Air PermittingBiomass Combustion

UnitsPenn State University

Biomass Combustion ConferenceShort Course Series 2010

April 20, 2010

John Slade, ALL4INCjslade@all4inc.com 717-822-0009

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Today’s Presentation 1. The Basics:

•What is an Air Contaminant?•What is an Air Contamination

Source?•How are Air Contaminants

regulated? 2. Explain Air Permitting!

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Basics What is an Air Contaminant?

•“Smoke, dust, fume, gas, odor, mist, radioactive substance, vapor, pollen or any combination thereof.” (PA Air Pollution Control Act)

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Basics Examples of Air Contaminants:

• Pollutants with National Ambient Air Quality Standards (NAAQS - see 40 CFR Part 50)

• Pollutants regulated under federal NSPS and NESHAP rules (see 40 CFR parts 60, 61, and 63)

• Regulated new source review pollutants (see 40 CFR §52.21(b)(50))

• Title V regulated air pollutant as defined (40 CFR §70.2)

• Pollutants regulated under a State Implementation Plan (SIP) or under state or local rules or policy (e.g., air toxics policy)

• There are others (e.g., RMP, pollen!!!)

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Basics What is an Air Contamination

Source?•“Any place, facility or equipment,

stationary or mobile, at, from or by reason of which there is emitted into the outdoor atmosphere any air contaminant.” (25 PA Code §121.1)

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Basics Source, facility, emissions unit –

what’s the difference?•As defined, source can be either a

single unit or entire facility.•Important issue for understanding

air permitting requirements (e.g., an emission unit may be on exemption list but installation could be modification of facility requiring permit).

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Basics Common Air Emissions Sources:

•Boilers, furnaces, incinerators •Manufacturing process equipment•Material storage silos and stock

piles•Storage tanks

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Basics Who Regulates Air in PA?

• Pennsylvania Department of Environmental Protection (PADEP)

• Philadelphia Air Management Services (AMS) and Allegheny County (ACHD)

• U.S. EPA - Region 3

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Air Permitting

The Good Stuff!!!

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Does My Facility Need An Air Permit?

MYTHS My facility is too

small No one told me I

needed a permit My vendor says I

do not need a permit

I already have an air permit

FACTS Size does not

matter Responsibility lies

with the facility Vendors want to

make a sale You may need

more than one permit

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What Air Emissions Sources Require a Construction Permit? Simple Rule of Thumb: An air quality

plan approval to install a source is required for ANY air emission sources unless:•The source type is listed in the PADEP

rules or on the exemption list OR•PADEP makes a case-by-case

determination that the source does not require installation approval

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Is There More Than One Kind of Air Permit?

Permit to Install/Permit to Construct•Required before emissions units

can be installed or modified Permit to Operate/Operating Permit

•Needed to operate equipment once installation or modification is completed

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Pennsylvania Air Quality Permits

•Plan Approvals (Construction Permits)

(ACHD – Installation Permits, Major New Source Review permits)

•State Only Operating Permits (Minor Source /Synthetic Minor

OPs)•Title V Operating Permits (Major Source OPs)

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How Do I Know If My Project Needs a Permit?

Install new equipment that has the potential to emit a regulated air pollutant

A physical change to an existing emissions unit or process

A change in the “method of operation” of an existing emissions unit or process

A change to an existing permit condition

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Step 1: Define The Project Ask yourself…

•Will the project require a stack?•Will this project result in a

production increase?•Will this project remove any

existing production constraints?•Does this project require a physical

change to an existing process?

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Step 1: Define The Project•Does this project result in the use of

new and/or greater quantities of raw materials?

•For Biomass – it is likely any existing permit does not provide for biomass as a permitted fuel for the combustion unit!

•Will this project involve changes to existing pollutant control systems?

•Will this project increase my production capacity?

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Step 1: Define The Project If you answer “yes” to any of these,

project must be evaluated to determine if a new air permit or modification of your existing permit is required.

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Major Source Emission Increase

Pollutants Precursors Attainment Classification

Major Source Threshold (tons per

year)

SignificantEmission Increase(tons per

year)

NOx, SO2, Lead NA PSD General 100/250 As applicable

Ozone VOC/NOXNNSR

outside of Philadelphia

5-County Area

50/100 40

Ozone VOC/NOX NNSRSevere-

Philadelphia

25 25

PM2.5 NA PSD/NNSR 100 10

PM2.5 NOX PSD/NNSR 100 40

PM2.5 SOX PSD/NNSR 100 40

PM10 NA PSD/NNSR 100 15

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Step 2: Check The Air Regulations

Exempt activity lists:•Vary from State to State•Typically low-emitting emissions

units•May require a notification•Examples of except activities:

Small natural gas-fired boilers/heaters Fuel oil tanks less than certain size

•Be careful – exemption may not apply for multi-source facility

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Step 2: Check The Air Regulations

Federal New Source Performance Standards (NSPS)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

Maximum Achievable Control Technology (MACT) Standards

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Step 2: Check The Air Regulations

Maximum Achievable Control Technology (MACT) Standards•40 CFR Part 63 •EPA will propose a Boiler MACT the end

of April 2010 – Effective December 2010•Major and area sources of HAP•Emission limits, testing, monitoring,

recordkeeping and reporting requirements

•Lots of possible litigation – and delays

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Step 2: Check The Air Regulations

Pennsylvania requires that all new or modified sources are subject to review for:•Best Available Technology (BAT)

And Major Air Emission Sources can be subject to review for: •Best Available Control Technology

(BACT)•Lowest Achievable Emission

Reductions (LAER)

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Step 2: BAT / BACT A PSD BACT review will require

performance of a “Top-Down” analysis•Determine what control

technologies are feasible vs. technically infeasible

•Rank “feasible” controls according to their effectiveness

•Evaluate operating costs on $/ton basis

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Step 2: LAER The rate of emissions based on the following,

whichever is more stringent: (A) The most stringent emission limitation which is

contained in the implementation plan of a state for the class or category of source unless the owner or operator of the proposed source demonstrates that the limitations are not achievable.

(B) The most stringent emission limitation which is achieved in practice by the class or category of source.

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Step 2: Determine Emission Increase

New Sources: • Potential To Emit

Existing Major Facilities or Where the Emission Increase Will Be Major Itself • Modified Sources – Projected

Actual Emissions minus Baseline Actual Emissions

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Step 3: For New Sources Calculate PTE

Calculate PTE rates for all regulated pollutants• PTE assumes 8,760 hours/year at max rated

capacity, unless operations are restricted• Account for the presence of control devices• Account for physical constraints

• Criteria pollutants (NOX, SO2, PM, PM10, VOC, CO)

• Hazardous air pollutants• State-only air toxics

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Step 3: Calculate PTE Pollutants not previously emitted or

increased existing emissions may trigger permitting.

Decreased amounts of pollutants already emitted may or may not trigger permitting or a streamlined paper exercise.??????

Recent EPA decisions do not allow maximum credit for substitution of cleaner fuels.

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Step 3: Calculate PTE Accepted ways of calculating PTE

•Mass/Material balance•Facility-specific emission factors (EFs)•Vendor-supplied emission factors or

emission rate guarantee•Published emission factors•“Engineering judgment”

There can be more than one way to calculate PTE from your operation

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Step 3: Existing Modified Sources

Calculate Baseline Actual Emissions (BAE)

Determine a Future Projected Actual Emissions (PAE)

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Step 3: Existing Modified Sources

Emission increase is PAE minus BAE Emission increase may be reduced by

emissions the unit could have accommodated If the Project is greater than major source

significance then all facility emission increases and deceases must be considered over the last 5 years (contemporaneous period).

If the Project is less than significant, all de minimis emission increases are counted over the past 10 years for offsets.

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Step 4: Dispersion Modeling

Required for PSD Major Source Permits State air toxics modeling sometimes

required Screen modeling - simple, conservative,

overestimates ambient concentrations Refined modeling – more complex,

accounts for terrain features, building downwash effects

Refined modeling typically only required if screen fails

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My Application Is Submitted; Now What?

Application “completeness” letter within 30-days of submittal

Applications processed on first-come, first-served basis

Typical review time is 3 to 6 months for “minor” modifications. 6 to 12 months (or more) for “major” modifications.

Construction cannot begin until permit is issued

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Delays Can Occur Relationships are important

•Agency relationship•Public relationship

Public comment period Public hearings may be requested, so

plan this into uour timeline Modeling results if performed by

state

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Commence Construction A facility cannot “commence construction”

until a permit is issued

Here’s what you can do:• Site clearing activities• Excavation and demolition activities

Here’s what you cannot do:• Start any construction directly related to

the project• Bring any project equipment on site

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Operating Permit Once construction is complete and

agency is satisfied, an operating permit is needed

Depending on the state agency, construction permit may automatically become an operating permit

May require paperwork