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New Source Review. NSR Reforms Oklahoma Department of Environmental Quality Air Quality Council Presented by Matt Paque, Attorney, ODEQ - AQD April 20, 2005. Federal New Source Review (NSR) Program. Established by the 1977 Clean Air Act Amendments

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New Source Review

NSR Reforms

Oklahoma Department of Environmental Quality

Air Quality Council

Presented by Matt Paque, Attorney, ODEQ - AQD

April 20, 2005


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Federal New Source Review (NSR) Program

  • Established by the 1977 Clean Air Act Amendments

  • To ensure that new major stationary sources and major modifications

    • Install state-of-the-art pollution controls

    • Assess air quality impacts

    • Protect against violations of health-based air quality standards


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New Sources

  • A new source with a Potential to Emit (PTE) at or above the applicable threshold amount “triggers,” or is subject to NSR.


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“Major Modification”

“Any physical change in, or change in the method of operation of a [existing] stationary source which increases the amount of any air pollutant emitted by such source or which results in the emission of any air pollutant not previously emitted.”

Exclusions:

  • Routine maintenance, repair and replacement.

  • Changes that do not result in a significant emissions increase.


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“Major Modification”

A project is a major modification for a regulated NSR pollutant if it causes:

(1) A significant emissions increase at the project;

(2) A significant net emissions increase at the source.


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NSR Reform RulesPublished December 31, 2002

  • Final Rules (67 FR 80186)

    • Revision to Major Modification determination

      • Baseline Actual Emissions

      • Actual-to-Projected Actual Applicability Test

    • Plantwide Applicability Limitations (PALs)

    • Clean Units

    • Pollution Control Project (PCP)


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OAC Chapter 100

  • ODEQ/AQD is working to propose changes to the Oklahoma Air Pollution Control Rules that will incorporate the NSR Reforms as well as earlier EPA NSR rulemakings.


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Revision to Major Modification Determination

  • Two changes to existing NSR regulations that will affect how to calculate emissions increases to determine whether projects trigger NSR requirements:

    • “Baseline Actual Emissions” changes the method for determining the source’s baseline emissions prior to a project.

    • “Actual-to-Projected Actual Applicability Test” changes the method for estimating the emissions after the project.


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Baseline Actual Emissions

  • Baseline actual emissions are based on any consecutive two-year period within the 5 years immediately preceding the project.

  • Use same 24-month period for all emissions units involved in project and same 24-month period for each pollutant.


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Baseline Actual Emissions

  • Used to calculate emissions increases for:

    • Modifications, to determine a modified unit’s pre-change baseline actual emissions as part of the new actual-to-projected actual applicability test.

    • For netting, to determine the pre-change baseline actual emissions of an emissions unit that underwent a physical or operational change within the contemporaneous period.

    • Also used to establish a PAL emissions cap.


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Actual-to-Projected Actual Calculation

  • Source must make a projection of post-change annual emissions that are expected to result from the project.

  • Source must project changed unit’s maximum actual annual emissions rate that will occur during any one of the 5 years after the change,

    OR

  • 10-year period after the change (if the change involves an increase in the emissions unit’s PTE or capacity).


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Projected Actual Emissions

  • Compares pre-change actual emissions to post-change “projected actual” emissions.

  • Avoids major NSR as long as difference in emissions is not significant.

  • Apply to changes at any existing emissions unit (includes replacement and reconstructed units).


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Plant-wide Applicability Limits (PALs)

  • Plant-wide applicable limits (“PALs”) allow source owners to make changes to their facilities without obtaining a major NSR permit.

  • Once a PAL is established, plant may make any change without undergoing major NSR provided the emissions do not increase above the PAL “actual emissions” level (known as “actuals PALs”).


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Clean Unit Certification

  • A source that underwent a post-1990 BACT/LAER review (or equivalent at time of installation) may be exempt from the standard NSR applicability test for certain future changes; even if emissions do increase, “no emissions increase will be deemed to occur.”

  • Available for up to 10 years after applying emissions controls, with a 10-year renewal possible.


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Pollution Control Project (PCP) Exclusion

  • Designed to encourage projects at existing major sources that will result in a net overall reduction of air pollutants, even if there will be a significant increase of a collateral pollutant.

  • Old “primary purpose” test eliminated.


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PCP Exclusion, cont’d

What Qualifies for the Exclusion?

  • A project must pass two tests to qualify for the exclusion:

    • Environmentally Beneficial Test (shows benefits outweigh emissions increase).

    • Air Quality Test (project cannot result in an emissions increase that will cause a violation of a NAAQS or PSD increment or result in an adverse impact on Class I areas).


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Revisions to 252:100 Subchapter 8, Part 7

  • First proposal: July 20, 2005 - Air Quality Council meeting.

  • Revisions to Oklahoma Air Pollution Control Rules should be adopted by AQC and submitted to EPA by January 6, 2006.


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