44 



expeditiously to issue final guidance on this issue. Hadson 

 decision at 15. 



While EPA's Director of the Office of Air Quality Planning 

 and Standards issued a memorandum on October 19, 1992 indicating 

 that large sources beyond 100 kilometers need to be considered 

 when such impacts reasonably could affect the outcome of the 

 Class I analysis, EPA needs to go further and make clear that all 

 major sources within 200 kilometers of Class 1 areas and large 

 sources beyond 200 kilometers should at least be screened with 

 regard to whether they contribute to Class I increment 

 consumption and whether they can contribute to adverse impacts on 

 air quality-related values. The Interagency Working Group on Air 

 Quality Modeling has recommended the use of models that can 

 routinely be used for calculating impacts from sources at 

 distances of 200 kilometers, and can be applied to mega-sources 

 locating beyond 200 kilometers from Class I areas. 



The Hadson decision also briefly addressed the issue of 

 offsetting new PSD emissions with reductions of emissions from 

 existing sources. While EPA noted that offsets are not 

 specifically required by law, they are a means to alleviate an 

 adverse impact, thus allowing the permit to issue. Through the 

 PSD process in Virginia, applicants have offered offsets in an 

 attempt to resolve the federal land managers' concerns. 

 Unfortunately, there are no rules for assessing the validity of 

 these offsets and whether they in fact offset the adverse impact. 

 We believe that EPA should adopt an offset policy that will allow 

 new sources to replace existing dirtier sources and ensure that 

 the reductions in existing emissions will offset the contribution 

 of the new source to adverse impacts at the Class I area. 



(2) What do vou view as the positive impact of the PSD 

 program ? 



The efforts of the National Park Service, U.S. Forest 

 Service and the environmental community in the PSD program in 

 Virginia have yielded some positive results, but they are not 

 sufficient to protect and remedy the existing adverse impacts at 

 the Class I areas in the Southern Appalachians. The first 

 positive impact of the PSD process in Virginia has been the 

 tighter pollution controls required on new coal-burning 

 facilities in the state. The Virginia Department of Air 

 Pollution Control required selective catalytic reduction on the 

 Cogentrix of Dinwiddie permit, the Hadson-Buena Vista permit and 

 most recently, the SEI-Birchwood plant just east of 

 Fredericksburg, Virginia. SEI-Birchwood is a 220 megawatt coal- 

 fired plant that has received a PSD permit that will require a 

 NO x design rate of .1 lbmm/btu with a maximum emission limit of 

 .15 lbmm/btu. 



