Transcript Prevention of Significant Deterioration (PSD

PSD/Nonattainment
Review
You can do this!
Marc Sturdivant
Air Permits Division
Texas Commission on Environmental Quality
Environmental 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
Current Nonattainment
DFW Ozone
Areas
Nonattainment
Wise County (DFW) –
Ozone
Nonattainment Area
- 1997 Attainment
- 2008 Moderate
(Effective 7/20/12)
Moderate PM10
Nonattainment
Area
Area
– 1997 Serious
– 2008 Moderate
Wise
Lead
Nonattainment
Area
HGB
Ozone Nonattainment Area
– 1997 Severe
– 2008 Marginal
Minor & Major NSR
State (Minor) NSR
----------------------- NSR permit
Federal (Major) NSR
----------------------- PSD
 Standard permit
 Nonattainment
 PBR
 De minimis
•
•
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 Program
Major Modification
Significant Emission Rates for Criteria Pollutants:
CO
NOX
SO2
VOC
PM
PM10
PM2.5
Pb
≥
≥
≥
≥
≥
≥
≥
≥
100
40
40
40
25
15
10
0.6
tpy
tpy
tpy
tpy
tpy
tpy
tpy
tpy
PSD Program
Major 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 Program
Review 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 Program
Overview
 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
Current Nonattainment
Areas
DFW - Serious
Major Source ≥ 50 TPY
Major Mod. ≥ 25 TPY
Wise County (DFW) Moderate
Major Source ≥ 100 TPY
Major Mod. ≥ 40 TPY
Wise
HGB - Severe
Major Source ≥ 25 TPY
Major Mod. ≥ 25 TPY
Nonattainment Program
Ozone 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 Program
Offset:
 An actual emission reduction, greater than or equal
to the project’s potential emission increase
 The amount of offset depends on the
nonattainment classification
Current Nonattainment
Areas
DFW - Serious
Major Source ≥ 50 TPY
Major Mod. ≥ 25 TPY
Offset Ratio = 1.2 to 1
Wise County (DFW) Moderate
Major Source ≥ 100 TPY
Major Mod. ≥ 40 TPY
Offset Ratio = 1.15 to 1
Wise
HGB - Severe
Major Source ≥ 25 TPY
Major Mod. ≥ 25 TPY
Offset Ratio = 1.3 to 1
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 1
Info.
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
Example 1
Potential Increase
Current PTE = 20 tpy
Proposed PTE = 40 tpy
Major
MajorSource
Source== 25
25 tpy
40 tpy – 20 tpy = 20 tpy
The project is not a major source by itself
(greater than or equal to 25 tpy for
severe nonattainment area).
Major NSR is not triggered, but minor NSR
permitting requirements do apply.
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 Emissions
Steps
 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 Emissions
Project Emission
Increase
Planned Emission
Rate
(project increases
only)
Baseline Actuals
(affected facilities)
Project Emission
Increase
Determine Emissions
Planned Emission Rate
Either the...
 Potential to emit, or
 Projected actual emission rate
Determine Emissions
Baseline 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 Emissions
Baseline Timeline
2015 Jan 1,
Application
Submittal
2005
2010
2011
2012
2013 2014
10-year window for selecting
24-month Baseline Actual Emission Rate
<-------------------------------------------------------------------->
2015
Determine Emissions
Project Emission
Increase
Planned Emission
Rate
(project increases
only)
Baseline Actuals
(affected facilities)
Project Emission
Increase
Netting
Netting
Netting Applicability
Planned
Emission
Rate
(increases only)
Baseline
Actual
>
Netting
Significance
Level
Netting
Netting Significance
Levels
 PSD: same as PSD major modification
significance levels
 Nonattainment:

Serious & Severe: ≥ 5 tpy

Moderate: ≥ 40 tpy
Netting
Why 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
Netting
How 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)
Netting
Contemporaneous Period/
The Netting Window
Five years before start of
construction
to proposed
start of operation
Netting
Contemporaneous Period
Example
Start of
Construction
2007
2008
2009
2010
2011
Start of
Operation
2012
2013
2014
Netting
Modifications Identified
Within 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
Netting
Creditable 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
Netting
Creditable 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)
Netting
Creditable 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)
Netting
Determining 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)
Netting
Baseline 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
Netting
Using 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
Netting
Netting Window Example
Baseline
Actual
Emissions
2007
2008
10 Years
2009 Project
2009
2010
2011
2012
2013
2014
Netting
Net Emissions Increase
Project
increase
Emission
increases
Non-project sourcewide creditable
contemporaneous
Emission
decreases
Amount
that
exceeds
zero
Source-wide creditable
contemporaneous
(including the current
project)
Netting
Triggering 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 2
Info.
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
Example 2
Netting Required?
Major Source;
Severe Nonattainment Area;
Current PTE = 50 tpy;
Proposed PTE = 52 tpy; Baseline Actual = 48 tpy; Project Increase = 4 tpy
The 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 3
Info.
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 - Baseline Actual)
Example 3
Netting Required?
Major Source;
Serious Nonattainment Area;
Current PTE = 50 tpy;
Proposed PTE = 60 tpy; Baseline Actual = 47 tpy; Project Increase = 13 tpy
Emissions increase exceeds the netting significance level
of 5 tpy.
Netting is required!
Example 3
Table 3F
NOx
Example 3
Finding Total Increase
13
tons/yr
increase
5
tons/yr
(increase)
0.25
tons/yr
(increase)
Current
Project
11/2010
Project
10/2011
Project
4.25
tons/yr
(decrease)
14
tons/yr
Total
Increase
Example 3
Nonattainment 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 4
Info.
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
Example 4
PSD Required?
Major Source;
Attainment Area;
Current PTE = 200 tpy;
Proposed PTE = 210 tpy; Baseline Actual = 190 tpy; Project Inc. = 20 tpy
The 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