TM 5-815-1/AFR 19-6
(f)
Consider the questions related to preven-
that are being met are designated as an
tion of significant deterioration and
"attainment" area. Designation of the area
nonattainment. If it is found the facility
as "attaining", or "nonattaining", for each
will be a major source, determine for
pollutant encountered determines which of
which areas and pollutants you will have
the two routes is followed to procure a
to follow PSD rules. Determine possible
permit. Note that the area can be attaining
"off-sets" if any will be required.
for one pollutant and nonattaining for
(g) List the tasks and steps required for a per-
another pollutant. If this occurs one must
mit and estimate the costs and time incre-
use different routes for each of the
ments involved in the review process.
pollutants and would have to undertake
Coordinate the New Source Review
both
"preventation
of
significant
schedule with the facility planning
deterioration" (PSD) and "nonattainment"
schedule and determine how the New
(NA) analyses simultaneously.
Source Review will affect construction
(2) Attainment area. If the proposed source is
plans, siting, budgetary impact, schedules
in an "attainment" area, there is a specified
and the engineering for controls
allowed maximum increase, or "increment",
technology.
of higher air pollutant concentrations. The
upper limit of this increment may be well
4-4.
Mathematical modeling
below the prevailing National Ambient Air
Quality
Standard
(NAAQS).
The
a. Modeling requirement. Air quality modeling is
increment" concept is intended to "prevent
necessary to comply with rules for proposed sources in
significant deterioration" of ambient air
both attaining and nonattaining areas. Modeling is a
quality. The new source might be allowed
mathematical technique for predicting pollutant con-
to consume some part of the increment'` as
centrations in ambient air at ground level for the spe-
determined
by
regulatory
agency
cific site under varying conditions.
negotiations.
b. Modeling in attainment areas. Modeling is used,
(3) Nonattainment area. If the proposed new
under PSD rules, to show that emissions from the
source is in a "nonattainment" area, it may
source will not cause ambient concentrations to exceed
have to be more than off-set by decreases
either the allowable increments or the NAAQS for the
of emissions from existing sources,
pollutant under study. It may be necessary to model the
resulting in air cleaner after addition of the
proposed new source along with others nearby to dem-
new source than before it was added. In the
onstrate compliance for the one being considered.
absence of pollutant reductions at an
c. Modeling in nonattainment areas. Modeling is
existing source which is within
used to determine the changes in ambient air con-
administrative control, it may be necessary
centrations due to the proposed new source emissions
to negotiate for, and probably pay for,
and any off-setting decreases which can be arranged
emission reductions at other sources.
through emissions reduction of existing sources. The
(4) Summary of permitting path. The steps
modeling then verifies the net improvement in air
listed below present a summary of the
quality which results from subtracting the proposed
permitting steps:
off-sets from the new source emissions.
(a) Formulate a plan for obtaining a con-
d. Monitoring. Modeling is also used to determine
struction permit. It is usually advisable to
the need for monitoring and, when necessary, to select
engage a consultant familiar with the per-
mitting procedures to aid in obtaining the
monitoring sites.
permit.
e. Guideline models. EPA's guideline on air quality
(b) Contact state regulatory agencies.
recommends several standard models for use in reg-
(c) Determine if the modification could
ulatory applications. Selection requires evaluation of
qualify for exemption from the New
the physical characteristics of the source and surround-
Source Review process.
ing area and choice of a model that will best simulate
(d) Determine if the proposed facility will be
these characteristics mathematically. Selection of the
considered a "major source" or "major
proper model is essential because one that greatly over-
modification" as defined by the
predicts may lead to unnecessary control measures.
regulations.
Conversely, one that under-predicts ambient pollution
(e) Determine if, and how, with appropriate
concentration requires expensive retrofit control mea-
controls, emissions can be held to less
sures. Because of the subtleties involved, it is usually
than "de minimis" emission rates for the
advisable to consult an expert to help select and apply
pollutant so New Source Review
the model.
procedures might be avoided.
4-2
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