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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


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    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