part of nsr program applicable to major sources in areas attaining the naaqs prevention of...

Part of NSR Program Applicable to Major Sources in Areas Attaining

the NAAQS

Prevention of Significant Deterioration (PSD) Program

Presentation Outline

•Re-cap of Permitting Process

•Description of PSD Program Requirements

•Main Requirements Summary

3Permitting Process Simplified

Start

Source not

subject toNSR

Source owner submits permit

application

Reviewing authority reviews:• Application

• Proposed/Required Control Technologies

• Compliance with other applicable requirements

Draft permit

developed

Final permitIssued

End

EPA issued permits may be appealed through EPA’s Environmental Appeals

Board (EAB). After EAB process, permits may be appealed in Federal Court.

APPL

ICAB

ILIT

YAP

PLIC

ATIO

NAP

PEAL

S

Are the source proposed emissions ≥

applicable thresholds or emission rates? (per

pollutant, may include fugitives)

Is the

permit for a new source or a

modification to an existing

source?

Is source in an area

that is attaining or nonattaining the

NAAQS?No

Yes

30 day comment

period

Public hearing

Usually appealed within

30 days of finalpermit decision

After appeal processends, permit is

finally approved orrevoked.

Is thesource

exempted?

4

• New sources locating in attainment areas with air emissions equal to or higher than 100 or 250 tons per year (tpy), higher thresholds for Greenhouse Gases (GHGs)

• Modifications to existing sources in attainment areas with a net emissions increase higher than the Significant Emissions Rate

• Regulated pollutants: NAAQS, GHGs and other pollutants– NAAQS: Carbon Monoxide (CO), Lead (Pb), Nitrogen Dioxide (NO2), Ozone,

Particulate Matter (PM), and Sulfur Dioxide (SO2)– Greenhouse Gases: Carbon dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O),

Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulfur Hexafluoride (SF6)

– Other Pollutants Include: Sulfuric Acid Mist (H2SO4), Hydrogen Sulfide (H2S)

– Excludes Air Toxics: Mercury (Hg), Cadmium (Cd), Benzene (C6H6), etc.

Applicability: New and Modified Sources

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)

Higher Thresholds

5

6

• Emissions calculations are based on Potential to Emit, includes fugitive emissions if the source is part of the 28 source category list

• It can also consider limitations on source operation and emission controls

• Thresholds: 250 tpy for most source categories, 100 tpy for 28 listed source categories (same categories for which fugitives are accounted for)– Higher thresholds for GHGs

Applicability: New Sources

Start

Determine source’s

Potential to Emit (PTE)

(per pollutant, may include

fugitives)

Is PTE ≥ applicablethreshold?

(per pollutant)

Source not

subject toPSD

Yes

No

Source subject to

PSD

7

• Emissions calculations are based on Actual Emissions – “day-to-day” emissions at the source– Actual emissions = projected emissions after the change – baseline

emissions before the change (actual-to-projected actual test)– Baseline emissions: average of any 24 consecutive months of

emissions within 10 yrs prior to project (5 yrs for electric utilities)– Projected emissions: max. annual emissions (tpy) that will occur

during any one of 5 yrs after project– If unit was unpermitted or is added, emission increase based on PTE

• Includes fugitive emissions if source is part of the 28 source category list

Applicability: Modifications

8

Applicability: Modifications (Continued)

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

Major modification = one that results in (1) a significant emissions increase from the project and (2) a significant net emissions increase (NEI)• Significant Emission Rate (SER) – emissions rate limit 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 the source commences

construction and ends when the source commences operation

9

• As with the Tribal NA NSR program, NSR applicability is determined for all new and modified units at the source– New units – applicability based on PTE– Modified units – applicability based on actual emissions

• Includes all regulated NSR pollutants that the source emits • Source emissions are calculated using:

– On-site measurement (e.g. stack testing)– Vendor design capacity or rated capacity information – Material (i.e. mass balance) balance calculations – Emission factors

• The annual maximum emissions from all production processes/equipment are added for each regulated NSR pollutant

Applicability: Steps

Applicability: PSD Thresholds for GHGs

Applicability: GHG Emissions Calculations

• The following example illustrates the method to calculate GHG emissions on both a mass basis and CO2e basis

• A proposed emissions unit emits five of the six GHG compounds in the following amounts (Global Warming Potentials for each compound included in parenthesis):– 50,000 TPY of CO2 (GWP = 1)– 60 TPY of methane (GWP = 21)– 1 TPY of nitrous oxide (GWP = 310)– 5 TPY of HFC-32 (a hydrofluorocarbon) (GWP = 650)– 3 TPY of PFC-14 (a perfluorocarbon) (GWP = 6,500)

• GHGs mass-based emissions:– 50,000 TPY + 60 TPY + 1 TPY + 5 TPY + 3TPY = 50,069 TPY

• CO2e-based emissions:– (50,000 TPY x 1) + (60 TPY x 21) + (1 TPY x 310) + (5 TPY x 650) + (3 TPY x 6,500)

= 50,000 + 1,260 + 310 + 3,250 + 19,500 = 74,320 TPY CO2e

12

• Concept known as “Major for One Major for All”• Mainly Applicable to New Sources

Applicability: Other Circumstances New Source or Modified Source Might be Subject to PSD

Start

Determine PTE of other

pollutants thatare below

thresholds (per pollutant)

Is PTE ≥ applicableSER?

(per pollutant)

Pollutantnot

subject toPSD

Yes

No

Source ismajor for

PSDfor one

pollutant

Pollutantsubject to

PSD

13

• PTE less than thresholds• Source is

“grandfathered”• Source opted for

“synthetic minor” permit

Applicability: New or Modified Source not Subject to PSD

Potential to Emit (PTE)

Actual0

50

100

150

200

250

300

350

Synthetic Minor Source Emissions

Type of Emissions

Emiss

ions

(tpy

)

Major Source Threshold


Start

Source not

subject toNSR


application




Draft permit

developed

Final permitIssued

End



APPL

ICAB

ILIT

YAP

PLIC

ATIO

NAP

PEAL

S




Is the



source?



NAAQS?No

Yes

30 day comment

period

Public hearing





Is thesource

exempted?

15

• Main requirements:1. Install Best Available Control Technology (BACT)2. Perform air quality analysis to assess impacts on air quality3. Perform class I area analysis to assess impacts on national

parks and wilderness areas 4. Perform additional impacts analysis5. Allow for opportunities for public involvement

Application: PSD Program Requirements

16

• Pollutant specific emissions limit, case-by-case– Takes into account energy, environmental, or economic impacts

• Limit must be at least as stringent as applicable:– New Source Performance Standard (NSPS) and/or – National Emission Standard for Hazardous Air Pollutants (NESHAP)

• Selected by “Top Down” BACT analysis1. Identify all available control technologies2. Eliminate technically infeasible control options3. Rank remaining control technologies by its effectiveness (considers

economic, energy and environmental impacts)4. Evaluate most effective controls and document results5. Select BACT

Application: Best Achievable Control Technology (BACT)

17

• Pollutant specific analysis that involves: – An assessment of existing air quality and – Modeling estimate of ambient concentrations from

proposed project and future growth associated with project

• Purpose is to determine if new plus existing emissions will cause or contribute to a violation of a:– NAAQS and/or – PSD increment

Application: Air Quality Impact Analysis (AQIA)

18

• A new source or modification cannot cause or contribute to significant deterioration of air quality in attainment areas

• Maximum amount of deterioration allowed is called an increment

• Increments exist for:– 3 pollutants (PM--PM10 and PM2.5, SO2 and NO2)– Various averaging periods (annual, 1-hour)– 3 area classifications (Class I, Class II, Class III)

Application: AQIA for Increment Compliance

PM2.5 Increments by Area Classification (g/m3) NAAQS (g/m3) Averaging Period Class I Class II Class III

Annual 1 4 8 1524-hr 2 9 18 35

19

Application: AQIA for Increment Compliance (Continued)

• Change in air quality measured against a certain baseline

• Not all sources consume increment

• Two important concepts apply: – Baseline area• All portions of the attainment area in which the PSD applicant proposes

to locate and/or would have a significant ambient impact (i.e. higher than Significant Impact Level)

• Limited to intrastate areas: baseline areas not triggered across state lines

– Baseline date• When increment consumption starts, pollutant specific

20

• Baseline Date(s) - when increment consumption starts, pollutant specific

Application: AQIA for Increment Compliance (Continued)

Major Source Baseline Date

Minor Source Baseline Date

SO2 and PM - Jan. 6, 1975 NOx - Feb. 8, 1988

Date of first complete permit application

when actual emission changes from all sources affect the available increment

when actual emissions associated with construction at a major source affect increment

Start

21

• A new source or modification cannot cause or contribute to a violation of any NAAQS in any area

• Compliance with any NAAQS is based on proposed source and all other sources in baseline area– No baseline dates exist– Analysis requirements similar to increment analysis

• NAAQS analysis independent from increment analysis

Application: AQIA for NAAQS Compliance

22

• Compliance determined by using air quality models

• Preliminary analysis (significant impact analysis)– Screening type models– Representative meteorology– Only proposed source emissions – Refined receptor grids

• Full impact analysis (cumulative impact analysis)– Refined model– Representative meteorology– All applicable increment affecting sources– More refined receptor grids (smaller grid spacing)

Application: AQIA Steps

23

• Evaluation of NAAQS, PSD increments and Air Quality Related Values (AQRVs) when a major source’s emissions may affect a Class I area– Class I Area – areas reserved for special air quality protection, usually

national parks and wilderness areas– AQRVs – feature or property of a Class I Area that may be affected by a

change in air quality; differ for each Class I area

• Generally for sources within 100 km of Class I area, not always

• Federal Land Manager (FLM) must be notified of potential impacts– Determines data and analyses needed

Application: Class I Area Impact Analysis

24

• Assesses potential effects of increased air, ground and water pollution from proposed source and associated growth on:– Soils and Vegetation– Visibility

• Pollutant specific

• Performed within the impact area of the proposed source

Application: Additional Impact Analysis

25

• Reviewing authority is required to provide:– Public notice to the affected community and the general public on the

draft permit– At least a 30 day public comment period on the draft permit– Opportunity for public hearing on draft permit, if requested by public

• All public comments must be considered before a final permit is developed

• A Technical Support Document (TSD), generally including responses to comments, may also be available with the final permit

Application: Public Involvement


Start

Source not

subject toNSR


application




Draft permit

developed

Final permitIssued

End



APPL

ICAB

ILIT

YAP

PLIC

ATIO

NAP

PEAL

S




Is the



source?



NAAQS?No

Yes

30 day comment

period

Public hearing





Is thesource

exempted?

27

• Provisions for permit appeals available under the program, same as Tribal NA NSR and minor NSR program

• Appeals are conducted through the EPA’s Environmental Appeals Board (EAB)

• If all remedies for permit appeal through the EAB are exhausted, person may appeal to Federal Court

Appeals

28

• Program for major sources located in attainment areas (generally for emissions at or higher than 100 or 250 tpy)

• Pollutants regulated: NAAQS, GHGs, other pollutants

• Main requirement: Best Available Control Technology (BACT)

• Permits are usually issued no later than 1 year after the date the permit application is deemed complete

Key Points to Remember: PSD

Appendix

28 PSD Source Categories

30

28 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

Significant Emission Rates (SERs)

31

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)

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