air permitting biomass combustion units
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TRANSCRIPT
Air PermittingBiomass Combustion
UnitsPenn State University
Biomass Combustion ConferenceShort Course Series 2010
April 20, 2010
John Slade, [email protected] 717-822-0009
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Today’s Presentation 1. The Basics:
•What is an Air Contaminant?•What is an Air Contamination
Source?•How are Air Contaminants
regulated? 2. Explain Air Permitting!
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Basics What is an Air Contaminant?
•“Smoke, dust, fume, gas, odor, mist, radioactive substance, vapor, pollen or any combination thereof.” (PA Air Pollution Control Act)
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Basics Examples of Air Contaminants:
• Pollutants with National Ambient Air Quality Standards (NAAQS - see 40 CFR Part 50)
• Pollutants regulated under federal NSPS and NESHAP rules (see 40 CFR parts 60, 61, and 63)
• Regulated new source review pollutants (see 40 CFR §52.21(b)(50))
• Title V regulated air pollutant as defined (40 CFR §70.2)
• Pollutants regulated under a State Implementation Plan (SIP) or under state or local rules or policy (e.g., air toxics policy)
• There are others (e.g., RMP, pollen!!!)
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Basics What is an Air Contamination
Source?•“Any place, facility or equipment,
stationary or mobile, at, from or by reason of which there is emitted into the outdoor atmosphere any air contaminant.” (25 PA Code §121.1)
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Basics Source, facility, emissions unit –
what’s the difference?•As defined, source can be either a
single unit or entire facility.•Important issue for understanding
air permitting requirements (e.g., an emission unit may be on exemption list but installation could be modification of facility requiring permit).
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Basics Common Air Emissions Sources:
•Boilers, furnaces, incinerators •Manufacturing process equipment•Material storage silos and stock
piles•Storage tanks
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Basics Who Regulates Air in PA?
• Pennsylvania Department of Environmental Protection (PADEP)
• Philadelphia Air Management Services (AMS) and Allegheny County (ACHD)
• U.S. EPA - Region 3
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Air Permitting
The Good Stuff!!!
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Does My Facility Need An Air Permit?
MYTHS My facility is too
small No one told me I
needed a permit My vendor says I
do not need a permit
I already have an air permit
FACTS Size does not
matter Responsibility lies
with the facility Vendors want to
make a sale You may need
more than one permit
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What Air Emissions Sources Require a Construction Permit? Simple Rule of Thumb: An air quality
plan approval to install a source is required for ANY air emission sources unless:•The source type is listed in the PADEP
rules or on the exemption list OR•PADEP makes a case-by-case
determination that the source does not require installation approval
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Is There More Than One Kind of Air Permit?
Permit to Install/Permit to Construct•Required before emissions units
can be installed or modified Permit to Operate/Operating Permit
•Needed to operate equipment once installation or modification is completed
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Pennsylvania Air Quality Permits
•Plan Approvals (Construction Permits)
(ACHD – Installation Permits, Major New Source Review permits)
•State Only Operating Permits (Minor Source /Synthetic Minor
OPs)•Title V Operating Permits (Major Source OPs)
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How Do I Know If My Project Needs a Permit?
Install new equipment that has the potential to emit a regulated air pollutant
A physical change to an existing emissions unit or process
A change in the “method of operation” of an existing emissions unit or process
A change to an existing permit condition
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Step 1: Define The Project Ask yourself…
•Will the project require a stack?•Will this project result in a
production increase?•Will this project remove any
existing production constraints?•Does this project require a physical
change to an existing process?
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Step 1: Define The Project•Does this project result in the use of
new and/or greater quantities of raw materials?
•For Biomass – it is likely any existing permit does not provide for biomass as a permitted fuel for the combustion unit!
•Will this project involve changes to existing pollutant control systems?
•Will this project increase my production capacity?
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Step 1: Define The Project If you answer “yes” to any of these,
project must be evaluated to determine if a new air permit or modification of your existing permit is required.
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Major Source Emission Increase
Pollutants Precursors Attainment Classification
Major Source Threshold (tons per
year)
SignificantEmission Increase(tons per
year)
NOx, SO2, Lead NA PSD General 100/250 As applicable
Ozone VOC/NOXNNSR
outside of Philadelphia
5-County Area
50/100 40
Ozone VOC/NOX NNSRSevere-
Philadelphia
25 25
PM2.5 NA PSD/NNSR 100 10
PM2.5 NOX PSD/NNSR 100 40
PM2.5 SOX PSD/NNSR 100 40
PM10 NA PSD/NNSR 100 15
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Step 2: Check The Air Regulations
Exempt activity lists:•Vary from State to State•Typically low-emitting emissions
units•May require a notification•Examples of except activities:
Small natural gas-fired boilers/heaters Fuel oil tanks less than certain size
•Be careful – exemption may not apply for multi-source facility
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Step 2: Check The Air Regulations
Federal New Source Performance Standards (NSPS)
National Emission Standards for Hazardous Air Pollutants (NESHAP)
Maximum Achievable Control Technology (MACT) Standards
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Step 2: Check The Air Regulations
Maximum Achievable Control Technology (MACT) Standards•40 CFR Part 63 •EPA will propose a Boiler MACT the end
of April 2010 – Effective December 2010•Major and area sources of HAP•Emission limits, testing, monitoring,
recordkeeping and reporting requirements
•Lots of possible litigation – and delays
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Step 2: Check The Air Regulations
Pennsylvania requires that all new or modified sources are subject to review for:•Best Available Technology (BAT)
And Major Air Emission Sources can be subject to review for: •Best Available Control Technology
(BACT)•Lowest Achievable Emission
Reductions (LAER)
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Step 2: BAT / BACT A PSD BACT review will require
performance of a “Top-Down” analysis•Determine what control
technologies are feasible vs. technically infeasible
•Rank “feasible” controls according to their effectiveness
•Evaluate operating costs on $/ton basis
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Step 2: LAER The rate of emissions based on the following,
whichever is more stringent: (A) The most stringent emission limitation which is
contained in the implementation plan of a state for the class or category of source unless the owner or operator of the proposed source demonstrates that the limitations are not achievable.
(B) The most stringent emission limitation which is achieved in practice by the class or category of source.
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Step 2: Determine Emission Increase
New Sources: • Potential To Emit
Existing Major Facilities or Where the Emission Increase Will Be Major Itself • Modified Sources – Projected
Actual Emissions minus Baseline Actual Emissions
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Step 3: For New Sources Calculate PTE
Calculate PTE rates for all regulated pollutants• PTE assumes 8,760 hours/year at max rated
capacity, unless operations are restricted• Account for the presence of control devices• Account for physical constraints
• Criteria pollutants (NOX, SO2, PM, PM10, VOC, CO)
• Hazardous air pollutants• State-only air toxics
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Step 3: Calculate PTE Pollutants not previously emitted or
increased existing emissions may trigger permitting.
Decreased amounts of pollutants already emitted may or may not trigger permitting or a streamlined paper exercise.??????
Recent EPA decisions do not allow maximum credit for substitution of cleaner fuels.
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Step 3: Calculate PTE Accepted ways of calculating PTE
•Mass/Material balance•Facility-specific emission factors (EFs)•Vendor-supplied emission factors or
emission rate guarantee•Published emission factors•“Engineering judgment”
There can be more than one way to calculate PTE from your operation
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Step 3: Existing Modified Sources
Calculate Baseline Actual Emissions (BAE)
Determine a Future Projected Actual Emissions (PAE)
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Step 3: Existing Modified Sources
Emission increase is PAE minus BAE Emission increase may be reduced by
emissions the unit could have accommodated If the Project is greater than major source
significance then all facility emission increases and deceases must be considered over the last 5 years (contemporaneous period).
If the Project is less than significant, all de minimis emission increases are counted over the past 10 years for offsets.
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Step 4: Dispersion Modeling
Required for PSD Major Source Permits State air toxics modeling sometimes
required Screen modeling - simple, conservative,
overestimates ambient concentrations Refined modeling – more complex,
accounts for terrain features, building downwash effects
Refined modeling typically only required if screen fails
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My Application Is Submitted; Now What?
Application “completeness” letter within 30-days of submittal
Applications processed on first-come, first-served basis
Typical review time is 3 to 6 months for “minor” modifications. 6 to 12 months (or more) for “major” modifications.
Construction cannot begin until permit is issued
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Delays Can Occur Relationships are important
•Agency relationship•Public relationship
Public comment period Public hearings may be requested, so
plan this into uour timeline Modeling results if performed by
state
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Commence Construction A facility cannot “commence construction”
until a permit is issued
Here’s what you can do:• Site clearing activities• Excavation and demolition activities
Here’s what you cannot do:• Start any construction directly related to
the project• Bring any project equipment on site
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Operating Permit Once construction is complete and
agency is satisfied, an operating permit is needed
Depending on the state agency, construction permit may automatically become an operating permit
May require paperwork