contacted nearby tribes

16. Public comment–what to look for
Was the public notice clear and well publicized?
Were there any public comments? Were these addressed?

17. Formalities
Did source submit the permit application before commencing construction?
Has the state been working with the source?
Is the permit easy to follow?

18. How to submit comments? 30-day public comment period
Send to issuing party
Can request hearing and provide verbal comments at hearing