Docstoc

Nonattainment - TCEQ e-Services.pptx

Document Sample
Nonattainment - TCEQ e-Services.pptx Powered By Docstoc
					 Prevention of Significant
Deterioration/Nonattainment
           Review
              The Basics


           Johnny Vermillion, P.E.
            Air Permits Division
  Texas Commission on Environmental Quality
       Environmental Trade Fair 2012
               Overview
• NAAQS

• PSD

• Nonattainment

• Location of Equipment

• Netting

• Examples
 TCEQ            EPA
Minor NSR      Major NSR

Chapter 106       PSD

Chapter 116   Nonattainment
              EPA
 SIP         Control
              Rules
Chapters      40 CFR
  111      60 - NSPS
  112      61 - NESHAP
  115      63 - NESHAP
  117      (MACT Standards)
 TCEQ         EPA
Health       Major
Effects      NSR

Toxicology   NAAQS
 Review
                 NAAQS
• Primary NAAQS – protect public health

• Secondary NAAQS – protect public welfare

• Federal Clean Air Act –
  Ø In compliance with NAAQS – attainment
  Ø Out of compliance with NAAQS – nonattainment
                                            Lead
                                     Nonattainment Area
                  Serious Ozone
                Nonattainment Area

Moderate PM10
Nonattainment
    Area




                                         Severe Ozone
                                       Nonattainment Area
            PSD Program
• New major sources

• Major modifications of existing major
  sources in attainment areas

• Criteria pollutants (pollutants with a
  NAAQS)

• Certain non-criteria pollutants
           PSD Program
           Major Source Definitions


• Named Source > 100 Tons/year
   (includes fugitive emissions)

• Un-named Source > 250 Tons/year
      PSD Program
Major Modification – Criteria Pollutants

  CO >       100 Tons/year
  NOX >       40 Tons/year
 SO2 >        40 Tons/year
 VOC >        40 Tons/year
 Pb    >       0.6 Tons/year
 PM >         25 Tons/year
  PM10 >       15 Tons/year
  PM2.5 >      10 Tons/year
              PSD Program
    Major Modification – Non-Criteria Pollutants


Fluorides                           > 3 Tons/year
Sulfuric Acid Mist                  > 7 Tons/year
Hydrogen Sulfide                    > 10 Tons/year
 Total Reduced Sulfur              > 10 Tons/year

                Plus others........
               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

• PM10, PM2.5 include filterable & condensable
     Nonattainment Program

• New major sources

• Major modifications of existing major
  sources in nonattainment areas

• Most commonly encountered area - ozone

• Ozone regulated through NOX and VOC
    Nonattainment Program
What are the significant rates for a:



Major Source

&

Major Modification
It depends...
     It depends...

...on the classification
 of the nonattainment
           area
   DFW – Serious

Major Source ≥ 50 TPY
Major Mod. ≥ 25 TPY




         HGB – Severe

     Major Source ≥ 25 TPY
     Major Mod. ≥ 25 TPY
     Nonattainment Program
          Nonattainment Review Requires...


• Must be a major source or major
  modification for either NOX or VOC

• NOX and VOC are evaluated independently

• Application of LAER

• Application of offsets
 Nonattainment Program

What is an offset
    Nonattainment Program

Offset:

• An actual emission reduction, greater
  than or equal to the project’s emission
  increase

• The amount of offset depends...
    Nonattainment Program

Offset:

• An actual emission reduction, greater
  than or equal to the project’s emission
  increase

• The amount of offset depends...
  on the nonattainment classification
   DFW – Serious

Major Source ≥ 50 TPY
Major Mod. ≥ 25 TPY
Offset Ratio = 1.2 to 1




         HGB – Severe

     Major Source ≥ 25 TPY
     Major Mod. ≥ 25 TPY
     Offset Ratio = 1.3 to 1
 Is it possible to.....

trigger both PSD and
nonattainment, at the
 same time, for the
   same pollutant?
      Yes, yes it is !

For NOX...

             Why?
      Yes, yes it is !

For NOX...

             Why?
 NOX is an ozone precursor
 and has a NAAQS of its
            own
      Location of New or
      Modified Equipment
Is the equipment located:

 ØIn an attainment or nonattainment area?


 ØAt a grassroots or at an existing minor
  source?


 ØAt an existing major source?
      Location of New or
      Modified Equipment




To trigger major NSR, project must be
     a major source in and of itself
      Location of New or
      Modified Equipment




To trigger major NSR, the net emissions
  increase must be > major modification
         significant emission rate
            Netting
How do you know if a
 modification is a “major
 modification” triggering major
 NSR?????

You conduct a “netting” exercise
                Netting
• An “applicability step” to determine if
  major NSR has been triggered

• An evaluation of :

  Ø The current project, plus
  Ø All creditable increases and decreases
   within the contemporaneous period (netting
   window)
                Netting
• Is conducted on a pollutant-by-pollutant
  basis

• Ensures smaller projects do not add up
  to be a major modification

• For NOX, it’s possible to trigger netting
  for both PSD and nonattainment
         Netting Definitions

Baseline Actual Emission Rate--

• Emissions, in Tons/year, actually
  emitted during a consecutive 24-month
  period out of...

  ØThe previous 10 years or

  ØThe previous 5 years (for electric utilities)
        Netting Definitions
Baseline Actual Emission Rate--
       Netting Definitions

Planned Emission Rate--

• Either the Potential to Emit (PTE) or

• A Projected Actual Emission Rate
        Netting Definitions

Netting Significance Levels--

• PSD: > the same value used for the major
  modification significant emission rate

• Serious & Severe Nonattainment Areas:
  > 5 Tons/year
    Is “Netting” Triggered?

If the Baseline Actual Emission Rate of
  new or modified equipment, compared to
  the Planned Emission Rate, is > the
  netting significance level...

• Netting is required

(Evaluate increases only, no decreases in this
  step)
                Netting
Contemporaneous Period (netting window)--

          From 5 years before
            start of construction
            to the proposed start
            of operation


 If the sum of the projects within the
 period > the significant emission rate,
 major NSR is triggered
              Netting
Contemporaneous Period--
                Netting

• Increases and decreases within the
  contemporaneous period are based on a
  comparison of the following:

  Ø Baseline Actual Emission Rate and

  Ø The PTE of that project (projected actuals
   are not used in this step)
                Netting
• What do you do with the netting
  results?
  Ø Compare them to the appropriate
   significant emission rate

• If the netting value equals or exceeds
  the significant emission rate....
  Ø Major NSR is required
Netting
Is Baseline Actual
 Emission Rate and the
 actual emission rate...

the same thing?
No, no they aren’t!
Baseline Actual Emission Rate:
Highest consecutive 24-month
period out of the last ten years
(five years for utilities)

Actual Emission Rate:
24-months immediately before the
change (used in modeling)
Time to put everything
      together
           Example 1
Company is a minor un-named source, in
 an attainment area



  Current PTE    = 70 Tons/year SO2

  Proposed PTE   = 130 Tons/year SO2

  Baseline Actual = 70 Tons/year SO2
                Example 1
The project increase is:
130 Tons/year – 70 Tons/year = 60 Tons/year

The project is at a minor source and is not a
 major source in and of itself

Major NSR is not triggered but minor NSR
 permitting requirements do apply
              Example 2
Company is a named major source, in an
 attainment area



Current PTE    = 200 Tons/year NOx

Proposed PTE = 210 Tons/year NOx

Baseline Actual = 190 Tons/year NOx
                Example 2
What is the project increase?
210 Tons/year – 190 Tons/year = 20 Tons/year

The project is at a major source; however, the
 emissions increase is less than the netting
 significance level of 40 Tons/year

Is Major NSR triggered?
Major NSR is not triggered but minor NSR
  permitting requirements do apply
            Example 3
Company is a named major source, in a
 severe nonattainment area



  Current PTE   = 50 Tons/year NOx

  Proposed PTE = 70 Tons/year NOx

  Baseline Actual = 40 Tons/year NOx
               Example 3
What is the project increase?
70 Tons/year – 40 Tons/year = 30 Tons/year

The project is a named major source in a
 severe nonattainment area, the emission
 increase exceeds 5 Tons/year

Is netting required?
Yes, the project increase exceeds the
  netting significance level of 5 Tons/year
             Example 3
              Netting Evaluation


Includes the current project, and all
  creditable increases and decreases
  within the contemporaneous period
               Example 3
               Netting Evaluation


   Current project: 30 Tons/year

   11/2009 project: 10 Tons/year increase
   10/2010 project: 20 Tons/year increase
   12/2011 project: 5 Tons/year increase



30 + 10 + 20 + 5 = 65 Tons/year NOx increase
               Example 3
                Additional Review

The major modification significant emission rate
 for a severe nonattainment area is 25
 Tons/year

The project is a “major modification” and major
 NSR (nonattainment review) is required

Now what ?????
The company must apply LAER and provide
 offsets at a 1.3:1 ratio
   Is a netting analysis
potentially required for all
         sources?
        No, no it’s not

• Only “net” at existing major sources

• There is NO netting at minor sources
Thank You

 Air Permits Division
   (512) 239-1250

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:0
posted:1/22/2014
language:English
pages:57
Lingjuan Ma Lingjuan Ma
About