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Part of NSR Program Applicable to Major Sources in Areas Not Attaining the NAAQS Nonattainment NSR Program (NA NSR) Slide 2 2 Re-cap of Permitting Process Brief Description of NA NSR Program Main Requirements Summary Presentation Outline Slide 3 3 Permitting Process Simplified Start Source not subject to NSR Source owner submits permit application Reviewing authority reviews: Application Proposed/Required Control Technologies Compliance with other applicable requirements Draft permit developed Final permit Issued End EPA issued permits may be appealed through EPAs Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. APPLICABILITY APPLICATION APPEALS 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 final permit decision After appeal process ends, permit is finally approved or revoked. Is the source exempted? Slide 4 4 New sources locating in nonattainment areas with air emissions of 100 tpy or more Lower thresholds apply depending on nonattainment severity Modified sources located in nonattainment areas with a net emissions increase higher than the significant emissions rate Regulated pollutants: NAAQS only Applicability: New and Modified Sources Slide 5 5 Emissions calculations are based on Potential to Emit, includes fugitive emissions if the source is part of the 28 source category list28 source category list It can also consider limitations on source operation and emission controls Thresholds: 100 tpy or lower depending on nonattainment severity (See Presentation Appendix)See Presentation Appendix Applicability: New Sources Start Determine sources Potential to Emit (PTE) (per pollutant, may include fugitives) Is PTE applicable threshold? (per pollutant) Source not subject to NA NSR Yes No Source subject to NA NSR Slide 6 6 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 Applicability: Modifications Slide 7 7 Applicability: Modifications (Continued) Yes Start Are Proposed modification emissions SER? (per pollutant) Modification not subject to Major NSR Determine Sources Net Emissions Increase (NEI), (per pollutant) Is the NEI SER? Modification is a major modification and subject to Major NSR Yes No 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 Significant Emission Rate (SER) NEI = Sum of contemporaneous emissions increases and decreases to the proposed modification emissions increase/decrease Under Tribal NSR Rule, contemporaneous period starts 5 years before the source commences construction and ends when the source commences operation Slide 8 8 As with the Tribal Minor 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 NAAQS 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 Slide 9 Modification Example Slide 10 10 SO 2 emissions from a proposed project are 80 tpy The SER for SO 2 is 40 tpy First step, determine if source emissions are higher than the SER In this case, 80 tpy > 40 tpy SER for SO 2 Since project emissions > significant emissions rate (SER), source has to do second step, determine if its net emissions increase is higher than the SER Applicability: 1. Determine the emissions increase from the proposed project Slide 11 11 To determine the sources net emission increase, we need to define the contemporaneous period Under Tribal NSR rule, period starts 5 years before the source commences construction and ends when the source commences operation For example, if the SO 2 source planned to commence construction in June 2012 and begin operation in September 2014, the contemporaneous period for Appendix S is defined as: Applicability: 2. Determine the beginning and ending dates of the contemporaneous period June 2012 Commence Construction June 2011 June 2010 June 2009 June 2008 June 2007 June 2013 June 2014 Sept. 2014 Commence Operation 80 tpy Slide 12 12 Determine emission increases and decreases associated with a physical change or change in the method of operation at the source which did not require a permit For example, our SO 2 source increased its SO 2 emissions in 2009 and decreased its emissions in 2014 Applicability: 3. Determine which units experienced an increase or decrease in emissions during contemp. period June 2012 Commence Construction June 2011 June 2010 June 2009 June 2008 June 2007 Sept. 2014 Commence Operation June 2013 June 2014 80 tpy Slide 13 An increase or decrease is not creditable if it has been previously relied on for issuing a permit and the permit is in effect during the review A decrease is creditable only to the extent that it: Is federally-enforceable from the moment that the actual construction begins Occurs before the proposed emissions increase A source cannot take credit for: A decrease that it has had to make, or will make, in order to bring an emission unit into compliance An emissions reduction from a unit which was permitted but never built or operated Applicability: 4. Determine which emissions are creditable Slide 14 14 On a pollutant by pollutant basis Based on difference between old level and new level of emissions for each unit (actual-to-projected actual test) Past decreases and/or increases in actual emissions based on: Average of any two consecutive years in the past 5 for electric utilities Average of any two consecutive years in the past 10 for non-utilities For example, SO 2 emissions decreases and increases are: Applicability: 5. Determine the amount of each contemporaneous emissions increase or decrease June 2012 Commence Construction June 2011 June 2010 June 2009 June 2008 June 2007 Sept. 2014 Commence Operation June 2013 June 2014 80 tpy 40 tpy 25 tpy Slide 15 15 NEI = PME + CEI CED where: PME = Proposed modification emissions CEI = Creditable emission increases CED = creditable emission decreases For example, NEI = 80 + 25 - 40 = 65 tpy 65 tpy > 40 tpy SO 2 SER, project is a major modification Applicability: 6. Sum all contemporaneous and creditable increases and decreases with the proposed modification June 2012 Commence Construction June 2011 June 2010 June 2009 June 2008 June 2007 June 2013 June 2014 40 tpy 80 tpy25 tpy Sept. 2014 Commence Operation Slide 16 16 PTE less than thresholds Source is grandfathered Source opted for synthetic minor permit Applicability: New or Modified Source not Subject to NA NSR Major Source Threshold Slide 17 17 Main requirements: 1.Install Lowest Achievable Emission Rate (LAER) technologies 2.Obtain emission offsets 3.Perform alternative sites analysis 4.Show statewide facility compliance w/air regulations 5.Allow for opportunities for public involvement For Indian Country: same requirements as current NA Major NSR rules for areas lacking an implementation plan 40 CFR Part 51, Appendix S Application: NA NSR Permit Requirements Slide 18 18 Permitting Process Simplified Start Source not subject to NSR Source owner submits permit application Reviewing authority reviews: Application Proposed/Required Control Technologies Compliance with other applicable requirements Draft permit developed Final permit Issued End EPA issued permits may be appealed through EPAs Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. APPLICABILITY APPLICATION APPEALS 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 final permit decision After appeal process ends, permit is finally approved or revoked. Is the source exempted? Slide 19 19 Rate that has been achieved or is achievable for a defined source Rate may be in a permit or regulation Requirement does not consider the following: Economic Energy Environmental Other factors RACT/BACT/LAER Clearinghouse http://cfpub.epa.gov/rblc/index.cfm?action=Home.Home http://cfpub.epa.gov/rblc/index.cfm?action=Home.Home Application: Lowest Achievable Emission Rate Slide 20 20 Emissions reductions from existing sources to balance emissions from proposed new or modified sources Offset must be at least 1:1 (See Appendix)See Appendix Emissions offsets reductions must be: Quantifiable, Enforceable, Permanent and Surplus (QEPS) From Actual Emissions Real, No paper Reductions Federally enforceable at the time of permit issuance In effect before the new source can commence operation Application: Emission Offsets Slide 21 21 We do not have the legal authority to waive the offset requirement under