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