Transcript PSDJessicaMontanez073008.ppt

Prevention of Significant Deterioration (PSD)
NSR Program
Jessica Montañez
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
919-541-3407, [email protected]
Agenda
1. PSD Applicability
2. PSD Requirements
3. NSR Applicability Example
2
Prevention of Significant Deterioration
(PSD) NSR Program Basics
Which sources might be subject to the major
PSD program?
• Sources locating in areas attaining the National Ambient
Air Quality Standards or areas that are unclassifiable


New major sources
Existing major sources making major modifications
 Physical or operational changes at the source
 Change should show significant net emissions increase
4
How do you know when PSD applies
to a source?
1. Determine source’s potential to emit (PTE)
2. Assess attainment status of source’s geographic area
3. Determine applicable source thresholds
4. Determine if source is major for PSD
5
1. What is the source’s potential to emit (PTE)?
• The maximum capacity of source to emit a
pollutant under its physical and operational
design


Based on operating 24 hours a day, 365 days a year
(8760 hours/year)
Can include effect of emissions controls, if
enforceable by permit or:
 State Implementation Plan (SIP),
 Tribal Implementation Plan (TIP) or
 Federal Implementation Plan (FIP) conditions
6
2. What is the attainment status of source’s
geographic area?
• Determine if area is in attainment for each National
Ambient Air Quality Standard (NAAQS) emitted by the
source

To find this information:
 Contact the appropriate EPA Regional office or applicable
permitting authority
 Search an EPA database such as: www.epa.gov/air/data
7
3. What is the applicable PSD threshold?
• 250 tons per year (tpy) for most source categories
• 100 tpy, if part of the 28 listed source categories
8
4. How do you determine if a source is major
for PSD?
• For each pollutant, compare the source’s PTE
with applicable threshold
• If PTE is equal to or higher than threshold,
source is major for PSD
• For example:


Source PTE for NO2 is 300 tpy
300 tpy > 250 tpy, source is subject to PSD
9
When might a modification be subject to the
PSD program?
• Based on significant net emissions increase


Determine if proposed source emissions exceeds significant
emissions rate (SER)
Determine net emissions increase (NEI)
 Sum of contemporaneous emissions increases and decreases to
the proposed modification increase


NEI = PMEI + CEI – CED (ERC) where:
 PMEI – Proposed modification emissions increase
 CEI – Creditable emissions increase
 CED – Creditable emissions decreases
 ERC – Emissions reduction credit(s)
Check if NEI is greater than SER, if so, source is major
10
Why might a new or modified source not be
subject to PSD?
• PTE less than major
source thresholds
• Source is “grandfathered”
• Source opted for
“synthetic minor” permit
350
300
Major Source
Threshold
250
200
Actual
PTE
150
100
50
0
Emissions
(tpy)
Synthetic Minor Source
Emissions
11
In what other circumstances can a source
be subject to PSD?
• Once it is determined that a source is major for PSD,
source also has to review pollutants that are below the
thresholds by comparing PTE to Significant Emissions
Rate (SER)


Pollutants for which the area is in attainment (NAAQS)
Other pollutants
• Emissions equal to or higher than SER make pollutant
also subject to PSD
• Concept known as “Major for one Major for all”
12
What must a major source subject to PSD do?
• Install of Best Available Control Technology (BACT)
• Perform air quality analysis
• Perform class I area analysis
• Perform additional impacts analysis
• Allow opportunities for public involvement
13
NSR Applicability Example
Which pollutants are subject to PSD,
NA NSR, and minor NSR permitting?
• New Kraft Pulp Mill
• PTE’s:


PM-10 – 10 tpy
VOC – 80 tpy
SO2 – 185 tpy
http://esask.uregina.ca

• Area:


In attainment for PM-10
and VOC
In moderate
nonattainment for SO2
Kraft pulp mill’s produce the dark
colored wood pulp used in the
manufacture of a variety of paper
products.
15
Example Solution
1.
Evaluate for PSD
•
Determine applicable threshold
•
•
•
Kraft pulp mills part of 28 listed source categories
Major source threshold is 100 tpy, not 250 tpy
Determine if the source is major based on the threshold
• 185 tpy of SO2 > 100 tpy threshold
• Mill is a major source for PSD
• Now review all attainment pollutants for PSD applicability
PTE’s: SO2=185 tpy, VOC=80 tpy, PM-10=10 tpy; Area in: NA for SO2, Att. for VOC and PM-10
16
Example Solution (Continued)
• Review the two attainment pollutants based on their SER

VOC:
 PTE = 80 tpy, VOC not on SER list
 However, VOC is ozone precursor

Ozone on list, SER = 40 tpy
 80 tpy of VOC > 40 tpy ozone SER, VOC subject to PSD

PM-10:
 PTE = 10 tpy
 PM-10 SER = 15tpy
 10 tpy of PM-10 < 15 tpy SER, PM-10 not subject to PSD
PTE’s: SO2=185 tpy, VOC=80 tpy, PM-10=10 tpy; Area in: NA for SO2, Att. for VOC and PM-10
17
Example Solution (Continued)
2. Evaluate for NA NSR
•
Determine applicable threshold
•
•
Major source threshold for moderate NA is 100 tpy
Determine if the source is major based on the threshold
•
•
Only NA pollutant is SO2
185 tpy of SO2 > 100 tpy threshold, SO2 subject to NA NSR
3. Evaluate for Minor NSR
•
•
PM-10 PTE = 10 tpy
PM-10 may be subject to minor NSR
•
•
Proposed minor Tribal NSR rule, PM-10 Att. threshold = 5 tpy
10 tpy of PM-10 > 5 tpy threshold, PM-10 subject to minor NSR
PTE’s: SO2=185 tpy, VOC=80 tpy, PM-10=10 tpy; Area in: NA for SO2, Att. for VOC and PM-10
18
PSD Requirements Details
Agenda
1. PSD Requirements Details
2. Refinements of Increment Modeling Procedures Proposal
20
Review: What must a major source subject to
PSD do?
• Install of Best Available Control Technology (BACT)
• Perform air quality analysis
• Perform class I area analysis
• Perform additional impacts analysis
• Allow opportunities for public involvement
21
What is Best Available
Control Technology (BACT)?
• Pollutant specific emissions limit, case-by-case

Takes into account energy, environmental, or economic impacts
• Limit must be at least as stringent as applicable:


New Source Performance Standard (NSPS) and/or
National Emission Standard for Hazardous Air Pollutants
(NESHAP)
• Selected by “Top Down” BACT analysis
22
What are the requirements for the
“Top-down” BACT analysis?
1. Identify all available air pollution control technologies,
regardless of cost
2. Eliminate technical infeasible control options
3. Rank remaining control technologies according to
control effectiveness. For each pollutant, list includes:
–
–
–
–
–
Control efficiency (percent of pollutant removed)
Expected emissions reduction (tons/year)
Economic Impacts
Environmental Impacts (i.e. significant impact on surface water)
Energy Impacts
4. Evaluate most effective controls based on all the factors
in step 3 and document results
5. Select BACT
23
What is an air quality analysis and its purpose?
• Analysis that involves:


An assessment of existing air quality
Modeling estimate of ambient concentrations from proposed
project and future growth associated with project
• Purpose:

Will new plus existing emissions cause or contribute to:
 NAAQS and/or
 PSD increment violation
• Pollutant specific, noncriteria pollutants are also
evaluated
24
What are the steps of the air quality analysis?
Determine Need for Pre-application
Monitoring
Meteorological Data
Source Input Data (Pollutants with
Significant Emissions)
Model Impact of Proposed and Other
Emission Sources
Ambient
Concentrations
Above Air
Quality
Significance
Level
No
No Further NAAQS or PSD
Increment Analysis
Performed for Pollutant
Yes
Determine Impact Area
Develop Emissions Inventories of
Other Sources
Meteorological Data
Source Input Data (Pollutants with
Significant Emissions)
Model Impact of Proposed and Other
Emission Sources
Demonstration of Compliance
25
What do we require for an increment analysis?
• A new source or modification cannot cause or contribute
to significant deterioration of air quality in attainment
areas
• Maximum amount of deterioration allowed is called an
increment
• Change in air quality measured against a certain
baseline
• Not all sources consume increment
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What is an increment?
• Increment

Maximum allowed increase in concentration of a pollutant above
baseline (concentration as of baseline date) in an area
• Increments exist for:
• 3 pollutants:
• PM-10, SO2, NO2
• Variety of averaging periods
• 3-hour, 24-hour, annual
• Variety of area classifications
• Class I - national parks
and other natural areas
• Class II - nearly all other
areas in the US
• Class III - areas targeted
for industrial development
Increment per Area
Classification (g/m3)
Averaging
Period
Pollutant
I
II
III
Annual
PM-10
4
17
34
SO2
2
20
40
NO2
2.5
25
50
PM-10
8
30
60
SO2
5
91
182
SO2
25
512
700
24-hr
3-hr
27
How is increment compliance determined?
• By using air quality models
• Preliminary analysis (significant impact analysis)




Screening type models
Representative meteorology
Only proposed source emissions
Refined receptor grids
• Full impact analysis (cumulative impact analysis)




Refined model
Representative meteorology
All applicable increment affecting sources
More refined receptor grids (smaller grid spacing)
28
How is increment compliance determined?
(cont.)
1.
Determine Need for Pre-application Monitoring

If existing ambient impact is less than the Significant
Monitoring Concentration (SMC), permitting agency can
exempt an applicant from monitoring
29
How is increment compliance determined? (cont.)
2.
Conduct Significant Impact Analysis
•
Acquire meteorological and source emissions data (actual
emissions)
•
Model impact of proposed source

If source ambient concentrations are:

Lower than the Significant Impact Levels* (SILs), no
further analysis needed

Higher than the SILs, full impact analysis is needed
*EPA’s current PSD regulations do not contain SILs, but they have been widely used as a
screening tool.
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How is increment compliance determined?
(cont.)
3.
Determine Baseline Area(s)
•
•
•
All portions of the attainment or unclassifiable area in which
the PSD applicant proposes to locate (See section 107 of the
Act) and/or
Any attainment or unclassifiable area in which the PSD
applicant would have a significant ambient impact (i.e. higher
than SIL)
Limited to intrastate areas
• Baseline areas not triggered across state lines
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How is increment compliance determined? (cont.)
4.
Determine Baseline Date(s) - when increment
consumption starts, pollutant specific
Minor Source Baseline Date
Date of first complete permit
application
Trigger Date
SO2 and PM – 1977, NOx - 1988
Major Source Baseline Date
SO2 and PM - Jan. 6, 1975
NOx - Feb. 8, 1988
when actual emission changes from all
sources affect the available increment
when the minor source baseline date may
be established
when actual emissions associated
with construction at a major source
affect increment
Start
32
How is increment compliance determined
(cont.)?
• Example: Baseline Areas and
Dates



New source planned for Iowa
county, Wisconsin
Wisconsin lists attainment status
by counties
Minor source baseline dates (if
already established) for Iowa and
surrounding counties listed below
PM-10
SO2
NO2
County
Date
Date
Date
Dane
09/13/1998
09/13/1998
09/13/1998
Iowa
--
--
--
Sauk
09/27/2002
--
--
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How is increment compliance determined?
(cont.)
•
Source:


•
What is the baseline area?

•
Is major for SO2 and PM-10 (area in
attainment for both pollutants)
Submits complete PSD application
on November 30, 2007
Dispersion modeling shows impact
area covers Iowa, Sauk and Dane
counties (e.g., ambient
concentrations for SO2 and PM-10
exceed 1g/m3 annual SIL)
What are the baseline dates?



Iowa – November 30, 2007 for SO2
and PM-10
Sauk –November 30, 2007 for SO2:
September 27, 2002 for PM-10
Dane –September 13, 1998 for SO2
and PM-10
Significant Impact Area
PM-10
SO2
NO2
County
Date
Date
Date
Dane
09/13/1998
09/13/1998
09/13/1998
Iowa
--
--
--
Sauk
09/27/2002
--
--
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How is increment compliance determined?
(cont.)
• Conduct Cumulative Impact Analysis

Determine Impact Area
 Based on impact area determined for preliminary analysis

Circular area with a radius extending from the source to:
 Largest area for all the pollutants modeled during preliminary analysis
or
 Receptor distance of 50 km, whichever is less
County A
County B
Proposed Source
35
How is increment compliance determined?
(cont.)
• Conduct Cumulative Impact Analysis

Develop Emissions Inventory
 Includes all increment affecting sources within the impact area and
the annular area extending 50 kilometers beyond the impact area.
 Includes mobile, area and secondary sources
 Based on actual emissions over the 2 years preceding the particular
date (i.e., baseline or current)

Other time periods may be used if they are “more representative of
normal source operations”
County A
County B
50 km
Proposed
Source
36
How is increment compliance determined? (cont.)
5.
Conduct Cumulative Impact Analysis
C.
Model Impact of Proposed and Existing Sources

D.
Uses emission inventory data and meteorology to determine the
change (Δ) in concentration from baseline
Determination of Compliance

If model output for each pollutant and averaging period is higher
than the increment, the permit:


Is denied or
Granted, if emissions are “offset’ by other sources in the area
37
What do we require for the NAAQS analysis?
• A new source or modification cannot cause or contribute
to a violation of any NAAQS in any area
• Compliance with any NAAQS is based on proposed
source and all other sources in baseline area


No baseline dates exist
Analysis requirements similar to increment analysis
• NAAQS analysis independent from increment analysis
38
What is an class I area impact analysis?
• Evaluation of NAAQS, PSD increments and Air Quality
Related Values (AQRVs) when a major source’s
emissions may affect a Class I area

AQRVs – feature or property of a Class I Area that may be
affected by a change in air quality
 Differ for each Class I area
 Defined by the Federal Land Manager (FLM) for Federal lands, or
by the applicable State or Indian Governing body for nonfederal
lands

Generally for sources within 100 km of Class I area, not always

FLM must be notified of potential impacts
 Determines data and analyses needed
39
What is an additional impact analysis?
• Assesses potential effects of increased pollution from
new source and associated growth on:


Soils and Vegetation
Visibility
• Pollutant specific
• Performed within the impact area of the proposed source
• Depends on:




existing air quality
quantity and type of emissions
sensitivity of local soils and vegetation (especially commercial
crops)
general visibility concerns
40
What is done with the PSD information?
• Source submits the analyses in PSD permit application
to permitting authority
• Permitting authority evaluates analyses/application to
determine requirements for PSD permit
• Reviewing authority then prepares or provides:




Draft permit
Adequate public notice to affected and general public
30-day public comment period on draft permit
Opportunity for public hearing on draft permit
• If all requirements met, permitting authority grants permit
41
Proposed Refinements to Increment
Modeling Procedures Rule
Refinements of Increment Modeling
Procedures Proposal
• Purpose:




Clarifies the status of existing PSD increment guidance
Addresses how the emissions and meteorology inventory for
increment purposes can be developed
Seeks comment on some of the Western States Air Resources
Council (WESTAR) recommendations for improving the PSD
program
Addresses the issue of Class I Federal Land Manager (FLM)
variances
• Proposal:

Published in Federal Register on June 6, 2007
• Promulgation:

Scheduled for December 2008
43
What have been some difficulties in
increment modeling?
• Often don’t have adequate older emissions data
• Don’t have direct emissions data for all averaging
periods
• Don’t have hourly data for any sources other than utilities
• Don’t have older meteorological data
• Regions and states using different methods
44
Issues Addressed in the Proposal
• What is the effect of the 1990 Draft NSR Workshop
Manual?

Manual not a binding regulation, not final agency policy
• How are emissions estimated for increment purposes?

No prescribed method, reviewing authority discretion allowed
 Requested comment on WESTAR’s recommended approaches:




menu of acceptable emissions calculation approaches for both shortterm and annual increments
set of guiding principles for selecting the most appropriate option from
the menu
Mobile sources emissions should be included
Other time periods may be used to establish actual emissions if
they are “more representative of normal source operations”
45
Issues Addressed in the Proposal (cont.)
• How are meteorological data estimated for increment
purposes?


Reviewing authorities have discretion for using prognostic
meteorological models (models that fill gaps in data)
Years of Data Needed:
 Observational data: 5 years and at least 1 year for site specific data
 Prognostic data: less than 5, but at least 3 years of data

If proprietary data or software needed, reviewing authority has
discretion for:
 requiring independent review of the proprietary data and conducting
the review, provided that confidential information is protected
 determining software acceptability based on the: (1) reproducibility
of the data or model simulation and (2) quality assurance
procedures used in its development
46
Issues Addressed in the Proposal (cont.)
• How future sources in the area where a variance has
been granted treat the emissions from the source who
received the variance?

Variances – approval of permit when increment is exceeded, but
AQRVs are not impacted
• We proposed:



Area now has to comply with two increments: the Class I and
Class II increments. The Class II increment can never be
exceeded.
Variance source(s) emissions not counted in future Class I
increment analyses, counted toward future Class II analyses
Implementation Plans (SIPs) not amended to correct violation
47
Appendix
48
What are the pollutants regulated by the NSR
program?
• The National Ambient Air Quality Standards (NAAQS)
pollutants
• Any NAAQS precursors
• Any pollutant regulated under the New Source
Performance Standards (CAA, Section 111)
• Any pollutant otherwise regulated under the Act,
except the National Emission Standards for
Hazardous Air Pollutants (CAA Section 112)
• Any Class I or Class II substance regulated by Title VI
of the Act, Stratospheric Ozone Protection
49
What are the National Ambient Air Quality
Standards (NAAQS)?
• EPA sets NAAQS for:



Ozone (smog)
Carbon Monoxide (CO)
Particulate Matter (dust/soot)
– Nitrogen dioxide (NO2)
– Sulfur dioxide (SO2)
– Lead (Pb)
• For each of the NAAQS pollutants, every area of the
U.S. is designated into one of the following categories:



Attainment - air quality concentrations equal to or lower than
NAAQS
Nonattainment - air quality concentrations higher than NAAQS
Unclassifiable – not enough data on air quality; generally
treated as attainment
50
National Ambient Air Quality Standards
Pollutants
Primary
Standards
Averaging Times
Secondary
Standards
Carbon Monoxide
9 ppm (10 mg/m3)
8-hour
-------
35 ppm (40 mg/m3)
1-hour
-------
Lead
1.5 µg/m3
Quarterly Average
Same as Primary
Nitrogen Dioxide
0.053 ppm
(100 µg/m3)
Annual (Arithmetic Mean)
Same as Primary
Particulate Matter (PM10)
150 ug/m3
24-hour
-------
Particulate Matter (PM2.5)
15 µg/m3
Annual (Arithmetic Mean)
Same as Primary
35 ug/m3
24-hour
-------
0.08 ppm
8-hour
Same as Primary
0.12 ppm
1-hour
(Only in some areas)
Same as Primary
0.03 ppm
Annual (Arithmetic Mean)
-------
0.14 ppm
24-hour
-------
-------
3-hour
0.5 ppm (1300 ug/m3)
Ozone
Sulfur Oxides
As of June 19, 2008; changes have been proposed to the Lead NAAQS
51
PSD 28 Source Categories with 100 tpy thresholds
1. Coal cleaning plants (with thermal dryers)
15. Coke oven batteries
2. Kraft pulp mills
16. Sulfur recovery plants
3. Portland cement plants
17. Carbon black plants (furnace process)
4. Primary zinc smelters
18. Primary lead smelters
5. Iron and steel mills
19. Fuel conversion plants
6. Primary aluminum ore reduction plants
20. Sintering plants
7. Primary copper smelters
21. Secondary metal production plants
8. Municipal incinerators capable of charging
more than 250 tons of refuse per day
22. Chemical process plants
9. Hydrofluoric acid plants
23. Petroleum storage and transfer units with a total
storage capacity exceeding 300,000 barrels
10. Sulfuric acid plants
24. Taconite ore processing plants
11. Nitric acid plants
25. Glass fiber processing plants
12. Petroleum refineries
26. Charcoal production plants
13. Lime plants
27. Fossil fuel-fired steam electric plants of more than 250
million British thermal units (BTU)/hour heat input
14. Phosphate rock processing plants
28. Fossil-fuel boilers (or combination thereof) totaling
more than 250 million BTU/ hour heat input
52
Significant Emission Rates (SERs)
SER – a rate of emissions that would equal or exceed any of the following rates:
Pollutant
SER
(tpy)
Pollutant
SER
(tpy)
Carbon Monoxide
100
Hydrogen sulfide(H2S)
10
Nitrogen Oxides
40
Total reduced sulfur (including H2S)
10
Sulfur Dioxide
40
Reduced sulfur compounds (includes H2S)
10
Particulate Matter (PM10)
15
Municipal waste combustor organics
3.5 x 10-6
Ozone
40 of VOCs or NOx
Municipal waster combustor metals
15
Lead
0.6
Municipal waste combustor acid gases
40
Fluorides
3
Municipal solid waste landfills emissions
50
Sulfuric acid mist
7
Notwithstanding the above, any emissions rate or any net emissions increase associated with a major
stationary source or major modification, which could construct within 10 km of a Class I area, and have
an impact on such area equal to or greater than 1 g/m3 (24-hour average)
As of June 19, 2008; SER has been proposed for PM-2.5
53
Significant Impact Levels (SILs)
SILs– air quality concentrations below which a full impact analysis may be
exempted by the permitting authority
Proposed Significant Impact Levels (µg/m3)
61 Fed. Reg. 38250; July 23, 1996
Pollutant
Averaging Time
Class I
Class II
Class III
Sulfur Dioxide (SO2)
Annual
0.1
1.0
1.0
24- hour
0.2
5.0
5.0
3-hour
1.0
25.0
25.0
Annual
0.2
1.0
1.0
24- hour
0.3
5.0
5.0
Annual
0.1
1.0
1.0
Particulate Matter
(10µm)
Nitrogen Oxides (NO2)
As of June 19, 2008; SIL has been proposed for PM-2.5
54
Significant Monitoring Concentrations (SMCs)
SMCs– air quality concentrations below which monitoring may be exempted by
the permitting authority
SMC (µg/m3) and Averaging Time
Pollutant
Carbon Monoxide
575 (8-hour)
Nitrogen Dioxide
14 (Annual)
Sulfur Dioxide
13 (24-hour)
Particulate Matter (PM10)
10 (24-hour)
Lead
0.1 (3-month)
Fluorides
0.25 (24-hour)
Hydrogen sulfide (H2S)
0.2 (1 hour)
Reduced sulfur compounds (includes H2S)
10 (1 hour)
Ozone
Applicants with a net emissions increase of 100
tons/year or more of VOC’s or NOx required to monitor
As of June 19, 2008; SMC has been proposed for PM-2.5
55
Air Quality Models
• Screening Models

Used to determine if a more refined air quality model is needed
 Examples: SCREEN3/AERSCREEN
• Preferred/Recommended Models (40 CFR Appendix W)

Required for NSR permitting and SIPs. These models include:
 AERMOD

source-oriented dispersion model that characterizes atmospheric processes by
dispersing a directly emitted pollutant plume to predict concentrations at selected
downwind locations
 CALPUFF


dispersion model that simulates the effects of time- and space-varying
meteorological conditions on pollution transport, transformation, and removal
May be applied for long-range transport and for complex terrain on a case-bycase basis
• Alternative Models

Not listed in Appendix W, can be used in regulatory applications with
case-by-case justification (See Section 3.2 in 40 CFR Appendix W)
56