
Date:
October
24,
2005
To:
Raj
Rao,
EPA/
OAQPS/
AQPD/
IIG
Cc:
Project
file
for
Work
Assignment
0­
4,
EPA
Contract
EP­
D­
05­
087
From:
Stephen
Edgerton,
EC/
R
Incorporated
RE:
Analysis
of
the
Proposed
Minor
NSR
Thresholds
Purpose
The
purpose
of
this
memorandum
is
to
document
the
analysis
performed
to
evaluate
the
potential
effect
of
the
proposed
minor
new
source
review
(
NSR)
thresholds
in
the
Federal
Minor
NSR
Program
in
Indian
Country.

Methodology
To
evaluate
how
the
proposed
NSR
thresholds
might
affect
new
sources
locating
in
Indian
country,
EC/
R
examined
the
thresholds
in
the
context
of
the
existing
population
of
sources
in
the
United
States.
That
is,
the
analysis
examined
the
potential
effect
of
the
proposed
thresholds
under
the
assumption
that
the
distribution
of
new
sources
locating
in
Indian
country
will
mirror
the
distribution
of
existing
U.
S.
sources.

For
the
analysis,
we
used
the
National
Emission
Inventory
(
NEI),
which
is
the
most
comprehensive
inventory
of
existing
U.
S.
stationary
point
sources
that
is
available.
The
inventory
used
for
the
analysis
was
the
final
1999
NEI,
extrapolated
forward
to
2001,
which
was
the
most
recent
quality­
assured
version
at
the
time
of
the
analysis.
We
obtained
the
NEI
point
source
facility
summary
dataset
directly
from
EPA.

For
each
of
the
criteria
pollutants
except
lead,
we
determined
which
of
the
NEI
sources
fall
below
the
proposed
minor
NSR
thresholds,
which
are
between
the
minor
NSR
and
major
NSR
thresholds,
and
which
are
above
the
major
NSR
threshold.
For
each
pollutant,
we
determined
the
percent
of
sources
in
each
category
and
the
percent
of
total
emissions
represented
by
each
category.
See
the
Results
section
below
for
the
outcome
of
the
analysis.

The
minor
and
major
NSR
thresholds
that
were
evaluated
for
each
pollutant
are
presented
in
Attachment
1.
As
these
tables
show,
for
the
minor
NSR
thresholds
we
evaluated
the
proposed
thresholds
and
some
alternative
thresholds
to
assess
the
effect
of
varying
the
levels.
Memorandum:
Analysis
of
the
Proposed
Minor
NSR
Thresholds
2
The
major
NSR
threshold
for
each
pollutant
was
determined
based
on
the
attainment
status
and,
where
applicable,
nonattainment
classification
of
the
area
in
which
each
source
is
located.
Attainment
status
and
nonattainment
area
classifications
were
obtained
from
a
dataset
provided
by
EPA
representing
the
summer
2005
EPA
"
Green
Book."
This
dataset
gives
attainment
and
nonattainment
information
for
each
county
in
the
United
States.
In
this
dataset,
counties
that
are
divided
between
areas
that
are
categorized
differently
are
assigned
the
most
restrictive
of
the
relevant
nonattainment
classifications.
Ozone
attainment
status
and
nonattainment
classifications
used
in
this
analysis
are
based
on
the
8­
hour
ozone
standard.
In
addition,
PM2.5
status
is
based
on
the
1997
standard.

After
consulting
with
the
EPA
work
assignment
manager,
we
made
simplifying
assumptions
regarding
the
major
NSR
thresholds
for
sources
in
attainment
areas.
These
sources
are
subject
to
the
prevention
of
significant
deterioration
(
PSD)
regulations.
Specifically,
we
used
a
250
ton
per
year
(
tpy)
threshold
for
sources
in
all
source
categories,
rather
than
attempting
to
identify
sources
in
the
"
listed"
source
categories
which
are
subject
to
a
100
tpy
threshold
under
PSD.
In
addition,
we
evaluated
each
pollutant
against
the
250
tpy
threshold,
without
regard
to
whether
a
source
was
a
major
source
of
a
different
pollutant
(
i.
e.,
did
not
apply
the
lesser,
"
significant"
emission
rate
if
a
source
was
major
for
another
pollutant).

It
should
be
noted
that
the
point
sources
populating
the
NEI
are
primarily
the
larger
sources.
The
NEI
is
compiled
from
State
inventories,
and
States
typically
address
smaller
sources
through
their
area
source
inventories.
Thus,
while
the
NEI
contains
many
sources
with
low
emissions
of
one
or
more
pollutant,
most
are
likely
to
be
major
sources
of
at
least
one
pollutant.
In
this
respect,
the
NEI
is
likely
not
to
be
fully
representative
of
the
population
of
minor
sources
that
would
be
evaluated
for
minor
NSR
applicability.

A
factor
that
introduces
an
indeterminate
level
of
uncertainty
into
the
analysis
is
the
fact
that
the
NEI
provides
actual
annual
emissions,
while
NSR
applicability
typically
is
determined
based
on
potential
emissions.
It
is
likely
that
some
sources
were
placed
in
a
lower
category
based
on
actual
emissions
than
they
would
have
been
based
on
their
potential
emissions,
had
they
been
known.

Results
Attachment
2
presents
a
summary
of
the
results.
Table
2­
1
of
this
attachment
summarizes
the
results
for
the
proposed
minor
NSR
thresholds.
For
each
pollutant,
the
table
gives
the
total
number
of
facilities
in
the
NEI
and
the
total,
nationwide
emissions.
The
column
labeled
"
unregulated
minor
sources"
represents
the
percentage
of
total
sources
that
falls
below
the
minor
NSR
threshold,
along
with
the
percentage
of
total
annual
emissions
that
those
sources
emit.
The
"
minor
sources"
column
gives
the
same
information
for
sources
that
fall
between
the
minor
and
major
NSR
thresholds,
while
the
"
major
sources"
column
addresses
sources
that
exceed
the
major
NSR
threshold.
If
we
assume
that
the
distribution
of
new
sources
will
mirror
the
existing
source
distribution,
this
analysis
approximates
the
fraction
of
new
Memorandum:
Analysis
of
the
Proposed
Minor
NSR
Thresholds
3
sources
that
will
be
exempt
from
minor
NSR,
subject
to
minor
NSR,
and
subject
to
major
NSR.

Table
2­
1
shows
that,
for
each
pollutant,
only
about
1
percent
(
or
less)
of
total
emissions
would
be
exempt
from
review
under
the
minor
NSR
program
at
the
proposed
threshold
level
for
the
program.
However,
anywhere
from
42
percent
to
76
percent
of
sources
(
depending
on
the
pollutant)
would
be
below
the
proposed
threshold
and,
therefore,
exempt
from
preconstruction
review.

Tables
2­
2
and
2­
3
of
Attachment
2
summarize
the
results
for
two
alternative
cases.
In
Case
1,
we
examined
the
effect
of
increasing
the
minor
NSR
threshold
for
volatile
organic
compounds
(
VOCs).
In
Case
2,
we
evaluated
the
effect
of
increasing
the
minor
NSR
thresholds
for
all
the
pollutants.
These
tables
show
that
increasing
the
minor
NSR
thresholds
generally
has
a
small
effect
on
the
percentage
of
total
emissions
and
the
percentage
of
sources
that
would
be
exempt
from
minor
NSR
review.

Attachment
3
presents
the
full
results
of
the
analysis.
These
tables
show
the
distribution
of
sources
by
attainment
status
and
by
nonattainment
classification,
where
applicable.
1­
1
ATTACHMENT
1
Table
1­
1.
Proposed
Minor
NSR
Thresholds
and
Major
NSR
Thresholds
Attainment
Status
Proposed
Minor
NSR
Threshold
(
tpy)
Major
NSR
Threshold
(
tpy)

Carbon
monoxide
(
CO)

Attainment
Nonattainment
Serious
Moderate
10
5
5
250
50
100
Nitrogen
dioxide
(
NO2)

Attainment
(
no
nonattainment)
10
250
Sulfur
dioxide
(
SO2)

Attainment
Nonattainment
10
5
250
100
Particulate
matter
<
10
µ
m
(
PM10)

Attainment
Nonattainment
Serious
Moderate
5
1
1
250
70
100
Particulate
matter
<
2.5
µ
m
(
PM2.5)
(
attainment
status
based
on
1997
PM2.5
NAAQS)
Attainment
Nonattainment
3
0.6
250
100
Ozone
(
attainment
status
based
on
8­
hour
ozone
NAAQS)

Nitrogen
oxides
(
NOx)
Attainment
Nonattainment
Severe
Serious
Moderate
Marginal
10
5
5
5
5
250
25
50
100
100
Volatile
organic
compounds
(
VOC)
Attainment
Nonattainment
Severe
Serious
Moderate
Marginal
5
2
2
2
2
250
25
50
100
100
1­
2
Table
1­
2.
Case
1:
Alternative
Minor
NSR
Thresholds
for
VOC
(
Major
NSR
Thresholds
Unchanged)

Attainment
Status
Proposed
Minor
NSR
Threshold
(
tpy)
Major
NSR
Threshold
(
tpy)

Ozone
(
attainment
status
based
on
8­
hour
ozone
NAAQS)

Volatile
organic
compounds
(
VOC)
Attainment
Nonattainment
Severe
Serious
Moderate
Marginal
10
5
5
5
5
250
25
50
100
100
1­
3
Table
1­
3.
Case
2:
Alternative
Minor
NSR
Thresholds
for
All
Pollutants
(
Major
NSR
Thresholds
Unchanged)

Attainment
Status
Proposed
Minor
NSR
Threshold
(
tpy)
Major
NSR
Threshold
(
tpy)

Carbon
monoxide
(
CO)

Attainment
Nonattainment
Serious
Moderate
20
10
10
250
50
100
Nitrogen
dioxide
(
NO2)

Attainment
(
no
nonattainment)
20
250
Sulfur
dioxide
(
SO2)

Attainment
Nonattainment
20
10
250
100
Particulate
matter
<
10
µ
m
(
PM10)

Attainment
Nonattainment
Serious
Moderate
5
3
3
250
70
100
Particulate
matter
<
2.5
µ
m
(
PM2.5)
(
attainment
status
based
on
1997
PM2.5
NAAQS)
Attainment
Nonattainment
3
1
250
100
Ozone
(
attainment
status
based
on
8­
hour
ozone
NAAQS)

Nitrogen
oxides
(
NOx)
Attainment
Nonattainment
Severe
Serious
Moderate
Marginal
20
10
10
10
10
250
25
50
100
100
Volatile
organic
compounds
(
VOC)
Attainment
Nonattainment
Severe
Serious
Moderate
Marginal
20
10
10
10
10
250
25
50
100
100
2­
1
ATTACHMENT
2
Table
2­
1.
Summary
of
the
Distribution
of
Sources
and
Emissions
under
the
Proposed
Minor
NSR
Thresholds
Table
2­
2.
Summary
of
the
Distribution
of
Sources
and
Emissions
under
Case
1
Total
facilities
Unregulated
minor
sources
Minor
sources
Major
sources
Pollutant
No.
(
x103)
TPY
(
x106)
%
of
total
%
of
TPY
%
of
total
%
of
TPY
%
of
total
%
of
TPY
CO
SO2
PM10
PM2.5
Ozone
­
VOC
Ozone
 
NOx
NO2
28.9
21.2
33.9
33.8
43.3
30.5
30.5
4.43
13.90
1.69
1.33
1.60
7.93
7.93
65
76
65
59
42
53
59
0.8
0.1
1.3
0.8
1.1
0.4
0.6
29
16
32
38
53
36
32
11
1
22
23
41
6
7
6
8
4
3
5
11
9
88
99
76
76
58
93
92
Total
facilities
Unregulated
minor
sources
Minor
sources
Major
sources
Pollutant
No.
(
x103)
TPY
(
x106)
%
of
total
%
of
TPY
%
of
total
%
of
TPY
%
of
total
%
of
TPY
Ozone
­
VOC
43.3
1.60
56
2.8
39
39
5
58
2­
2
Table
2­
3.
Summary
of
the
Distribution
of
Sources
and
Emissions
under
Case
2
Total
facilities
Unregulated
minor
sources
Minor
sources
Major
sources
Pollutant
No.
(
x103)
TPY
(
x106)
%
of
total
%
of
TPY
%
of
total
%
of
TPY
%
of
total
%
of
TPY
CO
SO2
PM10
PM2.5
Ozone
­
VOC
Ozone
­
NOx
NO2
28.9
21.2
33.9
33.8
43.3
30.5
30.5
4.43
13.90
1.69
1.33
1.60
7.93
7.93
73
81
65
61
68
63
68
1.6
0.24
1.3
0.9
6.1
0.8
1.1
21
11
31
36
27
26
23
10
1.2
33
23
36
6
7
6
8
4
3
5
11
9
88
99
76
76
58
93
92
3­
1
ATTACHMENT
3
Table
3­
1.
CO
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Threshold
Sources
of
Carbon
Monoxide
(
CO)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
CO
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
CO
=
Attainment
+
Nonattainament
18,678
36,900
8,421
484,357
1,816
3,909,012
28,921
4,430,727
Attainment
Area
Sources
for
CO
>
10
TPY
>
250
TPY
16,768
35,477
8,166
480,421
1,728
3,829,929
26,662
4,345,827
Nonattainment
Area
Sources
for
CO**
=
Serious
+
Moderate
Nonattainment
1,910
1,423
255
3,936
88
79,083
2,259
84,900
Serious
Nonattainment
Areas
>
5
TPY
>
50
TPY
1,865
1,369
230
3,369
78
61,916
2,173
66,655
Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
45
53
25
567
10
17,166
80
17,786
Sources
of
Carbon
Monoxide
(
CO)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
CO
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
CO
=
Attainment
+
Nonattainament
65%
0.8%
29%
11%
6%
88%

Attainment
Area
Sources
for
CO
>
10
TPY
>
250
TPY
63%
0.8%
31%
11%
6%
88%

Nonattainment
Area
Sources
for
CO*
=
Serious
+
Moderate
Nonattainment
85%
1.7%
11%
5%
4%
93%

Serious
Nonattainment
Areas**
>
5
TPY
>
50
TPY
86%
2.1%
11%
5%
4%
93%

Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
56%
0.3%
31%
3%
13%
97%

*
Total
includes
6
facilities,
emitting
459
TPY
of
CO,
in
nonattainment
areas
defined
as
not
classified
that
are
not
included
in
the
minor/
major
breakdown
because
of
undefined
cutoffs.

**
This
analysis
assumes
that
stationary
sources
contribute
significantly
to
CO
levels
in
all
serious
nonattainment
areas.
3­
2
Table
3­
2.
SO2
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Threshold
Sources
of
Sulfur
Dioxide
(
SO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
SO2
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
SO2
=
Attainment
+
Nonattainament
16,209
18,089
3,296
183,932
1,709
13,700,139
21,214
13,902,160
Attainment
Area
Sources
for
SO2
>
10
TPY
>
250
TPY
16,068
17,964
3,222
182,134
1,667
13,380,132
20,957
13,580,230
Nonattainment
Area
Sources
for
SO2
>
5
TPY
>
100
TPY
141
125
74
1,798
42
320,006
257
321,929
Sources
of
Sulfur
Dioxide
(
SO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
SO2
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
SO2
=
Attainment
+
Nonattainament
76%
0.13%
16%
1.3%
8%
99%

Attainment
Area
Sources
for
SO2
>
10
TPY
>
250
TPY
77%
0.13%
15%
1.3%
8%
99%

Nonattainment
Area
Sources
for
SO2
>
5
TPY
>
100
TPY
55%
0.04%
29%
0.6%
16%
99%

Table
3­
3.
NO2
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Threshold
Sources
of
Nitrogen
Dioxide
(
NO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
NO2
>
10
TPY
>
250
TPY
17,869
45,509
9,881
572,764
2,739
7,310,616
30,490
7,928,889
Sources
of
Nitrogen
Dioxide
(
NO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
NO2
>
10
TPY
>
250
TPY
59%
0.6%
23%
7%
9%
92%

Note:
no
areas
are
listed
as
NO2
nonattainment
in
the
current
Green
Book
3­
3
Table
3­
4.
NOx
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Threshold
Sources
of
Oxides
of
Nitrogen
(
NOx)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
NOx
=
Attainment
+
Nonattainament
16,065
32,630
11,069
498,884
3,356
7,397,375
30,490
7,928,889
Ozone
Attainment
Area
NOx
Sources
>
10
TPY
>
250
TPY
7,006
19,915
5,943
380,657
1,841
4,865,540
14,790
5,266,112
Ozone
Nonattainment
Area
NOx
Sources
=
Sum
of
Nonattainment
Levels
9,059
12,714
5,126
118,227
1,515
2,531,836
15,700
2,662,777
Severe
Nonattainment
Areas
>
5
TPY
>
25
TPY
1,823
1,926
327
3,403
143
47,864
2,293
53,193
Serious
Nonattainment
Areas
>
5
TPY
>
50
TPY
446
507
187
2,701
36
12,934
669
16,142
Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
3,889
5,766
2,358
54,879
570
848,390
6,817
909,036
Marginal
Nonattainment
Areas
>
5
TPY
>
100
TPY
2,901
4,516
2,254
57,243
766
1,622,648
5,921
1,684,407
Sources
of
Oxides
of
Nitrogen
(
NOx)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
NOx
=
Attainment
+
Nonattainament
53%
0.4%
36%
6%
11%
93%

Ozone
Attainment
Area
NOx
Sources
>
10
TPY
>
250
TPY
47%
0.4%
40%
7%
12%
92%

Ozone
Nonattainment
Area
NOx
Sources
=
Sum
of
Nonattainment
Levels
58%
0.5%
33%
4%
10%
95%

Severe
Nonattainment
Areas
>
5
TPY
>
25
TPY
80%
3.6%
14%
6%
6%
90%

Serious
Nonattainment
Areas
>
5
TPY
>
50
TPY
67%
3.1%
28%
17%
5%
80%

Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
57%
0.6%
35%
6%
8%
93%

Marginal
Nonattainment
Areas
>
5
TPY
>
100
TPY
49%
0.3%
38%
3%
13%
96%
3­
4
Table
3­
5.
VOC
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Thresholds
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
18,403
17,355
22,848
653,926
2,094
924,411
43,345
1,595,692
Ozone
Attainment
Area
VOC
Sources
>
5
TPY
>
250
TPY
8,415
11,438
9,663
438,017
754
499,155
18,832
948,610
Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
9,988
5,917
13,185
215,909
1,340
425,256
24,513
647,082
Severe
Nonattainment
Areas
>
2
TPY
>
25
TPY
1,353
887
1,544
11,066
238
17,717
3,135
29,670
Serious
Nonattainment
Areas
>
2
TPY
>
50
TPY
548
234
216
2,130
13
1,866
777
4,231
Moderate
Nonattainment
Areas
>
2
TPY
>
100
TPY
3,363
1,702
4,774
84,413
390
141,157
8,527
227,271
Marginal
Nonattainment
Areas
>
2
TPY
>
100
TPY
4,724
3,094
6,651
118,300
699
264,516
12,074
385,910
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
42%
1.1%
53%
41%
5%
58%

Ozone
Attainment
Area
VOC
Sources
>
5
TPY
>
250
TPY
45%
1.2%
51%
46%
4%
53%

Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
41%
0.9%
54%
33%
5%
66%

Severe
Nonattainment
Areas
>
2
TPY
>
25
TPY
43%
3.0%
49%
37%
8%
60%

Serious
Nonattainment
Areas
>
2
TPY
>
50
TPY
71%
5.5%
28%
50%
2%
44%

Moderate
Nonattainment
Areas
>
2
TPY
>
100
TPY
39%
0.7%
56%
37%
5%
62%

Marginal
Nonattainment
Areas
>
2
TPY
>
100
TPY
39%
0.8%
55%
31%
6%
69%
3­
5
Table
3­
6.
PM10
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Thresholds
Sources
of
Particulate
Matter
<
10um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
(
PM10)
by
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
PM10
=
Attainment
+
Nonattainament
21,851
21,816
10,802
377,973
1,212
1,288,423
33,865
1,688,212
Attainment
Area
Sources
for
PM10
>
5
TPY
>
250
TPY
18,535
20,029
9,601
362,496
1,099
1,235,559
29,235
1,618,084
Nonattainment
Area
Sources
for
PM10
=
Serious
+
Moderate
Nonattainment
3,316
1,786
1,201
15,478
113
52,864
4,630
70,128
Serious
Nonattainment
Areas
>
1
TPY
>
70
TPY
1,902
1,444
374
6,245
45
14,291
2,321
21,981
Moderate
Nonattainment
Areas
>
1
TPY
>
100
TPY
1,414
342
827
9,233
68
38,572
2,309
48,147
Sources
of
Particulate
Matter
<
10um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
PM10)
by
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
PM10
=
Attainment
+
Nonattainament
65%
1.3%
32%
22%
4%
76%

Attainment
Area
Sources
for
PM10
>
5
TPY
>
250
TPY
63%
1.2%
33%
22%
4%
76%

Nonattainment
Area
Sources
for
PM10
=
Serious
+
Moderate
Nonattainment
72%
2.5%
26%
22%
2%
75%

Serious
Nonattainment
Areas
>
1
TPY
>
70
TPY
82%
6.6%
16%
28%
2%
65%

Moderate
Nonattainment
Areas
>
1
TPY
>
100
TPY
61%
0.7%
36%
19%
3%
80%
3­
6
Table
3­
7.
PM2.5
Facilities
and
Emissions
Under
the
Proposed
Minor
NSR
Thresholds
Sources
of
Particulate
Matter
<
2.5um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilties
(
PM2.5)
by
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
PM2.5
=
Attainment
+
Nonattainament
19,967
11,262
12,730
301,659
1,080
1,012,725
33,777
1,325,645
Attainment
Area
Sources
for
PM2.5
>
3
TPY
>
250
TPY
15,392
10,496
8,466
259,961
731
652,336
24,589
922,793
Nonattainment
Area
Sources
for
PM2.5
>
0.6
TPY
>
100
TPY
4,575
765
4,264
41,697
349
360,389
9,188
402,852
Sources
of
Particulate
Matter
<
2.5um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
PM2.5)
by
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
PM2.5
=
Attainment
+
Nonattainament
59%
0.8%
38%
23%
3%
76%

Attainment
Area
Sources
for
PM2.5
>
3
TPY
>
250
TPY
63%
1.1%
34%
28%
3%
71%

Nonattainment
Area
Sources
for
PM2.5
>
0.6
TPY
>
100
TPY
50%
0.2%
46%
10%
4%
89%
3­
7
Table
3­
8.
VOC
Facilities
and
Emissions
Under
Case
1
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
24,479
45,376
16,772
625,905
2,094
924,411
43,345
1,595,692
Ozone
Attainment
Area
VOC
Sources
>
10
TPY
>
250
TPY
10,466
26,205
7,612
423,250
754
499,155
18,832
948,610
Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
34,013
19,172
9,160
202,654
1,340
425,256
24,513
647,082
Severe
Nonattainment
Areas
>
5
TPY
>
25
TPY
2,097
3,362
800
8,591
238
17,717
3,135
29,670
Serious
Nonattainment
Areas
>
5
TPY
>
50
TPY
630
494
134
1,870
13
1,866
777
4,231
Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
4,634
5,894
3,503
80,221
390
141,157
8,527
227,271
Marginal
Nonattainment
Areas
>
5
TPY
>
100
TPY
6,652
9,421
4,723
111,972
699
264,516
12,074
385,910
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
56%
2.8%
39%
39%
5%
58%

Ozone
Attainment
Area
VOC
Sources
>
10
TPY
>
250
TPY
56%
2.8%
40%
45%
4%
53%

Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
57%
3.0%
37%
31%
5%
66%

Severe
Nonattainment
Areas
>
5
TPY
>
25
TPY
67%
11.3%
26%
29%
8%
60%

Serious
Nonattainment
Areas
>
5
TPY
>
50
TPY
81%
11.7%
17%
44%
2%
44%

Moderate
Nonattainment
Areas
>
5
TPY
>
100
TPY
54%
2.6%
41%
35%
5%
62%

Marginal
Nonattainment
Areas
>
5
TPY
>
100
TPY
55%
2.4%
29%
29%
6%
69%
3­
8
Table
3­
9.
CO
Facilities
and
Emissions
Under
Case
2
Sources
of
Carbon
Monoxide
(
CO)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
CO
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
CO
=
Attainment
+
Nonattainament
20,969
68,961
6,130
452,296
1,816
3,909,012
28,921
4,430,727
Attainment
Area
Sources
for
CO
>
20
TPY
>
250
TPY
18,938
66,686
5,996
449,212
1,728
3,829,929
26,662
4,345,827
Nonattainment
Area
Sources
for
CO**
=
Serious
+
Moderate
Nonattainment
2,031
2,275
134
3,083
88
79,083
2,259
84,900
Serious
Nonattainment
Areas
>
10
TPY
>
50
TPY
1,976
2,151
119
2,588
78
61,916
2,173
66,655
Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
55
124
15
495
10
17,166
80
17,786
Sources
of
Carbon
Monoxide
(
CO)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
CO
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
CO
=
Attainment
+
Nonattainament
73%
1.6%
21%
10%
6%
88%

Attainment
Area
Sources
for
CO
>
20
TPY
>
250
TPY
71%
1.5%
22%
10%
6%
88%

Nonattainment
Area
Sources
for
CO*
=
Serious
+
Moderate
Nonattainment
90%
2.7%
6%
4%
4%
93%

Serious
Nonattainment
Areas**
>
10
TPY
>
50
TPY
91%
3.2%
5%
4%
4%
93%

Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
69%
0.7%
19%
3%
13%
97%

*
Total
includes
6
facilities,
emitting
459
TPY
of
CO,
in
nonattainment
areas
defined
as
not
classified
that
are
not
included
in
the
minor/
major
breakdown
because
of
undefined
cutoffs.

**
This
analysis
assumes
that
stationary
sources
contribute
significantly
to
CO
levels
in
all
serious
nonattainment
areas.
3­
9
Table
3­
10.
SO2
Facilities
and
Emissions
Under
Case
2
Sources
of
Sulfur
Dioxide
(
SO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
SO2
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
SO2
=
Attainment
+
Nonattainament
17,271
33,159
2,234
168,862
1,709
13,700,139
21,214
13,902,160
Attainment
Area
Sources
for
SO2
>
20
TPY
>
250
TPY
17,105
32,856
2,185
167,242
1,667
13,380,132
20,957
13,580,230
Nonattainment
Area
Sources
for
SO2
>
10
TPY
>
100
TPY
166
303
49
1,620
42
320,006
257
321,929
Sources
of
Sulfur
Dioxide
(
SO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
SO2
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
SO2
=
Attainment
+
Nonattainament
81%
0.24%
11%
1.2%
8%
99%

Attainment
Area
Sources
for
SO2
>
20
TPY
>
250
TPY
82%
0.24%
10%
1.2%
8%
99%

Nonattainment
Area
Sources
for
SO2
>
10
TPY
>
100
TPY
65%
0.09%
19%
0.5%
16%
99%

Table
3­
11.
NO2
Facilities
and
Emissions
Under
Case
2
Sources
of
Nitrogen
Dioxide
(
NO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
NO2
>
20
TPY
>
250
TPY
20,730
86,160
7,020
532,113
2,739
7,310,616
30,490
7,928,889
Sources
of
Nitrogen
Dioxide
(
NO2)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
NO2
>
20
TPY
>
250
TPY
68%
1.1%
23%
7%
9%
92%

Note:
no
areas
are
listed
as
NO2
nonattainment
in
the
current
Green
Book
3­
10
Table
3­
12.
NOx
Facilities
and
Emissions
Under
Case
2
Sources
of
Oxides
of
Nitrogen
(
NOx)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
NOx
=
Attainment
+
Nonattainament
19,310
65,932
7,824
465,582
3,356
7,397,375
30,490
7,928,889
Ozone
Attainment
Area
NOx
Sources
>
20
TPY
>
250
TPY
8,446
40,338
4,503
360,234
1,841
4,865,540
14,790
5,266,112
Ozone
Nonattainment
Area
NOx
Sources
=
Sum
of
Nonattainment
Levels
10,864
25,594
3,321
105,348
1,515
2,531,836
15,700
2,662,777
Severe
Nonattainment
Areas
>
10
TPY
>
25
TPY
2,029
3,404
121
1,924
143
47,864
2,293
53,193
Serious
Nonattainment
Areas
>
10
TPY
>
50
TPY
526
1,074
107
2,135
36
12,934
669
16,142
Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
4,723
11,688
1,524
48,958
570
848,390
6,817
909,036
Marginal
Nonattainment
Areas
>
10
TPY
>
100
TPY
3,586
9,429
1,569
52,331
766
1,622,648
5,921
1,684,407
Sources
of
Oxides
of
Nitrogen
(
NOx)
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
NOx
=
Attainment
+
Nonattainament
63%
0.8%
26%
6%
11%
93%

Ozone
Attainment
Area
NOx
Sources
>
20
TPY
>
250
TPY
57%
0.8%
30%
7%
12%
92%

Ozone
Nonattainment
Area
NOx
Sources
=
Sum
of
Nonattainment
Levels
69%
1.0%
21%
4%
10%
95%

Severe
Nonattainment
Areas
>
10
TPY
>
25
TPY
88%
6.4%
5%
4%
6%
90%

Serious
Nonattainment
Areas
>
10
TPY
>
50
TPY
79%
6.7%
16%
13%
5%
80%

Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
69%
1.3%
22%
5%
8%
93%

Marginal
Nonattainment
Areas
>
10
TPY
>
100
TPY
61%
0.6%
26%
3%
13%
96%
3­
11
Table
3­
13.
VOC
Facilities
and
Emissions
Under
Case
2
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
29,682
97,923
11,569
573,358
2,094
924,411
43,345
1,595,692
Ozone
Attainment
Area
VOC
Sources
>
20
TPY
>
250
TPY
12,597
56,874
5,481
392,581
754
499,155
18,832
948,610
Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
17,085
41,050
6,088
180,776
1,340
425,256
24,513
647,082
Severe
Nonattainment
Areas
>
10
TPY
>
25
TPY
2,536
6,432
361
5,521
238
17,717
3,135
29,670
Serious
Nonattainment
Areas
>
10
TPY
>
50
TPY
691
933
73
1,431
13
1,866
777
4,231
Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
5,710
13,553
2,427
72,561
390
141,157
8,527
227,271
Marginal
Nonattainment
Areas
>
10
TPY
>
100
TPY
8,148
20,130
3,227
101,263
699
264,516
12,074
385,910
Sources
of
Volatile
Organic
Compounds
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
VOC)
by
8­
hr
Ozone
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
VOC
=
Attainment
+
Nonattainament
68%
6.1%
27%
36%
5%
58%

Ozone
Attainment
Area
VOC
Sources
>
20
TPY
>
250
TPY
67%
6.0%
29%
41%
4%
53%

Ozone
Nonattainment
Area
VOC
Sources
=
Sum
of
Nonattainment
Levels
70%
6.3%
25%
28%
5%
66%

Severe
Nonattainment
Areas
>
10
TPY
>
25
TPY
81%
21.7%
12%
19%
8%
60%

Serious
Nonattainment
Areas
>
10
TPY
>
50
TPY
89%
22.1%
9%
34%
2%
44%

Moderate
Nonattainment
Areas
>
10
TPY
>
100
TPY
67%
6.0%
28%
32%
5%
62%

Marginal
Nonattainment
Areas
>
10
TPY
>
100
TPY
67%
5.2%
27%
26%
6%
69%
3­
12
Table
3­
14.
PM10
Facilities
and
Emissions
Under
Case
2
Sources
of
Particulate
Matter
<
10um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilities
(
PM10)
by
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
PM10
=
Attainment
+
Nonattainament
22,036
21,846
10,617
377,944
1,212
1,288,423
33,865
1,688,212
Attainment
Area
Sources
for
PM10
>
5
TPY
>
250
TPY
18,535
20,029
9,601
362,496
1,099
1,235,559
29,235
1,618,084
Nonattainment
Area
Sources
for
PM10
=
Serious
+
Moderate
Nonattainment
3,501
1,816
1,016
15,448
113
52,864
4,630
70,128
Serious
Nonattainment
Areas
>
3
TPY
>
70
TPY
1,767
910
509
6,780
45
14,291
2,321
21,981
Moderate
Nonattainment
Areas
>
3
TPY
>
100
TPY
1,734
906
507
8,668
68
38,572
2,309
48,147
Sources
of
Particulate
Matter
<
10um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
PM10)
by
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
PM10
=
Attainment
+
Nonattainament
65%
1.3%
31%
22%
4%
76%

Attainment
Area
Sources
for
PM10
>
5
TPY
>
250
TPY
63%
1.2%
33%
22%
4%
76%

Nonattainment
Area
Sources
for
PM10
=
Serious
+
Moderate
Nonattainment
76%
2.6%
22%
22%
2%
75%

Serious
Nonattainment
Areas
>
1
TPY
>
70
TPY
76%
4.1%
22%
31%
2%
65%

Moderate
Nonattainment
Areas
>
1
TPY
>
100
TPY
75%
1.9%
22%
18%
3%
80%
3­
13
Table
3­
15.
PM2.5
Facilities
and
Emissions
Under
Case
2
Sources
of
Particulate
Matter
<
2.5um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
Total
Facilties
(
PM2.5)
by
Attainment
Status
Potential
Minor
Major
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
#
fac.
TPY
All
Sources
Emitting
PM2.5
=
Attainment
+
Nonattainament
20,969
11,831
12,001
301,090
1,080
1,012,725
33,777
1,325,645
Attainment
Area
Sources
for
PM2.5
>
3
TPY
>
250
TPY
15,392
10,496
8,466
259,961
731
652,336
24,589
922,793
Nonattainment
Area
Sources
for
PM2.5
>
1
TPY
>
100
TPY
5,304
1,334
3,535
41,129
349
360,389
9,188
402,852
Sources
of
Particulate
Matter
<
2.5um
Source
Category
Thresholds
(
TPY)
Unregulated
Minors
Minor
Sources
Major
Sources
(
PM2.5)
by
Attainment
Status
Potential
Minor
Major
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
%
of
fac.
%
of
TPY
All
Sources
Emitting
PM2.5
=
Attainment
+
Nonattainament
61%
0.9%
36%
23%
3%
76%

Attainment
Area
Sources
for
PM2.5
>
3
TPY
>
250
TPY
63%
1.1%
34%
28%
3%
71%

Nonattainment
Area
Sources
for
PM2.5
>
1
TPY
>
100
TPY
58%
0.3%
38%
10%
4%
89%
