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Slide 2 Prevention of Significant Deterioration/Nonattainment Review The Basics Richard (Rick) Goertz, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014 Slide 3 NAAQS Criteria pollutants CO, NO X, SO 2, Ozone (NO X /VOC) PM 10, PM 2.5, and Pb Primary NAAQS protect public health Secondary NAAQS protect public welfare Slide 4 Important Terms Attainment In compliance with NAAQS Nonattainment Out of compliance with NAAQS Slide 5 Current Nonattainment Areas Wise HGB Ozone Nonattainment Area 1997 Severe 2008 Marginal DFW Ozone Nonattainment Area 1997 Serious 2008 Moderate Lead Nonattainment Area Moderate PM 10 Nonattainment Area Wise County (DFW) Ozone Nonattainment Area - 1997 Attainment - 2008 Moderate (Effective 7/20/12) Slide 6 Minor and Major NSR Federal (Major) NSR ------------------- PSD Nonattainment State (Minor) NSR ------------------------ NSR permit Standard permit PBR De minimis Federal (Major) NSR ----------------------- PSD Nonattainment Slide 7 PSD Program New major sources Major modifications of existing major sources Criteria pollutants that are in attainment Certain non-criteria pollutants Slide 8 PSD Program Major source definition: Named Source > 100 tpy (includes fugitives) Un-named Source > 250 tpy Slide 9 PSD Program Major Modification Significant Emission Rates for Criteria Pollutants: CO100tpy NO X 40tpy SO 2 40tpy VOC40tpy PM25tpy PM 10 15tpy PM 2.5 10tpy Pb0.6tpy Slide 10 PSD Program Major Modification Significant Emission Rates for Non-Criteria Pollutants: Fluorides3 tpy Sulfuric acid mist7 tpy Hydrogen sulfide10 tpy Total reduced sulfur10 tpy Plus others........ Slide 11 PSD Program PSD Review Requires... Major for one regulated pollutant, major for all Application of BACT Air quality analysis (modeling) If within 100 km of a Class I area, inform FLM PM 10, PM 2.5 include filterable & condensable Slide 12 Nonattainment Program Applies only to pollutants for which the area is designated as nonattainment New major sources Major modifications of existing major sources Most commonly encountered area - ozone regulated through NO X and VOC Slide 13 Nonattainment Area Limits DFW - Serious Major Source 50 TPY Major Mod. 25 TPY Wise County (DFW) - Moderate Major Source 100 TPY Major Mod. 40 TPY Wise HGB - Severe Major Source 25 TPY Major Mod. 25 TPY Slide 14 Nonattainment Program Nonattainment Review Requires (for ozone)... Must be a major source or major modification for either NO X or VOC NO X and VOC are evaluated independently Application of LAER Application of offsets Slide 15 Nonattainment Program Offset: An actual emission reduction, greater than or equal to the projects potential emission increase The amount of offset depends on the nonattainment classification Slide 16 Nonattainment Areas Offset Ratios DFW - Serious Major Source 50 TPY Major Mod. 25 TPY Offset Ratio = 1.2 to 1 Wise County (DFW) - Moderate Major Source 100 TPY Major Mod. 40 TPY Offset Ratio = 1.15 to 1 HGB - Severe Major Source 25 TPY Major Mod. 25 TPY Offset Ratio = 1.3 to 1 Wise Slide 17 PSD and Nonattainment Review Is it possible to trigger both PSD and nonattainment for the same pollutant? Yes, it is. NO X is an ozone precursor and has a NAAQS of its own. Slide 18 Location of New or Modified Equipment Where is the equipment located? In an attainment or nonattainment area? At a grassroots or an existing minor source? At an existing major source? Slide 19 Location of New or Modified Equipment To trigger major NSR at a grassroots or existing minor source, the potential project increase must be major in and of itself. Slide 20 Example 1 Company B is a minor un-named source in a severe nonattainment area. Current PTE = 20 tpy NO X Proposed PTE = 40 tpy NO X Baseline Actual = 25 tpy NO X Current PTE=20 tpy NO x Proposed PTE=40 tpy NO x Major Source =25 tpy NO x Current PTE=20 tpy NO x Proposed PTE=40 tpy NO x Major Source =25 tpy NO x Slide 21 Example 1 Current PTE = 20 tpy Proposed PTE = 40 tpy Major Source = 25 tpy The project potential increase is: 40 tpy 20 tpy = 20 tpy The project is not a major source in and of itself {greater than or equal to 25 tpy for a severe nonattainment area}. Major NSR is not triggered, but minor NSR permitting requirements do apply. Slide 22 Location of New or Modified Equipment To trigger major NSR at an existing major source, the net project emission increase must be greater than or equal to the major modification significant emission rate for the pollutant Slide 23 Determine Emissions Determine the project increase for each pollutant. Compare project increase to netting significance levels. If the increase is greater than the netting significance levels, netting is required. If net project increase exceeds significance levels, major NSR is triggered. Slide 24 Determine Emissions Project Emission Increase + Planned Emission Rate (project increases only) -Baseline Actuals (affected facilities) = Project Emission Increase Slide 25 Determine Emissions Planned Emission Rate Either the... Potential to emit, or Projected actual emission rate Slide 26 Determine Emissions Baseline Actual Emission Rate Emissions, in tons per year, actually emitted during a consecutive 24-month period out of... The previous 10 years, or The previous 5 years for electric utilities Slide 27 Determine Emissions 2014 Jan 1, Application Submittal 2004200920102011201220132014 10-year window for selecting 24-month Baseline Actual Emission Rate Slide 28 Determine Emissions Netting Netting is required if the project increase equals or exceeds the netting significance level for the pollutant. Planned Emission Rate minus Baseline Actual Netting Significance Level Slide 29 Determine Emissions Netting Significance Levels PSD: same as PSD major modification significance levels Nonattainment: Serious & Severe: 5 tpy Moderate: 40 tpy Slide 30 NETTING! Slide 31 About Netting Applies to existing major sources only Applicability step to determine if major NSR has been triggered Ensures smaller projects do not add up to be a major modification Slide 32 About Netting Conducted for each pollutant in which netting is triggered An evaluation of : The current project, plus Increases and decreases within the contemporaneous period (netting window) Slide 33 Contemporaneous Period Netting Window Five years before start of construction to Proposed start of operation Slide 34 Netting Contemporaneous Period Slide 35 Netting Window Modifications identified within the contemporaneous period may be based on: The date the modification was authorized, or The date the change is operated Must be used consistently Indicate which method is used Slide 36 Creditable Emissions Occurs during the contemporaneous period Cannot have been relied upon in issuing a major NSR permit for the source Sources/activities authorized by the major NSR permit are not in operation when the current increase is authorized Rely on Emissions Inventory Slide 37 Creditable Increases The new level of emissions exceeds the Baseline Actual Emission Rate (PTE Baseline = Increase) Does not include emission increases at facilities under a plant-wide applicability limit (PAL) Slide 38 Creditable Decreases The Baseline Actual Emission Rate exceeds the new level of emissions Enforceable at and after the time that project modification begins to operate. (Must be enforceable and real before the unit starts operation) Slide 39 Determining Increases and Decreases Increases and decreases for each project within the contemporaneous period are determined based on a comparison of the following: Baseline Actual Emission Rate and The PTE of that project (projected actuals are not used in this step except for the current project) Slide 40 Baseline Actual Emission Rate Emissions, in tons/year, actually emitted during a consecutive 24-month period out of the previous 10 years (previous 5 years for electric utilities) from the date the project is authorized or modifications are operated Slide 41 Using an Allowable to Allowable Comparison Situation #1: the Baseline Actual > current PTE Situation #2: a new facility is within two years of its initial start up date Slide 42 Netting Window Example Slide 43 Net Emissions Increase Project increase +Non-project source-wide creditable contemporaneous emission increases -Source-wide creditable contemporaneous emission decreases (including the current project) The amount that exceeds zero Slide 44 Triggering Major NSR Compare the net increases to the appropriate significant emission rate If the increase is greater than or equal to the significant emission rate for the pollutant, major NSR is required Slide 45 Time for some examples! Slide 46 Example 2 Company C is a named major source in a severe nonattainment area. Current PTE = 50 tpy NO X Proposed PTE = 52 tpy NO X Baseline Actual = 48 tpy NO X Project Increase = 4 tpy NO X Current PTE=50 tpy NO x Proposed PTE=52 tpy NO x Baseline Actual=48 tpy NO x Project Increase =4 tpy NO x Current PTE=50 tpy NO x Proposed PTE=52 tpy NO x Baseline Actual=48 tpy NO x Project Increase =4 tpy NO x Slide 47 Example 2 Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 52 tpy Baseline Actual = 48 tpy Project Increase = 4 tpy Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 52 tpy Baseline Actual = 48 tpy Project Increase = 4 tpy The project increase of 4 tpy does not exceed the netting significance level of 5 tpy for a serious nonattainment area. Netting is not required. Slide 48 Example 3 Company is a named major source in a serious nonattainment area. Current PTE = 50 tpy NO X Proposed PTE = 60 tpy NO X Baseline Actual = 47 tpy NO X Project Increase = 13 tpy NO X (Proposed PTE-Baseline Actual) Current PTE= 50 tpy NO x Proposed PTE= 60 tpy NO x Baseline Actual= 47 tpy NO x Project increase= 13 tpy NO x ( Proposed PTE-Baseline Actual) Current PTE= 50 tpy NO x Proposed PTE= 60 tpy NO x Baseline Actual= 47 tpy NO x Project increase= 13 tpy NO x ( Proposed PTE-Baseline Actual) Slide 49 Example 3 Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 60 tpy Baseline Actual = 47 tpy Project Increase = 13 tpy Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 60 tpy Baseline Actual = 47 tpy Project Increase = 13 tpy Emissions increase exceeds the netting significance level of 5 tpy. Netting is required! Slide 50 Example 3 Table 3F NO x Slide 51 Example 3 Finding Total Increase Current Project 13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase - 4.25 tons/year decrease Total Increase: 14 tons/year Current Project13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase 4.25 tons/year decrease Total Increase: 14 tons/year Current Project13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase 4.25 tons/year decrease Total Increase: 14 tons/year Slide 52 Example 3 Nonattainment? The major modification significant emission rate for a severe nonattainment area is 25 tpy. Net project increase is 14 tpy. The project is not a major modification and major NSR (nonattainment review) is not required. Slide 53 Check Your Calculations! Slide 54 Contacts JOHNNY VERMILLION (512) 239-1292 Or Rick Goertz (512) 239-5606