1 / 18

PSD/NNSR Applicability Examples

PSD/NNSR Applicability Examples. Matt Earnest, Ph.D. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014. Applicability Flow Chart. Go though flowchart, pollutant by pollutant. 1-is source in nonattainment area for the pollutants?

Download Presentation

PSD/NNSR Applicability Examples

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. PSD/NNSR Applicability Examples Matt Earnest, Ph.D. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014

  2. Applicability Flow Chart Go though flowchart, pollutant by pollutant. 1-is source in nonattainment area for the pollutants? 2-is the source an existing major source? (major for one, major for all) 3-increases only, no decreases at this step. Ensure the change is a modification. 4- a major mod occurs when increases > significant emission rates 5- are the project increases > than major source thresholds? 6- include all increases and creditable decreases in contemporaneous window.

  3. Does PSD/NNSR Apply?

  4. Major Source Thresholds

  5. Example: New Major Source(Type 1) NNSR: Yes, major source because NOX≥25 tpy PSD: Yes, major source for all pollutants because CO≥250tpy Will the following “unnamed” source, proposed to be built in a severe ozone nonattainment area (HGB), be major for NNSR and/or PSD? If so, for which pollutants?

  6. Project Increase at Major Source (Type 2) Is Project Increase≥ PSD Significant Emission Rate? Project Increase = Planned Emissions - Baseline Actual

  7. Example: Base Line (Type 2) A site is considering a throughput increase in 2014. What is the baseline actual emission rate, given EPN D was built in 2013 with an allowable of 50 tpy? • Right example-correct way to calculate BAE by using emissions from all EPNs from years 2007 and 2008 • Must be same time period for all facilities for common pollutant. • Adjust baseline if: • < 24-month operation • Compliance issues

  8. Planned Emissions EPN A is operating far below it’s PTE. What are the project increases given the following? EPN A Baseline Actual Emissions (BAE) = 61 tpy EPN A Potential to Emit (PTE) = 201 tpy EPN A Projected Actual after project (PAE) = 72 tpy Project increase: Based on Projected Actual: PAE – BAE = 72 – 61 = 11 tpy Based on Potential to Emit: PTE – BAE = 201 – 61 = 140 tpy Use of Projected Actuals may require additional record keeping.

  9. Table 2F

  10. Contemporaneous Window

  11. Example: Netting (Type 3) A company is considering a major project at EPN B that requires netting. The source has been affected by the following unrelated projects within the last five years. What is the contemporaneous change? 2010: PTE = 15 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy PAST • 2014: PTE = 20 tpy • Proposed PTE = 30 tpy • Baseline Actuals = 15 tpy • Project Change: 30 - 15 = 15 tpy • Net: 15 + 10 + 10 + 10 = 45 tpy CURRENT

  12. 3F: Contemporaneous Change

  13. Contemporaneous Window

  14. Example: End Points (Type 3) A company is considering a major project at EPN B that requires netting. The source has been affected by the following unrelated projects within the last five years. What is the contemporaneous change? 2010: PTE = 15 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2014: PTE = 20 tpy Proposed PTE = 30 tpy Baseline Actuals = 15 tpy Project Change: 30 - 15 = 15 tpy Net: 15 + 10 + 10 + 10 = 45 tpyNo...Year 2011 is not considered in the calculation to determine the contemporaneous change; 45 tons/year is not the correct answer 2010: Baseline Actuals = 15 tpy, 2011, 2011, 2014: Proposed PTE = 30 tpy, Net: 30 – 15 = 15 tpy Baseline Actuals = 15 tpy 2011: 2011: 2014: Proposed PTE = 30 tpy Net: 30 - 15 = 15 tpy

  15. 3F: Contemporaneous Change

  16. Items to Double Check • Project aggregation • Site definition • Inclusion of fugitives • Differences with power generation • Demand growth exclusion • Retrospective reviews

  17. Thank you For more information: See Guidance: APDG 5881, Major New Source Review - Applicability Determination (March 2013) APDG 6241v1, Fact Sheet – PSD and Nonattainment (Revised 07/14)

  18. Contacts Matt Earnest (512) 239-2618 Johnny Vermillion (512) 239-1292 Air Permits Division (512) 239-1250 Matt Earnest Johnny Vermillion (512) 239-2618 (512) 239-1292 Air Permits Division Air Permits Division Main Line (512) 239-1250 Air Permits Division

More Related