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Home My WebLink AboutAPA2116[}{]&rn3~&c §[ID&®©@ Susitna Joint Venture Document Number Q //0 Please Return To DOCUMENTCONTROL Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD) ..' (U.S.)Environmental Protection Agency Research Triangle Park,NC Nov 80 W'PW+W maw E&¥Wig;,S!I L:i MHW¥M'4 MS¥?fllS'WZSJlIS a-=, 1 -..a:!dAi5~etdWi+¥" U.S.Department of Commerce National Technica!irlformation Service N .~.~ EPA·450/4·80-012 November 1980 no( 11../2.& ;:,~,<·:f ,';:,>:;:;':·;;:~::::':Y'><':~,;.;ye;~,"':-:);:t;1''~::i:;;,:J!,::,:::'C';CI"!,:',',:J~~~i~:' li!.~o."-, rw,21'l?Office of Air Quality P:anning and Standards Research Trillngle Park NC 2771·1 United States Environmental Protection Age:lCY . P.ir AmbientrtJIonitoring Guidelines for Prevention of Significant Deterioration (PSD) &EPA r 'i r r- r L r [ r~ L r~ [ [ [~ L L .mae L,- l. I' L -,-----------------------------=------- RfPllOOUCED BY NATIONAL TeCHNICAL INFORMATION SERVICE'.u.s.DEPARTMENT or COIiIiERC! SPRINGHHD,~A 22161 TECHilllCAL REPORT DATA (Please read luur..ctions all the rCI'ene belore completing) 1.REPORT NO.12 . 3.RECIPIENT'S A':CESSION'NO. EPA/450~4-80-0l2 PERl 1 532 3 1 4.TITLE AND SUBTITLE 5.REPORT DATE Ambient Monitorin]Guidelines for ..?revention November 1980 of Significant Deterioration (PSD)6.PERFORMING ORGANIZATION CODe 7.AUTHORISI 8.PI::RFOPMING ORGANIZATION REPORT NO. 9.PERFORMING ORGANIZATION NAME AND ADDRESS 10.PROGRA!I.'ELEMENT NO. Monitoring &-Data Analysis Div.i.cion Office of Air Quality Planning and Standards 11.CONTRACT/GRANT NO. Research Triangle Park,NC 27711 . 12,SPONSORING.AGi:NCY NAME AND ADDRESS 13.TYPE OF REPOnT AND PERIOD COVERED C:),;;,,,..c.. 14.SPCNSvRING AGENCY CODE .. 15.SUPPLEMENTARY NOTES - 16.ABSTRACT Amt~ent air monitoring guidelines are described for that maysources be reqt.ired to monitor the air quality unde!'the Prevention of Significant Deterioration (PSD)regulations.Some step-by-step discussion is presented for a source to det2rrnine if monitoring will be necessary.Situations whe:o:e existing dir quality and meteorological data,modeling,and use of assumed b?ckground concentrations for certair:areas may be used in lieu of monitoring, are shown. If a source must undertake a monitoring program,general guidance is given for pollutants to be monitored,number and location of monitoring sites,equipment,frequency and duration of sampli;tg,and data reporting. More detailed guidanc~is discussed for air quality monitoring probe siting criteria for various pollutants,meteorological monitoring,and qual it:' assurance procedures. 17.KEY WORDSIAND DOCUMENT ANALYSIS ,a.DElSCRIPTORS I b.IDENTIFIERS/OPEN ENDED TERMS Ie.COSAT I Ficld/Grot·p Prevention of Sigilificant Deteriorati pn Ambient Air Quality Monitoring iMeteorologicalMonitoringi - Quality Assurance ,-.'... HI.DISTfll!:l.U·1 ION STATEMENT ..19.SECURITY CLASS (This Report)21.Nv.OF PAGES Unlimited·"...,...'''ee~i"ipn 79 .... '.' 20,SECURITY CLASS (Thi:rag~)22.PRICE unclassified ',-_._.........--"-.. r';r-- r-fI r I r' ,-- I L f- t: (- r [ L 1- tc J L L L EPA Form 2220·'(9-73) L r- ,- f- L f' L I; [ [ f" L f. L [~ L L [~ ;r--r ... j 1 j ':".'-..,".. EPA-450/4-80-012 Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD) by Monitoring and Data Analysis Division Office of Air Quality Planning and Standardf> and Environmental Monitoring Systems U:tboratory Office of Research and Development U.S.ENVIRONMENTAL PROTECTION AGENCY Research Triangle Park.North Carolina 27711 November 1980. I (Co.\ [ L [ 1- L L [ L r--- I 'I This report is issued by the Environmental P::cotection Agency to report techr.ical data of interest to a limited number of readers.Copies are available -in limited quantities -from the Library Services Office (MD-35),IT.S.Environmerltal Protection Agency,Research Triangle Park,North Carolina 27711;<Jr,for a fee,from the National Technical Infor- mation Service,5285 Port Royal Road,Springfield,Virginia 22161. Publication No.EPA-450j4-80-0l2 i i .Many individuals were involved in the preparation of this document and should be conta~ted if any questions arise in the application of the guideline. FOREwORD -... .."....,..;,..,.".:,.~ 629-2566 629-2665 541-2666 541-2665 Phone Number Contact (Area Code ~FTS Number StanS1eva 541-5351 629-5351 David Lutz S41-5351 629-5351 James Dicke ~i41-5381 629-5381 Darryl yon Lehmden 541-2415 629-2415 j'1i ke Trutna 54'1-5291 629-5291 iii Larry Purdue Ken Rehme Subject Area Ambient Air Quality Monitoring. Meteorological Monitoring Quality Assurance (Ambient Air Quality) PSD Policy and Interpretation of Regulations Acceptable Method for Non-Criteria Pollut~nts r' r: [ r ·' -~ [ f' {' I~ L L L L I L ........~. NETWORK DESIGN AND PROBE SF.fING CRITERIA -------.:..-----..---------- v 1 6 8 8 9 10 13 14 15 -=--'::,':~,.~-<.~:,"''''''';:::-:.''')~.;-.:~''.',•..:'..'.r;~'>"':'.\.:";):-:'<,.--.•:.,.~•.•"...•,_---."",;",'::'_":."'•..:~:'<~"l,:":..'-.>:',,."J.'-J NOi"maZ Cor..di tions --------------------------------- ~~ansition Period ---------------------~------------- FPeconstru,~tion Phase ------------------------------- PostconstFl{ction Phase -~-------------------------- speaiaZ C01wepns for Location ofJ.!onitol>s ----------- />ion·l.tor Location ------------------------------------ Data QuaZity ---------------------------------------- Cuprentness of uata -------------------------------- 3.2.1 3.2.;? 3.2.3 2.1.1 Criteria PoZZutants -Preconctruction Pr~se ---------3 2.1.2 Criteria PoZZutants -Postconstruction Phase --------4 2.1.3 Noncriteria POZZUUu2ts -Preconstruction and Postconstruction Phase ------------------------------5 2.9 MeteoroZogical P:zraneters and Measureme;1t Methods ----------11 2.4 Use of Representative Air Q'.AaZity Data --------------..------6 TABLE OF COllTENTS 2.5 Duration of Monitol>ing -----------.:..-------------------------9 3.3 Probe Siting Crit9ria ----------------:---------------------15 2.7 Frequency of SampEng ---------------------------:....--------'-11 2.8 M?nitaring PZan ---------------.--------------------'--------11 3.1 Network Design ---------__----------------------------------1J 3.2 Number and Locati:m of Monitors ----------------------------13 2.6 SampZi,1g Methods and FPocedures --------------~-----------~-10 2.3 VOC and 0 7 110nitoring Requirements -------------------------5.. 2.1 Monitoring Data RationaZe ----------------------------------3 2.2 Monitoring Objective and Data Uses -------------------------5 GENERAL REQUIREMENTS AND CONSIDEF~XIONS ----~-------------------- INTRODUCTION --------------------------------..----------------- 3. 2. - r p.=--- f~ L r~ L L [ [~ [ [ [ L [' L L L rL L L TABL~'OF CON2~NTS (continued) 3.3.1 TotaL Suspeneed Pcu'ticuLates (TSP)------~-------------17 3.3.1.1 3~3.1.2 3.3.1.3 3.3.1.4 Vertical Placement --------------------------- Spacing from Obstructions -------------------- Spacing Jrom Roads --------------------------- Other Considerations ------------------------- j7 17 17 17 3.3.2 Sulfur Dioxide (80 2 )----------------------------------17 HorizontaL and VerticaL Probe PZacement ------ Spacing from Obstructions -------------------- 17 20 L J.3.3 C~~bon Monoxide (CO)----------------------------------20 3.3.3.1 HorizontaL and Verti~aL Probe PLacement ------20 3.3.3.2 Spacing from Obstructions --------------------20 3.3.3.3 spacinr from Roads ---------------------------21 3.~.4 Ozone (0 3 )--------------------------------------------21 3.3,5 Hi trogen Dioxide (NO ,,)--------------------------------6 . [ [ 3.3.4.L 3.3.4.2 3.3.4.3 Vertical and HorizontaL Probe PLacement ------. Spacing from Obstructions -------------------- Spacing from Roads --------------------------- Vc~tica~ar~HorizontaL Probe PLacement ------ Spacing jrmn Obstructions -------------------- 21 21 2J 22 22 22 3.3.6 Lead (Pb)--------------------------------------------.-22 3.3.6.1 3.3.6.2 3.3.6.3 3.3.6.4 Vertical Placement --------------------------- Spacing from Obstructions -------------------- Spacing from Roads --------------------------- Other Considerations ------------------------- 22 22 23 ·23 3.3.7 Noncriteria PoLlutants -------------------------------- L 3.3.7.1 3.3.7.2 3.Z.?3 Vertical Placement --------------------------- Spacing from Obstructions -------------------- Othc~Considerations ----~-------------------- 23 3.4 Probe Material and PolZ.utant SampLe Residence Time -----------24 L L L 4. 3.5 Summary of Frobe Siting Requirements -------------------------21 QUALITY ASSURANCE FOR AIR QUALITY DATA ----------------------------22 4.1 {rvlality Assurance for Criteric.Air PoZZutC.r:.t3 --.-------------- 4.1.1 General Info:rmation ----------------------------------- vi vii 4.1.5 Calculations for Manual Methods -----'-----------------35 4.1.3 Data Quality Assessment Requirements -----------------30 42 42 38 36 36 37 37 35 35 35 35 36 29 29 30 30 30 31 32 32 ..........-.-...,-'.."';"'-'.~.'. TABLE OF CONTEllTS (continued) Single A~~lyzer Precision ------------------- Single Ar~lyzer Accuracy -------------------- Organizational Re~direments ----------------- Primary Guidance ---------------------------- Pollutant Standards ------------------------- Purformance and System Audit Progmms ------- Precision of Automated Methods -------------- Accvracy of Automated Methods --------------- Precision of Manual Meth.ods --..-------------- Accuracy of Manua~Methods ------------------ Single Instro.unent Precision for TSP aY'.d Pb .- Sir~le Instr.~ent Acav~aay for TSP ---------- Single Instru~ent Sampling Accuracy for Fh -- Single-Anal.ysis-Day AcauY'a~Y for Pb --------- 4.1.4.1 4.1.4.2 Selection of Method ---------------------------------- Calibration ------------------------------------------ D~ta Validation -------------------------------------- Standard and Split Samples --------------------------- 4.1.3.1 4.1.3.2 4.1.3.3 4~1 •.s.4 ·4.1.5~1 4.1.5.2 4.1.5.3 4.1.5.3 4.1.2.1 4.1.2.2 4.1.2.·:l 4.1.2.4 4.2.1 4.2.2 4.2.3 4.2.4 4.1.6 Organization Reporting Re~direments ------------------36 6 .1.1 rli~ul Sys tems (horizonta Z ;.yind)-----------------------42 6.1.2 Wind Systellls (vc;rt-icaZ 'JJi>:.dJ -------------------------42 6.1.3 Wind Fl.u~tuations ------------------------------------42 4.1~2 QuaZity Contr?l Requirements -------------------------29 .. 4.1.4 Calculations for Automated Methods -------------------33 5.1 Data Required -----------------------------------------------38i. 5.2 Exposure of Ne.teopol.ogiaaZ!Instroa:71entE'---------------------39 4.2 Quality Assurance fOl'Noncriteria Air Pollu~ants ------------36 ft1ETEJROLOGICAL MOhITORING -------------------------------~-------- METEOROLOGICAL INSTRUMEN1~TIaN ----------------------------------- j .- 6 1 5 'J"~.:'...pec7-J 7-~a ';7-cns -----------------------------------..---------- 5. 6. .'I ~ f'.".,.:: I~ I' [' L I: [~ [ [ l: L r ' L [ L r L L L 8.DATA REPORTING ----------------------------------------------------46 APPENDIX A -PROCEDURES TO DETERMINE IF HONITORING Dfi.TA WILL BE REQUIRED FOR A PSD APPLICATION viii A-l A-l 11-1 .j A-J A-5 A-5 A-7 A-7 A-7 .4-9 A-22 Page 6.1.4 Vertiaa~Temperature Differenae -----------------------43 6.1.5 T~e~ature -------------------------------------------43 6.1.6 Humid~~y ----------------------------------------------43 6.1.7 F~iation -So~ar and Terrestrial ---------------------43 6.1.8 Mi-~ng Height -----------------------------------------43 6.1.9 Preaipitation -----------------------------------------44 6.1.10 Visibi~ity --------------------------------.------------44 TABLE OF CONTENTS (aontinuedJ 2.1 Part 1 -Sourae AppZiaabiZity Determination ------------------ 2.2 Part 2 -PoZlutant AppZiaabiZity Determination --------------- 2.3 Part 3 -BACT Analysis -----------------------------------~--- 2.4 Part 4 -~hier.t Air'QuaZity AnaZysis ------------------------ 2.5 Part 5 -Scurae Impaat Analysis ------------------------------ 2.6 Part 6 -Additio~.aZ Impaat Analysis -------------------------- 2.7 Part 7 -FiZe CompZete PSD AppZiaation ------------~---------- QUALITY ASSUP~ICE FOR ft~TEOROLOGICAL DATA -------------------------45 8.1 Air QuaZity Data Reporting -----------------------------------46 8.2 MeteoroZogiaa~Data Format and Reporting ---------------------46 2.PSD PER"1IT APPLICATION PROCEDURES ------------------------------..- REFERENCES ~-~ 3.DECISIONS FOR f1ONITORfliG DATA REQUIRENEllTS ------------------------ 7. 1.INTRODUCTTON ------------------------------------------------------ ~ ~ ~ I~ r [ r' [ [~ [' [ [ [ L~ L f' f- Lo l [ l l~ I- I I~' L L L L L [' L r~ L L L l_ L l L f ' L ';.'\"~"c",:"",,:.~:~-...., 1.INTRODUCTION The Clean Air Act Amendments of 1977,Part C,Prevention of Significant Deterioration,require that certain new major stationary sources and major mod;fications be subject to a preconstruction review which includes an ambient air quality analysis.Furthermore,the Act requires that an analysis be conducted in accordance with regulations promulgated by the EPA.In this regard,the Agency promulgated PSD regulations [lJ on June 19,1978,which included ambient monitoring requirements.Guidelines were pub 1i shed i n ~'ay 1978 [2J to di scuss moni toring for PSD purposes. However,in response to the June 18,1979 preliminary Court Decision (Alabama Power Com ~n v.Cost1e,13 ERC 1225).EPA proposed revised PSD regulations 3 on September 5,1979.The final court decision was rendered December 14,1979 [4J.3ased on the public comments to the September 5.1979 proposed PSD regulation~and the December 14,1979 court decision,EPA promulgated new PSD regulations on August 7,1980. Some of the pertinent provisions of the 1980 PSD regulations that affect PSD monitoring are discussed below: (a)Potential to emit. The PSD regulations retain the requirement that new major stationary sources would be subject to a new source review on the basis of potential to emit.However,the annual emission potential of a source will be determined after the application of air pollution controls rather than before controls as was generally done under the 1978 regulations [lJ. (b)De min'~is cutoffs. The PSD regulations will exempt on a pollutant specific basis major modifications and new major stationary sources from all rr.onitoring requirements when emissions of a particular pollutant are below a specific significant emission rate,unless the source is near a Class I area.Also included are significant, air quality levels which may be used to exempt sources or modifications from PSD monitorins when the air quality impacts from the sourc~s or modifications are below specified values. (c)Noncriteria pollutants. The 1978 PSD regulations [1J required monitoring on~y for those pollutants for which national ambient air quality standards exist.However,there are a number of pollutants for which no ambient standards exist (noncriteria pollutants)but which are regulated under new source performance standards and nationdl emission standards for hazardous pollutants.The 1980 regulations [5]require an ambient air quality analysis for all regulated pol1utdnt5 emitted in significant amounts. This analysis will generally be based on modeling of the impact the pollutants in lieu of collecting monitoring data. ", ! j r L I II. I (d)Preconstruction monitorinp. A list of air quality concentrations is inc.luded in the PSD regulations as crtteria for generally exempting proposed sources or modifications from collecting monitoring d-ta. Basically,monitoring data will be required if the existing air quality and the impact of the proposed source or modification is equal to or greater than these concentrations.In certain cases,even though the air quality impact or background air quality·mdY be less thai1 these concentrations,monitoring data may be required if the proposed source or modification will impact a Class I area,nonattainment area,or area where the PSD increment i5 violated. ..(e)Postconstruction monitor;ng. ThePSD l'egulations include authority to require postconstruction monitoring.In general,EPA may require postconstruction monitoring from large sources or sources whose impacts will threaten standards or PSD increments.The permit granting authority will make this decision on a case-by-case basis. (f)Transition period for phase-in of new regulations. Provisions have beer.ma.~e in the 1980 PSD regulations r5]to phase in the new requirements for monitoring.Additional data gathering beyond the 1978 requirements will not b2 effective until June S,1981,which is 10 months after promulgation of the PSD regulations [5J.The new monitoring requir~ments ~il1 be p~ased'in during the period 10 to 18 months after promulgatiun. All monitoring requirements in the 1980 PSD t'egulatlcns will be in effect February 10,1982,18 months after promulgation. Bec~use·of the above changes,as well as other r~visions to the PSD re9ul~tions,this guideline has been modified to r~flect such rev~sions. The purpose of this guideline is to address those items or activities which are considered essential in conducting an ambient air quality monitoring program.Guidance is given for designing a PSD airqL!ality monitoring network as well as the operaticJal Getails such as sampling procedures and methods,dura t i on of samp 1i ng,qua 1ity assurance procedurf;s, etc.Guidance is also given for a meteorological monitoring program as well as the specific~tions for mcteorrrlogical ir.strumentation and quality assurance procedures. An appendix is included to JhOW how the ambient air quality analysis fits in the overall PSD requirements.Flow diagrams are presented to aid a proposed source or modification in assessing if monitoring da~a may be required.i Genera 1 adherence to tIle gui dance conta i ned in thi s document shoul d ensure consistency in implementing the PSD monitoring regulations. ·.•..<j.'...t..::;1. .-." J~" r rr: L I~ L r~ L [ [ [ [ [ !" L L L r" L [ L 2.GENER4L REQUIREf.fEl:TS ANE'CONSIDERATIONS 2.1 Moni:orinQ Data Rational~ The court decision 1:4J has affirmed the C.mgressic.malinteJlt in the Clean Air Act as it relates to PSD monitoring requirements.The court ruled that Section l65(e)(1)of the Clean Air Act requires that an air quality Jnalysis be conducted for each pollutant subject to regulation under the Act before a major stati~nary source or major modification could construct.This analysis may be accomplished by the use of moceling and/or monitoring the air quality.EPA has discretion in sp~:ifying the choice of either monitoring 01'mvC:eling,consistent with the provisions in Section l65(e)(2).As will be discussed later,modeling will be used in most cases for the analysis for the noncriteria pollutants. The court ruled that Sectior.l65(e)(2)of the Clean Air Act requires that continuous preconstruction air q~ality monitoring data must be collected t:dete~ine whether emissions from a source will result in exceeding the National Jlmbient Air Qual ity Standards (rlAAQS).Further, the data could be used to verify the accuracy of the mode~ing estimates since modeling will be the principJl mechanism to determine whether emissions from the proposed source or modificatinn will result in exceeding allowable increments.In regard to monitoring requirements,the court stated that EPA had the authority to exempt de minimis situations. Postconstruc:tion monitoring data requiremen'~s are addressed in Section l65(a)(i)of the Clean Air Act.Sources may have to conduct such monitori~g to determine the air quality effect its emissions may have on the area it impacts.EPA has the discretion of requiring ~~nitoring data and the court stated that guidelines could ,be prepared to show the circumstances that may require postconstruction monitoring data. In view of the provisions of Sections l65(e)(1),l65(e)(2),and l65(a)(7,of the Clean Air Act,the de minimis concept,and sections of the final PSD regulations,sections 2.1.1,2.1.2 a1u1 2.1.3 present the basic rationale which generally will be followed to determine when monitoring data will or will not be req<Jired.It should be noted that the subs~quent use of "monitoring data"refers to either the use of existing represe~tative air 4UJlitj data or monItoring the existing a~r quality. Additional discussio:1 and flO\I diagrarlis are presented in Appendix A of this gUldeline which show variou~decision points leading toa determinction as to when monitoring data will or will not be rer.juired. Also,these procedures indicate at what points a I.lodeling analysis must be perfoljTjed. 2.1.1 C~iteria Pollutants -?reconstruction Pr~se For the criteria pollutants (TSP,S02'CO,NO ,Pb)continuous air quality monitoring data must,in general,be used fo establistl existing ail'qua 1i ty conce:.trations in the vicinity of the proposed source or modifi~ation.Fnr VOC emissions,continuous ozone monitoring data must 3 ... L [' l' L [ i0 I, to L t, L [ r" f . I L be used to establish existinr ail quality concentration~in the vicinity of the proposed source or modi flcation.However,110 preconstruction lI'.onitoring data \'1i11 generally be required if the ambient air quality concentration b~fore construction is less than the significant monitoring· concentrations.(The significant monitoring concentrations for each pollutant are shown 'n Table A-2 in the appendix to this guiJeline.)To ·require monitoring data where the air quality concentration of a pollutant is less than these values would be questionable because these low level concentrations cannot reasonably be determined because of measurement errors.These measurement errors may consist of errors in ~;ample collection, a~alytical m~a~urement,calibration,and interferences. Cases where the projected impact of the source or mod~fication is less than the significant monitoring concentrations would also generally be exempt from preconstruction monitoring data,consistent with the dt- minimis concept.[40 CFR 51.24(1)(8)and 40 CFR 52.21(i)(8)J. The one exception to the de minimis exemption occurs when a proposed sour~e or modification would adversely impact on a Class I area or would pose a threat to the rem"ining allowable increment or NMQS.For those situations where the air quality concentration before constructicn is near the significant monitoring concentration,and there are uncertainties asscciated with this air quality situation,then preconstruction air quality monitoring data may be required.These situations must be evaluated on a case-by-case basis by th~permit granting authority before a final decision is made. .2.1.2 Cl'iter>ia PoUutants -Pos-::ao"l".stl'"v/.ctionPhase E~A has discretion in requiring pcstconstruction monitoring data under Section 16~(a)(7)of the Clean Air Act and in general will not require postconstruction monitoring data.However,to require air quality moni~oring data implie~that the permit grdnting authority will have valid reasons for the data and,in fact,will use the data after it is collected.Generally,this wiil be applied to large sources or squrces whose impact will threaten th~standards or PSD increments. Examples of when a permit granting authority may require postconstruction monitoring data may include: a.NAAQS are threatened -The postconstruction air quality is projected to be so close to the NMQS that monitoring is needed to certify attainment or to trigger appropriate SIP related actio~s if nonattainment results. b.Sburce impact is uncertain or unknC?_wn -Factors such as complex' terrain,fugitive emissions,~nd other uncertainties in source or emission cha·racteristi~s result in sig'nificant uncertainties about the !,rojected impact of the source or modification.Postconstructiun data is justified as a permit condition on the basis that model refinement is necessary to assess the impact of future sources of a similar type and configuration. 4 "":""..:--'-:~~,"':~' L [ f' I" [ [ r~ L L L 2.1.3 Noncriteria Pollutants -Preconstruct-Zon and Postconsb.......ction pr,ase... Consistent with Section l65{e)(1)of the Clean A~r Act,EPA believes that an analysis based on modeling of the impact of noncriteria pollutants on the air quality should generally be used in lieu of monitoring data. The permit g~anting authority,however,does have the discretion of :equiring preconstruction and postconstruction monitoring data.Before a permit granting authority exercises its discretion in ~equiring monitoring data,there should be an acceptable measurement method approved by EPA (see section 2.6)and the concentrations would generally be equal to or greater than the significant monitoring concentrations (shown in Table A-2 of the appendix). A permit granting authority may require monitoring data in cases such as (a)where a State or other jurisdiction has a standard for a noncriteria pollutant and the emissions from the proposed source or modification pose a threat to the standard,(b)where the reliability of emission data used as input to modeling existing sources is highly questionable,especially for the pollutants regul~ted under the national emission standards for hazardous pollutants,and ~c)where available models or complex terrain make it difficult to est~mate air quality or ~mpact of the proposed source or modification. Monitorino Objective a~A Data Uses The basic objective of PSD monitoring is to det€rmine the effect emissions from a source are having or may have on the air quality in any area that may be affected by the emission.Principal uses of the data are as follows: (a)To establish background air quality concentrations in the vicinity of the proposed source or modification.These background levels are important in determining whether the air quality before or after construction are or will be approaching or exceeding the NAAQS or PSD increment. ! (b)To validate and refine models.The data will be helpful in veri fyi ng t!;e accuracy of th~model ing estirr.dte$. 2.3 voe and 0_Monitoring Requirementso Volatile organic compounds (VaC)monitoring is not "required since the 0.24 ppm nonmethane organic compollnd (NMOC)standard is a guioe for developing State Implementation Plans to"attain the 03 ambient standard. However,VOC emissions are the precursors in the form~tion of ozone. Consequently,any new source or modified existing sou:'ce located in an unclassified or attainment area for ozone that is equal to or greater than 100 tons per year of vac emissions will be required to monitor ozonp..VOC monitoring will not be required. 5 r 2.4 US3 of RepresentaHve Ail'::;uo7ity Data The use of existing representative air quality data was one of the optiJns discussed in section 2.1 for monitoring data.In determining whether the data are representative,three major items which need to be considered are monitor location,quality ~~the data,una currentness o~ the data. l_ L [ [ [' [ t' [ L f ' L L L [ l 2.4.1 Monitop Location The existing monitoring data should be representative of three types of areas:(1)the location(s)of maximum concentration increase from the proposed source or modification,(2)the location(s)of the maximum air pollutant concentration from existing sources,and (3)the location(s)of the maximum impact area,i.e.,where the maximum pollutant concentration would hypothetically occur based on the combined effect of existing sources and the proposed new source or modification.Basically, the locations and size of the three types of areas are determined through the application of air quality models.The areas of maximum conc~ntration or mnximum combined impact vary in size and ar~influenced by factors such as the size and relative distribution of ground level and elevated sources,the averaging times of cor-cern,and the distances between impact areas 3nd contributing sources. In situations where there is no existing monitor in the atov~ ar~dS,monitors located 0utside these three types of areas mayor may not be used.Each detennination must be made on a ca~e-by-case basis. In order to clarify EPA's intent regarding the use of existing monitoring data,some exc~ples are included to demonstrate the overall intent. (a)Case I -If th~proposed source or modification will be constructed in an area that is generally free fro:n the impact of other point sources and area sources associated with human.activities, then monitoring data from ~"regional"site may be used as representative data.Such a site could be out of the max';mun impact area,but must be similar in nature to the impact area.This site would be rharacteristic of air quality across a broad region including that in which the proposed source or modification is located.The intent of EPA is to limit the . use of these "regional"sites to relatively remote areas,and not to use them in areas of multisource emissions or areas of complex terrain. (b)Case II -If the proposed construction will be in an area of multisource emissions and basically flat terrain,then th~proposed source or modification may propose the use of existing dati)at nea:-by monitoring sites !f either of the following criteria are m~t. 1.The existing monitor is within 10 km of the points of proposed emissions,or 2.The existing monitor is within or not Tcrther than 1 rm away from ~ither the area(s)of the maximum air pollutant concentration from existing sources or the area(s)of the combined maximum impiict from existing and pro~osed sources. 6 r-~ I --';-...~.:'"..",":~...,'~"-',...:....'..'".'- 1 -.'-. [ L L f' L L If the existing monitor(s)meets either of the above two conditions,the data could be use~together with mo~e~estimates ~o determine the concentrations at ~ll three types of areas discussed earlier in this section. A"an example of the first criterion,if an existing monitor i~ located within 10 km from the point~of proposed emissions but not within the boundaries of the modeled areas of either of the three locations noted above,the data could be used together with model estimates to detenninethe concentrations at the three types of required area. The next example applies to the second criterion.In eVil.luating the adequacy of the location of existing monitors,the applicant must first,through modeling,determine the significant ambient impact area of the proposed source.In general,except for impact on Class I areas, the application of air quality models for the purpose of determining significant ambient impact would be lim~ted to 50 km downwind of the source or to that ppint where the concentration from the source falls below the levels shown in Table A-3 of the Appendix.For Class I are~s, a significant impact is 1 v'.1/m3 (24-hr)for TSP and SO?The appl icant would then identify within this significant impact area the area(s)of the maximum air pollutant concentration from existing sources and the area(s)of the combined maximum impact from existing and proposed sources. Yhe ar2a(s)ofe~timated maximum concentration from existing scurces or the estimated maximum co~bined impact area(s)are determined as f~llows: First,within the modeled significant ambient impact area,estimate the point of maximum concentration from existing sources,and the point of combined maximum impact (existing and ~roposcd source).Using these concentration values,determine the areas enclosed by air quality concentration isopleths equal to or greater tr.an one half of the respective estimate~ maximum concentration.An existing monitor located within or not farther than 1 km away from of any of thes2 areas can yield representative data. The rationale for consideri~g the use of existing data collected from monitors satisfying the above criteria is that modelers have a reasonable degree 9f confidence in the modeling results within the 10 km distance and the maximum concentrations from most sources are ~~st likely to occur within this distance.Generally,the modeling results in this flat terrain case may uncer or over predict by a factor of two,and thus the actual maximum impact from the source(s)could occur at points where the model predicts one half of this impact.Data co11ected within or not farther than 1 km away from areas may be considered as representative. -fc)Case III -If the proposed construction will be in an area ~f multisource emissions and in ai~as of complex terrain,aerodynamic downwash complications,or la~dJwater interface situations,existing data could only be used for PSD purDcses if it were collected (1)at the modeled location(s)of the maximum air pollution concentration from existing sources,(2)at the location(s)of the maximum concentration increase from the proposed corstruction,and (3)at the location(s)of the maximum impact area.If a monitor is located at only one of the locations mentioned above and the locations do not coi~cide,the source would have to monitor at the other locations. 7 It must be emphasized that the permit granting authority may choose not to accept data proposed under the cases discussed above.This may occur because of additional factors,especially in Case II which were not discussed but must be considered,such as uncertainties in data bases fer modAling and high estimates of existing air quality resulting in possiule threats to the applicable standards.Because of such situations, the permit granting authority must review each p~oposal on a ~ase-by- case basis to determine if the use of existing data \'1i11 be acceptable. It is important for the proposed source or modification to meet with the permit granting authority to discuss any proposed use of existing data. If the data are not acceptable,then a monitoring program would have to be started to collect the necessary data. - 2.4.2 Data Quality The monitoring cata should be of similar qual ity as would be obtained if the applicant monitored according to the PSD requirements.As a minimum,this ~ould ~ean: [ L 1. 2. The monitoring data were collected with continuous instrumentation. ,No bubbler data should be included.See section 2.7 for frequency of particulate pollutant sampling. The applicant should be able to produce records of the quality control performed during the time period at which the data were collected.Such quality control records should include calibration,zero and span checks,and control checks. In additiun,quality control ~rocedures should be a mintmum specified in the instrument manufccturer'~operation and instruction manual. 8 The air quality monitoring data shoula be current.Generally,this would mear,for the preconstruction phase that the data must have been collected in the 3-year period preceding the permit application,provided the data are still representative of current conditions.When such data are required,the noncriteria pollutant data must also have been collected in the 3-year period preceding the permit application provided that an acceptable measurement method was used.For the postconstruction vhase, the data must be coll ected afte..r.the source or IT,odification becomes opera tiona 1. 3.Historical data that were gathered from monitors which were operated in conformance with Appendix A or B of the 40 CF;\58 regulations [10]would satisfy the quality assurance requirements. The calibration and span gases (for CO,SO anti NO.)should be working standards certified by comvaris6n to a N~tional eureau of Standards gaseous Standard Reference Mat:rial. The data recovery should be 80 percent of the data possible during the mo~itori~~effo~t. Cupppntnens of Data 5. 4. 2.4.3 [ L L L [ L , !"'":'~.,_~"':·f"J:':-~,:>l"";~"-_~-'.:.'~~ ~ Ir ir -.-j-..:-~.•. 2.5 Duration ofMonitopi~ 2.0.1 Normal Conditione If a source decides to monitor because representative air quality data is not available for the preconstruction monitoring data requirement, then monitorir.g must be conducted for at least 1 year prior to submission of the applicatiun to construct.Also,if a source decides to monitor because represer;tative air quality data is not available for the post- ccnstruction monitoring data requirement,then monitoring must also be cOlldlActed for at least 1 year .::fter the source or modification becomes operational.Ho~ever,under some circumstances,less than 1 year of air quality data may be acceptable for ti1e preconstruction and postconstruction phases.This will vary according ~o the pollutant being studied.For all pollutants,less than a full year will be acceptable if the a~plicant demonstrates through historical data or dispersion rr.odeling that the data are obtained during a time period when maximum air quality levels can be expected.However,a minimum of 4 months of ait quality data will be requir-ed.As discussed in section 2.1.3,monitoring for noncriteria pollutants will generally not be required.[ [ [ r~ L L L L L Special attention needs to be given to the duration of monitoring for ozone.Ozone monitoring will still be required during the time period when maximUi:'1 ozone concentrations will be expected.Temf.lerature is one of the factors that affect ozone concentrations,and the maximum ozone concentration5 will'generally occur during the warme-,t 4 morths of the year,i.e.,June-September.However,historical monitoring data have shown that the maximum yearly ozone concentration for some areas may not occur from .June-September.Therefol'e,ozone monitori ng wi 11 also be required for those months when historical ozone data have snown that the yearly maximum ozone concentrations have occut'red during months other than the WarmE!st 4 months of the year.This requirement is in addition to ll',:>nitor"ng during the warmest 4 months of the year.If there is an interva·j of time between the warmest 4 months of the year and month where his'corical monitoring data have shown that the maximum yearly ozene concer.tration has occurred,then monitoring mlist also be conducted during that interval.For example,suppose historical data have shown the maximum yearly ozone concentration for at least 1 year occurred in April.Also,suppose the warmest 4 months for that particular area occurred June-September.In such cases,ozone monitoring would be required for April (previous maximum concentration month),May (interval month),and June-'5eptember (warmest 4 months). Some situat',ons may occur where a source owner or operator may not operate a new source or ll'odification at the rated capacity applied for in the PSD perm 4t.Generally,the postconstruction monitoring should not begin until the source is operating at a rate equal to or greater than 50 percent of its design capacity.However,in no case should the postconstructi~r.monitoring be started later than 2 years after the start-up of th~new source or modification. g L I' [~ L [ [ L r~ l ~ L t- L L L l ~._..- -..-.-__.-.-._-_- ...... I~the permit.granting authority ha~determined that jess than 1 yea;'of monitorina data is permissible.the sourcerr:ust agree to use the appropriate waxir.JulJ values colic:cted ove:--thi.s s.hort ;:>eriod -:'0;":cr.Darison to all appl ica~leshort-tenn standards.and th2 aVer-32~valt.:e for'th::short perio~as the equivalent of ~heann~a1 standard. -It should also be noted that the,above discussion of less than 1 year of data pertains to air quality data.not meteorological data.When the air quality ~mpact must be determined usi~g a dispersion model.the preferred meteorological data base is at least 1 year of on-site data. Althbughless than:l year of data may be sufficient to detennine the acceptability fot-a model.once the model has been accepted.a full year of meteorological data must be used in the PSD analysis. 2.5.2 Transitic~Period A transition period has been provided in the 1980 PSD regulations [5]for phasing in new monitoring requirements.Additional data gathering beyond therequiremeilts of the 1978 PSD regulations [1]will not be effective for permit applications submitted before June 8.1~81.10 months aft~r promulgation of the 1980 PSD regulations.The 10 month period was der'ived by assuming that 5 months are neede/j for instl'ument and equipment procurement.1 month to install th~equipment.calibrate and ensure satisfactory operation.and a minimum of 4 months of monitoring data. PSD pennit applications submitted from 10 to 18 months aft~r August 7.1980.should have dJta collected from February 9,1981.to the time the PSD application becomes otherwise co~plete.Howe~er.as discussed in seotior-2.5.1.iess data will be acceptable if the upplicant demonstrates through historical data Qt.dispersion modeling that the data would be obtafned during a time period when maximum air quality can be expected.The minimum of 4 months of air qual ity data would sti 11 be required. D~ring this 10 to 18 month ~ransition period.the permit granting authority may waive the additional monitoring requirements for ozone ~.if the monitoring could not be performed during the maximum--- concentration time .period as discussed in 8ecti~!2.5.1. ?SD pennlt applications submitted later than 18 rnonthsafter August 7,1980.would not be in the transition period and must.therefore.neet all monitoring r,:quirernents of the 1980 PSD regulations [5]. 2.6 SampZin~Methods and Proced~ (a)Criteria pollutants.. \ All ambient air quality monitoring must be done with continuous Reference or Equivalent Methods.'with the exception of TSP and lead for whichr.ontinuous Reference or Equivalent Methods do not exist.For TSP and lead.samples must be taken in accordance with the Reference Method. The Reference Methods are described in 40 CFR 50.A list of designated continuous Reference or Equi~dlent Methods can be obtained by writing Envircnmental Monitorif'10 Syst.ems Laboratory,Department E (~m-76).U.S. Environmental Protection Agency.Research Tr~dngle Park.NC 27711. 10 .-, f f J ; 11 2.8 M'mitol'ing Plan .'i ~"'::',~>'.'(,":-' 2.9 MetecroZogical Paramrters and Measurement Methods (b)Noncriteria pollutants. A monitoring plan prepared by the source should be submitted to and approved by the permit granting authority before any PSD monitoring begins.Note that approval of the monitoring plan before a monitoring program is started is not a requirement.H0wever,since the network size and station locations are determined Jr.a case-by-case basis.it would be pruder.t ~or the owner or operator to seek review of the network and the overall monito:"ing plan from the permit granting authority prior to collecting data.This review could avoid delays in the processing of the permit application and could also result in the elimination of any unnecessary monitoring.Delays may result from insufficient,inadequate, poor.or unknown quality data.Table 1 lists the types of information that should be included in the monitoring plan. For noncriteria pollutants.a list of acceptable measurement methods is available upon request by writing Enviror.mental Monitoring Systems Laboratory.Qt.:al ity Assurance 01 llision (MO-77).U.S.Enviror.lnen~.al Protection Agellcy.Research Triangle Park,NC 27711.This list of acceptable methods will be revic~~d at least an~ually ar.ci are available frrnn the above address.MeaSurement methods considered candidates for the noncriteria pollutant list should be brought tc the attention of EPA at the address give~above. 2.7 Frequen~y of Sampling For all gaseous pollutants and for all meteorological parameters, continuous analyzers must be used.Thus,continuous sampling (over the time period determined necessary)is required.For particulate pollutants, daily sampling (i.e.,one sample every 24 hours)is required except ~n areas where the applic~nt can demo~strate that significant pollutant variability is not expected.In ~hese situations,a sampling schedule less frequent thar every day woulrl be permitted.However.a minimum of one sample every 6 days will be r~quired fer these areas.The sampling f~equency would apply to both preconstruction and postconstruction monitoring. Meteorological data will be required for input to dispersion model~ used in analyzing the impact of the proposed ne~sourCE or modification on amb~ent air quality and the analyses of effects on soi1,vegetation, and visibility in the vicinity of the proposed S0urce.In some cases, representative data are available from sources sucn as the National Weather Service.However,in some situatiolls,on-s~te·data collecticn "'ill be required.The meteorological monitoring and instrumentation considerations are discussed in sections 5 and s. L ;,~ r"v; [ L r" I r" L [' [ [ [~ L r~ [" L f " L L L l TABLE 1.HININUN CONTENTS OF A NONITORING PLAN 1.SOURCE ErIVIRONr'~E!fi DESCRIPTION (...Hhiii 2 k,..,of source) •topogr~phical description •land-use descrirtion •topographical map of source and env;-rons (including location of existing stationary source£,roadways,and monitoring ~ites) •climatolcgical description •quarterly wind roses (from meteorological data collected at the source or other representative meteorological data) SAMPL!NG PROGRAM DESCRIPTION •time perlod for whi~h the pollutant(s)will be measured •rationale for location of monitors (include modeling results and analysis of existing sources in the areaj •rationale for joint utilization of monitorin:;net\'iork by other PSD sources •name of manufacturer •description of calibration system to be used •type of flow control and flow recorder V.DATA REPORTING •format of data submission •frequency of data !'eporting II. III.MONITOR SITE DESCRIPTION •Universal Transverse Mercator (UTM)coordi~at~s e height of sampler (air intake)above ground •distance from obstructions and he)ghts of obstructions •distance from other sources (statior.ary and mobile) •photographs of each site (five ptotos:one in each cardinal direction looking out from each existing sampler or where a future sampler will be located,and one closeup of each existing sampler or where a future sampler will he located.Ground cover should be included in tne closeup photograph.) IV.MONITOR DESCRIPTION L L VI.QUAL!TY ASSURANCE PROGRAM •calibration frequenr.y •independent audit program •internal quality control procedures •data precision and accuracy calculation procedures !' L l 12 r~ L [ L L L L L t~ r' [ L. I II' ~:;".-...-~.-;..".':-,,...·,·'3.i.·Y .;"":'". 3.NETWORK DESIGN AND PROBE SITING CRITERIA A source subject to PSD should only proceed with designing a PSD monitoring network on~y after going throu9h the procedure in Appendix A to determine if·monitoring data.will be required.To fulfill that requirement.a source may use representa·tive air qua I ity data which was discussed in seition2.4 or monitor This section presents guidance to be used if an applicant decides to monitor in lieu of using representative air qua 1i ty da ta • 3.1 ,Rei;;,Jor·k Design The Q0sign of a network for crit~ria dnd noncriteria pollutants will be affected by many factors,suen as :.~pog;-,aphy,climatology, population,and existing emission source$.Therefore.the ultimate design ofa network for PSD purposes must be decided on a case-by-case basis by the permit granting authority.Section 3.2 discusses the number and location of monitors for a PSD network.Additional guidance on the general siting of the monitors may be found in references 6-9 which discuss highest concentration stations.isolated point sources, effects of topography.etc.Probe siting criteria fer the monitors are discussed in s2ction 3.3.The guidelines presented here should be followed to the maximum extent practical in developing the final PSD monitoring network. 3.2 N":/.J'iber ar>.d Location of f.fonito:>s The number and iocation of monitoring sites wi~l be determined Qt.a case-by-case oasis by the source owner or operator and reviewed by the pe~it granting author-ity.Consideration should be given to the effects of existing sources,terrain.meteorolc~ical conditions.existence of fugitive or recntrained dusts.averaging time for the pollutant.etc. Generally.the number of monitors will be higher where the expected spatial variability of the pollutant in the area(s)of study is higher. 3.2.l Preconstructi~Phase Information obtaineo in the ambient air quality analysis in Appendix A will be used to assist in determining the number al1d location of monitors for the preconstruction phase.The air quality levels before construction were determined by modeling or in conjunction with monitoring data.The screening p,ocedure (or r.,ore refined model)estimates were determined in Appendix A.. The SOijrc~should first use t~e screening procedure or refined model estimates to determine the general location(s)for the maximum air quality concentrations from the proposp.d source or modification.Secondly, the source should determine by modeling techniques the general location(s) for the maximum air ql'ality levels from existing sources.Thirdly.the modeled pollutant contribution of the proposed source or modification should be analyzed in conjunction with the modeled results for existing sources to determine the maximum impact area.Application of these models mt.:st be consistent with EPA 's "Guideline on Ail"Qua7..ity Models" [34J.This would provide sufficient informatioli for the applicant to place a n,onitor at (a)the location(s)of the maximu,n concentration 13 r r-==:=- r" f" r I" r" [' L r~ [ (" L I" I- L L r- ," L L increase expected frc~the proposed source or modification,(b)the 10cation(s)of the maximum air pollutant conrentration from existing sources of emissions,and (c)the location(s)of the maximum impact area,i .r..,where the maximum pollutant concentration would hypothetically occur based on the combination effect of existing sources and the pr0pose( n~w source cr modific:.ltion.In some cases,'two 01 more of these locations may COi.lcide and thereby reduce the number of monitoring stations. Monitoring should then be conducted in or as close to these areas as possible (also see discussion in se~tion 3.2.3).Generally,one to four site5 would cover most situations in multisource settings.For remote areas in'which the permit granting authority has determined that there are no significant existing sources,a minimum number of monitors would be needed,i.p..,one or probably two at the most.For new sources, in these remote areas.as opposed to modifications,some concessions will be made on·the locations of these mon~tors.Since the maximum impact fro~these new sources would be in remote areas,the monitors may be located,based on conven]ence or accessibility,near ~he proposed new source rather than near the maximum impact area since the existing air quality would be essentially the same in both areas.However,the maximum impact area is still the preferred location. When industrial process fugitive particulate emissions are involved, the appli~ant should 10ci3te a monitor at the proposed source site (also see ~ection 3.2.3).If stack emissions are also involved,a dO\vr~winG location shou1d also be selected.For fugitive hydrocarbon emis~ions, the applicant should locate a monitor downwind of the source at the point of expected maximum ozone concentration contribution.This location will be found do~mwind during conditions tlJ.'lt are most conducive to ozone formation,such as temperature above 20 c C (58°F)and high ~olar radiation intensity.For 11ydrocarbon emissions from a stack,the appl icant should also locate the ~onitor in the ar~a of expected maximum ozone concentration.For both fugitive and stack emissions,the selection of areas of highest ozone concer.crations will reouire wind speed and direction data for periods of pho~ochemical activity.Monitar~~g for ozone will only be n€:cessary during the seasons when higr.concentl'ations occur. Since ozone is the res~lt ofa co~pl:x photochemical process,the rate of movement across an area of the air mass containing ~recursors should be considered.The distance frOffi the proposed sourc~to the monitor for an urban situation should be about equal to ~he distance traveled by the air moving for 5 to 7 hours et wind speeds occurring during periods of photochemical activity.In an urban situation,020:1e formation over the initial few hours may be supressedby nitric oxide (NO)emissions.For a point source,the NO interactions may be minimal, and the travel time to the expected maximum ozone concentration may be 3 to 4 hours downwind.In general,the dOWl"wind distance for the maximulII ozone site should generally not be more than 15 to 20 miles from the source because a lower wind 3peed (2-3 miles per hour)with l~ss dilution would b~a more critical case.Additionally.the frequency that the wind would blow from the source over the site diminishes with increasing dista:lces. ".2.2 PostcCllStY'UCt1:011 Pha.sc As discussed above for preconstruction mC'nit~ring.appropriate dis- persion modeling techniques are used to estimate the location of the 14 ~. .:: ~··.i·'-~~'-_':'i._' t 15 The desire for comparability in monitoring data requires adherence, to some consistent set of guidelines.ThereforE,the probe siting criteria discussed below must be followed to the maximum extent possible to ensure uniform collection of air quality data that are comparable and compatible. Before proceeding with the discussion of pollutant specific ~robe siting criteria.it is important to expand on the discussion in secti.or. 3.2 of the location of monitors.In particular.reference is made to two monitoring objective~. •Case ~:Locating monitors to determine where the combined impact of the proposed source and existing sources would be expected to exhibit the highest concentrations. •Case 1:Locating monitors to determine the maximum concentration frcm the pro~Jsed source and/or existing sources. 3.3 Probe Sitinq Crite!'ia 3.2.3 Special C01!ce!'ns to!'Location of Monitors For the precon~truction and postconstruction phases,modeling is used to d:~ermin~the ~eneral area where monitors would be located.Some of the modeled locations may be within the confines of the SOUI"CeIS boundary.However,monitors should be placed in :hose locations satisfying the:definition of ami:dent air.Ambient air is defined in 40 CFR50.l(e) as "that po.-tion uf the atmosphere,external to buildings,to which the general public has access."Therefore,if the modeled locations are within an area excluded from ambier:t air,the mo~itors should be located downwind at the boundary of that area. In some cases.it is simply not practical to place monitors at the indicated modeled locations.Some examples may include over open bodies of water.on rivers.swamps.cliffs.etc.The so~rcc an~the permit granting authority should determine on a case-by-case basis alternative locations. air quality impact of the new source or modification.Monitors should then ~e placed at (a)the expected area of the maximum concentration from the new source or modification,and (b)the maximum impact area(s), i.e.,where the maximum pollutant concentration wlll occur based on the combined effect')f existing sources and the new source or modification. It should be noted that locations for these monitors may be different from those sites for the preconstruction phase due to other new sources or modifications in the area since the preconstruction monitoring. Generdlly.two to three sites would be sufficient for most situatfons in multisource areas.In remote areas where there are no significar.t existing sources,one or two sites would be sufficient.These sites would be placed at the locations indicated from tr.e model results.The same concerns discussed in section 3.2.1 regarding industrial process fugitive particulate emissions,fugitive hydrocarbon emissions,and ozone monito~ing would also be applicable for the postconstruction phase. [' [ [ [ r~ L L L L L L L. L =-I' r'I [ L L L r' L r' I' l~ [~ L l~ L r' L., L L For Case 1,the driving force for locating the siting area of the monitor as well as the specific location of the probe or instrument shelter is the objective of measuring the maximum impact from the proposed source.Two Case 1 exaiTlples are given.Consider the first situation in which a proposed source would be emittin':!pollutants from an elevated stack.Under these circumstances,sufficient mixing generally occurs during the transport of the emissions from the stack to the ground resultin~in small vertical gradients near ground levPl,thus,a wide range of probe heights,3-15 meters for gases and 2-15 meters for particulatE's is ccceptable.For the same objective (maximum concentration 'from proposed source),consider the second example in which pollutants would be emitted from a ground level so~rce.In this case,the concentration gradient near the ground can be large,there~y requiring 3 much tighter rang:a of acceptable probe heights.For ground level sources 'endtting pollutants with steep vertical concentration gradients,efforts should be made to locate the inlet probe for gaseous pollutant monitors as close to 3 meters (a reasonable practical representation of the breathing zone)as possible and for particulate monitors using the hi-volume sampler 2 to 7 meters above grounc level.The rationale for the 3 meters is that for gaseous pollutant measurements,the inlet probe cnn be adjusted for vc-ious heiqhts even though the monitor is located in a bui1di1g or trailer.Conversely,the 2-3 meter height for the hi- volume sampler placement is not practical in certain areas.The 7 meter height allows for placement on a one sto~y building and is reasonably close to represe~ting th~breathing zone. Turn now to the second monitoring objective,Case 2,which is locating mo~itors to detennine the maximum impac:area taking into consideratio~the proposed source as well as exi~ting sources.The critical element to keep in mind in locating a monitor tc satisfy this objective is that the intent is to maximize the combined effect.Thus, in one circumstance,the existing source might contribu~e the largest impact.The importance of the above-discussion to the topic of ~lobe siting criteria is that in attempting to locate a JTlonitor to achieve this objective,the placement of the probe or inrtrument shelte~can vary depending upon which source is the predominant influence 011 the maximum impact area.As an extrem~example,consider the situation where a proposed elevated source would emit CO into an urban area and have Il1aximum combined CO impact coincident to an area adjacent to a heavily traveled traffic corridor.It is known that traffic along corridors emit CO in fair1y steep cO:1centration gradients so th~placement of the probe to measure the areas of highest CO concentration can vary significantly \'fith probe height as well as distance from the corridor. In this example,the traffic corridor has the major influence on the combined impact and therefore controls the probe placew.ent.As noted in the CO probe ~iting criteria in section 3.3.3 as well as Appendix E of the May 10,1979 Federal Register;promulgation of the Ambient Air Monitoring Regulations [10],the required ~r6be height in such microscale case~is given as 3 +1/2 meters wh~le the distance of the probe from tbe roadway would be between 2 and 10 meters. .~~. ",.- ~.,..;..,.,-..:'.'.:." 3.3.1.2 Spaci~~[porn Obstpuetions -If the sampler is located on a roof or other structure,then there must be a minimum of 2 meters separation from wa 11 s,parapets,penthou"es,etc.Furtherrr,ore,no furnace or . incineration flues should be nearby.The separatoion distance from flues is dependent on the heoight of the flues,type of Jiaste 0-fuel burned, and quality of the fu£~(ash content).For example,if the emissions from the chimney are the reslJlt of natural gas combustion,no special precautions are necessary except for tne avoidance of obstructions, i.e.,at least 2 meter's sepal"ation.On the other hand,if fuel oi l, coal,or solid waste is burned and the stack is sufficip.ntly short so that the plume couid reasonably be expected to impact on the ~ampler intake a significant part of the tiGe,ot~er buildings/locations in the area that are fr'ee from these types ot ',Ollrces should be considered for sampling.Trees provide surfaces for pa~ticulate ~eposition and also 3.3.1 Total Suspe~~ed Particulates (TSP) 3.3.1.1 Vel'tical PZace:r.ent -The most desirable height for a TSP moni~or is neai the breathing zone.Howev~r,practical considerations such as ~rcvention of vandalis~,security,accessibility,availability of electricity, etc.,generally requi,-e that the sampler be elevated.Therefore,a range of accepteble heights needs to be used.In addition,the type of source,i.e.,elevated or gruund level,predominantly i~fluencing the ared of impact must be considered wh~n locating the monitor.For purposes of determining elevated source impact,the sampler air intake must be located 2-15 met~rs above ground level.The lower limit was based on a compromise between ease of servicing the sampler and the desire to avoid reentrainment from dusty surfaces.The upper limit represents a compromise between the d€::s ire to have nleasurements whi ch are most !"epresentati ve of population exposures.and the considerations noted earlier.For ground lpvel sources with steep vertical concentration gradients,the air intakf'must be as close to the breathing zone as practical. As another example,consider the case where the same propos2d CO source would emit CO at elev3ted heights and have a combined maximum CO impact in an urban area that is only slightly affected by CO emissions from a roadway.The CO!l1bin~d impact area in this case is far enough away from the two sources to provide adequate mixing and olily small vertical concentration gradients at the impact area.In thi:;case,the 3~ceptable probe height w~uld be in the range of 3-15 meters . • It is recognized that there may be ether si.tuations occurri,1g which prevent the probe siting criteria from being followed.If so,the differences must be thoroughly documented.This documentation should minimize future questions about the data. The desire for comparability in monitoring data requires adherence to some consistent set of guidelines.Therefore,the probe siting criteria discus:ed below must be followed to the maximum extent possible to ensure uniforJ'T1 collectio,1 of .air quality data that are comparable and compatible.To achieve tris goal,the specific sitin~criteria that ere prefaced with a "must"are defined as a requir:!ment end exceptions must be approved by Hie permit granting Juthority.HOfJever,siting criteria chat are prefaced with a "should"are defined as a goal to meet for consistency,but are not a r~quirement. j", r'\".. ! r o f~ L r' 1 L L L [ L L L L L rL L L L I IL r L L L L L L r 1 restrict airflow.Theref0~e,the sampler should be placed at least 20 meters from trees. Obstacles such as buildings must also be avoided so that the distance between obstacles and the sampler is at least twice the height that the obstacle protrudes above the sampler.In addition,there must be unrestricted airflow in an arc of at least 27(0 around the sampler,and the predominant di rection for the season of greatest poll utant concentration potential must be included.in the 270 0 arc. 3.3,1.3 Svaeing [rem Roads -A number of studies [11-18J sUPport the conclusion that particulate concentrations decrease with increasing height of the monitor and distance from the road.Quite nigh concentrations have been reported at monitors located at a low elevation close to heavily traveled roads.Moreover,monitors located close to streets are within the concentrated plume of particulate matter emitted and generated by vehic1e traffic.Therefore,ambient moritors for TSP should be located beyond the concentrated particulate plume generated by traffic, ant!not so close that the heavier reentrained rodway particles totally dominate the measured ambient co~centration. An ar.laysis of various monitoring studies [19J shows that a l'inear relationship between sampler height and distance from roadways defines a zone where the plume generated by traffic greater than approximately 3,000 vehicles per day is diminished.Figure 1 illustrates thi~relationship by showing two zones where TSP monitors could be located.Zone A represents locations which are recommended and Zone B represents locations which should be avoided in order to minimize undesirable road~ay influences. Roads with lower traffic (less than approximately 3,000 vehicles per day)are generally not con~id~red to be a m~jor source or vehicular- related pollJtants,and so as noted in Figure 1 do not preclude the use of monitors in Zone B for those situations.However,note that for those cases where the traffic is less than approximately 3,000 vehicles per day,the monitor must be locat~d grea~er than 5 meters from the edge of tre nearest traffic lane and 2 to 15 meters above ground level . .In the case of elevated roadways where the monitor,must be placed below the level of the roadway,the monit0r should be located ~o closer tha~approximat~ly 25 mete~5 from the edge of the nearest traffic lane. This separation distance appl ies for those situ~tions whet'e the road is elevated greater chan 5 meters above the ground level,and applies to all traffic volumes. 3.3.1.4 O~hep Conside~ati~~s -Stations should not be located in an unpaved area unless there is vegetative ground cover year round so that the impact of reentrained or fugitive dusts will be kept to a minimum. Additional information on TSP Iprobe siting may be found in reference 6. 3.3.2 ~;l"Tf:a'Dioxide (802) 3.3.2.1 HOT'izor.tal an.d l'eptiJc:i P"o'!Je Plaaemer;t -As with TSP monitoring, the most deslra51e helght for an SO?lnlet probe is near the breathing height.Various factors enumeratec before may require that the inlet probe be elevated.Consideration must also be given to the type of source predominantly influencing the impact area,For elevated sources, the .inlet probe must be located 3 to 15 meters above ~~ound level.For 18 ", I~,'J r ZONE C (UfJACCEPTAOlE) 16- i Q) E ...=:ct'J to - w J: 6- , .~. ~L_---:-__-.l--~ °'-0---6 10 2IJ 25 30 35 DISTANCE ,:nOM EOG~OF NEAnEST TnArFlC LANE,motor,' "APPLIES WIIEnE ADT >3 000 Figure 1.i\cccpt".l.>le zone for siting TSP monitors L r ! r~ r~ r' (~ [' L: L [ L [' [ L L L t~ r' L L L ground le~el sources,locate ~s close to the breathing zone as possible. If the inlet probe is located on the side of the building,then it shou1d be ~ocated on the windward side of the building relative to the prevailing winter wind direction.The inlet probe must ~!10cate~ more than 1 meter vertically or horizontally away from any supporting structure and also away from dirty.dusty areas. 3.J.~.2 Spaoing [rom Obstruotions -t:o furnace or incineration flues, or other minor ~ources of 50 2 should be nearby.The separation distance is dependent on the height of the flu~s,type of waste or fuel burned. and the ylJality of the fuel (sulfur content).If the inlet probe is- located on a roof or other structure,it must be at lea~t 1 meter from walls,parapets.penthouses.etc. Thr:;inlet pr'obe should be placed more than 20 meters from trees and must be located away from obstacles and buildings.The distance between the vb~tacles and the in1et probe must be at least twice the height that the obstacle protrudes above the inlet probe.Airflow must also be unrestricted in an arc of at least 270 0 around the inlet probe,and the predominant direction for the season of greatest po11utant concentration potential must be included in the 270 0 arc.If the probe is located on the side of a building,180 0 clearance is required.Additional infonr.~tion on 50 2 probe siting criteria may be found in reference 7. 3.3.3·Carbon Monoxide (CO) 3.3.3.1 Hori~ontal and ~]rtioal Pr0be Placement -Because of the importance of measuring population exposure to CO concentrations.optimum CO sampling should be done at average breathing heights.However,prnctica1 factors require that the inlet probe be higher.In general.fer CO emitted at elevated heights,the inlet probe for CO monitoring should be 3-15 meters ~bove ground level.For those situation~where the ~missions from a proposed source would impact a street canyon or corridor type area in an u:--ban area,and the area is prodominantly influenced by the traffic from the street canyon or traffic corridor,the inlet probe should be positioned 3 +1/2 meters above ground level which coincides witn the vertical probe-placement criteria for a street canyon/corridor type site [lOJ.The criteria is more stringent than the 3 to 15 meter range specified earlier because CO concentration gradients resulting from motor vehic~es traveling along street canyon or corridors are· rather steep and show wide variations in CO levels at different heights. The 3 meter height is a compromise between breathing height representa.~ion and such factors as the prevention of obstructions to pedestrians.• vandalism,etc. In addition to the vertical probe criteria,the inlet probe must also be located more than 1 meter in the vertical Ol'"horizcntal direction from any supporting structure. 3.3.3.2 Spacing [pom Obstru(!tions -Airflow must also be lnrestl"icted in an arc of at least 270 c around the inlet probe.and the predominant direction for the season of greatest polluta~t concentratio~potential must be included in the 270 0 arc.If the probe is located ~n the side of a building,180 0 clearance is required. 20 .'~ 20 30 50 100 .>250 > Minimum Separation Distance Between Roadwa s and Monitors,Meters I I I ,\ i MINIMUM SEPARATION DISTANCE BETWEEN OZONE MONITORS AND ROADWAYS (EDGE OF NEARiST TRAFFIC LANE) <10,000 15,000 20,000 40,000 70,000 >110,000 Roadway Average Daily Traffic;I', Vehicles Per Day I TABLE 2. aDistances should'be interpolated based on traffic flow. 2i i I ,I, ! 2.3.4 ,Ozone (O~).... 3.3.4.3 S~acinc from Raa:::s -It is important in the probe siting process to minimize destructive ir.terfel·ences from sources of nitric oxide (NO) since NO readily reacts with ozone.Regarding NO from notor vehicles~ Table 2 provides the required minimum separation distances between road~3Ys and ozone monitoring stations.These distances were based on reralculations using the methodology in r~ference 9 and validated using more recent ambient data collected near a major roadway.The minimum separation distance must also be maintained between an ozone station and other .similar volumes of automotive traffic,such as parking lots. Additional information on ozone probe siting criteria may be found in refe\'£nce 9. ~.J.4.2 S~aair.q :ro~ObS~~Aatior.$-The probe must be lC.1ted away from oDstacles and buildings such that the distance between the obstacles and the inlet probe is at least twice the height that the obstacle protrudes above the sampler ..Tre probe should also be located at least 20 meters from trees.Since the scavenging effect of trees is greater for ozone than for some of.tne other pollutants,strong consideration should be used in locating the inlet probe to avoid this effect.Airflow must be unrestricted in.an arc of a~least 270 0 around the inlet ~robe,and the predominant direction for the season of greatest pollutant concentration potential must be included in the 270 0 arc.If the ~robe is located on the side of a building,180 0 clearance is required. 2.3.4.1 Vertiaat.ad H[;Y'-:'zcnta.l ?!'.:;:'e ?lace:-nen-::-The inlet probe for ozone ~onitors should be as close as possible to the breathing zone.The complicating factors.discussed previously,however,require that the probe be elevated.The heiaht of the inlet probe rr.ust be located 3 to 15 meters above ground level.The probe must also be locateJ more than 1 meter vertically or horizontally away froIT.any supporting structure. Z.3.Z.Z:::;::!C!i'::·::.~>:J'"?ca:::::;-For those situations di::;cussed above where theefTlissions fio:D a 'proposed source\'lOuld impact a street canyon/corridor type area,the ir.let probe must be located at least 10 meters from an intersection and preferably at a rnidblock location.The inlet probe. must also be placed 2-10 met2rs from the edge of the nearest traffic lane.Additional information on CO probe siting may be found in reference 8. '--'! L f' L f" L I" f" L L r' (" L I' f' L r~ L L L r ,...-:- "_.- r', L [' [" L L r~ L [ r : L l ~ [- L r~ L L L J.3.5 Nitpoaen D~oxide (NO,)z; 3.3.5.1 Ve'l't,:cal and HO'l'izontaL n'obe PLaaement -As di sc:uss~dfor previous pollutants,the acceptable ranges for a monitor/probe inlet fer monitoring N0 2 emis ...ions in an area principally influenced by an elevated source is 3-15 meters.For areas influenced primarily by a ground level source,the height should be as close to 3 ~ters as possible. Regarding the distance of the probe from the supporting structure,a vertical or horizontal distance of 1 meter must be maintained. 3.3.5.2 Spaaing [pom ObstFu~tions -Bui1dings,trees.and other obstacles can serve as sC3vengers of N0 2.In order to avoid this kind of interference. the station must be lor,ated well away from such obstacles so that the distance between obstacles and the inlet probe is at least twice the height that the obstacle protrudes above the probe.Also,a probe inlet along a vertical wall is undesirable because air moving along that wali may be subject to possible removal mechanisms.S~milar1y,the inlet probe should also be at least 20 meters from trees.There must be unrestricted airflow in an arc of at least 270 0 around the inlet probe, and the predominant c;rection for the season of greatest pollutant concentration potential must b~included in the 270 0 arc.If the probe is located on the side of the building,180 0 clearance is requ~red. Additional information on N0 2 probe siting criteria may be found in reference 9. 3.3.6 Lead (Pb) 3.3.6.1 Ve'l'tiaaL PLaaement -Breathing height is the most desirable location for the vertical placement of the Pb monitor.However,practical factors previously mentioned require that the monitor be elevated.In elevating the sampler.consideration must be given to ground level 'emissions (wnether they be stationary or mobile sources)\'lith stee~vertical concentl'ation gradients.Placing the shelter too high could result in measured va~ues significantly lower than the level breathed by the general publi~.Accordingly, the sampler for ground level source monitoring must be located 2 to 7 meters above ground level.In cor.trast.samplers to monitor for elevated sources, as noted in previous discussion,are allowed a wider range of heights fo~ locating the sampler/inlet probe.For Pb samplers,the acceptable rangp for monitoring emissions from elevated sources is 2-15 meters above ground 1evel. 3.3.6.2 Spacina [rom Obstructions -J;minimum of.2 meters of separation from walls,parapets,and penthouses is required for samplers located on a roof or other structure.No furnace or incineration flues should be nearby.The height of the flues and i:he type,quality,and quantity of waste or fuel burned determine the separation distances from flues.For ~xample,if the emissions from the chimney have a high lead content and there is a high pl'obability that the plume would impact on the sampler during most of the sampling period,then other buildings/locations in the area that are free from the described sources should be chosen for the monitoring site.The sampler should be placed at least 20 meters from tr~p.s,since trees absorb particles as well as adversely affect airflow. 22 - r~ r~ L r r L r~ [ L [ [ [ r ~ r ' L L l L rL -=:ot .'•.,...,.'-':~.-:~-~'h~",":"!'~.·~·~:··_;'<~~~_.-~.'.:'-~.-'':;,~"",<s~.._~;.:--,;~~.'-~:;_5:r-.'··;;;'::J/'::~'>"~·:.~~.,:'-'-•.~',:.,"'f....~-:"'.'~:....'":""~o:!l;:1.'.",:S,':'.:~'_.;..:~.•:~..:;~:.~7~,':-·_;-,·;::.>-',"".'.'-;~'''.::::-;!-"'";:-~.~~;or-<,>:--",,,;,=.,,":-';"'~'>""0-''~'_!.,:~~.-:"-.";.',-':r.....',;",..::.i, l; The samph",r must be located away from obst.acles such as buildings, so that the distance between obstacles and the sampler is at least twice the height that the obstacle protrudes above the sampler.There must a1-so be unrestricted airflow in an arc of at least 270 0 around the sampler,and thl!predominant direction for the season of greatest pollution concentration potential must be included in the 270 0 arc. ", Z.3.6.3 Spacing [rom Roads -For those situations discussed in section 3.3.6.1 where the emiss'jons from a proposed source would impact close to a major roadway (greater than approximately 30,000 ADT),the ail"intake-' for the monitor Jnust be located within 15-30 meters from the edge of the nearest traffic lane.Monitors located in this area would thus measure the combined impact from the proposed sOLirce and the roadway.The sampler air intake must be 2 to 7 meters above ground level. 3.3.6.4 Other Considerations -Stations should not be loca~ed in an unpaved area unle,;s there is vegetative ground cover year round so that the impact of reentrained or fugitive dusts will be kept to a minimum. 3.3.7 N?ncriteria PoZZutants 3.3.7.1 VeT'tico.Z pz.aaement -Similar to the discussion on criteria pollutants, the most desiraole height for monitors/inlet proLes for noncrit~ria poll~tants is near the breathing zone.Again,practical factors require that the monitor! inlet probe be elevated.Furthermore,consideration must be given to the type of source,i.e.,elevated,ground level,stationary,or mobile.As the case may be,for noncriteria particulate pollutant monitors;the-follcw~ng monitor/inlet probe ranges are acceptable:for iw.pact areas predominantly inf1uenced by elevated sources,2-15 meters;for ground level sources 2 to 7 meters.Regarding noncrite~ia gaseous pollutants,acceptable heights are as follows:areas impacted primarily by elevated sources,3-15 meters; areas affected principally by sround level sources,as close to 3 meters as possible. 3.3.7.2 spaci~[T'om ObstT"..lctions -If the sampler/inlet probe is located on a roof or ot er structure,then there must be a minimum of 2 meters separation frow.walls,parapets,penthouses,etc.No furnace or incineration flues should be nearby.This separation distan~e from flues is dependent- on the height of the flues,type of waste or fuel burned,and quality of the fuel.For eY~mple,if the emissions from the chimney contain a high concentra:on of the noncriteria pollutant that is being measured and there is a high probability that the plume would impact the sampler/inlet probe during most of the sampling period,then other buildings,'locations in the area that are free from the described sources should be chosen for the monitoring site.The sampler/inlet probe should also be placed at least 20 meters from trees.- Th~sampler/inlet probe-must be located aw~y from obstacles and buildings such that the distance between the obstacles and the sampler/ inlet probe is at least twice the height that the obstacle protrudes above the sampler/inlet probe.Airflow must be unrestricted in an arc of at least 270 0 around the sampler/inlet probe,and the predominant 23 [' ~ r~ r~ L f' r~' r: r : [ [~ r: [ L r'L L L [ L L direction for the season of greatest pollutant concentration potential mJst be included in the 270 0 arc.,If the inlet probe is located on the side of a building.180 0 clearance is required. 3.3.7.{,Other'Consi.derations"-S:ations for measuringpart';culate non- criteria pollutants should not b=located in an unpaved area unless there is vegetative ground cover year round so that the impact of reentrainedor fugitive dusts will be kept to a minimum. 3.4 Probe Mataria"l and PoUutant Sarrrp"le Residrw..ae Time For reactive gases.special probe material must be used.Studies [20-24] have be€n conducted to determine the suitability of mat~rials such as polyprl'ilylene.polyethylene.polyvinyl chloride.tygon.aluminum.brass. stainless steel.copper.pyrex glass.ar.d teflon for use as intake sampling lines.Of the above n:ateri;:l.ls.only pyrex glass and teflon have been found to be acceptable for use a~intake sampling lines for all the reactive gaseous pollutants.Furthermore,EPA [25~has specified borosilicatp glass or FEP teflon as the on~y acceptable probe matel"ials for delivering test atmospheres in the determin;:l.tion of reference or equivalent methods.Therefcre,borosilicat£glass,FEP teflon,or their equivalent must be used for inlet probes. No matter how unreactive the sampling probe r.~teriQl is initially, after a period of use,reactive particulate matter is deposited on the probe walls.Therefore,the time it takes the gas to transfer from the probe inlet to the sampling device is also critical.Ozone in the presence of NO will show significc.nt losses even in :he most inert pl"obe material when the residence time exceeds 20 seconds [26].Other studies [27-28] indicate ~hat ~10-second or less residence time is easily achievable. Therefore,sampling 'probes for reac.tive ·ga-s monitors must have a sampler residence time less than 20 seconds. 3.5 SW77fnary of Probe 8itin:.r Requirements Table 3 presents a summary of the requirements for probe siting criteria w~th respect to distances and heights.These criteria are specified for consistency between,pollutants and to allow the use of a sir:gle manifold for monitoring more than one pollutant at a site. 24 ~ .~,ri:., i ,..-.- J .....---, J , I TABLE 3.SUMHARY·OF PRonc:SITHlG CRI'rr::IHA Other Spacing CriteriaVertical1I0:cizontalbHeightAbove Ground,MetersaPollutant .--------:--.:.-_------,-,--:---,---,,-------,-;:--,-----------------------Distance from Supporting structure,Meters TSP 2 -15 >2 3. 4. 5. Sho~id be >20 m~ters from trees. Dishmce from sampler to obstacle,such as buildings,lliust be at lc~st twice the heigltt the obstacle pr.otnluc:.above the sampler. Hust have unrestrictoJ aiLflow 270 0 arc around the sampler. No furnace or inL:incration flues should be nearby.C Must have minimum spacing from roads. This varies with height of monitor (see Figure I). 3.-15 >1 >1 1.Should bCl >20 mctel-G from tr.ee'S. 2.Distance from inlet probe to obstacle,such as buildings,most.be at least twice the height the obstacle protrudes above the inlet probe. 3.Hust have unrestricted airflow 270 0 arc ~round tho inlet probe,or lROo ~f ~robc is on tho side of a building. 4.No fl1rnace or incincrat ion flues sho'Jlc1 b .cenearoy. >1 >1 >1 >13 -15 3 +1/2Co (street canyon/ corridor) 1.Hust be >10 metcr.s from intersection and should be at a midbJock location. 2.f1llst be 2-1Li meters from edg<;o of 'loa rest traffic lan~. 3.Hust have unrestricted airflow 180 0 ~round the inlet probe. -----~--.:..-I-----------+_-----l--'-----+_-.---------------------------- j 1.Must hnve ullrestricted airflow 270 0 nr.ound the inlet probe,ot'"lOOU if probe il~Oil the side of a building. .--------.-_._.---...._.-.-.-.-....--.I CO (non streC't canyon/corridor)L..J --,_._.'--•__._ ,..-..- L ; )---- f ','~ J --, u -..., :J ....--.-,-:-l ~j 'I ) 'r1\l1J.E 3.SllHl>I/\RY OF PROBE SrfING CRITlmIl\ (continued) "(~i9ht 1\bove Gro1lnd,Mntersa I Di.stance from Supporting I.S t r uc tur e ,_I-_lc_t_e_.r_s 1vertica~--T Iltwizontal1 Other Spacing Criteria 3 -15 > 1 >1 1.Should be >20 meters from trees. 2.Distance from inlet probe to obstacle,such as buildings,must be at least twice the height the obstacl~protrudes above the inlet probe. 3~Must have unrestricted airflow 270 0 arc around the inlet probe,or 180 0 if probe is on the side of a building. 4.Spacing from roads varies with traffic (sec 'I'able 2). 1-------+-~--~-----1------+-----+---------------------_·- --;..2 l. 2. I 3. 4. 5. f ". .~.. i" ;'I .. N O'l Pb (impact nC!ilr. major roadway and/or ground level sources) 3 -15 2 - 7 I >1 >1 1.Should be >20 meters from trees. 2.Distance from inlet probe to obstacle,such as buildings,must be at least twice the height the obstacle protrudes above the inlet probe. 3.Hust have unrestricted airflow 270 0 arc around the inlet probe,or IBO o if probe is on the side of a build in(J. Should be >20 meters from trees. Distance from nampler to obstacle,such as I buildings,must be at l£,ast twice the heiyht cbstacle protrudes above the sampler. Must have unrestricted airflow 77U o ~rc around the sronplc r. No furnace or incinerat.ion flues which emiecleadshouldbene<\rby. l-llJst h(~15··30 IlIl"lters from major roadwily::;. -.----"--.---1---------------'---L ...-__-l.._ r~,.....----, J 'fl.U,l~3.SUmil.RY 'JF PROnT::SITING CRI'rERIl\ (Continued) I!"iqht 1\bo\'o (;1 ound,rh~tl'r-Sai'ollutant .Other Spacing.Cd.teda . ------.-:..--+------------l-----.--+.-------l--'----------.-:.....:.----.-:..-'-.-:..--->..;----.-:..---1 ----------,-------_._--,,.----_._----._---,--:---.-----------------"-----_._--.Distance froll Supporting __.str.u::tur_~,_Mc~cr!'l V<i!rd~~t Ilori.zonta~ Ph 2 -15 >2 1.Should be >::'0 meters frQm trees. 2.Distance from sampl~r to obstacle,such as buildings,must be at least twipe tP,P.height tho obstacle protrudes above tHe s~nplcr. 3.MUs~have unrestricted airflow 270 0 arc around the sampler. 4.No furnolce or incineratioll flude which emit lead should be nearby.c Pc'1rti-;~'--- Nonc:riteria Pollutants 2 -./for g.roulld level .--sources; 2 -15 for el~~ated source~ >2 1.Should be >20 meters from trees." 2.Distance from sampler to obstacle.such as buildings,must be at least twice the height tne obstacle protrudes above.the sampler •. 3.Must have unrostricted i'\irflow 270 0 arc around the sampler. 4.No furnace or .incineration flues which emit the noncriteria pollutant should be nearby.c -1-------------+._----_.+-------+----_._----------------------I .Gaseous t·lrmcr i tel:ia Pollutants 3 -15 >1 >1 1.Should ~e >20 meters from trees. 2.Distance frum inlet probe to obstacle,such as buildir.gs,m\lst be at least twiCE the heigh1 ·)l,,-tacle IJrotrud£s above t~e inlet probe. 3.Must have unrestricted airflo~~700 arc around the inlet probe,or 180 0 if the probn is on the side of a bu5lding. ,t.No iurnace or incineration flues wl:ic',emit "t .bthentlllCr1cr.la pollutant should be nearby. a For ground level soux-cC's,monitors/in:;et probes !3hould be placed as close to the breathing zone as possible. b WhclI probe is 10cated'{\11 rooftop,this sepclratlc)f\distance is in reference to walls,parapets,or penthousE'S locntcd on the £06f. CDistance is depcl:dent 6n heiqht of furancc or incineration flu£:<,type of fuel or waste burned,and quality :>f fuel.This is 1:0 avoid uJl'lue influences from minor poll'ltant sources. r 0:::::=- r r i [ rL [ t r: L L~ [ r~ r~ [~ l~ L L IL. C I IL~ 4.QUALITY A25UR.t..NCE FOR AIR QUAI,ITY DATA On !!jay 10,1979,EPA promJlgated quality assurance requiremenL.5 for PSD monitoring for SO?'N0 2 ,03'CO,and TSP.These quality a~surance requirements are Appendix B of 40 CFR 58 (part of reference 10).EPA plans to amend Appendix B to include quality assurance requirements for lead.Section 4.1 describes minimum quality assurance requirements (promulgated and planned)for PSD monitoring for all criteria air pollutants (S02'N0 2 ,°3 ,CO,TSP,and lead).. In section 51.24 of reference 10,monitcring or~a~izations are required to meet qu~lity assurance requirem~nts of Appendix B for SO?' NO ,O?,CO,and TSP according to the following schedule:(a)no later th&n J~nuary 1,1980 for eXisting PSD monitoring stations;and (b)for new PSU monitoring stations,at the time the station is put into operation. Currently,quality a;surance for PSD monitoring for noncriteria air pollutants are EPA recommendations only.EPA promulgated requirements are not available for noncriteria air pollutants.Section 4.2 describes minimum quality assurance recommendations for noncriteria air pollutants. 4.1 Qua"lit:'v!ASSU1"CTrWe foT'Cl'itel'ic:.Iii}"PcZZutants ·.1.1.1 Gene]'aZ InfoT'mation The following specifies the minimum quality assurance requirements of an organization operating a network of PSD station~.These requirements are regarded as tne mirtimum necessary for the control and assessment.of the qual ity of the PSi)ambient air monitoring data submitted to EPI'.• Organi:ations dre ~nc6uraged to develop and implement quality assurance programs more extensive than the minimum required or to continue such programs where they already exist. Quality assurance consists of two distinct and equally important functions.One function is the assessment of the quality of the monitoring data by estimating their precision and 3ccuracy.The other function is the control,~nJ improvement,of the quali~y of the monitoring data by impiemen~ation of quality cor.trol policies,procedures,and corrective actions.These two fu~cticns forma control loop;when the assessment function indicates that thl~data quality i<;inadequate,the control effort ,nust be in:reased until the data qual ityis acceptable. In order to pro~'ide uniformity in the assessment and reporting of data quality,the assessment procedures are specified explicitly in sp-ci:Ums 4.1.3,4.1.4,4.1.5 and 4.1.6. In cuntrast,the~ontr:ol and corrective action function encompasses a variety of policies,procedures,specifications,standards,and corrective measures which have varying effects on the resulting data quality.The selection and degree of specific control measures and corrective actions used depend on a number of factors such as the monito~ing methods and equipme~t used,field and labcratory conditions,the objectives of the 28 '-l"'~;~',."i •..~ ';,:. r r .-~ L r r- t [ [ r- L [ L monitoring.the l~vel of data quality needed,the expertise of personnel, the cost of control procedures.pollutant ccncentration levels,etc. Accordingly.quality control requirements are specified in general terms in section 4.1.2 to al10w each organization to develop a quality control system which is most effective for its own circumstances. For purposes here,"orgardzation"is defined.as d source owner/operator, a government agency,or their contractor which operates an ambient air pollution monitoring network for PSD purposes. 4.1.2 Quality Control ReG,~irements 4.1.2.1 Organizational Requirement3 -Each organization must develoD and implement a quality control program consisting of policies.procedures, specifications,standard~and documentation necessary to: (a)me~t the moni~oring objectives and quality assurance rEquirements of the permi t granti ng authori ty, (b)minimize loss of air quality data due to malfunctions or out- of-control condition~ The quality control prog"'am must be described in detail.suitably docume:1ted,and approved by the permit granting i'uthor"ity. 4.1,,2.2 Primary Guidance -Primary guidance for developing the quality control program is contained in references 29 and 30 •.which also contain many suggested procedures.~hecks,and control specific~tions.Section 2.0.9 of reference 30 describes the specific guidanee for the deveiopment of a qUllity control program for PSD automated analyzers and manual methods.Many specific quality control checks and specifications for manual methods are included in the respective reference methods described in 40 CFR 50,or in the respective equivalent method descriptions available from EPA (see section 2.9).Similarly,quality control ~rotedures related to ~pecifically designated reference and equival~nt ar.alyzers are contained in their respective operation and i:1struc1;iorl manuals. This guidance.and any other pertinent information from ~ppropriate sources,should be used by organizations in ~eveloping their quality control ~rograms. As a minimum each quality control program must have operational procedures for each of the fo1lowing activities: (a)selection of methods,analyzers.or samplers, (b)installation of equiprllent, (c)calibration, Cd)zero and spac checks and adjustments of automated analyzer~ (e)control checks and their frequency. (f)_control 1imits for zero.span and other control checks,and .respective corrective actions when such limits are surpassed. 29 r ::-.- r~ r~ r r~ r~ [ [ [ [ [ r~ L L L t- L [ L (9)cal~bratiDn and zero/span checks for multiple range analyzers (h)pr~ventive ,and remedial maintenance (i)recording dnd validating data (j)documentation of quality control i nforma tion. P.s,p;~eviously mentioned,specific guidance for each activity listed above th3t'must be a part of an organization's quality control progl~am is described in section 2.0.9 of reference 30. 4.1.2.3 Pollutant St2ncc~ds -Gaseous standards (permeation tubes. permeation devices or cylinders of compressed gas)used to obtain test concentrations for CO.SO~.and N0 2 must be working standards certified by comparison to a Nation~l Bureau of Standards (NBS)gaseous Standord Reference Material (S~~).A traceability protocol for certifying a working standard by direct comparison to an NBS SRM is given in reference 21.Direct use of an NBS SkM as a working standard,is not prohibited but is discouraged because of the limited supply and expense of NBS SRM's.When available.gas manufactur~rs'cy:inder gases Ce~tified Reference Materials "CRM"may be subtitled for NBS SRM cylinder ga~es in establishing traceability. Test concentrations fOI"ozone must be obtained in accordance with the UV photometric calibration procedure specified in Append~x D of 40 CFR 50,or by means of an O!i)ne transfer sta,r.dard ;.,hich has been certified. Cunsult reference 32 for guidance on ozone transfer standards. Flow measurements must be made by a flow measuring instrument which 'is traceable to an authoritative volume or other standard. ,4.1.2.4 Per[o!'l71an'3,z and System Aud-it ppoqrX!73 -The organization operating a PSD monitoring neb/ark mu~t participate in EPA's national pel~formance audit program.The permit grdnting authority.or EPA.may conduct system audits of the ~mbient air monitoring programs of organizations opera ti ng PSD networks.See secti on 1.4.16 of reference 29 and reference 33 for additional information about these programs.Organizations should contact either the ~ppropriate EPA Regional Quality Control Coordinator or the Quality Assurance Division,EMSL/RTP.at the address given in reference 31 for instructions for partici~at~on. 4.1.3 Data QuaZity Azsessment Require~ents 4.1.3.1 Pre~ision oT Autom~ted Methods -A one-point preC1S)On check must be carried out at'least once every two \'Ieeks on each automated analyz~r used torneasure S02'N0 2 ,°3 ,and CO.The precision check is made by challenging the anaTyzer witfi a prf'cision check gas of k'lOwn concentration between 0.08 and 0.10 ppm f0r 5°2,NO?.and O~analyzers. and bp.tween 8 and 10 ppn.for CO analyzers.The stanoards fr5m which precision check te~t concentrations are obtai~ed must meet the specifications of Eection 4.1.2.3.Ejcept for certain CO analyzers described below. analyzers r.Just operate in their normal sampling mode during the precision check.and the test atmosphere must pass through all filters,scrubbers. conditioners,and oth:-r components used during normal ambient sampling and as much of the ambient air inlet system as is practicable.If permitted 30 .'~-'...,..,."..:--~." ,""..'-".;.," [ L L l~ L L L [ L bv the associated cperation or instruction manual.a CO a~alyzer~ay be temporarily modified during the preci~ion check to reduce vent or purge fl~ws.or the test atmosphere may enter the ~~alyzer a~a ~oint ot~er thdn the nomal sample inlet.provided that the analyzer's response is not likely to be altered by these deviations from the normal operational mode. If a precision check is made in conjunction.with zero/span adjustment, it must be made prior to such zero and span adjustments.The difference between the actual concentration of the p~ecision ~heck gas and the concentrativn indicated by the analyzer is used to assess the precision of the monitoring data as described in section 4.1.4.1.Report data only from automated analyzers that are approved for use in the PSD network. ~.1.3.2 Accurc:cy of Automated Methods -Each sampling quarter audit each analyzer that monitors for 502'NO ,0 ,or CO at least once.The audit is made by challenging the analyze?wiih at least one audit gas of known conce~tration from each of the following ranges which f~ll within the measurement range of the analyzer being audited: ~ Concentration I\ange •.ppm Audit Point 5°2'N0 2 •03 I CO 1 0.03 to 0.08 3 to 8 2 0.15 to 0.20 15 to 20 3 0.40 to 0.45 40 to 45 4 0.80 to 0.90 80 to 90 I The standards from which audit gas test concentrations are obtained ~1U~t meet the specifications of section 4.1.~.3.Working and transfer standards and equipment used for auditing must ~e different from the standards and equipment used for calibration·and spanning.The auditing standards and calibration standards may be referenced to the same NBS SRM or primary UV phutometer.The auditor must not be the operator/analyst who cond~cts the routine monitoring,calibra.tion,and analysis. The audit shall be carried out by allowing the analyzer to analyze an audit test atmosphere in the same manner as described for plec;si9n checks in cection 4.1.3.1.The exception given in section 4.1.3.1 for certain CO analyzers does not apply for audits. The difference between the actual concentration of the audit test gas and the concentrat~on indicated by the analyzer is used to asse~s the accuracy of the lilon~toring data as described in se(!tion 4.1.4.2.Report data only from automated analyzers that are approved for use in the PSD network. 31 r~ f r t I L L L r~ I' t' [ [ [ [ L L L L " L L L 4.1.5.:5 Precision oj':·!:;'Y:.UQ.Z J.1etho:is -(a)TS?Method.For a gi ven organization's monitoring neb/ork,one sampling site must have collocated samplers.A site ~ith the highest expected 24-hour pollutant concentration must be selected.The two samplers must be within 4 meters of each other but at least 2 meters apart to preclude airflow interference.Calibrdtion, sampling,and.analysis must be the same for both collocated samplers as well as for'all other samplers in the network.The collocated samplers must be operated as a minimum every third day when continuous samplin9 is used. When ~lesS frequent sample schedule is used,the collocated samplers must be operatec at least once eac~week.Fer each pair of collocated samplers, designute one sampler as the sar.lpler which will be used to repor"t ai:-ouality for the site and designate the other as the duplicate sampler.The differences in measured concentration (Ug/m3)b~tween the two collocated samplers are used to calculate precision as des~ribed in section 4.1.5.1. (b)Pb Methods.The open-.tion of collocated samplers at one sampling site must be used to assess the orecisicn of the reference or an equivalent lead method.The procedurt!to be followed for lead methods is the same as described in 4.1.~.j(a)for the TSP method. 4.1.3.1 Accurac~of Ua1~al Methods -(a)TS?Mp.thod.Each sampling quarter audit the flow rate of each high-volume samp1er at least once. Audit the flew rate at one flow rate using a referen<.e flow device . described in section 2.2.8 of reference 3~,or a similar transfer flow standard.The d2vice used for auditing must be different from the one used to calibrate the flow ~f the high-volume sampler being audited. The auditing device and the calibration device may both be referenced to the same pri'Tlary flow standard.:.lith the audit device in place, operat8 the high-volume s~mpler at its normal flow rate.The ditf~rence in flovJ nte (in m3 jmin)between the audit f'/ow measurp.ment and the -~low indicated by the sampler's normai flo1-'ir,Gicdtor is used to cal.:ulate accuracy as described in section 4.1.5.2. Great care must be-used in auditing high-volume samplers having flow regulators be~ause the intr0duction or resistance plates in the audit 'device can cause abnormal flow patterns at the point of flow se~sing.For th)s reason,the orifi:e.of the flow audit jevice should be used with a normal 0lass fiber filter in place and without resistance plat~s in auditing flow re9ul~ted high-volume samplers,or other ste~s sho~ld be taken to assure that flow pa~terns are not perturbed at the po"lnt of flow sensing. {b)Pb ho-:!thods.For the rt!ference method (Appendix G of I.'tO erR 50) each sarr,pl 109 quarter auJit the flow rate of each high-volumE;lead s;;lmpler at least onct::Audit the flow r~te at one flow ;'ate US~llg a reference flow device des.::ribed in ~ectio"2.2.8 of reference 3G,C1r a similar flow transfer standard.The device used for auditing mu~t be different from the one used to culibrate the flow of th2 high-volume sampler being audited. The auditina cevice and the ccribration device I!')y both be referenced to the same pr1mary flow standard.With the audit device in place,opet'ate 32 '33 0.5 to 1.5 3.('\to 5.0 EqUivalent Ambient Conc.lJ.g Pb/m 3 * 100 to 300 600 to 1000 Conc.Ug Pb/strip 2 1 *Equivalent ambient lead concentration in vg/~3 is based on sampling at 1.7 m3 /min for 24 hours on 20.3 cm x 25.4 em (3 inch x 10 inc!)glass fiber filter. Th~accuracy of an equivalent method is~ssessed in the same manner as the reference method.The flew auditing device and lead analysis audit samples ~ustb~compatible uith the specific requirements of the eGuivalent method. 4.1.4.1 Sinqle AnaZ:,zG'r TT'eaisior;-EilCh organization,at the end of each sampling quarter,sha11 c~)culate and report a precision probaDility interval for enciJ analyzer.Direction~~or calculations are qiven below and directions for reportin~are given in sea'dO};4.1.6.If monitoring data are invalicated the high-volume sampler at its normal flow rate.The diff~rence in flow rate (in m3 /min)between the audit flow measurement and the flow indicated by the sal:ipler's normal flow indicator is used ~o calci.Jlate accurac~'as described in section 4.1.5.3. Great care must be used in aud)ting high-volume sampler having flow regulators because the introduction of resistance plates in the audit device can cause abnormal flow patterns at the point of flow sensing. For this reason,the orifice of the flow a~dit device should be used with a normal glass fiber filter in place without res~stance plates to audit flow regulated high-volume samplers,or other steps should be: taken to assure that flow patterns are not perturbed at the point of flow sensing. Each sampling Quarter,audit the lead analys~using glass fiber filter strips containing a known Quantity of lead.Audit samples are prepared by depositing a lead solution on 1.9 em by 20.3 cm (3/4 inch by 8 inch)unexposed gla$~fib~r filter strips and allowing to dry thoroughly.The audit samples must be pre~ared using reagents different from th05e used to calibrate the lead analytical equipment being dudited. Prepare audit samples in the f01lowing concentration ranges: Audit samples must be extracted using the sameextr~ction ~rocedure used for exposed filters. Analyze ·at l~ast one audit sanple in each of the two ranges each day that s&mples are analyzed.~The difference between the audit concentration '(in vg Pb/strip)and the analyst's measured concentration (in vg Pb/strip) are 'lsed to calculate analysis accuracy as described in seaticn 4.1.5.4, ~.....~'.~._'-.c."_:_..>.-; L f~ r: r r~ r~ [ t' [ [ C [ L t~ L. L L [ L X.=known concentration of the test gas used for the i-th precision 1 check. w~ere:Vi =analyzer's indicated concentration from the i-th precision check, during the period represen~ed by a glven preC1Slon chec~,the results of that precision check shali be excluded from the calculations. Calculate the percentage diff~rence (d i )for each precision clteck us~ng equation 1. ·, (1 ) y.-X. d,.='1 X 100X.1 F0r each instrument,calculate the quarterly average (d j ),equation 2,and the standard deviation (Sj)'equation 3. Where n is the number of precision checks on the instrument made during the sampling quarter.For example.n should be 6 or 7 if span checks are made biweekly during a quarter. Calculate the 95 percent ~':obabi1ity limits for precision using equations 4 and 5. [ [ [ f~ L L~ L [ [ L n "d-=lrd j n i=l i 1 (~d.)~ n i=l 1 J Upper 95 Percent Probabil ity Limit =aj +1.96 Sj lower 95 Percent t'''obability Limit =dj -1.96 Sj 34 (2) (3) (4) (5) [ [ [' L [ L 4.1.4.2 Single Anab:;er Accuracu -:::ach orga"ization.at the end of each sampl"ing quarter,shall calculat~and report the percenta1e difference for each audit concentration for each analyzer audited during the quarter. Directions for caTculationsare given below (direcLion~for reporting are given in section ';.1.6),. ""Calculate and report the percentage difference (d i )for each audit con~entration using equatio~1 where Yj is the analyzer's indicated concentration from the i-th audit checl and Xi is the known concentration of the audit gas "used from the i-th audit check. 4.1.5 Cclcl.<.Zations for ganual Methods 4.15.1 Single Instr~ent Precision for TSP and ?~-Estimates of precision for ambient air quality measurements from the TSP method are calculated from results obtained from the collocation of two samplers at one sampling" site as described in section 4.1.2.Z(a)for TSP and 4.1.2.3(b)for Pb. At the end of each sampling quarter.calculate and report a precision probability interval using weekly collocation sampler results.Directions for calculations are given below and directions for ~eporting are given in section 4.1.6. "For the paired measurements described in section 4.1.2.3(a}or 4.1.2.3(b}.calculate the percentage difference (d i ).using equation 1 where Y.is the TSP or Pb concentr~tion measured by the duplicate sampler and Xi is the TSP or Pb concentration measured by the sam~ler reporting air quality for the site.Calculate the quarterly e.verarJe percentage difference (d.).equ~ticn 2.standard deviation (s.).equation 3.and upper and lo\...~r 95 percent probability limits f0r ~recision (equations 6 and 7). Upper 95 Percent ?robability Limit =aj +1.96 Sj/~(6) Lower 95 Percent Probab~lity Limit =aj -1.96 Sj/;-Z--(7) 4.1.5.2 Single Inst.Pument Accuraey for TSP -Each organization.at the end of each sampling quarter.shall calculate and report the percentage difference for each high-volume sampler audited during the quarter~ Directions for ca1cuhtion;;are given be"low and directions for reporting are"given in seation 4.1.6. For the flow rate audit described in section 4.1.3.4,let X.repr~sent the known flow rate and Yi represent the indicated flo~rate. Calculate the percentage difference (d i )using equation 1." 4.1.5.3 Simle Instrument saJlino Aacuracl!for Pb -Each organization, at the end of each sampling quarter.shall calculate and report the percentage difference for each,high-volume lead sampler audited during the quarter.Directions for calculations are given in see~ion 4.1.5.2 and directions for r"eporting are g~ven in seation 4.t.6 35 L r- r L L L L t~ [ [ [ [ [ r~ l~ l~ l' r ~ L_c r ' L_" r IL_~ 1,.:.-_..~__-._..•..._..~..._.__._.. 4.1.5.4 Single-Analysis-Val!Accvyacy fo'!'Pb -Each organi zation,at the end of each sampling quarter,shall calculcte and report the percentage difference for each Pb analysis audit during the quar~er.Directions for calculations are given below a~d directions for reporting are given in section 4.1.6. For each analysis audit for Pb described in section 4.1.3.4{b},letx.represent the known value of the audit sample and Yi the indicatedv~lue of Pb.Calculate the percentage difference (d i )for each audit at each concentration level using equation 1. 4.1.6 O'!'ganization Repoptina R2-oui'!'ements At the end of each sampling quarter,the organization must report t~e following data assessment information·(a)for automated analyzers - precision p"robabil ity 1imits from section 4.1.4.1 and percentage differences from section 4.1.4.£,and (b)for manual methods -precision probability limits from sectio~4.1.5.1 a~d percentage differences from sections 4.1.5.2,4.1.5.3 and 4.1.5.4.The precision and accuracy information for the entire sampling quarter must be submitted with the air monitoring data.All data used to calculate reported estimates of precision and accuracy including span checks,collocated sampler and audit result~ must be made available to the permit granting authority upon request. 4.2 Quality Assu'!'ance fo'!'NoncT'itC':<>ia Ai'!'Pollutants At the present time,there are no EPA regulations on quality assurance for PSD monitoring of noncriteria air pollutants.The following are EPA recommendations for a minimum quality assurance progrJm for noncriteria pollutants. 4.2.1 Selection of Method Selection of the maasurementmethod for noncriteria air pollutants is extremely important.A list of acceptable measurementinethods for noncriteria air pollutants is available and may be obtained ~y writing: U.S.Environmental Protection Agency,Environmental Monitoring Systems Laboratory,Quality Assurance D~vision (MD-77),Research Triangle Pa~k, North Carolina 2771l.This list of acceptable methods will be revised at least annually and be available from the above address.Measurement methcds considered candidates for the noncriteria pollutant list should be brought to the attention of EPA at the address given above. 4.2.2 CaZibpation Calibration procedures d~scribed in the acceptable methods shoul~ be followed and a schedule for calibrations should be established.In addition,flow measurement devices used to measure sampling rate ~',hould be calibrated and a schedule established for recalibration.Calib~ation procedures for several flow measuremer:devices (rotameter,critical 36 r r [ [' [ L L L L orifice,mass flow meter,and wet test meter)are described in section 2.1.2 of reference 30.All calibration procedures should be written and maintained up-to-date by a document control -system.A uescription of one document control system that has been found to be fffective is discussed in section 1.4.1 of reference 29. 4.2.3 Data Validation Measurement data uf poor quality may be worse than no data at al1.--Therefore.the monitoring organization should establ ish cata val id3.tior: procedures and implement these procedures to invalidate data of questionable quality.Examples of data validation procedures for criteria pollut~nt< described in section 2.0.9 of reference 30 may be useful as a guide II. establishing data validation procedures for noncriteria pollutants, 4.2.4 Standard and SpZit Samples Where possible,standard samples containing the pollutant of interest should be analyzed periodically during the analysis vf collected samples.This practice is useful in helping to determine if the analytical system is in control.Splitting samples with another lcboratory is quite useful in dete~lining if there are unidentified biases in the analytical system.' 37 ~ r~ r: L L r~ L L [ [ [' [ L L L L [ [ L -~ :t. •__.~.__.,~._~~,_""_~_".~_""""_','_~..,.,.-'-:.~;'.•..•~.~,_~.•••:J-.;~--;.~c;:,:-./."'~..~_~..•••_.~.'T '·l.:'·:;.:,~,;i.~~4, :;~t ~ 5.,'.f2TEOROLOGICAL NONITORII1G .l 5.1 Data Requil'ed The preconstruction review of proposed majur emitting facilities will require the use of meteorological data.It is essential that such data.be representative of atmospheric dispersion conditions at the source and at locations where the source may have a significant impact on air quality.The representativeness of the data is dependent upon (a)the proxirr.ity of the meteorological monitoring site to the area under consideration,{b)the complexity of the topography of the area,·(c)the exposure of the meteorological sensors,and (d)the period of time during which the data are collected.More guidance for determiningo-representativeness is presented in reference 33. A data base representative of the site should consist of at least the following data: a.hourly aveiage wind speed and direction b.hourly average atmospheri,stability based on Pasquil1 stability category or wind fluctu·ations (OA)'or vertical temperature . gradi ent combi ned wi th wi ild speea . c •.hourly s:;rface tern!,E:t'ature at standard height for climatological comparisons and plume ri~e calculations d.ooIJr1y precipitation amoun~s for climatological comparisons. In addition.hourly average mixing heights may be necessary for the air quality impact analysis.In most cases..this may be limited to an extrapolation of twice-daily l'adiosonde measurements routinp.ly collected by the National Weather Service (NWS).Sections 5.2 a~~6.1 contain specific information onoinstruwent exposure and specifications. Requirements for additional inst~umentation and data will depend upon t~e ~vai1abi1ity of )nformatio~needed to assess the effects of pollutant emissions on Rmb~ent air quality.soils.vegetation,and visibility in the vicinity of the proposed source.The type,quantity. and format of the required meteorological data will also be influenced by the input reCUlrements of the dispersion modeling techniques used in the air quality analysis.Any app1ic~tion of dispersion MOdeling must be consistent witr.the EPA "C:ddeZinelon Ai!'Q'.J.,i2.ity !·1adds"[34J.The guideline makes sr-ecific ·rec.:ommendations concerning air quality models and data bases.It a1;;.o specifies those situations for ~/l1ict;r.;odels,data'and techniques other than those recommend~d tnerein.may be applied. 38 .........~ [ [' [ L -- Site-specific data are always preferable to data collected off-site. The availability of site-specific rr.e1:eorological data permits relatively I detailed meteorological analyses and subsequent im~rov!ment of dispersion model estimates.Off-site mete~rological data may be used in lieu of site-specific data only if it i~agreed by source owner and permit granting authority that the off-site data are reason~bly representative of atmospheric conditions in the area under consideration.The off-site meteorolo~~cal data can sometimes be derived from routine measure:nents by NWS stations. The data are available as individual observations and in sumnarized form from the National Climatic Center,Federal Building,Asheville,NC 28801. On the other hand,if the nearest source of off-site data is co~siderably removed from the area under consideration,and especially if there are significant terrain features,urban areas,or large bodies of water nearby,it may be necessary that the required meteorological data bp site-~peci fi c. In some case,it will be necessary that data be collected at more than one site in order to provide a reasonable representation of atmospheric conditions over th2entire area of concer-n.Atmospheric conditions may vary considerably over the area.In some case,(e.g., complex terrain)it will not be feasible to adequately monitor the entire meteorolo~ical field of concern.Then the orly recourse is to site the stations in areas where characteristic and signficant airflow patterns are likely to be encountertd.In any event,one of the meteorological st"tioils should be located so that it repres(2nts atmospheric ccnditiom:in the imnediate vicinity of the source. Although at least 1 year of meteoiological data should be ~vailable, a shorter period of record that conforms to the air quality monitoring period of record discussed in section 2.6 is acceptable when appro~ed I;y the permit granting authority.If more than 1 year of data is available,it is recommended that such data be included in the analysis. Such a multiyear data base allows for more comprehensive considerat~on of variations i~meteorological conditions that occur from year to year.A 5-year period of record wiTl usually yield an adequate meteorological data base for considering such year-to-year variations. In all cases,the meteorological data used must be of a~least theqtla:ity of data collected by the National Weat~er Service.-Desired features of instrumentation for collecting met~orological data are discussed in section 6.1. 5.2 Exposu'l'e of l-feteo'l'oZo,:;icaZ Il1st'Y"vl.'1i€nts Measvrements of mos t meteorologi ca 1 parameters are affected by the exposure of the sensor.To obtain ~omparable observations at different sites,the exposures must be similar.Also,the exposure should be ~uch that the measured parameters provide a good representation of pollutant transport and dispersion within the area that the monitoring site ~s supposed to represent.For example,if wind flow data over a fairly broad area are desired,the wind sensors should be away from the immediate influence of trees,buildings,steep slopes,ridges,cliffs,or hollows. .39 , J, .~ L [. L [ [ [ [ L L L L L [ l -- The standard exposure of wind instruments over level open terrain is 10 meters above the ground.Open ~errain is defined as an area where the distance between the ~nemometer and any obstruction to the wind flow is at least five times the height of the obstruction.Where a standard exposure:is unobtainable at this height.the anemometer should be installed at such a height that its indications are reasonably unaffected by local obstructions and represent as closely as possible what the wind at 10 meters would be in the absence of the obstructions.Det~iled guidance on assessing adverse aerodynamic effects dUE to local ob~tructions is contained in reference 35.In locating winn sensors in rough terrain or volley situations.it will be necessary to determine if local effects such as channeling,slope and valley winds,etc.,are important,or whether the flow outside those zones of ir.fluence is to be measured.If the analysis concerns emissions from a tall stack,it may be desirable to avoid the local influences.On the other hand,if pollution from low-level sources is the main concern,the local influences may be important.. If the source emission point is substantially above the standard 10-meter level for wind measurements,additional wind m~asurements at the height of the emi·ssion point and at plume height are desirab1e. Such measurements are used to determine the wind regime in which the effluent plume is transported a~~a'y frolT.the source.(The wind speed and direction 50 to 100 meters or more above the surface rre often considerably different than at the lO-meter level.)An instrumented tower is the most common means of obtaining meteorological measurements at several el~vations in the lower part of the atmospheric boundary layer.For ~ind instruments mounted on the side of a tower,pr~cautions must be taken to ensure that the wind nlp.a~;Jremnts are not unduly influenced by the tower.Turbulence in the immedi~te wake of a tower (even a lattice- type tower)can be severe.Thus,depending on the supporting structure, \dnd measunng equipment should be mounted (e.g.,on booms)at least two structure widths away from the structure,.and two systems mounted on opposite sides of the structure will sometimes be necessary_A wind instrument mounted on top of a tow~r should be mounted at least one tower width above the top.If there is no alternative t.o mounting instruments on a stack,the increased turbulence problem [36 J,must be explicitly resolved to the satisfaction of the permit granting authority_ Atmospheric stability is another key factor in pollutant dispersion downwind of a source.The stability category is a function of static stability (related to temperature change with height),convective turbulence (caused by heating of the air at ground level),and mechanical tU\'bu1ence (a function of wind speed and surface roughness).A procedure for estimating stability category is given by Turner l37]which requires information on solar elevation angle,cloud cover.ceiling height,and wind speed.The hourly observations at NvlS stations include cloud cover,ceiling height,and wind speed.Alternative procedures for estima~ing stability categm-y may be applied if representative data are available.For example,stability categor.x estimates may be based upon horizontal wind direction fluctuations 138J,or vertical gradients of 40 .......".~-,.'. L L [ [ f - L [ [- t~ L L l l l '. te~p~rature and wind speed [39J ',u u~tain a representative reading of the air temperatl!""~.~;!E'te;;;perature sensor should be protected fr0m thp~::1 r'~'J:,:"",j0n from the sun,sky,cul'Lh.and a.1y:'..jf'rounding objects. dna must be ede'Juatel v vcn1.iiated,r:.;;pirated radiatio':shields are designerl rc jiuvide such protecticn.(Note thdt ambient te~perature uat:a·are also cOffir!!only r€ouired [01'plume rise estimates used in dispersion model calCulations.).. Mixing height is another para:npt~r that can be important in some cases.Mixi~~height i~tne dietance above the ground to which relatively free vertical mixing occurs in the ~tmosphere.For estimating long-ternl average concentrations.it is adequ~te to use a representative annual average mixing height [40).However.in many cases.~nd especially for estimates of short-tem concentrations,twice-daily or hourly mixing height dat~are ne~essary.Such data can sometimes b~derived [40]from represent.~'ve surface temperatures and twice-daily upper air soundings collected .y selected NWS stations. Precipitation collectors must be located so that obstructions do not prevent the precipitation from fall~ng into the collector opening or force precipitation into the opening.Several collectors may be required for adequate spatial resolution in complex topographic regimes. Visibility systems must be located to provide representative measurements not only prior to construction of the facility.but also for facility operational periods.Assessment of visibility impact is currently under study b.v EPA and other Federal agencies.Visibility definiti0ns.monitoring methods.modeling ronsid~rations and imoactassessment approaches are among the sllbjects'of a repc;.rt entitled,"n-otecting Visibi7.ity:An E?A Repol't to Congl'ecs"[41].*Since final visibil ity regulations have not l,een promulgated.only interim mor.itoring guidance for visibility is available at this time. 'Additional il)formation and guidanceon'siting and exposure oJ meteorological instruments is contained in reference 42. *In ·connection with EPJ\'s rroposed visibil:ty regulations,the Ag€:ncy published three draft rlocuments in July 1980.for public review and cOrmJent that are pertinent to the PSD Monitoring Guideline.The first is "Interim Guidance for'Visibility Monitoring."and its contents are arranged in similar fashion,though withou:as much detail as the PSD Nomtoring Guideline.The other documents :Ire:"Workbook for Est1mating Visibility lmpariment"and "Us~r's Manual for the Plume Visibility Model (PLUVJE)."These draft documents are available from th~Office of Air Quality Planning and Standards.CPDO (r~D-15J Research Triangle Park.NC 27711.The documents l\Iill be published in final form \'/herl the '1isibiiity regulations are promulgated. 41 l·.· 7••.'-.. .~.' j ~It r ::::=- r '" (~ r f' I, r t [ [' [ [ [ [' L L L L [ l 6.METEOROLOGlc..4.L INSTRUl·fENTATION 6.1 Sp€cifiaa~ions Meteorological instrumentation used for PSD monitoring must yield reasonably accurate and precise data.Accuracies and allowable errors are expressed ill this section as absolute values for digital systems; errors in analog systems may be 5~percent greatet.For example,an allowable error expressed as 5 percent means the recorded value should be within ±5percent of the true value for digital systems,and ±7.5 percent for analog systems.Records should be doted,and should be accurate to within 10 minutes.Wind speed and direction (or vector components).should be recorded continuously on strip recorders at intervals not to exceed 60 seconds for a given variable;digital re:orders 'may be t/:>ed as backup.These specifications apply to t'lP. meteorological in::;truments used to gather the site sj)ecific data that will accompany a PSD p~""lit application.When the use of existing representative meteor'oJogical data is approved by the permit granting authC'rity,the instrumentation should meet,as a .mi-nimullJ,NwS star.dards[43,44]. 6.1.1 Wind Spcteme (hC'r>izonta l !.JindJ Wind direction and wind speed systems should exhibit a star.ting threshold of less than 0.5 meter per second (m/s)wind speed (at 10 degrees deflection for direction va,les).Wind speed systems should be accurate above the starting threshold to .;ithin 0.25 m/s at speeds eq::al to or less than 5 m/s.At higher speeds,the erro~~hould not exceed 5 . percent of the observed speed (maximum error not to exceed 2.5 m/s).The damp~ng ratio of the wind vane should b~between 0.4 and 0.65 and the distcnce constant should not exceed 5 m.Wind direction system errors should not exceed 3 degrees from true lO-min or greater 1verages,incl~ding sensor orientation errors.Wind vane orientation procedures should be docUll".er,ted. 6.1.2 find Systems (ver>ti.eaZ l..lindJ In complex terrain,downwash of plumes due to significant terra~n relief ~ay pose a problem.If such a prob1~m potentially exists,it may be necess3ry to measure the vertical component of the wind at the proposed site,and as close as ~ossible to staCK height.The starting threshold for the vprtica1 wind speed component should be less than 0.25 m/s.Required accuracy for the vertical wind speed component is as specified in section 6.1.1 for horizontal speeds.. 6.1.J Wind Fluctuations Determination of the on-site standard deviation of wind fluctuations, or derived standard deviations of cross-plume concentrations may be necessary if dispersion paraITleters are being developed for use at 2.specific site.Since the analytical framework \'iithin which such wind f1uctuation measurements/ statistics are to b.e incorporated is expected to be unique Clr applied on a case-by-c2se basis,appro/al by th€"perml ~granting authority'is required .1? ,, :':-"'=" ~ and no general requirements regarding specifications are outlined in this guideline.Considerable care is required in the selection of wind instruments and data logging systems,especially in the choice of sampling and averaging times.Thus,response characteristics of ~ind sensors are especially critical [45,46 J.O\·;ners or operators designing progranls incorpol-ating these capabilitias should submit a statement from a qualified consultant identHying the adequacy of such wind system(s)within the context of the overall PSD ambient monitoring program. r r r c [ f' 1_ I- L~ 6.1.4 VertiaaZ Temperatul'e Differenae E.rrors in measur'ed temperature difference should not exceed 0.003 °C/m. 6.1.5 Temperc:ture Errors in temperatures sh~uld not exceed a.5°C if fog formation, 1c1ng,etc.,due to water spray or water vapor emitted from the facility may be a problem.Otherwise,errors should not exceed 1.O°C. 6.1.6 :JumiditlJ Atmospheric humidity can be measured and expressed in seve;a1 ways. If the permi~granting authority determines that ~significant potential exists for fog formation,icing,etc.,due to effluents from th~proposed facility,error in the selected measurement technique shcu~d not exceed an equivalent dewpoint temperature error of 0.5°C.Otherwise,erro:-s ;n equivalent dewpoint temperature should not exceed 1.5c C over a dewpoint range of -30°C to +20°C. 6.1.7 Radiation -'3oZar and Te!Testr>iaZ . The determination of Pasquill stability class may be based on whether the solar radiation is termed strong,moderate,or slight.,Stability class can be deterl"1ined from sun elevation and the presence,hei9ht,and amount of clouds [37],or by using a pyranometer and/or net l'adiometer.. during the daytime and a net radiorr.eter at night..Suet]radiation-to-stability relationships are expected to be site-specific,and the responsibil~ty for demonstrating their accuracy lies with the permit applicant.General accuracy for pyranometersand net radiometers used in a PSD monitoring network is expected to be ±5 percent. 6.1.8 Mixing Height Mixing height data may be derived fr'om NWS upper air data.If, available data are determined to be inappropriate by the pemit gnntln9 authority,such data may be obtained on-site by the permit applicant[47J. The instrument system to be used is not spe~ified in this guideline,but its precision and resolution should not exceed t~e limits associated with NWS ra::\"iosor.de systems [4.3,44]. •>.~t.~ "] l 1 [ L 43 r r r [ L [ [ [ r: L L f L L L •"-"-'•.•__.'._"••~,.~.~-".•y ••"•.•,.....•••••••~.,.'..,"..:.••••_._.-'-••••..•'- 6.1.9 ~:itation .A recording precipitation co11eGtor should have a resolution of 0.25 mm (0.01 inches)liquid precipitation per hour at precipitation rates up to 7.6 cm/hour.Accuracysbould be within 10 ~ercent of the recorded value.A heated system should be used to assu~e proper measurement of frozen prt::!cipitation ..A suitable windscreen should be used. 6.1.10 VisibiZitv Vislbility can be measured within 5 percent cf true over visu..~ ranges of about 80 meters to j km with available transmisso~eters. Estimates can be based upon .;ery short path lengths using other types of equipment such asnephelometers l48].At this time,the combined use of a multi-wavelength teleph6tometer,integregrating nephelometer and particulate monitor,together with color photography,should prove most helpful in documenting baseline v'js;::>i1ity related parameters.These components of a visibility monitoring program are discussed in the draft document "Interim Guidance for Visibility t·10nitoring,"referred to previou'slyat the end of section 5.2 of this guidenne.Reference 41 also contains much background informatior.. ". 4 .. .~. .'7 L f' I" ~._-...."'_.,.",,_.,._...........,-.',•.,....,.,...",.""'"-K.;.....~-~_;.'~.l!'"'"'....;..__...-"'-_.._..~......-.••_,_.._~._.__...._.......~c __~_••.~_••_~~•••_,__I~.~••••_.¥._..." t,f ?QUALITY J..SSURAtl::E FOR METEOROWGIC:iL ;;;''1'.4 All equip~ent should r.eceive an appropiiate examination and calibration pl"ior to initial instailaticiiI to assure the acquisition of the maximlA;n amount of usable data within the ~rror limits specified herein.Inspection. servicing.and calibration of cc;uilJment must be scheduled throughout the measurement program at appropriate intervals tQ assure at least 90 pzrcent data retrieval for each variable measured at sites where continuous air quality monitors are being operated.At remote sites.data retrieval· for measured .ariables should not fall below 80 percent.In addition. the joint frequency for the recove~y of wind and stability data should not fall below 90 percent on an annual basis;missing dota period~must not show marked correlation with the various meteorological cycles. Cclibration of systems 5hould be accomplished no less frequently than once every 6 months.In corrosive or dusty area;;,the interval should be reduced to assure adequate and valid data acquisition. If satisfactory calibration of a measuring system can be provided only by the manufacturer or in special lajoratories.such as wind-tunnel facilities,arrangements should be made for such calibrations prior to acquisition of the equipment.A parts inventory should be maintained at a readily accessible location to minimize delays in restoring operations after system failures. An independent meteorological audit (by other than one who cond:Jcts th~routine calibration and operation of the network)should ~e performed to provide an on-site calibration of instruments as well as an evaluation of (a)the net#ork inst~llation.(b)inspection.maintenance.an:calibration procedures.and logging thereof.(c)data reduction procedures.including spot checking of data.and (d)data logging and tabulation procedures. The on-site visit (requiring as little dS 1 day in many cases)should be made within 60 days after the network is first in full operation t and a written audit/evaluation should be provided to the o·wner.This report. should be retain~d by the owner.Any problems should be corrected and duly noted as to action taken in an addendum to the audit report.A reproducible copy of the audit report and the addendum should be furnished with the . source co~struction permit application. Such independent meteorological audit-evaluations should be performed about each 6 months.The last such inspection should be made no more than 30 days prior to the t~rmination of the measurem:nt program.and while the measurement operation is in progress. L L [' L 45 8.DATAREPORTIllG ! 8.1 Air Qualitv Data Reporting A summary of the air quality data,the raw air quality data,and the quality assurance data discussed in section 4.1.6 mt1st be submitted to the permit granting authority at the time of submittal of the PSD appl ication ..There should be a prior agreement between the source and the permit granting authority as to whether the raw data should be submitted in addition to a summary of the data.Some sources may a'so desire to submit data periodically to the permit granting authority for review to identify any problems in the data as they occur.Note that this is not a requirement.The applicant and the permit gr~nting authority should have a prior agreement as to th~format And procedure for the data submission.The air quality data should preferably be submitted in SA~OAD format and in.a machine readable form.A printout 0-:=the contents of the tape or cards should also be included.All raw data not previously . submitted (Le.,qir quality data calibration data,·fIO\·)rates,etc.)should be re.tained for 3 .years and submitted upon rec;uest to the permit granting authority. For continuous analyzers,at least 80 percent of the individua: hourly values should be reported by the source in ar.y sampling period. For manual Llethods(TSP and parti cul cite po 11 utants),80 percent of the individual 24-hour valves should be reportea in any sampling period. This capture rate is iMportant because of '!:he !>hort duration of a PSD monitoring program.1n addition,there should not be a correlation between missing d~ta periods and expected highest co~centrations. 8.2 MeteoroloflicaZ Data Format and Revorting Because of the different duta requirements for different types of analyse~that might be used to evaluate various facilities,there is no fixed forma~that applies to all data sets.However,a generalizati~n can be'made:all meteorolosical parameters filUSt be collated in chronological order and tabulated 'according to the observation time,and be fumished to the permit grantin£authority upon request.All meteorological variabies that have a SAROAD parameter code should be submittea in SAROAD·for,nat.All units shou~d be in the SI system (International System of Unit~)[49].All input data (in the formJt required by the dnalytical proceGures selected)used in,and all results of,the air quality analyses ;nust bl:furrdshed to the permit gl~anting authority upon request.. 46 i .'~ APPENDIX A PROCEDURES TO DETERMINE IF MONITORING DATA WILL BE REQUIRED FOR A PSD APPLICAfION r ' I L 1.IllTI?ODUCTIOiV This appendix has been included in this guideline to aid both the reviewing authorities and the source applicants in determining if monitoring data will or will not be required under PSD.The major cons~derations leading to a monitoring data decision have been simplified for presentation in this appendix.This discussion represents the Federal req~irements and the minimum State program requirements.It-is important to identify the reviewing authority,whether it be the local or State air pollution contr·ol agency,or the Regional Office of EPA for the final requirements.- For a complete discussion on the complex PSD issues.the reader is referred to the PSD regulations and the preamble discussion [5J. 2.PSD PERMIT APPLICATION PROCEDURES Figure A-l shows a simplified organizational overview of the pr0cedures to be followed in the preparation of a PSD permit application.Figure A-l shows that these procedures are divided into seven parts.This division is only for illustrative purposes within this appendix and is intended only to separate the complex procedures into distinct subparts. Within the Part l-Source Applicability Determination.both candidate new and modified major sources are reviewed to see if PSD review will apply. The Part 2-Pollutant Applicability Determination shows those pollutants emitted from subject sources that mayor may not be exempted fro~further analysis.The Part 3-BACT Analysis is to ensure the application of best available control technology (BACT)on subject pollutants.Air quality analysis covered in Part 4 includes both modelir.g and monitoring data considerations for certain BACT pollutants.The Part 5-Source Impact Analysis is to demonstrate that the ~roposed emissions woulo not cause- or contribute to a violation of any NAAQS or PSD increment.The Par~6- Additional Impact Analysis is to ensure that the proposed emissions increases would not impair visibility,or ~mpact on soils and veget~tion. Finally,Part 7 represents the complete PSD application which transfers to the permit granting authority the results of all the analysis from the first six parts.Normally,the source applicant will supply all the information including th~BACT and air quality analyses to make the necessary determinations.Each of these seven part::is discussed below in sections 2.1-2.7.Section 3 contains flow diagrams and discussion of the first four parts that pertain to the decision whether mOi.it0ring data will or will not be req~ired. 2.1 Papt 1 -Soup~e AooZicabiZity DetePmination The first step in the PSD program is to determine if a proposed new or modified source is subje:ct to the PSD regulations.The first test for PSD applicability is that the pro~osed construction must involve a major stationary source.Thus,the candida~e construction must either be a proDosed new major stationary source or involve the modification of an existing major stationary source.The criteria in cetermining whether A-l r'L Part 1 -Source Applicability Determination ,~ Part 2 -Pollutant Applicability Determination ~ I_Part 3 -BACT Analysis t ~ Part 4 -Ambient Air Quality Analysis ,~ Part 5 ..Source -Impact Analysis I .~ Part 6 -Additional Impact Analysis I ~ . [Part 7 -Complete -PSD Application J I 1 Figure A·'.Simplified procedures for the preparation of a PSD permit appiication. A-: --~--, __.0.._._0_'O'_.__~ 1 oJ r r [ [ [ r ~ L L~ L [ [ L the affected source 1S sufficiently large (in terms of ew,issions)to be a new major stationary source or major modification is based on consideration of its potential to emit at rates exceeding certain thresho~d values. Potential to emit is the capability at maximum design capacity t~emit a poll~tant after t~e application of all required a:r pJllution control equ'ipment,taking into account all federally E"rlfurce,'.ble requirements restricting the type or amount of source operation.A major modification is generally a physic3l change in or a change in the method of operation of a major stationary source which would resu1t in a significant net e~issions increase for any regulated pollutant.(There are several changes that are exempted from being considered a major modification.) Also.the proposed source or modification rnust locate in a PSD area--an area designated as "attainment"or "unclassifiable."If the proposed source or modificatio~would meet certain tests and commence construction in a continunus fashion at the proposed site within a reasonable time,a PSD permit under the August 7,1980 regulations would not be necessary. Lastly.there·are specific new sources and modifications that are exempted from PSD review.All of the above considerations are explained in more detail in seation 3 of this appendix. If it is determined that a new SOUI'ce or modification is subject to th~PSD regulations,then one must proceed to the Part 2-Pollutant Applicability Determination in order to learn how the pollutant-specific requirements of PSD may apply. 2.2 PaPt 2 -PolZutant A~pZiaability Dete~i7~tion If a source applicant has dete~mined·that a proposed new source or modification would be subject to the PSD require~ents,then the applicant must assess whether the pollutants the project would emit are subject to PSD.If a new ~~jor stationary source emits pollutants for which the area it locates in is desiQnated nonattainment.then the source is exempt from PSD review for-those pollutants.These sources mu~t,. however,meet the a~plicable requirements of new source review (NSP.)for each nonattainment pollutant.If a major c~nstruction proposed for a PSD area involves only changes for nonattainl:~nt pollutants,then the source is not subject to PSD.These sources n...!st meet the "ppropriate nonattainment ~SR under the SIP for the pollutant.Once the question of NSR jurisdiction is resolved,then the PSD review applies to significant emissions increases of regulated air pollutants. Specific nUlr.€rical cutoffs which define what emissions increases are "s ignificantll are shown in Table A-I.These emissiu ......rates will be used for pol1utant~to be emitted from a ?SD source unless the new source or mod~fication ~s to be located within 10 km of a Class I area [1].For these situations.the proposed source or modification must bp. prepared to demonstrate that it would not have a~ignificant impact with respect to a Class I area.A Class I significant impact is defined as . one microgr~m per cubic meter (~g/m3)or more for a 24-hour average. Further details on how the significant emission rates in Table A-l were derived may be found in the prea~b1e discussion of the PSD regulations [5]. If the emissions from a new source will be significant,or if the net emissions increase from a proposed modification will be significant, then one must proceed to the Part 3-BACT Analysis for these pOllutants. A-3 Pullutant Emissions Rate (tons/year) .- Carbon monoxide 100 Nitrogen oxides 40 Sulfur dioxide 40 To"tal suspended particulates 25 Ozone (volatile organic compounds)40 Lead 0.6 Asbestos 0.007 Beryl 1ium 0.0004 Mercury 0.1 .. Vinyl chloride 1.0 rFluorides3 Sulfuric acid mist 7 Total reduced sulfur (including H25)10 Reduced sulfur (including H2S)10 Hydl"ogen sulfide 10 ~ ~ I' l~ L L [ [~ [ [ [ [ r: L L L L [ L TABLE A-1.SIGNIFICANT EMISSIONS RP.TES A-4 .j 1 ~ ; ,1 5 .J r [ [ L L L L ;I i,1· ;';:;-.,;.:::::;..;.',:'~~·~'.c;.·:;',_·.~,'J'·•.~·~'$.,~t"·-:'···"'·..;':~I··~~·')"l!"_~;~'t,.,_-,:.".•-.",._.",;~;.,.•,";,","".,;'"~.--i..,'Y.,:,;,._.;;..;...v"'.,.:"-.."'.,._.~_-...••:_.~_~_._;_",....•..-~_,_--..._____.~._.•__..._._ 2.;)Pert:3 -hAC':'Ar-:.c.lysis Arty major stationary source 'or major modification subject to PSD must conduct an analysis to ensure application of be~t available control technology (BACT)for all applicable pollutants.O~ring each analysis, which will be done on a case-by-:a~e basis,the reviewing authority will evaluate the energy,environmentr'econo:nic,ar.d other costs associated with .each a1ternative technology.The reviewing authority will then specify an emissions limitation for the source that reflects the maximum degree of red~ction achievable with all these concerns in mind for each pollutant regulated under the Act.In no event can an emission limitation be requirea·wri'lrtli·~,"b'e less stringent than any applicable standard of perform~nce under 40 CFR Parts 60 and 61. After the BACT determination,the ~o~rce must then investigate the need for each pol1utant subject to BACT (BACT pollutant)to also undergo the remaining analyses Tor this pollutant. 2.4 Part 4 -Ambient Air ~lality Analusis Each application by a FSO source or modification must contain an air quality analysis for each BACT ~olluta~t to demonstrate that its new pollutart emissions w0 1J1d not violate either the applicable NAAQS or the applica~le PSD increment.Thi~analysis ensures that the existing air quality is better than that reauired by national standards and that baseline air quality is not degraded beyond the applicabie PSD increment. Two nar,'ow eXe'J1ptions to this requirement are specified in the regulations and involve ce~tair.existing sources with low BACT emissions and sources of temporarj emissions meeting certain criteria. In making the.above d'?terminations,mallY PSO sources must first assess the existing air quanty for each a::>plicab1e air pollutant that it emits in the affected urea.The requirement to monitor existing air qual it,Y r.la11:'r.ot a;::?ly to (a)~oi~li:ai1~s for-t'lhic:h ~h~ne~1 source 0:"modific.atior.~JOuid cal!se im;>act:i less than tl1~si~nifica;it monitoring concentrations (Table A-2).or (b).situations where the background conc£nfra ti on of the pollutant is below the si gnHi cant monitoring values.This exe:nption should not be used when there is an apparent threat to'an ap~licable PSO increment or NAAQS based on modeling alone or w~en there is a question of adverse impact on a Clas~I area. When monitoring data are required,the '!pplicant must provide ambient mOiltioring data that repi'"esent air qua1ay levels in the year's period preceding the PSD appiication.Where existinq data are not judged representative or adequate,then the 'app1icant must conduct its own monitoring program.Typical1Y,lmonitoring data are use~by applicants to support or extcn~the assess~ent made with air quality dispersion modeling.. , In addition to the above discussion,EPA in general intencs to limit the application of air quality models to a downwind distance of 50 kilometc.·s.This is because dispersion parameters commonly in use are based on ex~eriments relatively close to sources,and extp.nding t~ese parameters to long downwind distances results in great uncertainty as to accuracy'of the model estimates at such distances.EPA does not intend to analyze the impact of a SOUfce beyond the point where the concentrations from the source fall below certain levels (generally ·b~sed on Class I A-5 ., ':~ j .j j ;,, ! ~ TABI.E A-2.SIGNIFICANT MONITORING CONCENTRATIONS a No specific air quality concentration for ozone is prescribed.Fxemptions are granted when a source's VOCemissions are <100 tons/year. 575 (a-hour) 14 (24-hour) 13 (24-hour) 10 (24-hour) a 0.1 .(24-hour) b 0.0005 (24-hour) 0.25 (24-hour) 15 (24-hour) 0.25 (24-hour) b c c 0.04 (i-hour) A-6 Asbestos Lead Total reduced sulfur (including H2S)! Reduced sulfur (including H2S) ~lydrogen ::ulfide Sulfuric acid mist Fluoricies Air Quality Concentra ti on (;.:g/m3 ~I Pollutant and Averaging Time Beryll ium Carbon monoxide Nitrogen dioxide Sulfur dioxide Total suspended particulates Ozone f-1ercury Vinyl chloride bNo acceptable monitoring techniques available at this time.Thcr~fore, monitoring is not required until acceptable techniques i'ire available. c NO acceptable monitoring techniques available at this time.However, techniques are expected to be aV;l~:"L·le shortly. [ r r~ r~ L f < r L [ r f- l' [ L ~ [~ I: L [~ ~ f~ [' [ C L l- 1- [ L L 1- L ~ r - I L increments)shown in Table A-3.However,since the 1977 ~lean Air Act ~nendments provide s~ecial concern for Class !areas,any reasonably expected impacts for these areas must be considered it'respective of the 50 km limitation on the above significant values.* 2.5 Papt 5 -Sov~ce Imvact AnaZpsis The proposp.d source or modification mllst demonstrate that significant net emissions increases (inclucing secondary emissions and fugitive emissions),would not cause or contribute to ai~pollution in the violation of any NAAQS or any applicable maximum allowa~le increase over the baseline copcentration in any area. 2.6 Papt e -Additior~Z Impact AnaZ~sis An applicant is also required to analyze whether its_proposed emissions increases would impair visibility,or impact on soils or vegetation.Not only must the applicant loor.at the d~re~t effect of sourc~emissions on these resources,but it also must consider the impacts from general :ommercial,residential,industrial and other growth associated with the proposed source or mo~ification. 2.7 P~pt 7 -File Co:rlete PSD ApvZication After completion of the preceeding ana~yses,the source may submit a PSD application to the permit granting authority.Top.application, after being judged complete and being reviewed for propt:!r determination of applicability,BACT,and air qUnlity impacts,must undergo adequate public participation.The regulations solicit and encourage participation by the general public,industry,and other affected persons impacted by the proposed maJor stationary source or major modification.Specific public notice requirements,including a oublic comment period and the opportunity for a publ ic heal'ing must be met befol'e the rSD review agency takes final action on a PSD application.The public notice must indicate \'{hethel'the reviewing authority has proposed approval,denial, or conditional approval of the proposed major 50urce or major modific~tion. Consideration is given to all comments received prOVided they are relevant to the scope of the review. The source shall also submit all information necessary to perform any analysis in Parts 1-6 above or mar.e any determinations reqUired in Parts 1-6.Such information shall include (a)a description of the nature.location,design capacity,and typical operating schedule of the *It should be noted that there are three seoarate and distinct sets of values which are considered "significant"wi~hin the PSD program: (a)Sigr.ificant emissions rates; (b)Significant monitoring concentrations;and (c)Significant ambient impacts (including the specific significant Class I area impacts). As point:d out,each set of values r.as a different application,and therefore.this guideline has been worded to clarify the appropriate values to be used while assessing the need to collect monitoring data. A-7 AVERAGIi~G TIME Pollutant Annual 24-Hou r I 8-Hour 3-Hour 1 Hour 5°2 1 ]Jg/m 3 5 ]Jg/m 3 --25 ~g/m3 -- ! T5P 1 ]J g/m 3 5 ]Jg/m 3 I ------ N0 2 1 ]Jg/m 3 -------- I ·co ----I0.5 '9/m3 --2 ]Jg/m 3 L ,I,-- L ~ L [ L L r~ 1" C [ L L f ~ L L f', L L L NOTE: I i I TABLE A-3.,SIGNIFICANT AMBIENT AIR QUALITY IMPACTS This table does not apply to Class I areas.A significant impact for Class I areas is 1 ]Jg/m 3 on a 24-hour basis for TS?and 502. A-a L L L L [- L proposed source or modification,including specifications and drawings showing its design and plant layout,(b)a detailer schedule for construction of the propo$ed source or modification.and (c)a detailed description as to what system of 'continuous emission reduction is p~anned for the proposed source Ctr modification.emission Estimates,ar,d a:1Y other informdtion necessary to determine that best available control technology would be applied.The proposed source or modi~ication shall also provide information on (a)the air quality impact of :t'.e proposed source or modification,including meteorological and topographical data necessary to estimate such impact,and (b)the air quality impacts,and the nature and extent of any or all general commercial,residential,industrial, and other growth which has occurred since August 7,1977 in any area the proposed source or modification would affect. 3.DECISIONS POR MONITORING DI.TA REQUIREMENTS Figure A-l and the discussion that followed in section 2 provided an overview of the various activities relating to a PSD permit application. This section will go into more detai1 on those activities that n~ed to be considered in deciding if air quality monitoring data will be required. It should be noted that the procedures described in this appe~dix do not include any detr.ils on how the modeling analyses are to be conducted but on-ly indicate at what points (boxes)th~results of such analyses are necessary.Also,while these pY-ocedures lead to a determination of when air quality monitoring is likely to be required,they do .not lead to a decision as to when meteorologica1 monitoring is necessary (for model input).Guidance on the requir~ments and procedures for_conducting modeling analyses is contained in r~ference 34.S~ction 5 of this guideline describes general meteor~lDgical ~onitoring reqUirements,and reference 50 also provides further guidance on this subject. Figures A-2 and A-3 show ~arious steps that must be made fora proDosed PSO source at'modificetion in:order to assess how the monitoring data requirement might apply.The decisions in these flow diagrams must be applied separately for eac~~agulated pollutant that would be emitted from a proposed source or modification.Boxes 1-14 apply to Figure A-2 ar.J boxes 15-29 apply to Figure A~3 .B::;;;1.Is proposed source a mcr!oi.·st:ztiona':'"'d SOVT'Ci:?OT'majoT'modification-, Zocatir~in a PEn dPca? A major stationary source is defined as any one of 28 source categories (Table A-4)which emits,or has the potential to emit,100 tons per year or more of any pollutant regulated under the Act.In addition,the definition includes any other stationary source I'/hich emits,or has the potential to emit,250 tons per year or more of any regulated pollutant. Finally,major stationary SOUl'ce <.1lso means any physi~a1 change occurring A-9 .,., ','.' ..1- r ;~. .. " r .~ Parr 2 ~ Pollutant "'pPi<~bilI!>' Del~rmtn.ahon P~r1 1 • Saureo'Applic~bH:h DelermintllJon l YES 6.CLi"I ~'e~ ""....ning p,oeedu,.. I r-_---'---, j Morp refined modpl I (opbon~l~'ote;,~.,. requirp g~lhenn~of I ....._':~~~~:':ic.1 d~l •. 8.\\~!the propo.ed source or mocfiikation impact on a Cl.!••I ~rea? !I.° h prop"",d ","urce '\ns or modii"~lion ...ithi.,~~;,:_-::_.-,"~., 10 l..m of ~Cl.!~.I ~,ea! ''0 1.l~propo~"ll sourep a.m"jol st.ltio~r'\WUfCf'Or d major mQdnic~tion ioc.at;nK in ~PSO ~(e~: 9.Art"nt'\.'~mi~~io"!-or net em;.,c,;ons incrt'.~-of the re~ulJled pollutiln:?labi<>....1'. !l.0 10.'0 fUrlhe'.n.h·,j, lor thaI poliulanl ~. .-----..--.---------..-.-,.--...-.-...-.--..--..------..----.-.--..-..J 3.••••••••••_._.__••__•__._.__••_••__•••_ l I I I I j I'propo.ed con.I-"c"Jon a I" i---rplo'~tion 01 •pOrl~ble I I tdcilih "i~h p,(!\iou\ve rmitr I 12."'re Ihp,e p:lpnt~1 impaeb ""\YES I I cm ~CIJ ..1 .'e•.or ~rp..'/~I ..__...._..._~._._~~:::~.=~--j--1-.1 __..__...1_.__ ~1""'1 Par.3·n 1~.Appl'B...CT..J £lACl Aruh~.---_._---_._------_._.-_.__.__._-----__..__._-._.-.-._.,..__.._---.-_-_._.._-.._-_.___.-._-_._-- L [ (" L L_10 Figure A·2.Procedures used to determine th'l monitoring data requirement. L [ •rroeedu'e~are to be ,ppt-aled for ~II 'PguLued pollu!an"",hieh ...ould be emitlpd b'Ihe p,o;>o.ed conSlruetion. P~rt ~-Ambienl Air Quali!>'"'''''h-.i5 Par.5 •S<,urep Impael A".I,'" Part t .Addiuo",,1 Imp~cl Arul,"", P~rt ;•Compl"le PSO ApplOcation 'I •.1...·1~.~ .J i fIGlJRIII·J.PROCEDL:lUS lSID 1'0 O£l!R\Il'!TH!\lO'iITORl'oG O"rA R!QllRE\I!'T. H5 YES h.thf're .In "PP"""ftl rnrut to Ih~PSO ;ncf"('m~nl\0:'';~Q~. 01 is.fhf'f"f'•potf'nriIJ .c"f"f'W im,.....C1 .)ft ~aUto I "'f~.r 22 h the e"ning iir qv.lity.<hb~A·21 btim"ll'_qu.1i~·imp.l(ti 01 pro~cOrt!truction. •L:w Kle'e'ning procedu,r or mOte'r~ine-d mod~i •Ute'-good rngineoering pl,u:tiCf'- •Considf'f'SO lon/tear f'AflT1ption 21 ~re-1~.IRqu.k:;.' irnpoets <T.bIe A.2! hit)•BACT M.ly';'I i:P.ut 2 -f'03uunt App5<~b~Dtolermin.ation., YB 77.PrMon.,lruclH>n mone:orr.g d.lu re-quitt'd. •l.w reptf'Wnt.tA.f'_quoliitt d.i:.a •"t4ona!or fwur<.f'sp.·dfid l I I f i ! I i I ! I I p~"... 4.ml)tent .....Qu.lit) AIW.... I I I I i !I , I ! I ! IlJ!-----.--h~---··-r-·-------I -~ '-~_:_--------(~P~.~rt~·~;:.~~~~~e~!m=p.~C1~A~....~~~I,:...~_, P.rt 6·Ad~Imp.C1 A.w......I t I !?,I,rt i-Corn~l.e PSD AppfKoItion l~'o---_-'; ._-------_. ---_._------...._-- Ip,irt 1 ..So\:rte ~p~.llJiit\-O("I4~.min.ltion I, r--.~~17·~~~):-:Ol\<T.blr A-2'..j l8.k Ih.-reo din ..pp.lt'f'nf thrt-.r\I "'0 to the NAAQ5.0';,the:",,..Y:.;t::;S_____n .polenlill .en......imp.CI II ,I ~CL...1.",.1 .r\-9-.-W-'-;jj-P'W"--~--scvrc":--.-Of--"\ I I ..n:s meV.«...on pert",",pow- .ppro-~momtonng ..L.eou of preconstructioo mon~oring L ''-_d_._t.l_!J ___l'--~-----------' L L L L [ r r ----------1 r---•~ [ L l: L L L L L at a stational~source (which prior to the change 1$not major)if the change by itself would be major.That is,the change itself would reslJlt in an ec;uivalent stationary source which would emit 100 tons per year or more for any poll utant regulated under the Act for anyone of the 28 source ~ategories (Table A-4),or 250 tons per year for any other stationary source.The pollutants regulated under the Act were sho'lln in Part 2-Po11utant Applicability Determination. A stationary source generally includes all pvllutant-emitting activities which belong to the same industrial grouping,are located on contiguous or adjacent properties,and are under common control.Pollutant activities which belong to the same major group as defined in a standard industrial c1assification scheme developed by the Office of Management and Budget are considered part of .the same industrial grouping. The rest of the PSD size appl icabil ity for proposednel'/stationary sources is·simply that the cand idate source would be a major stationary source in terms of its potential to emit.T~eapplicability rules for determining wheth&a major modification would occur are more complex. A "major modification"is generally a physical change in or a change in the method of operation of a major stationary source which would result in a significant net emissions i~crease in the emissions of any regul~ted pollutant.In determining if a proposed increase would tause~significant net increase to occur,several detailed calculations must be performed.First,the source owner must quantify the amount of the proposed emissions increase.This amount will genera11y be the potential to emit of the new or modified unit.Second,t~e owner must r:locument and quantify a 11 emissions increases and decreases that have occurred or will occur contemporaneously (generally within the past five years)a~d have not been evaluatEd as part of a PSD review.The value of each contemporaneous decrease and increase is generally determined by subtracting the old level of actual emissions from the new or revised one.Third,the proposed emissions increase w~d the unreviewed contemporaneous c1langes must then be totalled.Finally,if there is a result~nt net emiss10ns increase that is latger than values specified in Table A-l, the modifica:ion is major and subject to PSD review. Certain cr.a~ges are exempted from the definition of major modification. These include:(a)routine maintenance,repair and replacement;(b)use of an alternative fuel or raw material by revision of an order under ,sections 2{a)and (b)of the Energy Supply and Environmental Coordination Action of 1974 (or any superseding legislation);(c)use of an alternative fuel by reason of an order or rule under section 125 of the Clean Air Act;(d)use of an alternative fuel at a steam generating unit to the extent it is generated from municipal solid waste;(e)usr of an alternative fuel or raw material which the source was capable of accomaodating;before January 6.1975 or which the source is approved to use under any permit issued under 40 CFR 52.21,or under regulations ap~foved pursuant to 40 CFR 51.24; and (f)·an increase in the hours of operation.or the production rate.The ~ast two exemptions,(e)and (fj,can be used only if the correspor,J;'19 change is not prohibited by certain permit conditions established after January 6,1975. A-12 it ..'___'____.A than 250 tons of thdn 250,000,000 A-13 TABLE A-I,.t-lJ..JOR STATIONARY SOURCES Petroleum storaqe and transfer units with a total storage capacity exceeding 300,000 barrels Taconite ore processing Plan\ts Glass fiber processing plants '. Charcoal production plants .....J Fossil fu~l-fireL steam electric plants of mor~ Briti:;h thermal units per hO,Jr heat input Coal cje~ning plants (with thermal drY2rs) Kra,ft pu1 p mill s Portland cemen~plants' Primary zinc smelters Iron and steel mill plants Primary aluminum ore reduction p1arits Primary copper smelters Municipal incinerators capable of charging more .refuse per day Hydrofluoric acid plants Sulfuric ac~d plants Nitric aci~p)ants Petroleum refineries L;me plants Phosphate rock processing plants Coke oven batteries Sulfur recovery plants Carbon black p~ants (furnace ~rocess) Prililary lead smelters Fuel conversion plants Sintering plants Secondary metal producti0n plants Chemical process plants Fossil-fuel boilers (or combinations thereof)totaling of more than .250,OGO,OOO Br;t;~h thermal units per hour hea~imput 26. p~: 25. 1. 2. 3. 4. 5. 6~ 7. 8. 9. 10. ll. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. " r- r ,-' r l~ f' f' L [ r~ r; [ r: [ [ L L L L r r [ r~ [ If the sile of a proposed source or modification thus qualifies as major,its pruspective location or existing location must also qualify as a PSD area,in order for PSD review to apply.A PSD area is one formally designqted by the state as "attaimr.ent"or "unc lassifiable"for any polluant for which a national ambient air qual ity standard exists. This geographic applicability test generally does not take into account what new pollutant emissions caused the construction to be major.It looks simply at whether the source is ~~:or for any pollutant and will be located in a PSD area.The 0ne exception is that if a major st~tionary source emits only nonattainment pollutar,ts,then no PSD review would apply. If a proposed source or modification would be subject to PSD review based on size,location,and pollutants ~mitted,it still may escape the PSD revi ew ,'?Qui rements under certai n grandfather provi s ions under 40 CFR 52.21 (i).,-or example,a proposed source or modification that WdS not subject to the 1978 PSD rule~and had received a]l necessary Federal, State and.lccal air permits before August 7,1980,would not be subject to the 1980 regulations.(See the PSD regulations for other exe~ptions.) Finally,the PSD regulations contain some specific exemptions for some forms of source construction.The requirements of the PSD regulations do not apply to any major stationary source or major modification that is (a)a nonprofit health or educational institution (only if such exemption is requested by the governor),or (b)a portabl~source which has already receive::!a PSD permit and proposes relocation,or the source or modification would be d major stationary source or major modification 0nl~·if fugitive emissions,to the extent quantifiable,are considered in ';.dlculating the potential to emit of the stationary source or m0dificat i .Jn and the source does not belong to any of the categories listed in Table A-4. [' L L L L L l L '::>oi l '.. _.;) Box 2.No PSD peX'l7li t needed. If the source has met the appropriate deadlines for construction; and is not a major stationary source,a major modification,is not located in a PSD araa,or is not subject to the specific exemptions mentioned above,the PSD program is not applicable,and ~herefore,no PSD permit is needed. i Box 3.Is const~uction p~oposed fo~an area ~hich is designated nonattainment a~ea fo~the ~eguZated pollutant?. . If the project is a major stationary source or a major modification, the prospective location must also qualify as a PSD area in order for the PSD review to apply.A PSD area is defined as an aY-ea formally designated hy the State as "attainment"or "unclassifiable"for any pollutant for which a NAAQS exists.An area not classified as either "attainment"or "unclassifiable"would be classified as "nonattainment". If the proposed construction is in a nonattainment area for any pollutant, proceed to box -1 for that pollutant;for all other regulated pol iutants, rroceed to box 5.. A-14 I tI- [ [ [ [ L L [' [ L L L r L Box';.No fUr'theT'PSD analysis fm'that poZluta!1t. If the proposed najor stationary source or major mocification will err.it pollutants from an area that has been designatod a,"nonattainment", then the proposed source or modification is exempt frc~further PSD r~view for 0nly those pollutants.However.the propos~d sourc~or modification must meet the applicable preconstruction requirements for each nonattainment pollutant.(See 40 CFR 51.18 and 40 CFR 52.24.) The pollutant applicability determination would be continued for all other regulated pollutants (except nonattainment pollutants)emitted by a proposed major statiunary source or rr.ajor modification by proceeding to cox 5. Box v.Is pT'oposed souroe OT'modificatian within to km of a Class I ~ea? The PSD regulations [40 CFR 51.24(b)(23)(iii)and 40 CFR 52.2l(b)(23) (iii)]require that a proposed sCurce or modification.which plans to construct within 10 km of a Class I area must demonstrate that if it would not impact the area,(less than 1 ug/m 3 )even if the proposed emissions are below the applicable significant emissions rates listed in Table A-l.If the pr0posed source or modification is within 10 km of a Class I area.proceed to box 6;if not.proceed to box B~ Box 6.Class I aT'ea sOT'eening pT'ooeduT'e. If the proposed s('~lrc~or modification is I'/ithin 10 km of a Class I area.then the screening procedures described in reference 50 may be used to estimate the impact on the Class I area.This screening procedure is based on a simple but conservative model for estimating each concentration due to the emissions from the proposed source or modification. Box ?MOT'e T'efined rnodd (optior.a.lJ. A proposed source or modification may choose not to accept or u~e the concentration estimates derived from the screening procedures in box 6,and may elect to use a more refined model which would more adequately reflect the impact or.the Class I area from the proposed source o~. modification.It should be emphasized that in order to perform a·refined modeling analysis.it may be necessary to collect 1 year of on-site meteorological data for the model input if an adequate amount of representative data are not already available.The application of any model used in . this analysis must be consistent with reference 34 as discussed in sq.otion 5.1.The application of any different mode:"'must be approved by EPA in order to avoid any delays in the processing of the permit application. Applicants should con5ult with the reviewing authority before investing considerable resources in the use of the different models.Therefore. the documentation and specific description of the model should be provided to the reviewing authority before the results are submitted. The concentration estimates from the screening procedure or therefilied model,are subsequently used in the Part 4-Ambient Air Quality Analysis and Part 5-Source Impact Analysis. A-15 i j ,~ "'.-'---'._-.~.._~_".-.'."-'.'-".~.._.._'-_.~~_._.-'- A-16 Box 10.No further'analysis for·that poUutant• Box 13.No PSD permit required. Box 12.Are there potential impacts on a Class I area,or a2"eas of knm.:'I1. 'increment vioZation? -._._.•.._._---.._.._._.~.~-~,.., >1 ...~.-j ~~ I I i "! Eox 8.WiU the propo'sed source or modification impact on a Class I ar:ea? The emissions from the portabie source should not exceed its allowable emiss~l)ns,a'r:d the emissions from the temporary source should impact no Class I area and no area where an applicable increment is known to be Violated.If there are potentially adverse impacts on a Class I area,or significant impacts on areas of known increment violation, proceed to box 14j if not,proceed to box 13. If there are nO'potential impacts on a Class I area,or areas of known increment violation.no PSD permit is required. I If a proposed source or modification is within 10 km of a C~ass I area,the proposed source or modification must be prepared to demonstrate for each regulat~d pollutant it'would emit that there ~lOuld be no significant impact ori the Class I area.Significant impact is defioed in thePSD regulations [40 CFR 51.24(b)(23)(iii)and 40 CFR 52.2l(b)!23)(iii)]as.l microgram per cubic meter (glm )or more,24-hour average. This Guestion is actually an applicability question that is normally considered under the~art l-Source Applicability Determination.However, there are certain other questions (see boxes 3~5 a~~a of Figure A-2) which are normally asked under pollutant applicability that are also germane to permitting a port."ble facility relocat1C'n.Thus,the reason for including box 11 in Part 2. The source must be a portable facility which has previously received a pe~it under the PSD regulation~,the ow~er proposes to relocate the facility,c;nd emissions at the new location would be temporary (not exceeding its allowable emissions).If the facility meets these requirements, then proceed to box 12;if nDt,proceed tv box 14. Box 11.Is proposed construction a relocation of a portable facility with previ~~s'pe~it? Box 9.Are new emissions or n~t emissions irerease of the regulated poUutant .:!Tdble A-l? If the proposed source or mod~fication is not within 10 km of a Class 1 area,~r if the proposed source is within 10 km of a Class I area and has no significant impact on the Class I 3rea,then the em~ssions for ea~h.pollutant from the proposed source of ll'~dification are compared to the significant emissions rates in Table A-l. . If the emissions from the proposed source or modification are not significant as defined in Table A-l,no further analysis is required for that pollutant.However,a similar review must be performed for all other regulated pollutants by proceeding to box 5 for the next pollutant. r~ r~ [' f~ L [' [ [ [ L L [ L L L L L L".... l L ~ L L ~ [' [ r l'-~ [ [ r~ r~ I: L [ I- L l L ••.•_.~_~_.0••_"•••••.•~_.•__••••••••_._.•.-.~-_M .••-•• box 14.Apply BACT. UBest available control technologyU means an emiss~ons limitation (including a visible emission standard)baseG on the :neximum degree of reduction for eac~pollutant subject to regulation und~rthe Act which would be emitted from any proposed major stational'y source or ~ajor modification which the Administrator.on a case-by-case basis,taking into accnunt energy,environmental,and economic impacts and other costs,determines is achievable for such source or modification thrcugh application of production process£s or available methods,systems,and techniques,including fuel cleaning or tre3t!!Jer!t or innovative fuel combustion techniques for control of such pollutant.In no event shall application of best available contrel technology result in emissions of any pollutant which would exceed the emissions allowed by any applicable standard under 40 CFR Parts 60 and 61.If the Administrator determines that technological or economic limitations on the application of measurement methodology to a particular emissions unit would make the imposition of an emissions standard infeasible,a design,equipment,work practice, ope~ational standard.or combination thereof,may be prescribed instead to satisfy the requirement for the applit.ation of best available control technology.Such st1lndard shall,to the degree possible,set forth the emissions reduction achievable by implementation of such design,equipment, work pl'actice or operation,and shall provide for compl iance by means which achieve equivalent results. Box lS.A~e the allo~uble emissions o~the neI emissior~increase temporary,impaating no Cums I area,or impaatir.g no area where the PSD increment -~s 1,io Zated? Temporary ell-dssions are defined as emissions from a temporary source that would be less than 2 years in duration,unless the Administrator determines that a longer time period wou:d be appropriate.If all of the conditions above are not met,proceed to box 16;if they are met, proceed to Part 7-Complete PSD Application. Box 16.Will the proj)osed source or modification emit vac? If the proposed source or modification will emit VOC,proceed to ba=1?~if rot.r~or~ed to hox 20.Also proceed to box 20 if the pollutants are TSP.S02'CO,N0 2 ,or Pb. Box 17.Are vac emissio'~<Table ~-2? If the voe emissions rates from the proposed source or modification are less than the value in Table A-2 (100 tons/year),proceed to bo=18; if not,proceed to;box lB. Box 18.Is there an appaPent threat to tne NAAQS,01'is there a potential- adverse impact on a ClasD I area? If the projected air quality after construction is equal to or qreater than 90 percent of the NAAQS,a threat to the NAAQS would genei-ally exist.Potential adverse impacts on a Class I area must be deternlinc?d 0:1 A-17 1-----fi /) J r~ r r~ r [' r [ [ [ [ [ L L L L r~ r~ L L a case-by-case tasis by the permit granting authority.Therefore,if there is an apparent threat to the NAAQS.or ~f there are potential adverse impacts on a Class I area,then proceed to box 19;if not, proceed to box 20. Box 19.WiU.proposed SOUl"ce modification perform postapproval monitoztirlg in lieu of preconstruction mOnitoring data? The PSD regulations [40 CFR 51.24(m)(1)(v)and 40 CFR 52.21(m)(1) (vi)]give special considerations regarding ozone monitoring data to new or modified sources of volatile organic compounds which have satisified a11 conditions of 40 CFR 51,Appendix A.section IV.This section generally requires affected sources to meet 10~est achi;vab1e emission rate limitations.secure emissions offsets which provide an overall net air quality improvement,and ensure all other major sources in the same State are :in compliance with the applicable SIP.If a proposed source or modification has met all of the above conditions for VQC,then the proposed source or modification may provide postapproval monitoring data for ozone in lieu of providing preconstruction data.Postapproval mo~itoring data are data collected after the date of approval of the PSD application.However.in no caseshoula the postapproval monitoring be started later than 2 years after the start-up of the new scurce or modification. If th(proposed source or modification ~ill provide postapproval m0nitoring,proceed to the Part 5-Source Impact Analysis;if not, proceed to hox 20 for the remainder of the ambient ~ir quality analysis. Box 20.Estimate existing air quality. The proposed source or modification must perform an initial analysis to estimate the existing air quality concentrations.The screening procedures described in reference 50 may be used.The screening procedures are based on simple models for estimating air quality due to the emissions from existing and approved but not yet built sources.A proposed source or modification may choose not to accept or use the concentration estiwates derived from the screening procedure above.and may elect to use a more refined model which would more adequately reflect the impact from existing sources.It should be emphasized that in order to perform a refined modeling analysis.it is generally necessary to collect 1 year of on- ~it~meteorological data for the model input.The application of any model used in this analysis must be consistent with reference 34 as discussed in section 5.1.The application of anyrr~del should be approved by the permit granting authority to avoid any futcre delays in the processing of the permit application.Therefore,the documentation of the specific description of the model should be provided to the permit granting authority before the results are SUbmitted. The concentration estimates from the screening procedure or the optional refined model will be used in the remaining portions of the ambient air quality analysis. A-18 I" l~ [' [ [ [: l~ l ' •.....< [ r l [ I' l' L L L L L .~ Box 21.Esti'7'Jate ail"quality impacts oJ proposed constl"'.4C!tior.. f' The proposed source or modification must estimClt(.,;ts ai:"qual i ty impacts to demonstrate that its new pollutant emissio,1s would not violate either the applicable NMQS or the applicab1e P5D increment.The proposed source ,or modification must use'the screening ~rocedures or more refined model,consider "good engineering practice"for stack height,and considet· the TS?and S02 increment exclusion for Class II areas u:'lder 50 tons per year exemption.These factors are discussed in more detail below. (a)"Screening pr-ocedure or more refi:'led model. If the proposed source or m~dification used the screening procedure or more refined model in box 6 or ?previously to estiwate the impact,then those results may be uspd in this impact analysis.If the screening proced~re or more refined model was not previously determined, then the screening procedures described in reference 50 may be used. This screening procedure is based on a simple model for estimating each concentration due to the emissions from the proposed source or modification. A proposed source or modificaticn may choose not to accept or use the concentration estimates derived from the screening pl'ocedure above,and ~~y elect to use a more refined model which would more adequately reflect the impact from the proposed source or modification.It should be emphasized that in order to perfonn a refined modeling analysis,it is generally necessary to collect 1 year of on-site meteorologiciH data for the model input.The application of any model used in this analysis must be co~sistent with reference 34 as discussed in s~ction &.1.The application of any model should be approved by the pennit granting authority to avoid any future delays i~t~e processing of the pennit application.Therefore,the documentation and specific description of the model should be provided to the permit granting authority before the results are submitted.' The concentration e~timat~5 from the screening procedure or the optional refined model will be used in the remaining portions of ,the ambient air quality analysis. (b)"Good en~ineering practice"(GEP)for stack height. The 1978 PSD regulations [1]provide for requiring GEP in the impact analysis for stack heights.The degree of emission limitations required for the control of any air pollutant would not be affected by stack heights (in existence after December 31,1370)as ,exceeds good engineering practice,or any other disper'sion techniques implE:!mented after then.I (c)Consider 50 tons per year exemption. , The ~SD regulations [40 CFR 51.24(i)(7)and 40 CFR 52.21(i)(7}] as they apply to a major modification exempt TSP and SO~from the Class I I increment consumption review if all of th-:following'-condH,ions are met:(1)the net increase of all pollJtants regulated under the Act after application of BACT would be less than 50 tons/year,(2)no pollutant would bl::causing or contributing to a violation of the standards (NAAQS), and (3)source must have been in existence on March 1,1978, A-19 r " L ._----"--~-_....-----~.--------.._._-~-~----~------------.1 ":, '.~ The results of the impact analysis as described in this box will be used for subsequent portions of the ambient air quality analysis. Box 22.Is the existing air q40.Zity <TabZe .4-2? The proposed source or modification must determine the existing air quality concentration in the area of impact of the proposed source or modification before construction for each applicable pollutant.Modeling by itself or in conjunction with monitoring data 'would be used for this determination.Application of these models must be consistent with re4'"ere!lce 34. If the proposed source or modification is remote and not affected bJf other readily identified man-made sources,two options for determining existing air quality concentrations from existir.g data are available. The first option is to use air quality data collected in the Vicinity of the proposed source or modification.t.he second option is to use average measured concentrations from a "regional"site to establish a background concentration.Additional guidan~e on determining the background air quality concentrations may be found in reference 34.See also the discussion or use of representative air quality data in section 2.4 of this guideline. If the exisi.1ng air quality is less than the values in Table A-2, proceed to box 24;·if not.proceed to bex 23. Box 23.Are the ail'quality impacts <Tcibl.e A-27 The projected impact of the proposed source or modification was previously d2termined by the screening procedure or refired model estimates. These modeled concentration~are compared to the significant monitoring concentrations shown in Tcb10 A-2.If these modeled concentrations are less than the values in Table A-2.proceed to box 24;if not.proceed to bo~25. Box 24.Is there an apparent th~eat to PSD increments or NAAQS3 or is there a potential.adverse impact on a CLass I area? An apparent threat to a PSD increment is consumption by the proposed sOurce or modification of 90 percent or more of the re~aining allowable .increment.An apparent threat to thp.NAAQS is when the projected air quality after construction is equal to or greater than 90 percent of the NAAQS.Potential ad~erse impacts on a Class I area must be determined on a case-by-case basis by the ~ermit granting authority.. Therefore,if there is an apparent threat to PSD'increments or NAAQS,or if there is a pctential adverse impact ona Class I area. proceed to box 29';if not.proceed to box 28. Box 25.Are proposed emissions a eriteria pollutant o~vac? Determine if the pollutant is a criteria pollutant (TSP.502'CO, NO?,or Pb)or VQC.If the pollutant is a criteria pollutant or VQe. prOceed to box 27;if not.proceed to box 26.. A-20 r~ __,._0_.,-_.',__ ~ [' r~ [ L L I~ [ [ r~ [ r ' l' L L L [ I L Box 26.Is there an approved mo,:itoring technique avaiZobZe? Acceptable measurement methods currently exist for some noncriteria poll utants.whi 1e other methods are currently under rev i i?\'l and have not bern designoted as an acceptable measurement method..>ec:tiofl 2.6 of this guideline discussed the designation of acceptable measurement methods for noncriteria pollutants.If an acceptable measurement meth~d does exist.proceed to box 29;if not.proceed to box 28. Box 27.P;reaonatruationmonitoring data required. Preconstruction air quality monitoring data are required for this part of the ambient air quality analysis.The proposed source or modific~tion has the option of using representative air quality data or monitoriny. Considerations and constraints on the use of existing data were discossed "in seation 2.4 of this guideline.It should be noted that a dispersion model may be u:ed in verifyinQ the representativeness of the data.If a proposed source or modification chooses to monitor instead of using representative air quality data.then the specifics to be followed ~n networ~design,probe siting.quality assurance.nljmbe~of monitors. etc .•were preViously discussed in this guideline. The monitoring data required in this box will be used in P3rts .5. 6 and 7 of the PSD permit application. Box 28.No preaonstruation monitorir.g data required. If there is no approved monitoring technique for the noncriteria pollutants.or if there is no apparent threat to PSD increments or NMOS,or if thel'eis no potentially adverse impact or.a Class·I area, then generally no preconstruction monitoring data will be required. However.proceed to the Part 5-$ource Impact Analysis for remaining analyses. Box 29.Preaonstruction monitorir.g data may be required. The permit granting authority must determine on a case-by-case basis if monitoring data will be required when there is an appal"ent threat to PSD increments or NAAQS,or when there is a potential ad~erse impact on a Class I area.Special atten~ion must be given to Class ! areas where the proposed source or modification would pose a ~~;'c:at to the remaining allowable increment.For those situations wher~the air quality concentration before construction is near the concentrations shown in Table A-2 and there are uncertainties associated with this air quality determination then preconstruction air quality monitoring data may be required.Some situations where noncriteria monitoring maybe required were discussed in section 2.1.3 of this guideline. Regardless of the monitoring ~ata decision,proceed on to the Part 5-Source Impact Analysis for remaining analyses. A-2l REFERENCES 5.Federal Regi5ter 45:52676-52748.~ugust 7,1980. 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