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Published byHannah Bramley Modified over 9 years ago
Michael Hopkins, P.E., Assistant Chief, DAPC
GP Development PBR Updates Other Updates Short BAT History <10 ton/yr BAT Exemption Status >10 ton/yr BAT Status
Have spent last 2 years developing GPs for typical quarry operations Includes: Compression ignition (diesel) engines (12) Mineral Extraction (1) Permanent aggregate processing plants (1) Portable aggregate processing plants (1) 15 different GPs
Multiple rounds of comments/revisions with industry/others Multiple updates to NSPS/MACT caused multiple revisions Changes in BAT caused other revisions
October 26 issued 12 Model General Permits for comment Multiple groups of compression ignition (diesel) engines Range from 50 to 1100 HP
Multiple variations that follows NSPS Subpart IIII and MACT Subpart ZZZZ See: http://www.epa.ohio.gov/dapc/genpermit/g enpermits.aspx for details http://www.epa.ohio.gov/dapc/genpermit/g enpermits.aspx Comment period closed November 29. Hope to have final early 2011 Contact Cheryl Suttman
Received comments from IP Made revisions including SB265 changes Currently with industry group for final comments Hope to have IP out in December Hope to have final in 2011
Have group started for biomass digester facilities Goal is to get developed early 2011 Expect to see multiple applications this spring Currently working on initial draft terms Jenny Avellana is the lead contact
Will need to update several GPs due to SB265/MACTs/rule changes Have not yet gotten volunteers to work on these.
Revised 31-03 to: Update PBR for small and mid-size printing facilities Revise emergency generator/air compressor/water pump exemption and PBR to allow use emergency load response programs Effective Thursday, August 26th, 2010
02/25/10: U.S. EPA approves Ohio NSR Reform rules (75 FR 8496) Originally filed October 2004 Now a part of our SIP
Feds issued revisions May 2008 Ohio EPA issued guidance in August 2008 DAPC issued IP rule package April 24, 2009 Need to finalize changes/revise per other issues
10/20/10 U.S. EPA finalized PM2.5 PSD changes PSD Increments (Eff. 09/29/11???) Significant Impact Levels (start using) Significant Modeling Thresholds (start using) Plan to incorporate into our PM2.5 rules
What about condensables? Methods 201A and 202 still not revised Feds working on Other Test Methods OTM 27, (Constant Sampling Rate Procedure) OTM 28, (Dry Impinger Method) Continue using August 2008 OEPA memo Exclude condensable for limits Collect condensable info
02/22/10 U.S. EPA proposed approval of past (U)(2)(f) approvals No comments received Finalized 06/21/10 (75 FR 34939) Allows us to use new procedure for U2f
Company submits PTI application w/U2f study (similar to BAT/BACT study) Ohio EPA sends study to U.S. EPA U.S. EPA reviews concurrent to Ohio EPA Ohio EPA issues draft
U.S. EPA OKs issuance of final Ohio EPA issues final Ohio EPA submits U2f portion of permit to U.S. EPA for SIP Work closely with CO permit contact
BAT began with permit program 1974 Key part of Ohios plan for 36 years Designed to ensure new sources install state-of-the-art controls or use state-of- the-art methods Historically has been a case-by-case determination SB 265 implements significant changes to BAT
SB 265 authors wanted certainty concerning BAT Did not like not knowing BAT before applying for permit After SB 265 became effective (08/06), Ohio EPA began working on revisions Some rule revisions effective 12/06 Others were being worked on.
Modified OAC rule 3745-31-05, Criteria for Decision by the Director Established exemption for <10 ton/yr controlled sources DAPC began issuing permits w/o BAT for <10 ton/yr sources Ohio EPA submitted SIP revision to USEPA
U.S. EPA not yet supportive of SIP revision (Currently not in SIP) Concerned change is backsliding Ohio EPA must show why not backsliding Difficult to prove See attached 06/05/08 U.S. EPA letter
Sierra Club filed suit to U.S. District Court, Southern District Claims: Adopting and enforcing requirements less stringent than SIP Anti-back sliding Failure to properly notice Failure to submit SIP support Significant litigation time
02/02/10 Magistrate Able grants Sierra Club's Motion for Reconsideration Director cant use BAT exemption until approved as part of federal SIP See attached decision
Ohio EPA suspends permit issuance for new and renewal sources Ohio EPA drafts guidance 02/19/10 Ohio EPA issues guidance on <10 ton exemption issue
Can now issue installation permits (PTIs, PTIOs) Must determine case-by-case BAT for all sources including <10 ton sources (no exemption allowed) Write dual language term for the <10 ton sources. Applies to new or modified, not yet renewals
Paragraph 1 Describes BAT using SIP-approved rule (11/30/01 version of OAC Chapter 31) Describes that BAT no longer applies once <10 ton rule is SIP approved Paragraph 2 – describes why BAT does not apply once the <10 ton rule is SIP approved See February 19, 2010 Permit Processing Memo page 2-3
Memo issued December 10, 2009 Follows SB 265 approach BAT = MACT, BACT or LAER… If not, then BAT = RACT… If not, then case-by-case BAT
Review 12/10/09 BAT Requirements Memo Check to see if MACTs, BACT, LAER applies If so, then establish BAT If not, then review RACT rules
Review 01/01/06 version of Chapter 21 for VOC limits VOC limits apply anywhere in the state to the same size and type of source? If so, then find most stringent, establish limit as BAT for VOC If not, then move on to case-by- case approach for VOC
Review existing OAC Chapter 110 (Nitrogen Oxides – Reasonable Available Control Technology rules) NOx limits apply anywhere in the state to the same size and type of source? If so, then find most stringent, establish limit as BAT for NOx If not, then move on to case-by-case approach for NOx
Step one – complete past case-by-case analysis for BAT (i.e., looking at similar source, cost-effectiveness etc.) for each criteria pollutant and each operating scenario Determine past BAT
Step two – determine the format for the limit Review BAT Emission Limit Format Table for similar source Locate pollutant for the source, then BAT Limit Format Convert the above limit into the BAT limit format
Uncontrolled Combustion Turbine Determined past BAT was 5.7 lbs PM/hour uncontrolled Find combustion Turbine in BAT Emission Limit Format Table
Find PM for uncontrolled situation Table says limit format should be X pounds PM/mmBtu Convert 5.7 lbs/hr limit to lb/mmBtu limit
BAT is determined to be the numerical limit in the determined format Must do same approach for each criteria pollutant emitted in significant amounts Must do same approach for each operating scenario Only one BAT limit for each pollutant for each operating scenario
Will need rules – memos not sufficient Will need to get in SIP… U.S. EPA will need to approve Prescriptive approach on hold Court actions add to uncertainty Unclear when rules will be written
If you have any questions, talk to CO contact Expect changes to occur We will let you know when we know Questions
Additional information: http://www.epa.state.oh.us/dapc/page/whatsn ew.html http://www.epa.state.oh.us/dapc/page/whatsn ew.html Questions?
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