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PSD/Nonattainment Review
You can do this!
Marc SturdivantAir Permits Division
Texas Commission on Environmental QualityEnvironmental Trade Fair 2015
Getting Oriented
NAAQS
Criteria pollutants:
CO, NOX, SO2, Ozone (NOX/VOC) PM10, PM2.5, and Pb
Primary NAAQS:
Protect public health
Secondary NAAQS:
Protect public welfare
Important Terms
Attainment:
In compliance with NAAQS
Nonattainment:
Out of compliance with NAAQS
LeadNonattainment
Area
DFW Ozone Nonattainment Area– 1997 Serious– 2008 Moderate
Moderate PM10 Nonattainment
Area
Wise
Wise County (DFW) – Ozone Nonattainment Area- 1997 Attainment- 2008 Moderate (Effective 7/20/12)
HGB Ozone Nonattainment Area– 1997 Severe– 2008 Marginal
Current Nonattainment Areas
Minor & Major NSRState (Minor)
NSR------------------------
NSR permit
Standard permit
PBR
De minimisFederal (Major) NSR
-----------------------
• PSD
• Nonattainment
Federal (Major) NSR
------------------------ PSD
Nonattainment
PSD Program
PSD Program Overview
New major sources
Major modifications of existing major sources
Criteria pollutants that are in attainment
Certain non-criteria pollutants
PSD Program Major Source
Definition:
Named Source > 100 tpy (includes fugitives)
Un-named Source > 250 tpy
PSD ProgramMajor Modification
Significant Emission Rates for Criteria Pollutants:
CO ≥ 100 tpyNOX ≥ 40 tpy
SO2 ≥ 40 tpy
VOC ≥ 40 tpyPM ≥ 25 tpyPM10 ≥ 15 tpy
PM2.5 ≥ 10 tpy
Pb ≥ 0.6 tpy
PSD ProgramMajor Modification
Significant Emission Rates for Non-Criteria Pollutants:
Fluorides ≥ 3 tpy
Sulfuric acid mist ≥ 7 tpy
Hydrogen sulfide ≥ 10 tpy
Total reduced sulfur ≥ 10 tpy
Plus others........
PSD ProgramReview Requires: Major for one regulated pollutant, major for
all
Application of BACT
Air quality analysis (modeling)
If within 100 km of a Class I area, inform FLM
PM10, PM2.5 include filterable and condensable
Nonattainment Program
Nonattainment ProgramOverview
Applies only to pollutants for which the area is designated as nonattainment
New major sources
Major modifications of existing major sources
Most commonly encountered area – ozone:
Regulated through NOX and VOC
DFW - SeriousMajor Source ≥ 50
TPYMajor Mod. ≥ 25
TPY
Wise County (DFW) - Moderate
Major Source ≥ 100 TPYMajor Mod. ≥ 40 TPY
Wise
HGB - SevereMajor Source ≥ 25
TPYMajor Mod. ≥ 25
TPY
Current Nonattainment Areas
Current Nonattainment Areas
Nonattainment ProgramOzone Review Requires:
Must be a major source or major modification for either NOX or VOC
NOX and VOC are evaluated independently
Application of LAER
Application of offsets
Nonattainment ProgramOffset:
An actual emission reduction, greater than or equal to the project’s potential emission increase
The amount of offset depends on the nonattainment classification
DFW - SeriousMajor Source ≥ 50 TPYMajor Mod. ≥ 25 TPYOffset Ratio = 1.2 to 1
Wise
Wise County (DFW) - Moderate
Major Source ≥ 100 TPYMajor Mod. ≥ 40 TPYOffset Ratio = 1.15 to 1
HGB - SevereMajor Source ≥ 25 TPYMajor Mod. ≥ 25 TPYOffset Ratio = 1.3 to 1
Current Nonattainment Areas
Current Nonattainment Areas
PSD & Nonattainment Review
Is it possible to trigger both PSD and nonattainment for the same pollutant?
Yes, it is. NOX is an ozone precursor and has a NAAQS of its own.
New/Modified Equipment-Where is it located?
In an attainment or nonattainment area?
At an existing major source?
New/Modified Equipment-Where is it located? At a grassroots or an existing minor
source?
If so, the potential project increase must be major by itself to trigger major NSR.
Example 1
Example 1Info.
Company A is a minor source in a severe nonattainment area. Current PTE = 20 tpy NOX
Proposed PTE = 40 tpy NOX
Major Source = 25 tpy NOX
Current PTE = 20 tpy NOx
Proposed PTE = 40 tpy NOx
Major Source = 25 tpy NOx
Example 1Potential Increase
Current PTE = 20 tpy Proposed PTE = 40 tpy Major Source = 25 tpy
40 tpy – 20 tpy = 20 tpy
The project is not a major source by itself or equal to 25 tpy for a severe nonattainment area.
Major NSR is not triggered, but minor NSR permitting requirements do apply.
severe nonattainment area).
(greater than or equal to 25 tpy for
Major Source = 25 tpy
Modified equipment at an existing major source?
To trigger major NSR at an existing major source, the net project emission increase must be greater than or equal to the major modification significant emission rate for the pollutant.
Determine Emissions
Determine EmissionsSteps
Determine the project increase for each pollutant.
Compare project increase to netting significance levels. If the increase is greater than the netting significance levels, netting is required.
If net project increase exceeds significance levels, major NSR is triggered.
Determine EmissionsProject Emission Increase
+ Planned Emission Rate (project increases only)
- Baseline Actuals (affected facilities)
= Project Emission Increase
Planned Emission Rate
(project increases only)
Project Emission Increase
Baseline Actuals (affected facilities)
Determine EmissionsPlanned Emission Rate
Either the...
Potential to emit, or
Projected actual emission rate
Determine EmissionsBaseline Actual Emission Rate
Emissions, in tons per year, actually emitted during a consecutive 24-month period out of...
The previous 10 years, or
The previous 5 years for electric utilities
Determine EmissionsBaseline Timeline
2015 Jan 1, Application Submittal
2005 2010 2011 2012 2013 2014 2015
10-year window for selecting24-month Baseline Actual Emission
Rate<----------------------------------------------------------------
---->
Determine EmissionsProject Emission Increase
+ Planned Emission Rate (project increases only)
- Baseline Actuals (affected facilities)
= Project Emission Increase
Planned Emission Rate
(project increases only)
Project Emission Increase
Baseline Actuals (affected facilities)
Netting
NettingNetting Applicability
Required if the project increase equals or exceeds the netting significance level for the pollutant.
Planned Emission Rate minus Baseline Actual ≥ Netting Significance Level
Planned Emission
Rate(increases only)
>Baseline Actual
Netting Significance
Level
NettingNetting Significance Levels PSD: same as PSD major modification
significance levels
Nonattainment:
Serious & Severe: ≥ 5 tpy
Moderate: ≥ 40 tpy
NettingWhy do we do it?
Applies to existing major sources only
Applicability step to determine if major NSR has been triggered
Ensures smaller projects do not add up to be a major modification
NettingHow to do it
Conducted for each pollutant in which netting is triggered
An evaluation of:
The current project, plus
Increases and decreases within the contemporaneous period (netting window)
NettingContemporaneous Period/ The Netting Window
Five years before start of construction to proposed start of operation
NettingContemporaneous Period Example
2007 2008 2009 2010 2011 2012 2013 2014
Start of Construction
Start of Operation
NettingModifications IdentifiedWithin the Window May be based on:
The date the modification was authorized, or
The date the change is operated
Must be used consistently
Indicate which method is used
NettingCreditable Emissions
Occur during the contemporaneous period
Cannot have been relied upon in issuing a major NSR permit for the source
Sources/activities authorized by the major NSR permit are not in operation when the current increase is authorized
Rely on Emissions Inventory
NettingCreditable Increases
The new level of emissions exceeds the Baseline Actual Emission Rate
(PTE – Baseline = Increase)
Does not include emission increases at facilities under a plant-wide applicability limit (PAL)
NettingCreditable Decreases
The Baseline Actual Emission Rate exceeds the new level of emissions
Enforceable at and after the time that project modification begins to operate (must be enforceable and real before the unit starts operation)
NettingDetermining Increases and Decreases...
...for each project within the contemporaneous window are based on a comparison of:
Baseline Actual Emission Rate and
The PTE of that project (projected actuals are not used in this step except for the current project)
NettingBaseline Actual Emission Rate
Emissions, in tons/year, actually emitted during a consecutive 24-month period out of the previous 10 years (previous 5 years for electric utilities) from the date the project is authorized or modifications are operated
NettingUsing an Allowable to Allowable Comparison
Situation #1: the Baseline Actual > Current PTE
Situation #2: a new facility is within two years of its initial start-up date
NettingNetting Window Example
2007 2008 2009 2010 2011 2012 2013 2014
10 Years
2009 ProjectBaseline Actual
Emissions
NettingNet Emissions Increase
Project increase
+ Non-project source-wide creditable contemporaneous emission increases
- Source-wide creditable contemporaneous emission decreases (including the current project)=
The amount that exceeds zero
Project increase
Emission increase
s
Emission decrease
s
Amount that
exceeds zero
Source-wide creditable contemporaneous
(including the current project)
Non-project source-wide creditable
contemporaneous
NettingTriggering Major NSR
Compare the net increases to the appropriate significant emission rate
If the increase is greater than or equal to the significant emission rate for the pollutant, major NSR is required
More Examples
Example 2Info.
Company B is a major source in a severe nonattainment area.
Current PTE = 50 tpy NOX
Proposed PTE = 52 tpy NOX
Baseline Actual = 48 tpy NOX
Project Increase = 4 tpy NOX
Current PTE = 50 tpy NOx
Proposed PTE = 52 tpy NOx
Baseline Actual= 48 tpy NOx
Project Increase = 4 tpy NOx
Example 2Netting Required?Major Source; Severe Nonattainment Area; Current PTE = 50
tpy;
Proposed PTE = 52 tpy; Baseline Actual = 48 tpy; Project Increase
= 4 tpyThe project increase of 4 tpy does not exceed the netting significance level of 5 tpy for a severe nonattainment area.
Netting is not required.
Example 3Info.
Company C is a major source in a serious nonattainment area.Current PTE = 50 tpy NOX
Proposed PTE = 60 tpy NOX
Baseline Actual = 47 tpy NOX
Project Increase = 13 tpy NOX
(Proposed PTE minus Baseline Actual)
Current PTE = 50 tpy NOx
Proposed PTE = 60 tpy NOx
Baseline Actual= 47 tpy NOx
Project Increase = 13 tpy NOx
(Proposed PTE - Baseline Actual)
Example 3Netting Required?
Major Source; Serious Nonattainment Area; Current PTE = 50
tpy;
Proposed PTE = 60 tpy; Baseline Actual = 47 tpy; Project Increase
= 13 tpyEmissions increase exceeds the netting significance level of 5 tpy.
Netting is required!
Example 3Table 3F
NOx
Example 3Finding Total Increase
Current Project 13 tons/year increase plus
11/2010 Project 5 tons/year plus
10/2011 Project 0.25 tons/year minus
4.25 tons/year
Total Increase: 14 tons/year
13 tons/yr increas
e
5tons/yr
(increase)
0.25 tons/yr
(increase)
4.25 tons/yr
(decrease)
14 tons/yr
Current Project
11/2010Project
10/2011Project
Total Increas
e
Example 3Nonattainment Review? The major modification significant emission rate
for a serious nonattainment area is 25 tpy.
Total increase (from previous slide) is 14 tpy.
Since 14 tpy is less than the major modification significant emission rate of 25 tpy, the project is not a “major modification” and
major NSR (nonattainment review) is not required.
Example 4Info.
Company D is a major source in an attainment area.
Current PTE = 200 tpy NOX
Proposed PTE = 210 tpy NOX
Baseline Actual = 190 tpy NOX
Project Increase = 20 tpy NOX
Current PTE = 200 tpy NOx
Proposed PTE = 210 tpy NOx
Baseline Actual= 190 tpy NOx
Project Increase = 20 tpy NOx
Example 4PSD Required?Major Source; Attainment Area; Current PTE = 200 tpy;
Proposed PTE = 210 tpy; Baseline Actual = 190 tpy; Project Inc. =
20 tpyThe project increase of 20 tpy does not exceed the major modification significance level of 40 tpy for NOX.
Netting is not triggered.
PSD review is not required.
Check Your Calculations!
Contact Info.
Air Permits Division(512) 239-1250