prevention of significant deterioration (psd) nsr program donald law u.s. epa region 8
TRANSCRIPT
PREVENTION OF SIGNIFICANT DETERIORATION (PSD) NSR PROGRAM
Donald LawU.S. EPA Region 8
2
Preconstruction Permit Programs
Minor Source NSRState
requirements for non-major new
sources and modifications
PSD
Requirements for new major
sources and major modifications in
attainment/ unclassifiable
areas
Nonattainment Area NSR
Requirements for new major
sources and major
modifications in nonattainment
areas
CAA
Title IPart A
Section 110Part C
Section 165Part D
Section 173
New Source Review
3
Preconstruction Permit Programs
Minor Source NSRState
requirements for non-major new
sources and modifications
PSD
Requirements for new major
sources and major modifications in
attainment/ unclassifiable
areas
Nonattainment Area NSR
Requirements for new major
sources and major
modifications in nonattainment
areas
CAA
Title IPart A
Section 110Part C
Section 165Part D
Section 173
New Source Review
4
Major Topics4
4 steps to determine whether new construction or modification project is subject to PSD Attainment status PTE Identify appropriate threshold (new construction)
or emission rate (modification) Compare proposed emissions to threshold or rate
When a modification may “net out” of PSD Common applicability issues
5
Which Sources Might be Subject to the PSD Program?
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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
Some sources have been “grandfathered” or have opted for “synthetic minor permit”
6
How Do You Know When PSD Applies to a Source?
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1. Assess attainment status of source’s geographic area
2. Determine source’s potential to emit (PTE)
3. Determine which thresholds or emissions rate applies
4. Determine if proposed emissions will exceed the applicable limit
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Step 1: What is the Attainment Status of Source’s Geographic Area?
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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
Check green book http:/www.epa.gov/oaqps001/greenbk/map_download.html
Search an EPA database such as: www.epa.gov/air/data
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What happens if the area is in non-attainment status?
8
Non-attainment status only applies to that particular pollutant
Emission source can be major for non-attainment pollutant (NA-NSR permit) and major for PSD pollutant (PSD permit)
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Step 1: What is the Attainment Status of Source’s Geographic Area?
9
Exampleo Denver is o non-attainment for Ozone (VOC
and NOx)o Attainment for CO, PM10, PM2.5,
NO2, Pb, and SO2
10
Step 1: What is the Attainment Status of Source’s Geographic Area? (cont.)
10
Exampleo Denver is
o Non-attainment for Ozone (VOC and NOx).o Attainment for CO, PM10, PM2.5, NO2, Pb,
SO2
o Therefore PSD requirements apply foro CO, PM10, PM2.5, NO2, Pb, SO2
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Step 2: What is the Source’s Potential to Emit (PTE)?
11
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 Other mitigating factors (site specific and quite uncommon)
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Calculating Emissions for NSR Applicability
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All new and modified units are subject to applicability determinations New units – based on PTE Modified units – based on actual emissions (or potential if new unit)
Include all regulated NSR pollutants that the source emits
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Calculating Emissions for NSR Applicability
13
Source emissions are calculated using On-site measurement (e.g., stack testing) Operational records of actual production Vendor design capacity or rated capacity
information Material balance (i.e., mass balance)
calculations Emission factors
Emissions from all affected emissions units are added for each regulated NSR pollutant
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Exercise on Potential to Emit
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American Widget and Doohicky, Inc. constructing brand new widget factory outside Albert, Kansas. Facility will have two 8-hour shifts per day, make 1500 widgets per day. No TIP, SIP, or FIP limitations apply to this facility. Based on testing data from similar AWD Inc. facility, the following emission rates can be expected
NOx – 60 lb/hrSO2 – 25 lb/hrVOC – .622 lb/widget
What is the PTE of the new AWD Inc. facility for these 3 pollutants?
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Exercise on Potential to Emit
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What is the PTE of the new AWD Inc. facility for these three pollutants?
a. What is source’s PTE for NOx? 60 x 8760 / 2000 = 262.8 tpy
b. What is source’s PTE for SO2? 25 x 8760 / 2000 = 109.5 tpy
c. What is source’s PTE for SO2? 1500 /16 x .622 *8760 / 2000 = 255 tpy
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Step 3. What is the Applicable PSD Threshold for New Sources?
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250 tons per year (tpy) for most source categories
100 tpy, if part of the 28 listed source categories (and include fugitive emissions for these source categories)
250 tpy of GHG and 100,000 tpy of CO2 equivalentsStart
Determine source’s
Potential to Emit (PTE)
(per pollutant, may include
fugitives)
Is PTE ≥ applicablethreshold?
(per regulated NSR pollutant)
Source not
subject toPSD
Yes
No
Source subject to
PSD
17
Applicability: Thresholds Attainment Areas Regulated NSR Pollutant Major Source Threshold (tpy)
Carbon Monoxide (CO)
100 or 250
Sulfur Dioxide (SO2)
Ozone - Oxides of Nitrogen (NOx)
Ozone - Volatile Organic Compounds (VOC)
PM
PM-10
PM-2.5
Lead
Fluorides
Sulfuric Acid Mist
Hydrogen Sulfide (H2S)
Total Reduced Sulfur (including H2S)
Reduced Sulfur Compounds (including H2S)
Municipal Waste Combustor Emissions
Municipal Solid Waste Landfills Emissions
Greenhouse Gases (Combination of gasesCO2, CH4, N2O, HFC, PFC, SF6)
250 tpy GHGs and 100,000 tpy of CO2e
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Step 4: How Do You Determine if Proposed Emissions will Exceed the Applicable Limit ?18
For each pollutant, compare source’s PTE with applicable threshold
If PTE is equal to or higher than threshold, source is major for PSD
Example Source PTE for NO2 is 300 tpy 300 tpy > 250 tpy, source is
subject to PSD
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Exercise on Applicability (100 tpy vs. 250 tpy)
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a. Primary copper smelter has PTE of 150 tpy of NOX. Major source for PSD?
b. Glass manufacturing plant plans to operate a dry scrubber designed to meet emission limit of 50 lb/hr of SO2 (or 219 tpy). Major source for PSD?
c. A power plant of more than 250 million BTU/hour heat input will burn natural gas and will have PTE of 200 tpy of CO and 82 tpy of NOX. Major source for PSD? For which pollutant(s)?
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Exercise on Applicability (100 tpy vs. 250 tpy)
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a. Primary copper smelter has PTE of 150 tpy of NOX. Major source for PSD? Yes.
b. Glass manufacturing plant plans to operate a dry scrubber designed to meet an emission limit of 50 lb/hr of SO2 (or 219 tpy). Major source for PSD? No.
c. Power plant of more than 250 million BTU/hour heat input will burn natural gas and will have PTE of 200 tpy of CO and 82 tpy of NOX. Major source for PSD? Yes. For which pollutant(s)? CO
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Significant Emissions Rate21
If a source is major, PSD applies to attainment pollutants emitted above significant emissions rate
See appendix with table for Significant emissions rates
22
Example22
A newly proposed natural gas-fired power plant (categorical facility) has potential to emit the following in an attainment area
250 TPY CO 101 TPY NO2
45 TPY VOC 20 TPY SO2
20 TPY PM10/2.5
23
Example23
A newly proposed natural gas-fired power plant (categorical facility) has potential to emit the following in an attainment area
250 TPY CO YES 101 TPY NO2 YES 45 TPY VOC YES 20 TPY SO2 NO 20 TPY PM10/2.5 YES
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Modifications that are Subject to the PSD Program
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Major modification = mod that results in (1) significant emissions increase and (2) significant net emissions increase, i.e., increase higher than significant emissions rate (SER)
Step 1: calculate proposed emissions Step 2: if emissions are greater than or equal to
SER, calculate Net Emissions Increase. Greater than or equal to SER?
YesStart
Are Proposed
modification emissions ≥
SER?(per pollutant)
Modification not
subject toMajor NSR
Determine Source’s NetEmissions Increase
(NEI),(per pollutant)
Is the NEI ≥ SER?
Modification is a major
modification and
subject toMajor NSR
Yes
No
No
25
Significant Emission Rate (SER) – emissions rate threshold in tpy, by pollutant
NEI = Sum of contemporaneous emissions increases and decreases to the proposed modification emissions increase/decrease
• Under PSD, contemporaneous period starts 5 years before source commences construction and ends when source commences operation
Applicability: Modifications
YesStart
Are Proposed
modification emissions ≥
SER?(per pollutant)
Modification not
subject toMajor NSR
Determine Source’s NetEmissions Increase
(NEI),(per pollutant)
Is the NEI ≥ SER?
Modification is a major
modification and
subject toMajor NSR
Yes
NoNo
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Calculating a Project’s Emissions Increases
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Emissions are based on actual emissions Actual emissions = projected emissions
after the change minus baseline emissions before the change (actual-to-projected-actual test)
Projected emissions: max. annual emissions (tpy) that will occur during any one of 5 yrs after project
If unit was added, emission increase based on PTE
Include fugitives if source is part of the 28 source category list
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Determining Net Emissions Increase (NEI)
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NEI = Sum of contemporaneous emissions increases and decreases to proposed modification emissions increase
Sum of contemporaneous emissions increases and decreases to 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)
Under PSD, contemporaneous period starts 5 years before source commences construction and ends when source commences operation
If NEI is greater than SER, source is major
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Exercise on Determining if a Modification is Major
28
Gas treating site plans to replace an outdated internal combustion engine with more efficient engine with greater capacity. Engine changeout will eliminate old unit’s NOX and CO emissions (78 and 125 tpy). New unit will emit 100 tpy of NOX and 175 tpy of CO. Do the net emissions increases make this changeout a major modification?
Assume no other emissions changes during the contemporaneous period
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Exercise on Determining if a Modification is Major
29
Gas treating site plans to replace an outdated internal combustion engine with more efficient engine with greater capacity. Engine changeout will eliminate old unit’s NOX and CO emissions (78 and 125 tpy). New unit will emit 100 tpy of NOX and 175 tpy of CO. Do the net emissions increases make this changeout a major modification?
Assume no other emissions changes during contemporaneous period
No, because emissions increases are below the SER for NOX (40 tpy) and the SER for CO (100 tpy)
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In What Other Circumstances Can a Source be Subject to PSD?
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Once determined a source is major for PSD, source must review pollutants below 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”
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Common Problem Areas31
Facilities may try to split major modifications into multiple “minor” modifications
Facilities may insist that their multiple emissions units are not part of the same “source” for PSD purposes
Facilities may try to use emission decreases for netting that are not creditable (i.e., not federally enforceable)
Facilities may try to use emission decreases for netting that were required by rules or consent decrees
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Defining the New Source32
Includes all related activities classified under the same 2-digit SIC code number
Has the same owner or operator
Is located on contiguous or adjacent properties
Includes all support facilities
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Example33
Rock Crushing operations and aggregate source Two separate rock crushing
operation at separate quarries Providing raw materials to an
aggregate source All owned by same parent company Shared staff and equipment
34
PSD Thresholds for GHGs (Permits issued on or after July 1, 2011)
34
PSD applies to GHGs, if The source is otherwise subject to PSD
(for another regulated NSR pollutant) and
The source has a GHG PTE equal to or greater than 75,000 tpy CO2e
OR source has a GHG PTE equal to or greater than: 100,000 tpy CO2e, and 100/250 tpy mass basis
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Calculating GHG Emissions on a Mass Basis and CO2e Basis
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To compute mass basis of GHG emissions, simply add tpy for each GHG emitted from facility
To compute CO2e basis, first multiply emissions of each GHG times its Global Warming Potential (GWP) value. Then add tpy of all GHGs Each GHG is assigned a value based on
its Global Warming Potential (GWP) with higher values going to pollutants with the most serious GWP
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Example Calculation36
Assume a proposed emissions unit emits 3 of the six GHG compounds in the following amounts 50,000 tpy of CO2 (GWP = 1) 60 tpy of methane (GWP = 25) 3 tpy of PFC-14 (a perfluorocarbon) (GWP = 6,500)
GHGs mass-based emissions 50,000 tpy +60tpy + 3 tpy = 50,063 tpy
CO2e-based emissions (50,000 tpy x 1) or 50,000 tpy, plus (60 tpy x 25) or 1,500 typ, plus (3 tpy x 6,500) or 19, 500 Total: 71,000 tpy
37
Major Modifications and GHGs (for Permits Issued after July 1, 2011)
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PSD applies to GHGs if Modification otherwise subject to
PSD (for another regulated NSR pollutant), and has GHG emissions increase and net emissions increase Equal to or greater than 75,000 tpy
CO2e, and Greater than 0 tpy mass basis
OR….(cont. next slide)
38
Major Modifications and GHGs (cont.)38
OR BOTH Existing source has PTE equal to or greater than
100,000 tpy CO2e and 100/250 tpy mass basis
Modification has GHG emissions increase and net emissions increase
Equal to or greater than 75,000 tpy CO2e and
Greater than 0 tpy mass basis OR BOTH
Source is existing minor source for PSD, and Modification alone has actual or potential GHG
emissions equal to or greater than 100,000 tpy CO2e, and 100/250 tpy mass basis
39
Final Applicability Exercise39
Existing Chemical Processing Plant will add a new process unit modify an existing process unit by removing an existing reactor vessel and adding a larger one Highest actual emissions from the last five
years are 150 tons VOC, 65 tons NOx, 115 tons CO, 145,000 tons CO2e
PTE of new reactor based on similar unit at sister facility 200 tons VOC, 85 tons NOx, 160 tons CO, 219,000 tons CO2, and 50 tons methane
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Details of Example Chemical Plant
40
Area is in attainment for all pollutants
Source add an emergency generator 4 years ago with a net emission increase of 25 tpy NOx and 45 tpy CO
Is the project a major PSD project, and if so, for what pollutants?
41
Example Solution 41
1. Evaluate for PSD• Determine applicable threshold
• Chemical Process Plants 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 • 150 tpy of VOC > 100 tpy threshold• 145,000 of CO2e > 75,000 tpy CO2e• Plant is a major source for PSD• Now review all attainment pollutants for PSD
applicability
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Example Solution42
Pollutant Net Emissions Increase VOC: 200 tpy – 150 tpy = 50 tpy increase NOx: 85 tpy – 65 tpy + 25 tpy = 45 tpy increase CO: 160 tpy – 115 tpy + 45 tpy = 90 tpy increase CO2e: 219,000 tpy -145,000 tpy + (50 x 25) tpy =
75,200
Project Applicability 50 tpy VOC > 40 tpy VOC SER - YES 45 tpy NOx > 40 tpy NOx SER - YES 90 tpy CO < 100 tpy CO SER – NO 75,200 tpy CO2e > 75,000 tpy CO2e - YES
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Summary43
4 step process used to determine if new construction or modification is subject to PSD PSD threshold for new construction is
based on PTE PSD emission rate (SER) is based on
actual emissions Higher thresholds and SER apply to
Greenhouse gases Potential applicability issues of
concern: “sham” minor modifications disaggregation of emissions units netting
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Appendix
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28 Source Categories28 source categories
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
46
Significant Emission Rates (SERs)
Pollutant SER (tpy) Pollutant SER (tpy)
Carbon Monoxide 100 Sulfuric Acid Mist 7
Nitrogen Oxides 40 Hydrogen Sulfide (H2S) 10
Sulfur Dioxide 40 Total Reduced Sulfur (Includes H2S) 10
Particulate Matter (PM10)
15 Reduced Sulfur Compounds (Includes H2S)
10
Particulate Matter (PM2.5)
10; 40 for VOCs, NOx or SO2
Municipal Waste Combustor Organics
3.5*10-6
Ozone 40 VOCs or NOx
Municipal Waste Combustor Metals 15
Lead 0.6 Municipal Waste Combustor for Acid Gases
40
Fluorides 3 Municipal Solid Waste Landfills Emissions
50
SER – a rate of emissions that would equal or exceed any of the following rates:
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)
47
Global Warming Potentials (GWP)
• Carbon Dioxide GWP =1 • Methane GWP = 21 (25) • Nitrous Oxide GWP = 300 • Sulfur Hexafluoride GWP = 23,900
• HFCs Vary • PFCs Vary
• Full list is found at 40 CFR Part 98, Subpart A Table A-1