implications of greenhouse gas (ghg), volatile organic compounds (voc), and fine particulate (pm2.5)

www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324

Implications of Greenhouse Gas (GHG), Volatile Organic

Compounds (VOC), and Fine Particulate (PM2.5)

to Air Quality PermittingJohn Slade | [email protected] | (610) 933-5246 x136

Dan Holland |[email protected] | (610) 933-5246 x115November 6, 2013

2 Your environmental compliance is clearly our business.

Overview of New Source Review (NSR) Major Modification VOC, GHG, and PM2.5 Emissions Under NSR

• VOC• GHG• PM2.5

Flexibility in Air Permitting

Agenda


Construction permits for major new sources or major modifications fall under the “Major New Source Review (NSR)” rules. There are 2 types:• Prevention of Significant Deterioration (PSD) permits

in attainment areas.• Non-attainment New Source Review (NNSR) permits in

non-attainment areas. Major NSR permits are required prior to

commencing construction.

New Source Review


NAAQS Summary

Pollutant Averaging Period NAAQS (µg/m3)

CO1-Hour 40,000

8-Hour 10,000

Ozone 8-Hour 75 ppb

Pb 3-Month Rolling 0.15

PM10 24-Hour 150

PM2.5

24-Hour 35

Annual 12

NO2

1-Hour 188

Annual 100

SO2

1-Hour 196

3-Hour 1,300


NSR can apply to:• New major sources.• Modifications to existing major sources.• Modifications to existing minor sources.

Major source criteria is based on “potential to emit”.

Major modification criteria is based on “net emissions increase”.

NSR Applicability


Major modification means any physical change in or change in the method of operation of a major stationary source that would result in: • a significant emissions increase (as defined in

paragraph (b)(40) of this section) of a regulated NSR pollutant (as defined in paragraph (b)(50) of this section) and

• a significant net emissions increase of that pollutant from the major stationary source.

NSR Major Modification


NNSR applies for non-attainment areas and areas in the Ozone Transport Region.

NNSR significance levels are less than PSD levels.• Precursor pollutant (NOX).

Degree of non-attainment is considered.• 25 tons for VOC and NOX in severe non-attainment

areas.• Emission Reduction Credits (ERCs) required at a ratio

of 1.3 to 1. Lowest Achievable Emission Rate (LAER).

Assessing VOC Permitting


May 2010: Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule (GHG Tailoring Rule). • January 2011: Step 1 - GHG air permitting began for

facilities that would otherwise require permitting.• July 2011: Step 2 - GHG permitting began for all

facilities that would emit more than 100,000 tons of CO2e per year and facilities that undergo modification that would increase emissions by 75,000 tons of CO2e per year.

• July 2012: Step 3 amendments and streamlining options.

Assessing GHG Permitting


July 2012: Step 3 amendments and streamlining options.• Step 1 and Step 2 PSD and Title V GHG thresholds not

changed.• Revisions to 40 CFR Part 52 for better implementation

of establishing PALs for GHG emissions.

Assessing GHG Permitting


Currently must address GHG in all applications.• Demonstrate PSD status.• Best Available Control Technology (BACT) analysis.

Full GHG emission inventories required in renewal applications.• “Major source” label for another pollutant.

Tailoring Rule Step 4 by April 2016.• Thresholds could be lowered.

GHG Permitting


NSPS/NESHAP requirements for energy efficiency.• Output based standard in current EGU proposal.

Questionable GHG control technologies. Energy efficiency requirements.

• Introduced in “Boiler MACT.”• Could be part of Step 4.• Could be added to existing standards.

GHG Standards


PM2.5 emissions may not have been quantified previously.

Precursor emissions (NOX and SO2) need to be considered.

Significance Level for PM2.5 is 10 tpy. Air quality modeling for PM2.5 is difficult.

• No “exemption” modeling via SILs.• May trigger ambient monitoring requirements.

PM2.5 PSD Permitting


NNSR pollutants trigger only that pollutant for NNSR permitting. • Facility 100 tpy PM2.5 – Significance Level 10 tpy.• Facility 100 tpy NOX – Significance Level 40 tpy.• Facility 100 tpy SO2 - Significance Level 40 tpy.

Must offset PM2.5 increase with emission reduction credits (ERCs).• ERCs are difficult to find and expensive to secure.• May need to demonstrate ERCs can be used.

Lowest Achievable Emission Rate (LAER) Control Technology is required.

PM2.5 NNSR Permitting


Method 201A for sizing of particulate.• Difficult to use on wet sources.• May need to utilize Method 5 and scale results.

Method 202 for condensable particulate matter.• Blank correction requires extended sampling times.• Artifact formation may occur with long sampling

times. Other test methods allowed.

• API Wet Stack Method.• U.S. EPA Conditional Test Method 039.

PM2.5 Emission Testing


Strategic planning for facility future must consider implications of both new air rule applicability and air permitting implications:• New rules likely require facility changes.• No exemption for pollution control projects.• Permitting issues can impact project design.

Future Planning


“Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease air permitting PSD cycle.

Federal PSD rule provides for PALs based on historic actual emissions.

PALs are pollutant specific and could be a critical part of a facility strategic plan.

PAL Option


Develop historic facility-wide baseline emission rates and potential PAL levels.

Address potential NAAQS issues. Consider new rules, facility operations plans,

potential energy efficiency improvements, new technologies, low hanging fruit for emissions reductions.

Weigh value of PAL for each pollutant.

PAL Planning Approach