major sources pollutant federal nsr 112(g) major major rop major psd major offset attainment...
TRANSCRIPT
Major SourcesMajor Sources
PollutantPollutantFederal NSRFederal NSR
112(g) 112(g) MajorMajor
Major Major ROPROP
Major Major PSDPSD
Major Major OffsetOffset
Attainment Attainment PollutantsPollutants
250 or 250 or 100100
NANA NANA 100100
Non-Attainment Non-Attainment PollutantsPollutants
NANA 100100 NANA 100100
Individual HAPsIndividual HAPs NANA NANA 1010 1010
Aggregate HAPsAggregate HAPs NANA NANA 2525 2525
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New
Existing
Minor
Major
No PSDNo PSD
But may be subject to But may be subject to minor source permittingminor source permitting
PSD for PSD for modifications that result in modifications that result in
a significant emissions a significant emissions increase increase andand a significant a significant
net emissions increasenet emissions increase
Modifications that Modifications that by by themselvesthemselves exceed exceed the Major Source the Major Source
thresholdthreshold
PSD for each pollutant PSD for each pollutant emitted at greater than the emitted at greater than the
Major Source threshold Major Source threshold and each additional and each additional
pollutant emitted at greater pollutant emitted at greater than its significant than its significant
emissions thresholdemissions threshold
II
IIII
IIIIII
IVIV
PSD Applicability MatrixPSD Applicability Matrix
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New
Existing
Minor
Major
PSD Applicability MatrixPSD Applicability Matrix
Applicability Applicability determination is based determination is based
on the potential on the potential emissions from the emissions from the
new equipmentnew equipment
Applicability Applicability determination is based determination is based
on the potential on the potential emissions from the emissions from the
new equipmentnew equipment
Applicability Applicability determination is based determination is based
on the potential on the potential emissions increase emissions increase resulting from the resulting from the
modificationmodification
Applicability Applicability determination is based determination is based
on the emissions on the emissions increase above increase above baseline actual baseline actual
emissionsemissions
Applicability Applicability determination is based determination is based
on the on the potential potential emissionsemissions from the from the
new equipmentnew equipment
Applicability Applicability determination is based determination is based
on the on the potential potential emissionsemissions from the from the
new equipmentnew equipment
Applicability Applicability determination is based determination is based
on the on the potential potential emissionsemissions increase increase resulting from the resulting from the
modificationmodification
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ApplicabilityApplicabilityNew FacilityNew Facility
60 TPY 60 TPY VOCVOC
600 TPY 600 TPY COCO
350 TPY 350 TPY NONOXX
New FacilityNew Facility
Existing FacilityExisting Facility
Existing FacilityExisting Facility
110 TPY 110 TPY COCO
60 TPY 60 TPY PM10PM10
275 TPY 275 TPY PM10PM10
Minor SourceMinor Source
Major SourceMajor Source
Minor Source Minor Source + Major Source+ Major Source
Major Source Major Source + Sign. Source+ Sign. Source
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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
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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.
Q1 SourcesQ1 Sources
249 TPY After249 TPY After- - 0 TPY Before 0 TPY Before== 249 TPY Increase249 TPY Increase
Q2 SourcesQ2 Sources
275 TPY After275 TPY After- - 0 TPY Before 0 TPY Before== 275 TPY Increase275 TPY Increase
Q3 SourcesQ3 Sources
498 TPY After498 TPY After- - 249 TPY Before249 TPY Before== 249 TPY Increase249 TPY Increase
No PSDNo PSD
No PSDNo PSD
PSDPSD
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Actual to Potential TestActual to Potential Test
The post-change The post-change POTENTIALPOTENTIAL emissions are emissions are compared with compared with the Baseline the Baseline ACTUAL ACTUAL EmissionsEmissions
ACTUAL
POTENTIAL
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350 - 270 = 80 TPY > 40 TPY Major350 - 270 = 80 TPY > 40 TPY Major
288 - 270 = 18 TPY < 40 TPY Minor288 - 270 = 18 TPY < 40 TPY Minor
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
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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
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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.
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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-
11
Add-on control devicesAdd-on control devices
Pollution prevention activitiesPollution prevention activities
Work practice standardsWork practice standards
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
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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)
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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
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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
Semi-annual deviation reports requiredSemi-annual deviation reports required
Annual compliance certification requiredAnnual compliance certification required
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What to ExpectWhat to Expect
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
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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
the Areathe Area
To Reward or To Reward or Encourage Encourage
Voluntary Emission Voluntary Emission Reductions, etc…Reductions, etc…
At RenewalAt Renewal
Ten steps to Ten steps to determine if an determine if an
increase is increase is allowable.allowable.
Turn to Turn to
Page 6-3Page 6-3
IncreasesIncreases
To correct typos or To correct typos or other errorsother errors
To accommodate the To accommodate the generation of ERCs generation of ERCs
or Offsetsor Offsets
To reflect the impact To reflect the impact of new State or of new State or
federal regulationsfederal regulations
To maintain air To maintain air qualityquality
DecreasesDecreases
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How Do I Get Out of the How Do I Get Out of the PAL?PAL?
Divide the PAL tonnage among all Divide the PAL tonnage among all the emission units at the facility the emission units at the facility
These allocations will become the These allocations will become the new permit limits for each new permit limits for each
emission unitemission unit
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Am I in?Am I in?A PSD Applicability Summary…A PSD Applicability Summary…
MethodMethod RecordsRecords CalcsCalcs ControlsControls New New EUsEUs
Emission Emission TestsTests
A2PA2P NoNo YesYes NoNo YesYes
A2AA2A YesYes YesYes NoNo NoNo
Alternate Alternate TestsTests
Clean Clean UnitUnit NoNo NoNo YesYes NoNo
PALPAL YesYes NoNo NoNo YesYes
PCPPCP NoNo MaybeMaybe YesYes NoNo
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Step 2: Eliminate TechnicallyStep 2: Eliminate TechnicallyInfeasible OptionsInfeasible Options
UNUSUAL CHARACTERISTICSUNUSUAL CHARACTERISTICS
Catalyst Blinding AgentsCatalyst Blinding Agents
Halogenated VOCs and Oxidizers Halogenated VOCs and Oxidizers
Sticky PM and BaghousesSticky PM and Baghouses
Cool Exhaust Temperatures and SCRCool Exhaust Temperatures and SCR
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Step 2: Eliminate TechnicallyStep 2: Eliminate TechnicallyInfeasible OptionsInfeasible Options
Nobody Else In Our Industry Has Used ItNobody Else In Our Industry Has Used It
There’s Not Enough Room For The DuctworkThere’s Not Enough Room For The Ductwork
The Roof Won’t Support ItThe Roof Won’t Support It
Consumes a Limited Natural Resource (Natural Consumes a Limited Natural Resource (Natural Gas)Gas)
Will Require Its Own Electrical SubstationWill Require Its Own Electrical Substation
Our Building Contains an Explosive Our Building Contains an Explosive AtmosphereAtmosphere
UNUSUAL CHARACTERISTICSUNUSUAL CHARACTERISTICS
REJECTED
REJECTED
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These usually end up in the These usually end up in the Economic AnalysisEconomic Analysis
Step 4: EvaluationsStep 4: EvaluationsEnergy Impact AnalysisEnergy Impact Analysis
Only Unusual Energy Impacts Only Unusual Energy Impacts Should Be ConsideredShould Be Considered
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Step 4: EvaluationsStep 4: EvaluationsEnvironmental Impact AnalysisEnvironmental Impact Analysis
This is not NAAQS and IncrementsThis is not NAAQS and Increments
Solid/HazardousSolid/HazardousWaste GenerationWaste Generation
Water DischargesWater DischargesVisibility ImpactsVisibility Impacts
Need to show Need to show unusual/unreasonable impacts unusual/unreasonable impacts
compared to other facilities compared to other facilities where this control option has where this control option has
been usedbeen used
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Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis
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
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Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis
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
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Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis
• Total Capital Investment annualized Total Capital Investment annualized over 10 years at 7% interestover 10 years at 7% interest
• Annual Labor Costs (oper/maint/supv)Annual Labor Costs (oper/maint/supv)
• Annual Energy Costs (fuel/electrical)Annual Energy Costs (fuel/electrical)
• Annual Overhead Costs Annual Overhead Costs (taxes/insurance)(taxes/insurance)
Annualized CostAnnualized Cost
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Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis
ExampleExample
Assume Recent BACT determinations = $5000 - Assume Recent BACT determinations = $5000 - $6000/ton$6000/ton
Control Option No. 1Control Option No. 1 Control Option No. 2Control Option No. 2
Reduces 142 TPY (EU A & B)Reduces 142 TPY (EU A & B)
TCI = $4,500,000TCI = $4,500,000
10 years @ 7% = $635,400/yr10 years @ 7% = $635,400/yr
Labor = $4000/yrLabor = $4000/yr
Energy/Util = $123,000Energy/Util = $123,000
Overhead = $75,400Overhead = $75,400
Reduces 130 TPY (EU A only)Reduces 130 TPY (EU A only)
TCI = $3,100,000TCI = $3,100,000
10 years @ 7% = $437,720/yr10 years @ 7% = $437,720/yr
Labor = $4500/yrLabor = $4500/yr
Energy/Util = $151,000Energy/Util = $151,000
Overhead = $56,780Overhead = $56,780
Control Cost = Control Cost = $837,800/yr$837,800/yr
$5900/ton for 142 tons$5900/ton for 142 tons
Control Cost = Control Cost = $650,000/yr$650,000/yr
$5000/ton for 130 tons$5000/ton for 130 tons
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Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis
ExampleExample
Assume Recent BACT determinations = $5000 - Assume Recent BACT determinations = $5000 - $6000/ton$6000/ton
Control Option No. 1Control Option No. 1 Control Option No. 2Control Option No. 2
Control Cost = Control Cost = $837,800/yr$837,800/yr
$5900/ton for 142 tons$5900/ton for 142 tons
Control Cost = Control Cost = $650,000/yr$650,000/yr
$5000/ton for 130 tons$5000/ton for 130 tonsIncremental CostIncremental Cost
$837,800 - $650,000 = $187,800$837,800 - $650,000 = $187,800
142 tons – 130 tons = 12 tons142 tons – 130 tons = 12 tons
$187,800 / 12 tons = $15,650/ton$187,800 / 12 tons = $15,650/ton
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ModelingModeling
WHO? -WHO? - All PSD ApplicantsAll PSD Applicants
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
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Modeling for PSD IncrementsModeling for PSD Increments
Triggering Dates Triggering Dates (See MDEQ Website)(See MDEQ Website)
Increment Consuming SourcesIncrement Consuming Sources
Increment Expanding SourcesIncrement Expanding Sources
80% Consumption Allowed80% Consumption Allowed
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Only for SOOnly for SO22, NO, NOXX and PM10 and PM10
• Emissions from All Sources Emissions from All Sources having a significant impacthaving a significant impact
• Measured BackgroundMeasured Background
• Source Inventories and Source Inventories and Background Concentrations Background Concentrations Available from MDEQAvailable from MDEQ
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Modeling for NAAQSModeling for NAAQS
What Affects Modeling?What Affects Modeling?
Stack HeightStack Height
Building HeightBuilding Height
Terrain HeightTerrain Height
Exhaust Flow Rate (CFM)Exhaust Flow Rate (CFM)
Exhaust TemperatureExhaust Temperature
Stack Exit DiameterStack Exit Diameter
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Another View of DispersionAnother View of Dispersion
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Building Downwash Building Downwash
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