Transcript No Slide Title

NEW COAL-BASED POWER
PLANT PERMITTING
Kevin J. Finto
Hunton & Williams
APPA
New Generation: Emerging Technologies and Financing
San Antonio, Texas
February 17-18, 2005
www.hunton.com
OVERVIEW
1.
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Why Are We Interested in Permitting Coal-Fired
Power Plants?
The Permitting Process
Permitting for a New Unit at an Existing Plant
Permitting New Facilities
Key Points
Procedural
a. Pre-Application Processes
b. Coordinating with Federal and State Agencies
c. Endangered Species Act Issues
d. Public Participation Process
7. Substantive Issues
a. Defining the Source
b. BACT
c. MACT
d. Enforceability
e. Air Quality Modeling Issues
www.hunton.com
WHY WE ARE INTERESTED IN
COAL-FIRED GENERATION
Percentage Electrical Generation by Fuel Type*
Gas/Oil
Nuclear
Renewables
Coal
18.8 %
19.7 %
10.7 %
50.8 %
* Statistics from EEI.org
Trends in Fossil Fuel Costs**
Gas
Oil
Coal
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** www.eia.doe.gov
Current as of 2/14/05
2002
2.95
24.45
25.52
2005
6.04 $/mmBtu
48.25 $/barrel
36.38 $/ton (Illinois basin)
PUBLIC POLICY ISSUES
www.hunton.com
Local:
Land use and siting issues
Local Support
National:
CAA and other environmental
permitting and regulatory issues
National security
International:
Carbon regulation
Sierra Club Legal Defense Fund (9/16/04):
“In general, our long-term objective is to make sure
that coal-fired plants get closed. Eventually, with
enough attacks against coal-fired plants, there will
be action to shut them down.”
PUBLIC POLICY ISSUES
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Develop public interest support
Low cost energy is vital to public health
and welfare especially for low and fixed
income citizens ( Klein Keeney report)
Low cost energy from coal is vital to
economy and national security (National
Coal Council: Opportunity to Expedite the
Construction of New Coal-based Power
Plants.
THE PERMITTING PROCESS
Pre-permitting activities
• Site analysis
• Community relations
• Preparation of application
The permit proceeding
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Building the record
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Avoiding delays
Permit appeals
Construction
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Operation
SUBSTANTIVE ISSUES
“Traditional” new source permitting issues
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Air quality analysis
BACT/LAER analyses
Air quality-related values and the FLM
State Air Toxics Rules
“New” issues
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Defining the source: IGCC/CFB/PC as BACT/LAER?
Endangered species review
MACT and mercury
Anticipating NSR modification analyses
Clear Skies, CAIR, NSPS and other new
requirements/regulatory regimes
PERMITTING PROCESS
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Optimizing a Plant and Permit Given the
Constraints Imposed.
 Constraints
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The Law (BACT/MACT/LAER, Air Quality Requirements,
Others)
Fuel Characteristics
Site Characteristics
Economics
Public Policy
Opposition
Need to Provide Certainty of the Goal and
Flexibility in Achieving It. Need to preserve
options
Permitting for New Unit at
Existing Plant
Options for Avoiding NSR
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Netting
Plantwide Applicability Limitations (PALs)
These options may be available for some,
but not all regulated pollutants
Netting
§52.21(b)(3)(i) – Net emissions increase
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means the amount by which the sum of
the following exceeds zero:
(a) Any increase in actual emissions from a
particular physical change … at a
stationary source; and
(b) Any other increases and decreases in
actual emissions at the source that are
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“contemporaneous”
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and “otherwise creditable”
Netting
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Contemporaneous period:
 5 years under federal rules
 States may adopt different periods
Decreases creditable only to the extent:
 Ambient impacts are the same
 Lower of old actual or allowable emissions
exceeds new level of actual emissions
 Enforceable
 Quantifiable
PAL Definition
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An emission limitation expressed in tons
per year, for a pollutant at a major
stationary source, that is enforceable as a
practical matter and established sourcewide in accordance with EPA’s PAL rules.
Effect of a PAL
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If you have a PAL, you can make emission
changes (including alterations to existing
emissions units and the addition of new
emissions units) without triggering new
source review.
Establishing a PAL
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Must apply for a PAL
Application must list all emissions units, their
size, all federal and state requirements
applicable to each emissions unit, and
baseline actual emissions for each emissions
unit
PAL must be established in a federally
enforceable permit
Reviewing authority must provide
opportunity for public participation, including
a comment period and the opportunity for a
public hearing on the PAL
Determining the PAL Level
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For each covered pollutant, baseline actual
emissions are added to an amount equal to
the applicable significance level per PAL
pollutant.
Determine baseline actual emissions using
the same 24-month period for all units.
Applicant may use allowable emissions for
any emissions unit added to the facility after
the selected 24-month period, but must
subtract emissions from units permanently
shutdown.
Determining the PAL Level
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Baseline actual emissions cannot exceed
emission limit allowed by current permits or
applicable rules (e.g., NSPS, RACT)
Set pollutant by pollutant
Can cover one or more pollutants
Expressed as TPY per pollutant
Term of PAL
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The term of a PAL is 10 years.
Between 6 and 18 months prior to expiration
of a PAL, permit holder must apply either to
request renewal or expiration of the PAL
When a PAL Expires
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Once a PAL expires, physical and
operational changes are no longer
evaluated under the PAL applicability
provisions.
Source owner must comply with any
applicable federal or requirement for a
specific emissions unit (e.g., BACT, RACT,
NSPS).
Limits eliminated by a PAL (e.g., 52.21(r)
limits) do not return upon PAL expiration.
PAL Renewal
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A source owner applying to renew a PAL
must recalculate the maximum PAL level,
taking into account newly applicable
requirements.
The new PAL level may not exceed the
source’s PTE.
PAL Renewal
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The permitting authority may renew a
source’s PAL at the original PAL level
without consideration of other factors if
the sum of the baseline actual emissions
for emissions units at the source (plus
significance levels) is equal to or greater
than 80% of the original PAL level.
“Use it or lose it”
PAL Renewal
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If the recalculated baseline plus
significance level value is less than 80% of
the original PAL level, the permitting
authority may set the PAL at a level that it
believes is appropriate, taking into
account air quality needs, advances in
control technology, anticipated economic
growth in the area, and other factors
identified by the authority.
Monitoring in PAL Permits
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Each permit must contain enforceable
requirements that accurately determine
plantwide emissions on a rolling 12-month
basis.
Recordkeeping in PAL Permits
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5 years from date most records are made
Term of PAL plus 5 years for the PAL
permit application and certifications of
compliance
Reporting in PAL Permits
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Semi-annual reporting is required.
Reports are to list all deviations or
monitoring malfunctions.
Each such report is to be signed by the
responsible official who certifies the
accuracy of the report
The Permitting Process
Key Points
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Think Backwards – “What Do I Need on Appeal?”
Anticipate Issues and Provide Solutions in the
Record
Keep the Momentum Moving Forward
Understand What is Required Versus What is
Desired – FLAG and Draft NSR Manual Are Not
Law
Join the Network – But Watch Out for the Folklore
Use Caution and Maintain Credibility
Preparing For The Permit
Challenge
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Plan Ahead – Build the Record
Know the Process and Standard of Review
 “Open” or “Closed” Record?
 When Does the Record Close?
 De Novo or Deference?
 Burden of Proof
 Choose your experts accordingly
Don’t Rely on Agency to Build a Good
Record – Be Proactive
Examples
Collecting Necessary Information
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Much of the Information Needed for a Permit
is Available in the Public Domain
Examples Include:
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Ambient Air Quality Monitoring
Meteorological Data
Source Inventories
Monitoring Information
Technology Databases
Think About Why the Information Was
Collected
Quality Assurance/Quality Control Issues
Remember That Many of the Permit Analyses
Are Case-by-Case
Meet With The Agencies
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Pre-Application Meetings
Site Visits
Determine the Level of Expertise in BACT/MACT,
Modeling and Other Areas
Be Prepared to Educate and Supplement
Resources
Identify Particular Concerns
Establish a Long-Term Working Relationship –
You Can’t Do This in a Vacuum and Neither Can
the Agency
Preparing the Permit Application
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Tell Your Story –Why is this project
“optimum” and in the public interest
Be Objective
Tell What You Did and Why
Tell What You Didn’t Do and Why Not
Look for Checklists
Include the Backup Information
Be Prepared for an Iterative Process
Coordinating With Federal and
State Agencies
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PSD Does Not Trigger NEPA
PSD Regulations Do Require Coordination With
Other Agencies in Their Compliance with NEPA.
40 C.F.R. § 52.21(s)
State Public Service Corporation Review
(economic development and increment)
Army Corps of Engineers Review
State Regulation (e.g., air toxics, little NEPAs,
State ESA)
ESA Issues
WHY THE ESA MATTERS
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Recent decisions and activities have
triggered ESA review in the context of
air permitting for power plants
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EPA has determined that PSD permitting by
delegated state is “federal action” triggering Section
7 of ESA
Sierra Club has filed notices of citizen suits against
EPA for failure to consider ESA in Title V permit
review
WHY THE ESA MATTERS
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ESA consultation process =
 Delay
 $
 Project Design or Operation Changes
 Uncertainty
FWS Can be Aggressive
(especially if they coordinate on visibility and
ESA issues)
Environmental Groups Aware of ESA’s Power to
Delay and Change a Project
ESA BASICS–CONSULTATION
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Endangered Species / “Critical Habitat”
+
Discretionary Federal Action (permitting or
funding) Affecting Species or Habitat
=
Requirement to Consult with Fish &
Wildlife Service
EXIT RAMPS
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No federal action
No discretionary authority affecting species or habitat
Screening Level Ecological Risk Assessment / ECO
Risk Software
No Effect – Convince State (if involved) and Federal
Agencies that Permitting the Plant Will Have No Effect
on Endangered Species and “Critical Habitat”
Not Likely to Adversely Affect and FWS Concurrence
Informal Consultation (Biological Assessment)
Formal Consultation (Biological Opinion/Incidental
Take Statement)
ESA BASICS-TAKE
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Prohibition on “Take”
“Take” broadly defined to include:
 Harm
 Adverse modification of habitat
Prohibition applies with or without Federal
action and consultation
Take requires “Incidental Take Permit”
Unpermitted take = liability
Examples; Wind energy; air emissions
ASSESSING ESA CONCERNS
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Potential causes of impacts
 Plant site
 Area of impact
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Associated facilities
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Air emissions
Water intake and discharge
Mine site
Transmission lines
Roads
Off-site construction area
Consider Migratory versus Local Species
OTHER LAWS OF CONCERN
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State Endangered Species Laws
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Fish and Wildlife Coordination Act
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National Historic Preservation Act
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Migratory Bird Treaty Act
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Bald and Golden Eagle Protection Act
Public Participation Process
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Build a Record So That the Public Can
Follow It
Work With the Agency to Ensure
Compliance with Public Participation
Requirements, Especially Public Notice
File Your Own Responses to Comments
Work With Permitting Agency to Ensure
Well Documented Permit Package
Commence Construction / Get an
extension (keep the permit alive)
Substantive Issues
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Defining the Source
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Case-by-Case Analysis
Operational Limits of the “Source”
 Tail Wagging the Dog Problem
 Common ownership
 Contiguous
 Same SIC Code
Restrictions on Construction (e.g., Retrofit)
Restrictions on Operation (e.g., Type of Fuel)
Type of Combustion
BACT/MACT
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Best Available Control Technology
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What is BACT? (It’s a limit)
Best Available Control Technology means an
emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for
each pollutant subject to regulation under Act which
would be emitted from any proposed major stationary
source or major modification which the Administrator, on
a case-by-case basis, taking into account energy,
environmental, and economic impacts and other costs,
determines is achievable for such source or modification
through application of production processes or available
methods, systems, and techniques, including fuel
cleaning or treatment or innovative fuel combustion
techniques for control of such pollutant. . . .
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Best Available Control
Technology
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( No, it’s a work practice)
If the Administrator determines that technological or
economic limitations on the application of
measurement methodology to a particular emissions
unit would make the imposition of an emissions
standard infeasible, a design, equipment, work
practice, operational standard, or combination thereof,
may be prescribed instead to satisfy the requirement
for application of best available control technology.
Such standard shall, to the degree possible, set forth
the emissions reduction achievable by implementation
of such design, equipment, work practice or
operation, and shall provide for compliance by means
which achieve equivalent results.
40 C.F.R. § 52.21(12)
Best Available Control
Technology
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BACT is an Emission Limit or Work Practice
BACT is a Case-by-Case Analysis
What is “Achievable”
What is “Available”
BACT Does Not Redefine the Source
BACT is Done on a Pollutant-by-Pollutant Basis
BACT Considers Multi-Pollutant Effects
BACT Considers Environmental, Energy and
Economic Costs
Best Available Control
Technology
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Information That Must Be Considered
 Other Permits
 RACT/BACT/LAER Clearinghouse
 Draft or Proposed Permits
 Permit Applications
 NSPS Proposal February 9, 2005
Best Available Control
Technology
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Other sources
 CEMs Data
 Source Tests
 Foreign Experience
 Vendor Guarantees
 Vendor Literature
Best Available Control
Technology
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BACT is not the lowest level ever recorded
Need for a Cushion
What Can Be Achieved Under Worst-Case,
Reasonably Foreseeable Circumstances
Not the Best Day or the Average Day
Long term achievability
IGCC as BACT
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“Defining the Source”
Greg Foote white paper
ED Memorandum to Utah DEQ
View of states/EPA HQ
NESCAUM briefs in several proceedings
We Energy
Practical advice
MACT
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NSPS Proposed Rule February 10, 2005
Proposed Rule – January 30, 2004
Supplemental Notice – March 16, 2004
Much Concern Over Feasibility of Proposed
Limits
Preambles Offer Some Insights
Case-by-Case MACT
 What is Demonstrated in Practice
 MACT Floor
Rule Due on March 15, 2005
Lot’s of possibilities.
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Enforceability
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New Source
Permitting Scenarios
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Preconstruction permitting only
 Title V permit application within 12 months
after start-up (unless state requires earlier)
Parallel processing (state requires
submission of Title V application earlier
but processes separately)
New Source
Permitting Scenarios
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Combined preconstruction/Title V
permitting program
 If state has adequate authority and NSR
programs uses “enhanced procedures”
that are substantially equivalent to Title V
 Could result in greater involvement of EPA
and public in PSD permitting (because of
veto authority and petition process)
Historical View of
Practical Enforceability
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To be “practically enforceable,” preconstruction
permitting requirements must contain
 A clearly defined emission limit and identify the
portion of source to which it applies
 A time period, e.g., 24-hours, daily, monthly,
annually
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Consistent with the substantive requirement
Consistent with the compliance method
A clearly defined compliance method, including
monitoring recordkeeping and reporting
Title V Monitoring
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Title V added “Periodic Monitoring”
 Applies if underlying requirement imposes
no requirement for ongoing testing (e.g.,
only startup performance tests)
 Must specify a frequency for additional
testing
No separate “sufficiency monitoring”
requirement (Jan. 2004 EPA rule)
Compliance Assurance
Monitoring (CAM)
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“Enhanced monitoring” implemented through
Title V
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An active control device is needed to meet limit
There is no “continuous compliance method” (e.g., CEMS)
CAM Plan must include
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Control device indicators to be monitored
Acceptable operating ranges (or process for developing
ranges or trigger levels)
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Necessary when CAM applies during preconstruction permitting
Must include a schedule for testing
Monitor performance criteria
Compliance Assurance
Monitoring (CAM)
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Permit will include enforceable obligation
to investigate and take corrective action
Must submit CAM Plan with Title V permit
application
Then and Now
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Historically, monitoring and testing in
preconstruction permits has ranged from AP-42,
to startup performance test, to CEMS
Title V adds
 A minimum frequency of testing after startup
 CAM as indicator monitoring for some emission
limits
Increasingly, citizen groups and agencies
insisting on continuous monitoring at
preconstruction stage
 Preference for CEMS
 Enforceable operating parameters where CEMS
not available
Implementation Issues
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Most issues are with PM and HAPS (SO2,
NOx, CO CEMS well proven in coal-fired
application)
Particulate matter (PM)
 PM CEMS
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EPA finalized Performance Specification (PS 11) and
quality assurance/quality control (Procedure 2) in
January 2004
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Utility Air Regulatory Group (UARG), Cement Kiln
Recycling Coalition, and Portland Cement Association have
challenged
Implementation Issues
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PM CEMS
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Technical issues
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Technology requires “calibration” to Method
5, calibration curves can change
Single point monitoring not account for
stratification
EPA statistics allows data with significant
error band to pass
Existing BACT/LAER standards not based
on PM CEMS data
Implementation Issues
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PM CEMS
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Applications to PSD permits
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Region 8 has commented to state that PM
CEMS should be required for new source
(headquarters says not national policy)
Two states have issued PSD permit with PM
CEMS requirement
Anticipate this will be an issue in most new coalfired source permits
Implementation Issues
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PM CEMS
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Defenses
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PM CAM Plan
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PS 11 preamble states that PM CEMS apply when
required by rulemaking and that additional industryspecific operational requirements may be required
(NSPS)
PM CEMS Technical documents acknowledge need
to establish limit with PM CEMS data
Difficult and complex because stack emissions are
affected by multiple control technologies
May need to propose multiple options and collect
test data prior to finalizing
Implementation Issues
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Hg
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Hg CEMS and Method 324 (Sorbent Trap)
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Hg CAM Plans
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No performance standard or QA/QC promulgated
Proposed standards never been achieved in practice
EPA/EPRI research project to install and test Hg CEMS and
Method 324 ability to meet proposed standards underway
Will become issue in permits once EPA issues final utility
mercury rule
CAM exempts standards proposed under § 112 after 1990
EPA position in Utility Hg proposals that CAM not sufficient
for MACT
Implementation Issues
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AP-42
 EPA initiative questioning use of emission
factors for establishing compliance
Condensible Particulate Matter
 PM –10 (the regulated pollutant) is defined to
include filterable and condensible PM
 EPA Method 202 for condensable has
positive artifact (overstates PM)
Implementation Issues
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Condensable Particulate Matter
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Establishment of appropriate limit will be
issue
 Little data exists on achievable PM-10
limits that include condensable
 Seek higher limit to account for Method
202 results or seek separate limits on
individual identifiable condensable
(sulfuric acid mist)
Air Quality Modeling Issues
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Modeling Required
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In all cases, a permit applicant must show
that a major new source will not cause, or
contribute to, air pollution in excess of—
 Any applicable PSD increment, or
 A National Ambient Air Quality Standard “in
any air quality control region”
An applicant must also analyze the impact
of the facility and associated growth on
visibility, soils and vegetation with
commercial or recreational value
Modeling Required
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For Class I areas, must also address “air
quality-related values,” including visibility
(AQRVs)
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No permit can be issued if a Federal Land
Manager (FLM) demonstrates to the
permitting state that emissions from a
proposed facility will have an adverse
impact on AQRVs
Selected Relevant Regulations
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40 C.F.R. § 51.166(c), (k), (l), (o), & (p)
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40 C.F.R. § 51.307
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40 C.F.R. Part 51, App. W
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40 C.F.R. § 52.21(b)(29), (c), (k), (l), (o), &
(p)
Selected Relevant Guidance
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New Source Review Workshop Manual:
Prevention of Significant Deterioration and
Nonattainment Area Permitting (Oct. 1990 Draft)
Federal Land Managers’ Air Quality Related
Values Workgroup (FLAG) Phase I Report
(December 2000)
Guidance on Deposition Analysis Thresholds
(2002) (From the National Park Service & the Fish
& Wildlife Service)
Interagency Workgroup on Air Quality Modeling
(IWAQM) Phase 2 Summary Report and
Recommendations for Modeling Long Range
Transport Impacts (Dec. 1998)
Models to Use
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For NAAQS and increment analyses, generally
must follow the Guideline on Air Quality Models
(40 C.F.R. Appendix W)
 ISC-3 for most applications
 CALPUFF for distances greater than 50 km
 General practice has been to use ISC-3 for nonClass I modeling and to set the SIA at 50 km
CALPUFF is also recommended by the Federal
Land Managers for AQRV analyses
Models to Use
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If the model specified by the Guideline is
“inappropriate,” it can be modified or
another model specified
 On a case-by-case or state-wide basis
 Requires written approval by the
Administrator
 Requires an opportunity for notice and
comment
NAAQS & Increment Analyses
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Getting Started
 Protocol
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Preliminary modeling
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Address all aspects of the modeling
Get it approved
Determine if exceed thresholds so preconstruction
monitoring and refined modeling is required
Determine the SIAs for refined modeling
Need to know if a short-term limit (3-hr or 24-hr) for SO2
will be required as it will affect the SIA
NAAQS & Increment Analyses
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Preconstruction monitoring
 If request approval to use existing data
remember to include ozone
Refined modeling
 Grid should identify highest impacts
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www.hunton.com
Annual – maximum annual mean
Short-term – high-second-high
NAAQS & Increment Analyses
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Adequacy of inventory can be a concern
 NAAQS and Increment inventories are not the
same
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NAAQS – all sources modeled using their potential emissions
Increment – sources modeled depend on whether minor
source baseline has been triggered and can use actual
emissions based on two years of data
Violations may be modeled in attainment areas
 Culpability analysis required to determine if
causing or contributing to the modeled violation
NAAQS & Increment Analyses
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Other issues
 Methods to model ozone or PM2.5 from a
single source must be selected on a caseby-case basis
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www.hunton.com
Typically single-source ozone modeling not required but
look for regional modeling to include in the record
8-hr Ozone and PM2.5 NAAQS have yet to
be fully implemented
Currently there are no increments for
ozone or PM2.5
Adverse Impact – Per FLMs
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“An unacceptable effect, as identified by an FLM,
that results from current, or would result from
predicted, deterioration of air quality in a Federal
Class I or Class II area. A determination of
unacceptable effect shall be made on a case-bycase basis for each area taking into account
existing air quality conditions. It should be based
on a demonstration that the current or predicted
deterioration of air quality will cause or contribute
to a diminishment of the area’s national
significance, impairment of the structure and
functioning of the area’s ecosystem, or
impairment of the quality of the visitor experience
in the area.”
AQRV Analysis -Visibility
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Visibility Impairment – “[A]ny humanly
perceptible change in visibility (light
extinction, visual range, contrast,
coloration) from that which would have
existed under natural conditions.”
Significant Impairment – “[V]isibility
impairment which, in the judgment of the
Administrator, interferes with the
management, protection, preservation, or
enjoyment of the visitor’s visual
experience.”
AQRV Analysis - Visibility
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Case-by-case analysis, taking into account
 Geographic extent of impairment
 Duration of impairment
 Frequency of impairment
 Time of impairment
 Correlation with times of visitor use
 Frequency and timing of natural conditions
that impair visibility
Visibility Impairment - FLMs
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Use the CALPUFF model to conduct a
single-source contribution analysis
 MESOPUFF II chemistry option
 Use hourly relative humidity
 Use default ammonia background levels
 Using the maximum predicted 24-hr values
for SO4, NO3, and HNO3, calculate
extinction coefficients for each pollutant
Visibility Impairment - FLMs
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Compare to natural conditions
 FLMs want a comparison to clean
background visibility
 Generally compare to the average 24-hour
extinction values for the 20% cleanest
conditions from the IMPROVE monitoring
network
Visibility Impairment- FLMs
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If the estimated single-source contribution to
impairment is <0.4% each day, the FLM will not
object or require further analysis.
If the estimated single-source contribution to
impairment is 10% on any day, the FLM is likely to
object to the permit
If, as is usually the case, no cumulative impact
analysis exists and the source’s contribution to
extinction is <5.0% on all days, the FLM will likely
not object to the permit
Visibility Impairment -FLMs
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In other situations, the FLM may ask for a
cumulative analysis
 If cumulative extinction is 10% and the
source contributes at least a 0.4% change
in any period, the FLM will likely object to
the permit
 If the cumulative extinction is always
<10%, the FLM is not likely to object to the
permit
Visibility Impairment - Issues
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www.hunton.com
Limits of human perception
Consideration of weather
Consideration of time of day
Characterization of natural background
Elevation effects
Time of day
Treatment of background ammonia
Deposition Impacts - FLMs
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Deposition Analysis Thresholds have been
established by the National Park Service
and the Fish & Wildlife Service
 In the East - 0.01 kg/ha/yr N or S
 In the West 0.005 kg/ha/yr N or S
These may not be used by the Forest
Service
Deposition Impacts - FLMs
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A deposition impact analysis may be
requested
 Estimate the current S and N deposition
rates at the Class I area
 Estimate future deposition rates
 Compare to screening criteria for the area
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Critical loads
Concern thresholds
Screening level values
Exceedence may trigger a permit objection
Ozone Impacts - FLMs
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Focus is on vegetation
 All native species are to be protected
 Most sensitive species may not be known
Focus is on NOx unless an area is shown
to be VOC-limited
If current ozone exposure is considered
phytotoxic or damage to vegetation is
seen, the FLM may seek “stricter than
BACT” controls or offsets
Additional Impact Analysis
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Comparison to NAAQS may not be
sufficient
Permitting agencies requesting analysis of
heavy metals
May need to consider ambient background
Guidance is available
 A Screening Procedure for the Impacts of
Air Pollution Sources on Plants, Soils, and
Animals, EPA 450/2-81-078 (Dec. 12,
1980)