are recent court rulings, with the most notable from the Washington, D.C. Circuit Court of Appeals in January 2013 that determined the full air qual- ity assessment could not be avoided merely by showing the impact of the project was below a minimal “Signifi- cant Impact Level.”
9
Is it possible to get a PSD permit for PM2.5
modified foundry source?
Te short answer is yes. In many instances it is possible to avoid review under the PSD and NNSR rules by demonstrating that a project is not a “major modification” using various tools in the rules including: com- parisons of “actual to projected actual emissions”; netting, wherein the benefits of recent or concurrent emis- sion reductions offset increases; or by applying more effective emission con- trols. For larger projects that cannot avoid review under these rules, a vari- ety of strategies can be used, including making adjustments to background data to remove the impacts of sources that do not impact the area where the source is located, and/or adjusting the locations of emission sources and the height or exit velocity of stacks.
10 It is important for metalcasting
What should metalcasters do to prepare PM2.5
• Obtaining accurate PM2.5 emission estimates is crucial to
in gaps in available information especially for CPM.
• More than ever before facili- for a new or
making strategic decisions and ensuring the source can comply with possible future limitations. Sources should consider conduct- ing PM2.5
emission testing to fill
ties need to budget sufficient time and resources for advanced planning for capital projects. Determining the applicability of the regulations, finding ways of avoiding unnecessary complex requirements and allowing suf- ficient time to prepare permit applications are key to success- ful projects.
issues?
facilities to understand how the regu- latory and permitting requirements may impact the facility. Key questions to answer include: • Is the facility (existing or new) a major source under the PSD or NNSR rule?
• Is the facility located in a non- attainment area or an attainment area that could be reclassified as nonattainment in the future?
•What are the physical changes the facility may want to undertake in the future and how will those changes impact the overall facility, such as increasing the capacity or throughput of other processes?
August 2015 MODERN CASTING | 39
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