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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?

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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
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.

example new major source type 1
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?

project increase at major source type 2
Project Increase at Major Source (Type 2)

Is Project Increase≥ PSD Significant Emission Rate?

Project Increase = Planned Emissions - Baseline Actual

example base line type 2
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
planned emissions
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.

example netting type 3
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

example end points type 3
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

items to do uble check
Items to Double Check
  • Project aggregation
  • Site definition
  • Inclusion of fugitives
  • Differences with power generation
  • Demand growth exclusion
  • Retrospective reviews
thank you
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)

contacts
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

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