PREVENTION OF SIGNIFICANT DETERIORATION (PSD) NSR PROGRAM

Donald LawU.S. EPA Region 8

2

Preconstruction Permit Programs

Minor Source NSRState

requirements for non-major new

sources and modifications

PSD

Requirements for new major

sources and major modifications in

attainment/ unclassifiable

areas

Nonattainment Area NSR

Requirements for new major

sources and major

modifications in nonattainment

areas

CAA

Title IPart A

Section 110Part C

Section 165Part D

Section 173

New Source Review

3

Preconstruction Permit Programs

Minor Source NSRState

requirements for non-major new

sources and modifications

PSD

Requirements for new major

sources and major modifications in

attainment/ unclassifiable

areas

Nonattainment Area NSR

Requirements for new major

sources and major

modifications in nonattainment

areas

CAA

Title IPart A

Section 110Part C

Section 165Part D

Section 173

New Source Review

4

Major Topics4

4 steps to determine whether new construction or modification project is subject to PSD Attainment status PTE Identify appropriate threshold (new construction)

or emission rate (modification) Compare proposed emissions to threshold or rate

When a modification may “net out” of PSD Common applicability issues

5

Which Sources Might be Subject to the PSD Program?

5

Sources locating in areas attaining the National Ambient Air Quality Standards or areas that are unclassifiable New major sources Existing major sources making major

modifications Physical or operational changes at the source Change should show significant net emissions increase

Some sources have been “grandfathered” or have opted for “synthetic minor permit”

6

How Do You Know When PSD Applies to a Source?

6

1. Assess attainment status of source’s geographic area

2. Determine source’s potential to emit (PTE)

3. Determine which thresholds or emissions rate applies

4. Determine if proposed emissions will exceed the applicable limit

7

Step 1: What is the Attainment Status of Source’s Geographic Area?

7

Determine if area is in attainment for each National Ambient Air Quality Standard (NAAQS) emitted by the source To find this information

Contact the appropriate EPA Regional office or applicable permitting authority

Check green book http:/www.epa.gov/oaqps001/greenbk/map_download.html

Search an EPA database such as: www.epa.gov/air/data

8

What happens if the area is in non-attainment status?

8

Non-attainment status only applies to that particular pollutant

Emission source can be major for non-attainment pollutant (NA-NSR permit) and major for PSD pollutant (PSD permit)

9

Step 1: What is the Attainment Status of Source’s Geographic Area?

9

Exampleo Denver is o non-attainment for Ozone (VOC

and NOx)o Attainment for CO, PM10, PM2.5,

NO2, Pb, and SO2

10

Step 1: What is the Attainment Status of Source’s Geographic Area? (cont.)

10

Exampleo Denver is

o Non-attainment for Ozone (VOC and NOx).o Attainment for CO, PM10, PM2.5, NO2, Pb,

SO2

o Therefore PSD requirements apply foro CO, PM10, PM2.5, NO2, Pb, SO2

11

Step 2: What is the Source’s Potential to Emit (PTE)?

11

Maximum capacity of source to emit a pollutant under its physical and operational design Based on operating 24 hours a day, 365 days a year

(8760 hours/year) Can include effect of emissions controls, if

enforceable by permit or State Implementation Plan (SIP), Tribal Implementation Plan (TIP) or Federal Implementation Plan (FIP) conditions Other mitigating factors (site specific and quite uncommon)

12

Calculating Emissions for NSR Applicability

12

All new and modified units are subject to applicability determinations New units – based on PTE Modified units – based on actual emissions (or potential if new unit)

Include all regulated NSR pollutants that the source emits

13

Calculating Emissions for NSR Applicability

13

Source emissions are calculated using On-site measurement (e.g., stack testing) Operational records of actual production Vendor design capacity or rated capacity

information Material balance (i.e., mass balance)

calculations Emission factors

Emissions from all affected emissions units are added for each regulated NSR pollutant

14

Exercise on Potential to Emit

14

American Widget and Doohicky, Inc. constructing brand new widget factory outside Albert, Kansas. Facility will have two 8-hour shifts per day, make 1500 widgets per day. No TIP, SIP, or FIP limitations apply to this facility. Based on testing data from similar AWD Inc. facility, the following emission rates can be expected

NOx – 60 lb/hrSO2 – 25 lb/hrVOC – .622 lb/widget

What is the PTE of the new AWD Inc. facility for these 3 pollutants?

15

Exercise on Potential to Emit

15

What is the PTE of the new AWD Inc. facility for these three pollutants?

a. What is source’s PTE for NOx? 60 x 8760 / 2000 = 262.8 tpy

b. What is source’s PTE for SO2? 25 x 8760 / 2000 = 109.5 tpy

c. What is source’s PTE for SO2? 1500 /16 x .622 *8760 / 2000 = 255 tpy

16

Step 3. What is the Applicable PSD Threshold for New Sources?

16

250 tons per year (tpy) for most source categories

100 tpy, if part of the 28 listed source categories (and include fugitive emissions for these source categories)

250 tpy of GHG and 100,000 tpy of CO2 equivalentsStart

Determine source’s

Potential to Emit (PTE)

(per pollutant, may include

fugitives)

Is PTE ≥ applicablethreshold?

(per regulated NSR pollutant)

Source not

subject toPSD

Yes

No

Source subject to

PSD

17

Applicability: Thresholds Attainment Areas Regulated NSR Pollutant Major Source Threshold (tpy)

Carbon Monoxide (CO)

100 or 250

Sulfur Dioxide (SO2)

Ozone - Oxides of Nitrogen (NOx)

Ozone - Volatile Organic Compounds (VOC)

PM

PM-10

PM-2.5

Lead

Fluorides

Sulfuric Acid Mist

Hydrogen Sulfide (H2S)

Total Reduced Sulfur (including H2S)

Reduced Sulfur Compounds (including H2S)

Municipal Waste Combustor Emissions

Municipal Solid Waste Landfills Emissions

Greenhouse Gases (Combination of gasesCO2, CH4, N2O, HFC, PFC, SF6)

250 tpy GHGs and 100,000 tpy of CO2e

18

Step 4: How Do You Determine if Proposed Emissions will Exceed the Applicable Limit ?18

For each pollutant, compare source’s PTE with applicable threshold

If PTE is equal to or higher than threshold, source is major for PSD

Example Source PTE for NO2 is 300 tpy 300 tpy > 250 tpy, source is

subject to PSD

19

Exercise on Applicability (100 tpy vs. 250 tpy)

19

a. Primary copper smelter has PTE of 150 tpy of NOX. Major source for PSD?

b. Glass manufacturing plant plans to operate a dry scrubber designed to meet emission limit of 50 lb/hr of SO2 (or 219 tpy). Major source for PSD?

c. A power plant of more than 250 million BTU/hour heat input will burn natural gas and will have PTE of 200 tpy of CO and 82 tpy of NOX. Major source for PSD? For which pollutant(s)?

20

Exercise on Applicability (100 tpy vs. 250 tpy)

20

a. Primary copper smelter has PTE of 150 tpy of NOX. Major source for PSD? Yes.

b. Glass manufacturing plant plans to operate a dry scrubber designed to meet an emission limit of 50 lb/hr of SO2 (or 219 tpy). Major source for PSD? No.

c. Power plant of more than 250 million BTU/hour heat input will burn natural gas and will have PTE of 200 tpy of CO and 82 tpy of NOX. Major source for PSD? Yes. For which pollutant(s)? CO

21

Significant Emissions Rate21

If a source is major, PSD applies to attainment pollutants emitted above significant emissions rate

See appendix with table for Significant emissions rates

22

Example22

A newly proposed natural gas-fired power plant (categorical facility) has potential to emit the following in an attainment area

250 TPY CO 101 TPY NO2

45 TPY VOC 20 TPY SO2

20 TPY PM10/2.5

23

Example23

A newly proposed natural gas-fired power plant (categorical facility) has potential to emit the following in an attainment area

250 TPY CO YES 101 TPY NO2 YES 45 TPY VOC YES 20 TPY SO2 NO 20 TPY PM10/2.5 YES

24

Modifications that are Subject to the PSD Program

24

Major modification = mod that results in (1) significant emissions increase and (2) significant net emissions increase, i.e., increase higher than significant emissions rate (SER)

Step 1: calculate proposed emissions Step 2: if emissions are greater than or equal to

SER, calculate Net Emissions Increase. Greater than or equal to SER?

YesStart

Are Proposed

modification emissions ≥

SER?(per pollutant)

Modification not

subject toMajor NSR

Determine Source’s NetEmissions Increase

(NEI),(per pollutant)

Is the NEI ≥ SER?

Modification is a major

modification and

subject toMajor NSR

Yes

No

No

25

Significant Emission Rate (SER) – emissions rate threshold in tpy, by pollutant

NEI = Sum of contemporaneous emissions increases and decreases to the proposed modification emissions increase/decrease

• Under PSD, contemporaneous period starts 5 years before source commences construction and ends when source commences operation

Applicability: Modifications

YesStart

Are Proposed

modification emissions ≥

SER?(per pollutant)

Modification not

subject toMajor NSR

Determine Source’s NetEmissions Increase

(NEI),(per pollutant)

Is the NEI ≥ SER?

Modification is a major

modification and

subject toMajor NSR

Yes

NoNo

26

Calculating a Project’s Emissions Increases

26

Emissions are based on actual emissions Actual emissions = projected emissions

after the change minus baseline emissions before the change (actual-to-projected-actual test)

Projected emissions: max. annual emissions (tpy) that will occur during any one of 5 yrs after project

If unit was added, emission increase based on PTE

Include fugitives if source is part of the 28 source category list

27

Determining Net Emissions Increase (NEI)

27

NEI = Sum of contemporaneous emissions increases and decreases to proposed modification emissions increase

Sum of contemporaneous emissions increases and decreases to proposed modification increase

NEI = PMEI + CEI – CED (ERC) where: PMEI – Proposed modification emissions increase CEI – Creditable emissions increase CED – Creditable emissions decreases ERC – Emissions reduction credit(s)

Under PSD, contemporaneous period starts 5 years before source commences construction and ends when source commences operation

If NEI is greater than SER, source is major

28

Exercise on Determining if a Modification is Major

28

Gas treating site plans to replace an outdated internal combustion engine with more efficient engine with greater capacity. Engine changeout will eliminate old unit’s NOX and CO emissions (78 and 125 tpy). New unit will emit 100 tpy of NOX and 175 tpy of CO. Do the net emissions increases make this changeout a major modification?

Assume no other emissions changes during the contemporaneous period

29

Exercise on Determining if a Modification is Major

29

Gas treating site plans to replace an outdated internal combustion engine with more efficient engine with greater capacity. Engine changeout will eliminate old unit’s NOX and CO emissions (78 and 125 tpy). New unit will emit 100 tpy of NOX and 175 tpy of CO. Do the net emissions increases make this changeout a major modification?

Assume no other emissions changes during contemporaneous period

No, because emissions increases are below the SER for NOX (40 tpy) and the SER for CO (100 tpy)

30

In What Other Circumstances Can a Source be Subject to PSD?

30

Once determined a source is major for PSD, source must review pollutants below thresholds by comparing PTE to Significant Emissions Rate (SER) Pollutants for which the area is in attainment

(NAAQS) Other pollutants

Emissions equal to or higher than SER make pollutant also subject to PSD

Concept known as “Major for one, Major for all”

31

Common Problem Areas31

Facilities may try to split major modifications into multiple “minor” modifications

Facilities may insist that their multiple emissions units are not part of the same “source” for PSD purposes

Facilities may try to use emission decreases for netting that are not creditable (i.e., not federally enforceable)

Facilities may try to use emission decreases for netting that were required by rules or consent decrees

32

Defining the New Source32

Includes all related activities classified under the same 2-digit SIC code number

Has the same owner or operator

Is located on contiguous or adjacent properties

Includes all support facilities

33

Example33

Rock Crushing operations and aggregate source Two separate rock crushing

operation at separate quarries Providing raw materials to an

aggregate source All owned by same parent company Shared staff and equipment

34

PSD Thresholds for GHGs (Permits issued on or after July 1, 2011)

34

PSD applies to GHGs, if The source is otherwise subject to PSD

(for another regulated NSR pollutant) and

The source has a GHG PTE equal to or greater than 75,000 tpy CO2e

OR source has a GHG PTE equal to or greater than: 100,000 tpy CO2e, and 100/250 tpy mass basis

35

Calculating GHG Emissions on a Mass Basis and CO2e Basis

35

To compute mass basis of GHG emissions, simply add tpy for each GHG emitted from facility

To compute CO2e basis, first multiply emissions of each GHG times its Global Warming Potential (GWP) value. Then add tpy of all GHGs Each GHG is assigned a value based on

its Global Warming Potential (GWP) with higher values going to pollutants with the most serious GWP

36

Example Calculation36

Assume a proposed emissions unit emits 3 of the six GHG compounds in the following amounts 50,000 tpy of CO2 (GWP = 1) 60 tpy of methane (GWP = 25) 3 tpy of PFC-14 (a perfluorocarbon) (GWP = 6,500)

GHGs mass-based emissions 50,000 tpy +60tpy + 3 tpy = 50,063 tpy

CO2e-based emissions (50,000 tpy x 1) or 50,000 tpy, plus (60 tpy x 25) or 1,500 typ, plus (3 tpy x 6,500) or 19, 500 Total: 71,000 tpy

37

Major Modifications and GHGs (for Permits Issued after July 1, 2011)

37

PSD applies to GHGs if Modification otherwise subject to

PSD (for another regulated NSR pollutant), and has GHG emissions increase and net emissions increase Equal to or greater than 75,000 tpy

CO2e, and Greater than 0 tpy mass basis

OR….(cont. next slide)

38

Major Modifications and GHGs (cont.)38

OR BOTH Existing source has PTE equal to or greater than

100,000 tpy CO2e and 100/250 tpy mass basis

Modification has GHG emissions increase and net emissions increase

Equal to or greater than 75,000 tpy CO2e and

Greater than 0 tpy mass basis OR BOTH

Source is existing minor source for PSD, and Modification alone has actual or potential GHG

emissions equal to or greater than 100,000 tpy CO2e, and 100/250 tpy mass basis

39

Final Applicability Exercise39

Existing Chemical Processing Plant will add a new process unit modify an existing process unit by removing an existing reactor vessel and adding a larger one Highest actual emissions from the last five

years are 150 tons VOC, 65 tons NOx, 115 tons CO, 145,000 tons CO2e

PTE of new reactor based on similar unit at sister facility 200 tons VOC, 85 tons NOx, 160 tons CO, 219,000 tons CO2, and 50 tons methane

40

Details of Example Chemical Plant

40

Area is in attainment for all pollutants

Source add an emergency generator 4 years ago with a net emission increase of 25 tpy NOx and 45 tpy CO

Is the project a major PSD project, and if so, for what pollutants?

41

Example Solution 41

1. Evaluate for PSD• Determine applicable threshold

• Chemical Process Plants part of 28 listed source categories

• Major source threshold is 100 tpy, not 250 tpy• Determine if the source is major based on

the threshold • 150 tpy of VOC > 100 tpy threshold• 145,000 of CO2e > 75,000 tpy CO2e• Plant is a major source for PSD• Now review all attainment pollutants for PSD

applicability

42

Example Solution42

Pollutant Net Emissions Increase VOC: 200 tpy – 150 tpy = 50 tpy increase NOx: 85 tpy – 65 tpy + 25 tpy = 45 tpy increase CO: 160 tpy – 115 tpy + 45 tpy = 90 tpy increase CO2e: 219,000 tpy -145,000 tpy + (50 x 25) tpy =

75,200

Project Applicability 50 tpy VOC > 40 tpy VOC SER - YES 45 tpy NOx > 40 tpy NOx SER - YES 90 tpy CO < 100 tpy CO SER – NO 75,200 tpy CO2e > 75,000 tpy CO2e - YES

43

Summary43

4 step process used to determine if new construction or modification is subject to PSD PSD threshold for new construction is

based on PTE PSD emission rate (SER) is based on

actual emissions Higher thresholds and SER apply to

Greenhouse gases Potential applicability issues of

concern: “sham” minor modifications disaggregation of emissions units netting

44

Appendix

44

45

28 Source Categories28 source categories

1. Coal cleaning plants (with thermal dryers) 15. Coke oven batteries

2. Kraft pulp mills 16. Sulfur recovery plants

3. Portland cement plants 17. Carbon black plants (furnace process)

4. Primary zinc smelters 18. Primary lead smelters

5. Iron and steel mills 19. Fuel conversion plants

6. Primary aluminum ore reduction plants 20. Sintering plants

7. Primary copper smelters 21. Secondary metal production plants

8. Municipal incinerators capable of charging more than 250 tons of refuse per day

22. Chemical process plants

9. Hydrofluoric acid plants 23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels

10. Sulfuric acid plants 24. Taconite ore processing plants

11. Nitric acid plants 25. Glass fiber processing plants

12. Petroleum refineries 26. Charcoal production plants

13. Lime plants 27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU)/hour heat input

14. Phosphate rock processing plants 28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input

46

Significant Emission Rates (SERs)

Pollutant SER (tpy) Pollutant SER (tpy)

Carbon Monoxide 100 Sulfuric Acid Mist 7

Nitrogen Oxides 40 Hydrogen Sulfide (H2S) 10

Sulfur Dioxide 40 Total Reduced Sulfur (Includes H2S) 10

Particulate Matter (PM10)

15 Reduced Sulfur Compounds (Includes H2S)

10

Particulate Matter (PM2.5)

10; 40 for VOCs, NOx or SO2

Municipal Waste Combustor Organics

3.5*10-6

Ozone 40 VOCs or NOx

Municipal Waste Combustor Metals 15

Lead 0.6 Municipal Waste Combustor for Acid Gases

40

Fluorides 3 Municipal Solid Waste Landfills Emissions

50

SER – a rate of emissions that would equal or exceed any of the following rates:

Notwithstanding the above, any emissions rate or any net emissions increase associated with a major stationary source or major modification, which could construct within 10 km of a Class I area,

and have an impact on such area equal to or greater than 1 g/m3 (24-hour average)

47

Global Warming Potentials (GWP)

• Carbon Dioxide GWP =1 • Methane GWP = 21 (25) • Nitrous Oxide GWP = 300 • Sulfur Hexafluoride GWP = 23,900

• HFCs Vary • PFCs Vary

• Full list is found at 40 CFR Part 98, Subpart A Table A-1