Major Sources Major Sources Pollutant Pollutant Federal NSR Federal NSR 112(g 112(g ) ) Major Major Major Major ROP ROP Major Major PSD PSD Major Major Offse Offse t t Attainment Attainment Pollutants Pollutants 250 250 or or 100 100 NA NA NA NA 100 100 Non-Attainment Non-Attainment Pollutants Pollutants NA NA 100 100 NA NA 100 100 Individual HAPs Individual HAPs NA NA NA NA 10 10 10 10 Insert After Page 1-6 Insert After Page 1-6
36
Embed
Major Sources Pollutant Federal NSR 112(g) Major Major ROP Major PSD Major Offset Attainment Pollutants 250 or 100 NANA100 Non-Attainment Pollutants NA100NA100.
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Minor Source Minor Source + Major Source+ Major Source
Major Source Major Source + Sign. Source+ Sign. Source
Insert After Page 2-4Insert After Page 2-4
PSD Applicability MatrixPSD Applicability MatrixQuadrants III and IV – Existing SourcesQuadrants III and IV – Existing Sources
We Must Decide:We Must Decide:
1.1. If the proposed change is a modificationIf the proposed change is a modification
AndAnd
2.2. What is the magnitude of the emissions What is the magnitude of the emissions
increase from the modificationincrease from the modification
Insert After Page 2-4Insert After Page 2-4
What’s a Modification?What’s a Modification?A more complete definitionA more complete definition
• Any physical change in;Any physical change in;• Or change in the method of operation of;Or change in the method of operation of;• An existing major (Q4) source that;An existing major (Q4) source that;• Would result in a significant emissions increase; Would result in a significant emissions increase;
andand• A significant net emissions increase.A significant net emissions increase.
ExcludingExcluding: : • Routine maintenance, repair, and replacement; Routine maintenance, repair, and replacement; • Use of alternative fuels (under certain Use of alternative fuels (under certain
circumstances); circumstances); • Changes of ownership; Changes of ownership; • The addition or replacement of a pollution control The addition or replacement of a pollution control
project;project;• Increases in operating hours or production rate, Increases in operating hours or production rate,
unless either are prohibited by permit conditionunless either are prohibited by permit conditionInsert After Page 2-4Insert After Page 2-4
Quadrants I - IIIQuadrants I - IIIPotential Emissions IncreasesPotential Emissions Increases
Potential emissions Potential emissions BEFORE the modification.BEFORE the modification.
Potential emissions AFTER Potential emissions AFTER the modification.the modification.
The post-change The post-change POTENTIALPOTENTIAL emissions are emissions are compared with compared with the Baseline the Baseline ACTUAL ACTUAL EmissionsEmissions
Company A submits an application to modify one of its boilers. Company A submits an application to modify one of its boilers. Company A is an existing major stationary source (Q4) of NOCompany A is an existing major stationary source (Q4) of NOXX. The . The
modification will increase potential NOmodification will increase potential NOXX emissions from 75 lb/hr to 80 emissions from 75 lb/hr to 80
lb/hr. The boilers have consistently operated 7200 hr/yr, but are lb/hr. The boilers have consistently operated 7200 hr/yr, but are permitted to operate 8760 hr/yr (allowed 329 TPY). Using the Actual to permitted to operate 8760 hr/yr (allowed 329 TPY). Using the Actual to Projected Actual Test, is this change subject to PSD?Projected Actual Test, is this change subject to PSD?
ExampleExample
Baseline:Baseline: 75 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 270 TPY75 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 270 TPY
Potential:Potential: 80 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 350 TPY80 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 350 TPY
Projected:Projected: 80 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 288 TPY80 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 288 TPY
Insert After Page 4-5Insert After Page 4-5
ExampleExampleInstead of remaining constant, boiler utilization will continue its Instead of remaining constant, boiler utilization will continue its historical trend of 2% growth per year from 7200 hr/yr. historical trend of 2% growth per year from 7200 hr/yr.
270270270270288288
294294300300
306306312312
318318324324
331331337337
344344
What emissions could the boiler accommodate prior to the change?What emissions could the boiler accommodate prior to the change?
323323
270270275275
281281287287
292292298298 304304
310310316316
11 22 33 44 55 66 77 88 99 1010
75 lb/hr x Projected Utilization (hr/yr)75 lb/hr x Projected Utilization (hr/yr)
Are these emissions independent of the change to 80 lb/hr?Are these emissions independent of the change to 80 lb/hr?Would they have happened anyway?Would they have happened anyway?
7474
Insert Insert After After
Page 4-5Page 4-5
QuestionQuestionSince the boiler was already permitted at 329 Since the boiler was already permitted at 329 TPY, why isn’t the level of excluded emissions TPY, why isn’t the level of excluded emissions equal to 329 TPY? equal to 329 TPY?
270270270270288288
294294300300
306306312312
318318324324
331331337337
344344
323323
270270275275
281281287287
292292298298 304304
310310316316
11 22 33 44 55 66 77 88 99 1010
2121
Because, at the level of projected business activity, the boiler could Because, at the level of projected business activity, the boiler could only have accommodated 323 TPY of emissions, otherwise it would only have accommodated 323 TPY of emissions, otherwise it would
have violated its permit.have violated its permit.
Insert Insert After After
Page 4-5Page 4-5
NettingNetting
For modifications at existing major sources For modifications at existing major sources (Q4), there are two parts to PSD (Q4), there are two parts to PSD
applicability…applicability………determining if determining if
a significant a significant emissions emissions
increase will increase will occuroccur
……determining if determining if a significant a significant netnet emissions emissions increase will increase will occuroccur
Emissions Emissions change from the change from the
projectproject
Emissions Emissions change from the change from the
facilityfacilityInsert After Page 3-6Insert After Page 3-6
In A NutshellIn A Nutshell
Each Emission Unit Each Emission Unit pays for admission pays for admission only once…only once…
……as long as it as long as it complies with the complies with the
terms of its terms of its admissionadmissionThe price of The price of
admission is admission is installing BACT installing BACT controlscontrols
The terms of The terms of admission are the admission are the
permit limits needed permit limits needed to ensure BACTto ensure BACTInsert Before Page 5-Insert Before Page 5-
What Are Qualifying What Are Qualifying Controls?Controls?
A monetary investment in theA monetary investment in the
controls is necessary!controls is necessary!
The investment must qualify as a capital The investment must qualify as a capital expense under the IRS filing guidelinesexpense under the IRS filing guidelines
Insert Before Page 5-1Insert Before Page 5-1
How Do I Get In On This?How Do I Get In On This?
Use the Front Door…Use the Front Door…New EUs that install New EUs that install qualifying BACT controls qualifying BACT controls through PSD through PSD automaticallyautomatically get in get in
……Use the Back Door…Use the Back Door…EUs that installed EUs that installed qualifying BACT controls qualifying BACT controls through PSD in past 10 years through PSD in past 10 years automaticallyautomatically get in get in
… … Or Climb in Through the WindowOr Climb in Through the WindowEUs with comparable, or “substantially as EUs with comparable, or “substantially as effective” control technology effective” control technology maymay get in (with a get in (with a demonstration)demonstration)
Insert After Page 5-2Insert After Page 5-2
What Should I Expect?What Should I Expect?
Monitoring, recordkeeping and Monitoring, recordkeeping and reporting requirements reporting requirements adequate to allow on-going adequate to allow on-going demonstration of compliance demonstration of compliance
Emission limits based on, or equal to, BACTEmission limits based on, or equal to, BACT
Permit limits on other terms such as operating Permit limits on other terms such as operating parameters, on which the BACT and CU parameters, on which the BACT and CU determinations were baseddeterminations were based
Permit limits specifying the start and end dates for Permit limits specifying the start and end dates for the CU designationthe CU designation
Insert After Page 5-6Insert After Page 5-6
What to ExpectWhat to Expect
The limit will be a rolling 12-month The limit will be a rolling 12-month total – effective for 10 yearstotal – effective for 10 years
Emissions from all sources of the Emissions from all sources of the PAL pollutant must be monitored, PAL pollutant must be monitored, or a default value usedor a default value used
Records must be kept for life of Records must be kept for life of the PAL plus 5 yearsthe PAL plus 5 years
The new PTI containing the PAL The new PTI containing the PAL conditions must go through the conditions must go through the public noticing requirementspublic noticing requirements
PAL conditions will be rolled into PAL conditions will be rolled into the ROP at its next opportunitythe ROP at its next opportunity
Insert After Page 6-4Insert After Page 6-4
Can the PAL Level Be Can the PAL Level Be Changed?Changed?
Appropriate level Appropriate level based on:based on:
Air Quality NeedsAir Quality Needs
Advances in Control Advances in Control TechnologyTechnology
Anticipated Anticipated Economic Growth in Economic Growth in
How can control costs be determined so that How can control costs be determined so that they can be compared among different they can be compared among different
facilities and for different control options?facilities and for different control options?
Dollars per Dollars per Ton of Ton of
Pollutant Pollutant ControlledControlled
Allows comparisons Allows comparisons among companiesamong companies
of different sizesof different sizes
Allows comparisons Allows comparisons among different among different types of companiestypes of companies
Dollars per Ton of Pollutant ControlledDollars per Ton of Pollutant Controlled
1.1. Calculate the Annualized Cost Calculate the Annualized Cost for the control optionfor the control option
2.2. Calculate the Annual Emissions, Calculate the Annual Emissions, in tons that will be reduced by in tons that will be reduced by the control optionthe control option
WHAT? – All New EmissionsWHAT? – All New Emissions
WHY? –WHY? – To Show They Don’t To Show They Don’t Cause or Contribute to A Cause or Contribute to A Violation of Any NAAQS Violation of Any NAAQS or PSD Incrementor PSD Increment
Insert Before Page 9-17Insert Before Page 9-17
Modeling for PSD IncrementsModeling for PSD Increments
Triggering Dates Triggering Dates (See MDEQ Website)(See MDEQ Website)