Prevention of Significant Deterioration/Nonattain
ment ReviewThe Basics
Johnny Vermillion, P.E.Air Permits Division
Texas Commission on Environmental QualityEnvironmental Trade Fair 2012
Overview• NAAQS
• PSD
• Nonattainment
• Location of Equipment
• Netting
• Examples
TCEQMinor NSR
Chapter 106
Chapter 116
EPAMajor NSR
PSD
Nonattainment
SIPChapters
111112115117
EPA Control Rules
40 CFR60 - NSPS61 - NESHAP63 - NESHAP
(MACT
Standards)
TCEQ Health EffectsToxicology
Review
EPA Major NSRNAAQS
NAAQS• Primary NAAQS – protect public health
• Secondary NAAQS – protect public welfare
• Federal Clean Air Act – In compliance with NAAQS – attainment Out of compliance with NAAQS –
nonattainment
LeadNonattainment Area
Severe Ozone Nonattainment Area
Serious Ozone Nonattainment Area
Moderate PM10 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 ProgramMajor 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/yearNOX > 40 Tons/year
SO2 > 40 Tons/yearVOC > 40 Tons/yearPb > 0.6 Tons/yearPM > 25 Tons/yearPM10 > 15 Tons/yearPM2.5 > 10 Tons/year
PSD ProgramMajor Modification – Non-Criteria Pollutants
Fluorides > 3 Tons/yearSulfuric Acid Mist > 7 Tons/year
Hydrogen Sulfide > 10 Tons/year Total Reduced Sulfur > 10
Tons/yearPlus others........
PSD ProgramPSD 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 ProgramWhat 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 TPYMajor Mod. ≥ 25 TPY
Nonattainment ProgramNonattainment 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 ProgramOffset:
• An actual emission reduction, greater than or equal to the project’s emission increase
• The amount of offset depends...
Nonattainment ProgramOffset:
• 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 TPYMajor Mod. ≥ 25 TPYOffset 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:
In an attainment or nonattainment area?
At a grassroots or at an existing minor source?
At an existing major source?
To trigger major NSR, project must be a major source in and of itself
Location of New or Modified Equipment
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 : The current project, plus 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...The previous 10 years or
The previous 5 years (for electric utilities)
Netting DefinitionsBaseline 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
From 5 years before start of construction to the proposed start of operation
Contemporaneous Period (netting window)--
If the sum of the projects within the period > the significant emission rate, major NSR is triggered
NettingContemporaneous Period--
Netting• Increases and decreases within the
contemporaneous period are based on a comparison of the following: Baseline Actual Emission Rate and
The PTE of that project (projected actuals are not used in this step)
Netting• What do you do with the netting
results? Compare them to the appropriate
significant emission rate• If the netting value equals or exceeds
the significant emission rate.... 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 1Company 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 1The 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
Current PTE = 200 Tons/year NOx
Proposed PTE = 210 Tons/year NOx
Baseline Actual = 190 Tons/year NOx
Example 2Company is a named major source,
in an attainment area
Example 2What 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
Current PTE = 50 Tons/year NOx
Proposed PTE = 70 Tons/year NOx
Baseline Actual = 40 Tons/year NOx
Example 3Company is a named major source,
in a severe nonattainment area
Example 3What 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 3Netting Evaluation
Includes the current project, and all creditable increases and decreases within the contemporaneous period
Example 3Netting Evaluation
30 + 10 + 20 + 5 = 65 Tons/year NOx increase
Current project: 30 Tons/year
11/2009 project: 10 Tons/year increase10/2010 project: 20 Tons/year increase12/2011 project: 5 Tons/year increase
Example 3Additional 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