Comparison of Current and Proposed Requirements for PSEL increases above SER in Attainment, Nonattainment and Maintenance Areas (Minor and Major NSR/PSD)
Nonattainment Areas
Program Elements | Current Requirements | Proposed Requirements |
Source Emissions after the PSEL increase 100 tons per year or more | ||
Source Classification | Major | Federal Major |
Preconstruction Monitoring | n/a | n/a |
Control Technology | LAER * | LAER * |
AQ Analysis-NAAQS/Increments/ AQRV | AQRV analysis (Federal Majors only) | AQRV analysis |
NAQB | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants **
Reduce impacts at majority of receptors; and Impacts less than SIL at all receptor | Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS |
Additional Impacts | n/a | n/a |
Alternatives Analysis | Alternative sites analysis * | Alternative sites analysis * |
Certify Compliance | Certify compliance for all sources * | Certify compliance for all sources * |
Source Emissions after the PSEL increase SER to 99 tons per year | ||
Source Classification | Major | Minor |
Preconstruction Monitoring | n/a | n/a |
Control Technology | LAER * | BACT * |
AQ Analysis-NAAQS/Increments/ AQRV | AQRV analysis
| n/a |
NAQB | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants ** • Reduce impacts at majority of receptors; and • Impacts less than SIL at all receptors | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources • Source plus competing sources since area was designated less than 10% of the NAAQS |
Additional Impacts | n/a | n/a |
Alternatives Analysis | Alternative sites analysis * | n/a |
Certify Compliance | Certify compliance for all sources * | n/a |
Source Emissions after the PSEL increase less than SER | ||
Source Classification | Minor | Minor |
NC rules or ACDP | NC rules or ACDP, no change |
* If a Major Modification is involved
** Offset ratio varies for certain areas such as Medford PM10, etc.
Somewhere explain change to FM classification
Maintenance Areas
Program Elements | Current Requirements | Proposed Requirements |
Source Emissions after the PSEL increase 100 tons per year or more | ||
Source Classification | Major | Federal Major |
Preconstruction Monitoring | Preconstruction Monitoring ***
| Preconstruction Monitoring ***
|
Control Technology | BACT *
| BACT *
|
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments AQRV analysis (Federal Majors)
| NAAQS and PSD Increments AQRV analysis
|
NAQB | • Offsets ◦ 1.1:1 for ozone ◦ 1.0:1 for other pollutants ** and NAQB ▪ Reduce impacts at majority of receptors; and ▪ Impacts less than SIL at all receptors
Or • Growth allowance Or • Model below maintenance area limits | • Offsets ◦ 1.1:1 for ozone ◦ 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources ** and NAQB ▪ Source plus competing sources since area was designated less than 10% of the NAAQS Or • Growth allowance Or • Model below maintenance area limits |
Additional Impacts | Additional impacts analysis (Federal Majors) | Additional impacts analysis |
Alternatives Analysis | n/a | n/a |
Certify Compliance | n/a | n/a |
Source Emissions after the PSEL increase SER to 99 tons per year | ||
Source Classification | Major | Minor |
Preconstruction Monitoring | Preconstruction Monitoring ***
| |
Control Technology | BACT *
| BACT *
|
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments AQRV analysis (Federal Majors)
| NAAQS and PSD Increments
|
NAQB | • Offsets ◦ 1.1:1 for ozone ◦ 1.0:1 for other pollutants ** and NAQB ▪ Reduce impacts at majority of receptors; and ▪ Impacts less than SIL at all receptors Or • Growth allowance Or • Model below maintenance area limits | • Offsets ◦ 1.1:1 for ozone ◦ 1.0:1 for other pollutants ** and NAQB ▪ Reduce impacts at majority of receptors; and ▪ Impacts less than SIL at all receptors Or • Growth allowance Or • Model below maintenance area limits |
Additional Impacts | Additional impacts analysis (Federal Majors) | |
Alternatives Analysis | n/a | n/a |
Certify Compliance | n/a | n/a |
Source Emissions after the PSEL increase less than SER | ||
Source Classification | Minor | Minor |
NC rules or ACDP | NC rules or ACDP, no change |
* If a Major Modification is involved
** Offset ratio varies for certain areas such as Medford PM10, etc.
*** If impacts are greater than the Significant Monitoring Concentration
Attainment Areas
Program Elements | Current Requirements | Proposed Requirements |
Source Emissions after the PSEL increase 100/250 tons per year or more | ||
Source Classification | Federal Major | Federal Major |
Preconstruction Monitoring | Preconstruction monitoring ***
| Preconstruction monitoring ***
|
Control Technology | BACT * | BACT * |
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments AQRV Analysis | NAAQS and PSD Increments AQRV Analysis |
NAQB | n/a | n/a |
Additional Impacts | Additional impacts analysis * | Additional impacts analysis * |
Alternatives Analysis | n/a | n/a |
Certify Compliance | n/a | n/a |
Source Emissions after the PSEL increase SER to 99/249 tons per year | ||
Source Classification | Minor | Minor |
Preconstruction Monitoring | n/a | n/a |
Control Technology | n/a | n/a |
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments | NAAQS and PSD Increments |
NAQB | n/a | n/a |
Additional Impacts | n/a | n/a |
Alternatives Analysis | n/a | n/a |
Certify Compliance | n/a | n/a |
Source Emissions after the PSEL increase less than SER | ||
Source Classification | Minor | Minor |
NC rules or ACDP | NC rules or ACDP, no change |
* If a Major Modification is involved
** Offset ratio varies for certain areas such as Medford PM10, etc.
*** If impacts are greater than the Significant Monitoring Concentration
Sustainment Comparison to Attainment and Nonattainment
Program Elements | Attainment | Sustainment | Nonattainment |
Source Emissions after the PSEL increase 100/250 tons per year or more | |||
Source Classification | Federal Major | Federal Major | Federal Major |
Preconstruction Monitoring | Preconstruction monitoring ***
| Preconstruction monitoring (required) | n/a |
Control Technology | BACT * | BACT * | LAER * |
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments AQRV Analysis | NAAQS and PSD Increments AQRV Analysis | AQRV analysis |
NAQB | n/a | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
| Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS |
Additional Impacts | Additional impacts analysis * | Additional impacts analysis * | n/a |
Alternatives Analysis | n/a | n/a | Alternative sites analysis * |
Certify Compliance | n/a | n/a | Certify compliance for all sources * |
Source Emissions after the PSEL increase 100 to 99/249 tons per year | |||
Source Classification | Minor | Federal Major | Federal Major |
Preconstruction Monitoring | n/a | Preconstruction monitoring (required) | n/a |
Control Technology | n/a | BACT * | LAER * |
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments | NAAQS and PSD Increments AQRV Analysis | AQRV analysis |
NAQB | n/a | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
| Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS |
Additional Impacts | n/a | Additional impacts analysis * | n/a |
Alternatives Analysis | n/a | n/a | Alternative sites analysis * |
Certify Compliance | n/a | n/a | Certify compliance for all sources * |
Source Emissions after the PSEL increase SER to 99 tons per year | |||
Source Classification | Minor | Minor | Minor |
Preconstruction Monitoring | n/a | n/a | n/a |
Control Technology | n/a | BACT * | BACT * |
AQ Analysis-NAAQS/Increments/ AQRV | NAAQS and PSD Increments | NAAQS and PSD Increments | n/a |
OR | |||
NAQB | n/a | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS |
Additional Impacts | n/a | n/a | n/a |
Alternatives Analysis | n/a | n/a | n/a |
Certify Compliance | n/a | n/a | n/a |
Source Emissions after the PSEL increase less than SER | |||
Source Classification | Minor | Minor | Minor |
NC rules or ACDP | NC rules or ACDP, no change | NC rules or ACDP, no change |
Reattainment Comparison to Nonattainment and Maintenance
Program Elements | Nonattainment | Reattainment | Maintenance |
Source Emissions after the PSEL increase 100/250 tons per year or more | |||
Source Classification | Federal Major | Federal Major | Federal Major |
Preconstruction Monitoring | n/a | n/a | Preconstruction Monitoring ***
|
Control Technology | LAER * | LAER * | BACT *
|
AQ Analysis-NAAQS/Increments/ AQRV | AQRV analysis | AQRV analysis | NAAQS and PSD Increments AQRV analysis
|
NAQB | Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources ** and NAQB
Source plus competing sources since area was designated less than 10% of the NAAQS Or • Growth allowance Or • Model below maintenance area limits |
Additional Impacts | n/a | Additional impacts analysis
| Additional impacts analysis
|
Alternatives Analysis | Alternative sites analysis * | Alternative sites analysis * | n/a |
Certify Compliance | Certify compliance for all sources * | Certify compliance for all sources * | n/a |
Source Emissions after the PSEL increase 100 to 99/249 tons per year | |||
Source Classification | Federal Major | Federal Major | Federal Major |
Preconstruction Monitoring | n/a | n/a | Preconstruction Monitoring ***
|
Control Technology | LAER * | LAER * | BACT *
|
AQ Analysis-NAAQS/Increments/ AQRV | AQRV analysis | AQRV analysis | NAAQS and PSD Increments AQRV analysis
|
NAQB | Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.2:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources ** and NAQB
Source plus competing sources since area was designated less than 10% of the NAAQS Or • Growth allowance Or • Model below maintenance area limits |
Additional Impacts | n/a | Additional impacts analysis
| Additional impacts analysis
|
Alternatives Analysis | Alternative sites analysis * | Alternative sites analysis * | n/a |
Certify Compliance | Certify compliance for all sources * | Certify compliance for all sources * | n/a |
Source Emissions after the PSEL increase SER to 99 tons per year | |||
Source Classification | Minor | Minor | Minor |
Preconstruction Monitoring | n/a | n/a | n/a |
Control Technology | BACT * | BACT * | BACT * |
AQ Analysis-NAAQS/Increments/ AQRV | n/a | NAAQS and PSD Increments | NAAQS and PSD Increments |
OR | OR | ||
NAQB | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources
Source plus competing sources since area was designated less than 10% of the NAAQS | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources ** and NAQB
Source plus competing sources since area was designated less than 10% of the NAAQS Or • Growth allowance Or • Model below maintenance area limits | Offsets • 1.1:1 for ozone • 1.0:1 for other pollutants, with provision to reduce the ratio if offsets are obtained from priority sources ** and NAQB
Source plus competing sources since area was designated less than 10% of the NAAQS Or • Growth allowance Or • Model below maintenance area limits |
Additional Impacts | n/a | n/a | n/a |
Alternatives Analysis | n/a | n/a | n/a |
Certify Compliance | n/a | n/a | n/a |
Source Emissions after the PSEL increase less than SER | |||
Source Classification | Minor | Minor | Minor |
NC rules or ACDP | NC rules or ACDP, no change | NC rules or ACDP, no change |