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EPA Releases Guidance on Compliance Demonstration for Ozone and Fine Particles in the PSD Program

In a memorandum dated April 17, 2018, EPA released guidance on significant impact levels (SIL) for each ozone and PM2.5…
In a memorandum dated April 17, 2018, EPA released guidance on significant impact levels (SIL) for each ozone and PM2.5 National Ambient Air Quality Standard (NAAQS) and for the PM2.5 Prevention of Significant Deterioration (PSD) increments. Permitting authorities may use the SILs when determining whether a proposed PSD source causes or contributes to a violation of a NAAQS or PSD increment in order to simplify the permitting process. Permitting authorities may choose use the SIL values to determine whether a proposed source will have a significant or meaningful impact on air quality. EPA intends to use a two-step process, in which these SILs provide a test run, in which permitting authorities may gain experience and information when usin their discretion and considering indiviudal permitting applications. EPA will then assess, refine, and potentially codify SIL values and specific applications of those values in a future rulemaking.
Permitting authorities may develop their own SIL values if they are supported in the record for permitting actions or decisions. The discretion of EPA and permitting authorities is limited by the 2010 rulemaking. Since the rule established by regulation that a PM2.5 impact greater than a certain value will be considered to cause or contribute to a NAAQS violation, the permitting authorities may not use a value higher than the PM2.5 SIL values for NAAQS. Because ozone is not addressed in 40 CFR 51.165(b)(2), authorities may develop a higher ozone NAAQS SIL value than the recommended value. 40 CFR 51.165(b)(2) does not address PSD increments, so permitting authorities may develop a higher SIL value for PSD increment purposes. EPA intends to learn from permitting authorities voluntary use of the SIL values during the permitting process to determine whether the use of SILs are appropriate.
The recommended SIL values for NAAQS are:
* The table accounts for the significance level for the 24-hour PM2.5 NAAQS in 40 CFR 51.165(b)(2). Refer to the guidance discussion for details
The recommended SIL values for ozone and PM2.5 NAAQS are the same regardless of the airshed class.
The recommended SIL values for PSD Increments are:
There are no PSD increments for ozone, so EPA has not calculated ozone SIL values for PSD increment compliance purposes.
Table 1. Recommended SIL Values for Ozone and PM2.5 NAAQS | |
Criteria Pollutant (NAAQS level) | NAAQS SIL concentration |
Ozone 8-hour (70 ppb) | 1.0 ppb |
PM2.5 24-hour (35 µg/m3 ) | 1.2 µg/m3 * |
PM2.5 annual (12 µg/m3 or 15 µg/m3 ) | 0.2 µg/m3 |
Table 2. Recommended SIL Values for PM2.5 PSD Increments | |||
Criteria Pollutant (averaging period) | PSD increment SIL concentration | ||
Class I | Class I | Class III | |
PM2.5 (24-hour) | 0.27 µg/m3 | 1.2 µg/m3 | 1.2 µg/m3 |
PM2.5 (annual) | 0.05 µg/m3 | 0.2 µg/m3 | 0.2 µg/m3 |
Sources:Memorandum from Peter Tsirigotis, Guidance on Significant Impact Levels for Ozone and Fine Particles in the Prevention of Significant Deterioration Permitting Program, April 17, 2018
Legal Memorandum, Application of Significant Impact Levels in the Air Quality Demonstration for Prevention of Significant Deterioration Permitting under the Clean Air Act, April 13, 2018
Peer Review Report for the Technical Basis for the EPA’s Development of Significant Impact Thresholds for PM2.5 and Ozone, March 2018