BACT Analysis ] Ambient Air Quality ] [ Impact Analysis ] Class 1 Area ] Public Notice ]

Additional Impacts Analysis

  All PSD permit applicants must prepare an additional impacts analysis for each pollutant subject to regulation under the Act. This analysis assesses the impacts of air, ground and water pollution on soils, vegetation, and visibility caused by any increase in emissions of any regulated pollutant from the source or modification under review, and from associated growth.

Growth Analysis

The elements of the growth analysis include
  • a projection of the associated5 industrial, commercial, and residential source growth that will occur in the area due to the source
  • an estimate of the air emissions generated by the above associated industrial, commercial, and residential growth.

  First, the applicant needs to assess the availability of residential, commercial, and industrial services existing in the area. The next step is to predict how much new growth is likely to occur to support the source or modification under review. The amount of residential growth will depend on the size of the available work force, the number of new employees, and the availability of housing in the area. Industrial growth is growth in those industries providing goods and services, maintenance facilities,and other large industries necessary for the operation of the source or modification under review. Excluded from consideration as associated sources are mobile sources and temporary sources.

5  Associated growth is growth that comes about as the result of the construction or modification of a source, but is not a part of that source. It does not include the growth projections addressed by 40 CFR 51.166(n)(3)(ii) and 40 CFR 52.21(n)(2)(ii), which have been called non-associated growth. Emissions attributable to associated growth are classified as secondary emissions.

  Having completed this portrait of expected growth, the applicant then begins developing an estimate of the secondary air pollutant emissions which would likely result from this permanent residential, commercial, and industrial growth. The applicant should generate emissions estimates by consulting such sources as manufacturers specifications and guidelines, AP-42, other PSD applications, and comparisons with existing sources.
  The applicant next combines the secondary air pollutant emissions estimates for the associated growth with the estimates of emissions that are expected to be produced directly by the proposed source or modification. The combined estimate serves as the input to the air quality modeling analysis, and the result is a prediction of the ground-level concentration of pollutants generated by the source and any associated growth.

Soils and Vegetation Impact Analysis

  The analysis of soil and vegetation air pollution impacts should be based on an inventory of the soil and vegetation types found in the impact area. This inventory should include all vegetation with any commercial or recreational value, and may be available from conservation groups, State agencies, and universities.

Visibility Impacts Analysis

  The Level 1 visibility screening analysis is a series of conservative calculations designed to identify those emission sources that have little potential of adversely affecting visibility. The VISCREEN model is recommended for this first level screen. Calculated values relating source emissions to visibility impacts are compared to a standardized screening value. Those sources with calculated values greater than the screening criteria are judged to have potential visibility impairments. If potential visibility impairments are indicated, then the Level 2 analysis is undertaken.
  The plume visual impact screening model VISCREEN, available on the US EPA SCRAM web site, is designed to ascertain whether the plume from a facility has the potential to be perceptible to untrained observers under "reasonable worst case" conditions. If either of two screening criteria is exceeded, more comprehensive Level 2 analyses should be carried out.
  The Level 2 screening procedure is similar to the Level 1 analysis in that its purpose is to estimate impacts during worst-case meteorological conditions; however, more specific information regarding the source, topography, regional visual range, and meteorological conditions is assumed to be available. The analysis may be performed with the aid of either hand calculations, reference tables, and figures, or an alternative computer-based visibility model called "PLUVUE II", also available on the US EPA SCRAM web site.