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FINAL PRESENTATION 1-24-051 Flexible Permitting Workshop Presented by: U.S. EPA Region 4 Air Permits Section.

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Presentation on theme: "FINAL PRESENTATION 1-24-051 Flexible Permitting Workshop Presented by: U.S. EPA Region 4 Air Permits Section."— Presentation transcript:

1 FINAL PRESENTATION Flexible Permitting Workshop Presented by: U.S. EPA Region 4 Air Permits Section

2 FINAL PRESENTATION PSD Scope What triggers PSD applicability?What triggers PSD applicability? New “Major” stationary sources constructed in attainment areas New “Major” stationary sources constructed in attainment areas “Major Modifications” to existing major stationary sources in attainment areas “Major Modifications” to existing major stationary sources in attainment areas Attainment areas are those areas that are meeting the various NAAQSAttainment areas are those areas that are meeting the various NAAQS SO 2, NO X, PM10, CO, Ozone, Lead and now PM2.5 SO 2, NO X, PM10, CO, Ozone, Lead and now PM2.5

3 FINAL PRESENTATION PSD Scope What is a major stationary source under PSD?What is a major stationary source under PSD? One of 28 “listed” major source categories with PTE > 100 tons per year (after control) of any pollutant regulated by the CAA including fugitive emissions (52.21(b)(1)(i)(a)) One of 28 “listed” major source categories with PTE > 100 tons per year (after control) of any pollutant regulated by the CAA including fugitive emissions (52.21(b)(1)(i)(a)) Any stationary source (other than the listed 28) with PTE > 250 tons per year of any pollutant regulated by the CAA excluding fugitive emissions (52.21(b)(1)(i)(b)) Any stationary source (other than the listed 28) with PTE > 250 tons per year of any pollutant regulated by the CAA excluding fugitive emissions (52.21(b)(1)(i)(b))

4 FINAL PRESENTATION PSD Scope What is a major modification?What is a major modification? Any physical change in or change in the method of operation of a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act (52.21(b)(2)(i)) Any physical change in or change in the method of operation of a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act (52.21(b)(2)(i))

5 FINAL PRESENTATION PSD Significant Emission Rates PollutantMajor Modification Threshold Particulate Matter (TSP)25 tpy Particulate Matter < 10 microns (PM10)15 tpy Sulfur Dioxide (SO 2 )40 tpy Oxides of Nitrogen (NO X )40 tpy Volatile Organic Compounds (VOC)40 tpy Carbon Monoxide (CO)100 tpy Lead (Pb)0.6 tpy Fluorides3 tpy Sulfuric Acid Mist7 tpy Hydrogen Sulfide (H 2 S)10 tpy Total Reduced Sulfur (TRS)10 tpy Any increase resulting in a > 1 µg/m 3 24 hour concentration if the source is within 10 km of a Class I area

6 FINAL PRESENTATION Determining PSD Applicability Review and define the entire project (i.e., new/modified equipment and affected equipment)Review and define the entire project (i.e., new/modified equipment and affected equipment) What project is being proposed? What project is being proposed? What new equipment will be added? What new equipment will be added? Is the project part of previous changes? Is the project part of previous changes? Is the project part of future changes? Is the project part of future changes? Will the operation or emissions from other facility emissions units be affected by the change (i.e., de- bottlenecking)? Will the operation or emissions from other facility emissions units be affected by the change (i.e., de- bottlenecking)? Will existing equipment be changed/removed? Will existing equipment be changed/removed?

7 FINAL PRESENTATION Determining PSD Applicability If the proposed change does not affect other emissions units or if the affected emissions units do not emit regulated PSD pollutants:If the proposed change does not affect other emissions units or if the affected emissions units do not emit regulated PSD pollutants: The project is limited to the change only The project is limited to the change only If the proposed change affects other emissions units:If the proposed change affects other emissions units: The project will include both the change and the equipment affected by the change The project will include both the change and the equipment affected by the change

8 FINAL PRESENTATION Determining PSD Applicability Evaluate the project-related emissionsEvaluate the project-related emissions Determine whether the project by itself (i.e., emissions from new or modified emissions unit plus incremental changes in emissions from affected units) will emit regulated PSD pollutants Determine whether the project by itself (i.e., emissions from new or modified emissions unit plus incremental changes in emissions from affected units) will emit regulated PSD pollutants Determine baseline actual emissions Determine baseline actual emissions Determine potential emissions increase following the modification Determine potential emissions increase following the modification Determine the project-related emissions from new, modified and affected emissions units Determine the project-related emissions from new, modified and affected emissions units

9 FINAL PRESENTATION Determining PSD Applicability Evaluate the “project” emissions to determine if the project is a major modification using the “actual to potential test”Evaluate the “project” emissions to determine if the project is a major modification using the “actual to potential test” Actual emissions = average emissions (tpy) over 2 years preceding the project Actual emissions = average emissions (tpy) over 2 years preceding the project oFugitive emissions must be quantified for 28 listed source categories Potential emissions = PTE of the project (tpy) Potential emissions = PTE of the project (tpy) oProject potential emissions include PTE of new/modified sources and incremental increases at affected sources Potential emissions minus actual emissions = project emission increase Potential emissions minus actual emissions = project emission increase

10 FINAL PRESENTATION Determining PSD Applicability If project emission increases are not significant, the project does not trigger PSDIf project emission increases are not significant, the project does not trigger PSD If project emission increases are significant, evaluate “contemporaneous” changes in emissionsIf project emission increases are significant, evaluate “contemporaneous” changes in emissions Contemporaneous changes are site-wide increases or decreases in actual emissions that have occurred at the site in the 5 years preceding the project Contemporaneous changes are site-wide increases or decreases in actual emissions that have occurred at the site in the 5 years preceding the project Determine whether the “net” change in emissions is significantDetermine whether the “net” change in emissions is significant

11 FINAL PRESENTATION PSD Permit Application Content Description of proposed projectDescription of proposed project Summary of applicable requirementsSummary of applicable requirements Emissions inventoryEmissions inventory Determination and defense of best available control technology (BACT) evaluationDetermination and defense of best available control technology (BACT) evaluation Air quality impact analysesAir quality impact analyses Other Class II impacts analysisOther Class II impacts analysis

12 FINAL PRESENTATION What is BACT? Any major stationary source or major modification subject to PSD must conduct an analysis to ensure the application of best available control technology (BACT)Any major stationary source or major modification subject to PSD must conduct an analysis to ensure the application of best available control technology (BACT) BACT is defined at 40 CFR 52.21(b)(12)BACT is defined at 40 CFR 52.21(b)(12) BACT is fundamentally an emissions limitationBACT is fundamentally an emissions limitation

13 FINAL PRESENTATION BACT Applicability (40 CFR 52.21(j)) (2) A new major stationary source shall apply BACT for each PSD-regulated pollutant that it would have the potential to emit in significant amounts(2) A new major stationary source shall apply BACT for each PSD-regulated pollutant that it would have the potential to emit in significant amounts (3) A major modification shall apply BACT for each PSD-regulated pollutant for which it would result in a significant net emissions increase at the source. This requirement applies to each proposed emissions unit at which a net emissions increase in the pollutant would occur as a result of a physical change or change in the method of operation in the unit.(3) A major modification shall apply BACT for each PSD-regulated pollutant for which it would result in a significant net emissions increase at the source. This requirement applies to each proposed emissions unit at which a net emissions increase in the pollutant would occur as a result of a physical change or change in the method of operation in the unit.

14 FINAL PRESENTATION NSR Revision - Background Why was NSR Revised?Why was NSR Revised? General industry concern over NSR regarding: General industry concern over NSR regarding: oComplicated applicability determinations oExtended permit preparation and review timelines oVolumes of precedent decisions, policy memos, and guidance documents pertaining to NSR NSR Revision discussions began in the early 1990’sNSR Revision discussions began in the early 1990’s EPA initially proposed changes in 1996EPA initially proposed changes in 1996

15 FINAL PRESENTATION NSR Revision - Final Rules Most of the proposed Revisions were finalized and published in the Federal Register on December 31, 2002Most of the proposed Revisions were finalized and published in the Federal Register on December 31, 2002 Effective in delegated States March 3, 2003 Effective in delegated States March 3, 2003 SIP approved States have 3 years to incorporate revisions into SIP rules (Region 4 States are SIP approved) SIP approved States have 3 years to incorporate revisions into SIP rules (Region 4 States are SIP approved) The Routine Maintenance, Repair, and Replacement (RMRR) Rule was Published in the Federal Register on October 27, 2003The Routine Maintenance, Repair, and Replacement (RMRR) Rule was Published in the Federal Register on October 27, 2003

16 FINAL PRESENTATION NSR Revision - Final Rules How are the NSR Revisions characterized by EPA?How are the NSR Revisions characterized by EPA? “These changes are intended to provide greater regulatory certainty, administrative flexibility, and permit streamlining, while ensuring the current level of environmental protection and benefit derived from the program and, in certain respects, resulting in greater environmental protection.” “These changes are intended to provide greater regulatory certainty, administrative flexibility, and permit streamlining, while ensuring the current level of environmental protection and benefit derived from the program and, in certain respects, resulting in greater environmental protection.”

17 FINAL PRESENTATION Final NSR Revisions Revised Baseline Actual Emission Calculation ProcedureRevised Baseline Actual Emission Calculation Procedure New “Actual-to-Projected-Actual” Applicability TestNew “Actual-to-Projected-Actual” Applicability Test Actuals Based Plantwide Applicability Limits (PALs)Actuals Based Plantwide Applicability Limits (PALs) New “Clean Unit” Designation – Vacated June 2005New “Clean Unit” Designation – Vacated June 2005 Pollution Control Project Exclusion – Vacated June 2005Pollution Control Project Exclusion – Vacated June 2005 Routine Maintenance, Repair, and Replacement (October 27, 2003)-VacatedRoutine Maintenance, Repair, and Replacement (October 27, 2003)-Vacated

18 FINAL PRESENTATION Baseline Actual Emissions Revised Baseline Calculus for Non- Electric Utility Steam Generating Units (Non-EUSGUs)Revised Baseline Calculus for Non- Electric Utility Steam Generating Units (Non-EUSGUs) The facility may use the annual average emissions that occurred during any consecutive 24-month period in the past 10 years The facility may use the annual average emissions that occurred during any consecutive 24-month period in the past 10 years Emissions must be adjusted to reflect current emission factors/control requirements Emissions must be adjusted to reflect current emission factors/control requirements Baseline emissions cannot exceed applicable standards/limits Baseline emissions cannot exceed applicable standards/limits

19 FINAL PRESENTATION Baseline Actual Emissions Revised Baseline Calculus for Non- Electric Utility Steam Generating Units (Non-EUSGUs)Revised Baseline Calculus for Non- Electric Utility Steam Generating Units (Non-EUSGUs) Adequate emissions data must be available Adequate emissions data must be available All emissions units are subject to same 24- month period for a given pollutant All emissions units are subject to same 24- month period for a given pollutant Different 24-month periods may be used for different pollutants (Note: some state rules may require a common 24-month period) Different 24-month periods may be used for different pollutants (Note: some state rules may require a common 24-month period)

20 FINAL PRESENTATION Actual-to-Projected-Actual Applicability Test New applicability determination option for all emissions unitsNew applicability determination option for all emissions units Baseline emissions are compared to projected actual emissions following the change Baseline emissions are compared to projected actual emissions following the change oFacility must project post change actual annual emissions by source for 5 years (10 years post change if change increases unit’s PTE or capacity) oEmissions that the unit could accommodate pre-change may be excluded (i.e., demand exclusion) oFacility must maintain records of actual annual emissions for 5 or 10 years, and report to regulatory authority if projection is exceeded

21 FINAL PRESENTATION Plantwide Applicability Limits What is a PAL?What is a PAL? An annual, facility-wide, pollutant specific, emission limitation under which the facility can make any changes without triggering NSR for that pollutant An annual, facility-wide, pollutant specific, emission limitation under which the facility can make any changes without triggering NSR for that pollutant PALs,as defined in 40 CFR Part 52, are:PALs,as defined in 40 CFR Part 52, are: Set using actual facility baseline emissions Set using actual facility baseline emissions Pollutant-specific Pollutant-specific Issued for a 10-year term Issued for a 10-year term Renewable Renewable

22 FINAL PRESENTATION “Actuals” Plantwide Applicability Limits Who is eligible for an Actuals Plantwide Applicability Limit (PAL)?Who is eligible for an Actuals Plantwide Applicability Limit (PAL)? Existing major stationary sources that meet certain additional criteria Existing major stationary sources that meet certain additional criteria How does a PAL benefit a major facility?How does a PAL benefit a major facility? Modifications under a PAL are not considered “major modifications” for the PAL pollutant Modifications under a PAL are not considered “major modifications” for the PAL pollutant Modifications do not have to be approved through the major NSR program Modifications do not have to be approved through the major NSR program Facility changes are not dictated by major NSR concerns Facility changes are not dictated by major NSR concerns

23 FINAL PRESENTATION “Actuals” PALs How does a facility obtain a PAL?How does a facility obtain a PAL? Interested facilities must submit a complete permit application specifically requesting a PAL or PALs Interested facilities must submit a complete permit application specifically requesting a PAL or PALs Minimum application requirements include: Minimum application requirements include: oListing of emissions units oSize of emissions units (small, significant or major) oAll Federal/State applicable requirements oEmission limits/work practice requirements oBaseline actual emissions oSupporting documentation

24 FINAL PRESENTATION “Actuals” PALs What type of application is required for a PAL?What type of application is required for a PAL? PALs must be established via a federally enforceable permit PALs must be established via a federally enforceable permit oMinor NSR construction permit oMajor NSR permit (i.e., PSD permit) oSIP-approved operating permit program Regulatory authority must provide opportunity for public participation Regulatory authority must provide opportunity for public participation o30-day public notice oOpportunity for public comment

25 FINAL PRESENTATION “Actuals” PALs How are PAL levels established?How are PAL levels established? Establish baseline emissions - select any consecutive 24-month period within the 10-year period preceding the PAL (5-year period for EUSGUs) Establish baseline emissions - select any consecutive 24-month period within the 10-year period preceding the PAL (5-year period for EUSGUs) oOnly one 24-month period may be used per pollutant oDiffering baseline periods may be used for different pollutants Identify all emissions units that were included in the baseline period Identify all emissions units that were included in the baseline period Identify any emissions units constructed since the baseline period Identify any emissions units constructed since the baseline period

26 FINAL PRESENTATION “Actuals” PALs How are PAL levels established? (cont.)How are PAL levels established? (cont.) For each emissions unit that existed during the baseline period: For each emissions unit that existed during the baseline period: oCalculate the average rate, in tons per year, at which each of the emissions units emitted the PAL pollutant Sum the baseline actual PAL pollutant emission rates of each emissions unit at the source Sum the baseline actual PAL pollutant emission rates of each emissions unit at the source Add an amount equal to the applicable significant level for the PAL pollutant Add an amount equal to the applicable significant level for the PAL pollutant

27 FINAL PRESENTATION “Actuals” PALs How are PAL levels established? (cont.)How are PAL levels established? (cont.) Subtract baseline PAL pollutant emissions associated with emissions units that have been permanently shut down since the baseline period Subtract baseline PAL pollutant emissions associated with emissions units that have been permanently shut down since the baseline period oShutdowns of more than 2 years or that have resulted in the removal of the source from the State’s inventory are presumed to be permanent Add potential PAL pollutant emissions from units from which construction began after the baseline period Add potential PAL pollutant emissions from units from which construction began after the baseline period

28 FINAL PRESENTATION “Actuals” PALs How are PAL levels established? (cont.)How are PAL levels established? (cont.) Baseline PAL pollutant emissions cannot exceed emission limits allowed by your permit or newly applicable requirements at the time the PAL is set Baseline PAL pollutant emissions cannot exceed emission limits allowed by your permit or newly applicable requirements at the time the PAL is set Adjust baseline PAL pollutants to reflect applicable requirements since the baseline period Adjust baseline PAL pollutants to reflect applicable requirements since the baseline period oRACT, NSPS, BACT, LAER, etc.

29 FINAL PRESENTATION “Actuals” PAL Example Surface coating facility with 7 emissions units defined as Units A through GSurface coating facility with 7 emissions units defined as Units A through G PAL pollutant is VOCPAL pollutant is VOC New State requirement in 1999 affected Unit DNew State requirement in 1999 affected Unit D Unit F was permanently shut down in 2000Unit F was permanently shut down in 2000 Unit G was added in 2004Unit G was added in 2004 Unit C allowable VOC is 60 tpyUnit C allowable VOC is 60 tpy

30 FINAL PRESENTATION “Actuals” PAL Example YearUnit AUnit BUnit CUnit DUnit EUnit FUnit G Total Baseline Emissions in excess of 60 tons are subtracted from baseline Choose representative baseline period ( )

31 FINAL PRESENTATION “Actuals” PAL Example YearUnit AUnit BUnit CUnit DUnit EUnit FUnit G Total Baseline CorrectUnit D for new applicable requirement (90% VOC control) and re-evaluate baseline periods Correct Unit D for new applicable requirement (90% VOC control) and re-evaluate baseline periods 1 Emissions in excess of 60 tons are subtracted from baseline A B

32 FINAL PRESENTATION “Actuals” PAL Example Calculate PAL level - ACalculate PAL level - A Highest baseline = 214 tpy (1997/1998) Highest baseline = 214 tpy (1997/1998) Subtract Unit F baseline emissions (52 tons) = 162 tons Subtract Unit F baseline emissions (52 tons) = 162 tons Add PTE of new Unit G (40 tons) = 202 tons Add PTE of new Unit G (40 tons) = 202 tons Add major modification threshold (40 tons) = 242 tons Add major modification threshold (40 tons) = 242 tons Evaluate Alternative Baseline Period - B Baseline = 205 tpy (1999/2000) Baseline = 205 tpy (1999/2000) Subtract Unit F baseline emissions (30 tons) = 175 tons Subtract Unit F baseline emissions (30 tons) = 175 tons Add PTE of new Unit G (40 tons) = 215 tons Add PTE of new Unit G (40 tons) = 215 tons Add major modification threshold (40 tons) = 255 tons Add major modification threshold (40 tons) = 255 tons

33 FINAL PRESENTATION “Actuals” PAL Example Proposed VOC PAL = 255 tonsProposed VOC PAL = 255 tons Is a 255 tpy PAL viable?Is a 255 tpy PAL viable? Recent actual emissions are well below baseline Recent actual emissions are well below baseline Abatement equipment was added to Unit D Abatement equipment was added to Unit D Facility plans to switch to powder and/or waterborne coatings on Units A and C within 5 years resulting in lower emissions Facility plans to switch to powder and/or waterborne coatings on Units A and C within 5 years resulting in lower emissions A 255 tpy PAL is viable for this facilityA 255 tpy PAL is viable for this facility

34 FINAL PRESENTATION PAL Permits What does a PAL permit look like?What does a PAL permit look like? PAL permits must include: PAL permits must include: oIdentification of PAL pollutant(s) and limits(s) oPAL effective and expiration dates oPAL renewal/transition provisions oRequirement to include emissions from start-ups, shutdowns,and malfunctions in compliance calculations oRequirement to comply with PAL expiration requirements

35 FINAL PRESENTATION PAL Permits PAL permits must include (continued) PAL permits must include (continued) oPAL calculation procedures oMonitoring requirements oRecord retention requirements oReporting requirements oOther “necessary” requirements

36 FINAL PRESENTATION PAL Permits How long are PALs and PAL permits good for?How long are PALs and PAL permits good for? The effective period for a PAL is 10 years The effective period for a PAL is 10 years Can PALs be re-opened by the regulatory authority?Can PALs be re-opened by the regulatory authority? Yes - mandatory reopening of PAL permits to: Yes - mandatory reopening of PAL permits to: oCorrect errors oReduce PAL for creditable reductions oRevise to reflect a PAL increase

37 FINAL PRESENTATION PAL Permits Do PALs/PAL permits expire?Do PALs/PAL permits expire? Yes – PALs/PAL permits not renewed expire at the end of their effective period (10 years) Yes – PALs/PAL permits not renewed expire at the end of their effective period (10 years) What happens if a PAL is allowed to expire?What happens if a PAL is allowed to expire? New emission limits are established New emission limits are established oSource proposes distribution of PAL emissions to each emissions unit that existed under the PAL oThe reviewing authority decides the ultimate distribution of PAL emissions to emissions units

38 FINAL PRESENTATION PAL Permits 1 In this example, emissions were apportioned to individual emissions units at PAL expiration based on the distribution of emissions during the baseline period PAL emissions are “distributed” to individual emissions units if the PAL expires Emissions UnitPAL Level (tons)Emissions at PAL Expiration (tpy) A 61.7 B 24.5 C D25.0 E 25.5 G 47.4

39 FINAL PRESENTATION PAL Permits PAL Expiration NotesPAL Expiration Notes Compliance with new enforceable tpy limits is based on a 12-month rolling basis Compliance with new enforceable tpy limits is based on a 12-month rolling basis Required monitoring systems may be similar to those under PALs Required monitoring systems may be similar to those under PALs Compliance with a site-wide emissions “cap,” equivalent to the previous PAL, is required until a revised permit is issued Compliance with a site-wide emissions “cap,” equivalent to the previous PAL, is required until a revised permit is issued Physical changes or changes in the method of operation are subject to major NSR if change is a major modification Physical changes or changes in the method of operation are subject to major NSR if change is a major modification State or federal requirements (BACT, LAER, RACT, NSPS, etc.) remain applicable State or federal requirements (BACT, LAER, RACT, NSPS, etc.) remain applicable

40 FINAL PRESENTATION PAL Permits Are PALs adjusted when they are renewed?Are PALs adjusted when they are renewed? Yes – PALs are evaluated at renewal using the same process used to set the original PALs Yes – PALs are evaluated at renewal using the same process used to set the original PALs If the new PAL level is > or = 80% of existing PAL level, PAL may be reset at original level If the new PAL level is > or = 80% of existing PAL level, PAL may be reset at original level The reviewing authority has discretion in setting a new PAL level to : The reviewing authority has discretion in setting a new PAL level to : oBe more representative of actual emissions oBe in accordance with local air quality needs oAccommodate anticipated economic growth oRepresent advances in air pollution control technology

41 FINAL PRESENTATION PAL Permits PAL renewal adjustment notes:PAL renewal adjustment notes: The “new” PAL may not exceed the facility PTE The “new” PAL may not exceed the facility PTE New PAL cannot exceed original PAL level unless undergoing PAL modification (increase) procedure New PAL cannot exceed original PAL level unless undergoing PAL modification (increase) procedure The PAL must reflect all requirements that became applicable during PAL term and that PAL was not adjusted for The PAL must reflect all requirements that became applicable during PAL term and that PAL was not adjusted for

42 FINAL PRESENTATION PAL Permits How can PAL levels be increased?How can PAL levels be increased? An application for a PAL increase is required that: An application for a PAL increase is required that: oIdentifies all emissions units contributing to the increase oDemonstrates a PAL exceedance after inclusion of proposed new/modified emissions units and an assumption of current BACT equivalent controls on all units A major NSR permit is required for emissions units associated with the increase, regardless of the magnitude of the emissions increase A major NSR permit is required for emissions units associated with the increase, regardless of the magnitude of the emissions increase oFacility must comply with any resulting BACT/LAER requirements

43 FINAL PRESENTATION PAL Permits How is a higher PAL level established?How is a higher PAL level established? The regulatory authority establishes a higher PAL level based on: The regulatory authority establishes a higher PAL level based on: The sum of the allowable emissions from new/modified emissions units - PLUS -The sum of the allowable emissions from new/modified emissions units - PLUS - The sum of the baseline actual emissions from all significant/major emissions units assuming BACT control - PLUS -The sum of the baseline actual emissions from all significant/major emissions units assuming BACT control - PLUS - The sum of baseline actual emissions from small emissions unitsThe sum of baseline actual emissions from small emissions units The end result - the magnitude of the proposed increase is minimized by the potential PAL decreases by assuming BACT control on significant and major emissions units The end result - the magnitude of the proposed increase is minimized by the potential PAL decreases by assuming BACT control on significant and major emissions units

44 FINAL PRESENTATION PAL Permits What type of monitoring requirements are specified in PAL permits?What type of monitoring requirements are specified in PAL permits? PAL general monitoring requirements specify that: PAL general monitoring requirements specify that: oPAL monitoring systems must be based on “sound science” oMust meet “minimum legal requirements for admissibility in a judicial proceeding to enforce the PAL permit” oEmissions must be quantifiable on an ongoing basis

45 FINAL PRESENTATION PAL Permits Acceptable PAL monitoring techniques include:Acceptable PAL monitoring techniques include: Mass Balance Calculations Mass Balance Calculations oFor sources using paints, coatings, and solvents Continuous Emission Monitoring Systems (CEMS) Continuous Emission Monitoring Systems (CEMS) Continuous Parameter Monitoring Systems (CPMS) Continuous Parameter Monitoring Systems (CPMS) Predictive Emission Monitoring Systems (PEMS) Predictive Emission Monitoring Systems (PEMS) Emission Factors Emission Factors Alternative methods as approved by the administrator Alternative methods as approved by the administrator

46 FINAL PRESENTATION PAL Permits Mass Balance CalculationsMass Balance Calculations Requirements include: Requirements include: oA demonstrated means to validate pollutant content in material(s) oAssumption that emissions unit emits all of a pollutant if the pollutant cannot be accounted for oThe use of the highest value of a pollutant where a range of the pollutant content is published Mass balance calculations are acceptable and are widely used for activities using coatings or solvents Mass balance calculations are acceptable and are widely used for activities using coatings or solvents

47 FINAL PRESENTATION PAL Permits Continuous Emission Monitoring Systems (CEMS)Continuous Emission Monitoring Systems (CEMS) Requirements Requirements oSystems must meet applicable Part 60, Appendix B Performance Specifications oSystems must sample, analyze, record data once every 15 minutes of operation

48 FINAL PRESENTATION PAL Permits Continuous Parameter Monitoring Systems (CPMS) and Predictive Emission Monitoring Systems (PEMS)Continuous Parameter Monitoring Systems (CPMS) and Predictive Emission Monitoring Systems (PEMS) Requirements Requirements oThe CPMS/PEMS system must demonstrate a correlation between monitored parameters and PAL pollutant emissions across the range of unit operation oThe CPMS/PEMS system must sample, analyze, record data once every 15 minutes of operation

49 FINAL PRESENTATION PAL Permits Emission FactorsEmission Factors Requirements Requirements oIf appropriate, factors must be adjusted for the uncertainty or limitations in the factor’s development oEmissions units must operate within the range of the factor’s development oIf technically practicable, the emission factors for significant units must be re-validated within 6 months of the PAL permit issuance Unless reviewing agency determines that testing is not requiredUnless reviewing agency determines that testing is not required

50 FINAL PRESENTATION PAL Permits How is missing monitoring data handled under a PAL?How is missing monitoring data handled under a PAL? Sources must record and report maximum potential emissions without considering enforceable limitations or operating restrictions Sources must record and report maximum potential emissions without considering enforceable limitations or operating restrictions What happens when a source operates at non- correlated operating ranges?What happens when a source operates at non- correlated operating ranges? A default value representing the highest potential emissions must be established and used, or A default value representing the highest potential emissions must be established and used, or The source is deemed in violation when the unit is operating outside of a correlated parametric range The source is deemed in violation when the unit is operating outside of a correlated parametric range

51 FINAL PRESENTATION PAL Permits Do emissions monitoring systems under a PAL ever have to be re-validated?Do emissions monitoring systems under a PAL ever have to be re-validated? Yes - data re-validation is required once every 5-years for all methods of monitoring Yes - data re-validation is required once every 5-years for all methods of monitoring Re-validation is accomplished by emission testing or or other scientifically valid means Re-validation is accomplished by emission testing or or other scientifically valid means The PAL applicant may want to consider including a re-validation protocol with the PAL application addressing each type of monitoring and the proposed re-validation procedures The PAL applicant may want to consider including a re-validation protocol with the PAL application addressing each type of monitoring and the proposed re-validation procedures

52 FINAL PRESENTATION PAL Permits How long must PAL related compliance records be retained?How long must PAL related compliance records be retained? Records necessary to demonstrate compliance with the PAL regulations must be retained for five (5) years from the date of the record Records necessary to demonstrate compliance with the PAL regulations must be retained for five (5) years from the date of the record Other PAL related records must be retained for the duration of PAL plus 5 years Other PAL related records must be retained for the duration of PAL plus 5 years oPAL application oPAL revision applications oAnnual Title V certifications

53 FINAL PRESENTATION PAL Permits Received multiple PAL applications under NSR Reforms Paper mill, chemical mfg., commercial printer/laminator, automobile assembly Others in development Is it right for your Facility?

54 FINAL PRESENTATION PSD-PALs What are PSD-PALs?What are PSD-PALs? A flexible permitting option that combines the permitting of a new major source or a major modification at an existing facility with an application for a PAL A flexible permitting option that combines the permitting of a new major source or a major modification at an existing facility with an application for a PAL The PALs are based on a combination of baseline emissions and projected future actual emissions The PALs are based on a combination of baseline emissions and projected future actual emissions PSD-PALs are issued through a SIP approved NSR permitting program PSD-PALs are issued through a SIP approved NSR permitting program

55 FINAL PRESENTATION PSD-PALs There are currently two PSD-PALs in Region 4There are currently two PSD-PALs in Region 4 Saturn Corporation - Spring Hill, Tennessee Saturn Corporation - Spring Hill, Tennessee BMW – Greenville, South Carolina BMW – Greenville, South Carolina The PSD-PAL discussion is based predominantly on EPA Region 4 experience with these two sourcesThe PSD-PAL discussion is based predominantly on EPA Region 4 experience with these two sources

56 FINAL PRESENTATION PSD-PALs What type of facility is ideal for a PSD-PAL permit?What type of facility is ideal for a PSD-PAL permit? Complex, well-controlled existing or new facilities with multiple, inter-dependant processes Complex, well-controlled existing or new facilities with multiple, inter-dependant processes oNew facilities are excluded from NSR PAL rules Facilities subject to frequent changes with: Facilities subject to frequent changes with: oA high potential to emit for one or more PSD regulated pollutants oWell characterized emissions oEffective monitoring systems Examples include automobile manufacturers, chemical manufacturers, and Kraft pulp millsExamples include automobile manufacturers, chemical manufacturers, and Kraft pulp mills These types of facilities are well represented in Region 4 These types of facilities are well represented in Region 4

57 FINAL PRESENTATION PSD-PALs PSD-PAL Level equals:PSD-PAL Level equals: Baseline emissions from all unaffected emissions units (including shutdown sources where applicable) PLUS PLUS PTE from new or modified emissions units MINUS MINUS Baseline emissions from sources permanently shutdown

58 FINAL PRESENTATION PSD-PALs Unit 1Unit 2Unit 3Unit 4Unit 5 1 Unit 6 1 Unit 7 2 Unit 8 2 Unit 9 2 Total UnaffectedAffected UnaffectedDown New Corrected YearVOC (tons) VOC 3 (tons) Baseline52N/A N/A 197 Projected Actual at BACTN/A8525N/A Last BACT N/A Unit 5 shut down in late 2000, Unit 6 shut down in late Units 7, 8, and 9 are new units 3 Total corrected VOC excludes emissions from affected units

59 FINAL PRESENTATION PSD-PALs Establish PAL ContributionsEstablish PAL Contributions Unaffected source baseline Unaffected source baseline o 73.5 tons New/affected sources New/affected sources o 285 tpy Shut-down sources in baseline Shut-down sources in baseline o tpy UnitStatusPAL Contribution (tons) 1Unaffected52 2Affected85 3Affected25 4Unaffected21.5 5Shutdown93.5 6Shutdown30 7New75 8New50 9New50 Total482

60 FINAL PRESENTATION PSD-PALs Compute the PSD-PAL level:Compute the PSD-PAL level: Baseline emissions from unaffected emissions units = 73.5 tons Baseline emissions from unaffected emissions units = 73.5 tons Baseline emissions from shutdown sources = tons Baseline emissions from shutdown sources = tons Projected actual emissions from new and affected sources = 285 tons Projected actual emissions from new and affected sources = 285 tons Compute PAL Compute PAL o73.5 tons tons tons – tons = tons PAL LEVEL = TONS PER ROLLING 12-MONTH PERIOD

61 FINAL PRESENTATION PSD-PALs Can PSD-PALs be written with “Flexibility” provisions?Can PSD-PALs be written with “Flexibility” provisions? Yes - PSD-PALs may include flexibility provisions Yes - PSD-PALs may include flexibility provisions Flexibility provisions are those conditions that reduce the administrative “friction” - costs, time, delay, uncertainty, and risks experienced by sources and permitting authorities when implementing a permit or making certain changes under a permit Flexibility provisions are those conditions that reduce the administrative “friction” - costs, time, delay, uncertainty, and risks experienced by sources and permitting authorities when implementing a permit or making certain changes under a permit Flexibility provisions are in addition to the inherent PAL benefits Flexibility provisions are in addition to the inherent PAL benefits

62 FINAL PRESENTATION PSD-PALs What do flexible provisions include?What do flexible provisions include? Pre-approved NSR Pre-approved NSR oAbility to add new emissions units oAbility to make physical changes or changes in the method of operation Certain requirements may be subsumed Certain requirements may be subsumed oFor example, compliance with PAL levels may be deemed to also be in compliance with: Individual BACT emission limitsIndividual BACT emission limits State SIP emission limitsState SIP emission limits Flexibility provided in PSD-PAL permits is largely dependent upon regulatory authority policy and is generally negotiated Flexibility provided in PSD-PAL permits is largely dependent upon regulatory authority policy and is generally negotiated

63 FINAL PRESENTATION PSD-PALs Flexible components must include safeguardsFlexible components must include safeguards Examples of safeguards include: Examples of safeguards include: oBACT on all new units > significance level oMinor source BACT or Best Available Technology (BAT) on all new units < significance level oStreamlined “registration” and public notice for all new major units oRequirement to operate and monitor air pollution control systems relied on for BACT oRequirement to comply with NAAQS and PSD increments

64 FINAL PRESENTATION PSD-PALs What type of monitoring procedures are required under a PSD-PAL?What type of monitoring procedures are required under a PSD-PAL? In general, monitoring procedures that are equivalent to those required under an NSR “actuals” PAL In general, monitoring procedures that are equivalent to those required under an NSR “actuals” PAL oMass Balance Calculations oCredible Emission Factors oContinuous Emission Monitors (CEMs) oContinuous Parameter Monitoring Systems (CPMS) oApproved alternative monitoring methods

65 FINAL PRESENTATION PSD-PALs What level of air pollution control device monitoring is required?What level of air pollution control device monitoring is required? In general, air pollution control device monitoring and recordkeeping should be equivalent to CAM requirements In general, air pollution control device monitoring and recordkeeping should be equivalent to CAM requirements Effective air pollution control device monitoring could be essential to flexibility provisions Effective air pollution control device monitoring could be essential to flexibility provisions oCompliance with unit specific BACT requirements is based on compliance with PAL limits oBACT compliance is contingent upon proper operation of air pollution control equipment oAn effective monitoring system is therefore essential to BACT/PAL compliance

66 FINAL PRESENTATION PSD-PALs Emission calculation proceduresEmission calculation procedures The applicant should develop and propose emission calculation procedures to convert monitoring data to a mass emission basis The applicant should develop and propose emission calculation procedures to convert monitoring data to a mass emission basis Calculations should be based on sound scientific/engineering principles and should compute emissions (tons) on a monthly basis Calculations should be based on sound scientific/engineering principles and should compute emissions (tons) on a monthly basis Monthly emissions (tons) are summed with the preceding 11 months worth of monthly data to demonstrate PAL compliance on t rolling 12-month basis Monthly emissions (tons) are summed with the preceding 11 months worth of monthly data to demonstrate PAL compliance on t rolling 12-month basis Calculations should be replicable Calculations should be replicable

67 FINAL PRESENTATION PSD-PALs A draft PSD-PAL permit is recommended as part of a PSD-PAL applicationA draft PSD-PAL permit is recommended as part of a PSD-PAL application Benefits of a draft permit in the application Benefits of a draft permit in the application oStarting point for negotiating conditions oClearly articulates source expectations and commitments oCompresses regulatory agency review time Draft permit components include: Draft permit components include: oPAL conditions oMonitoring requirements oRecordkeeping requirements oCalculations oFlexibility provisions

68 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Overview of the PSD/PAL Permit for the Saturn Spring Hill, Tennessee FacilityOverview of the PSD/PAL Permit for the Saturn Spring Hill, Tennessee Facility The Saturn facility is comprised of three business units: The Saturn facility is comprised of three business units: oBody Systems - body panels, body fabrication and paint shop oVehicle Systems - vehicle interior systems and final vehicle assembly oPowertrain - machining, engine assembly, and final dress Production of Saturn vehicles began in July of 1990 Production of Saturn vehicles began in July of 1990 The original PSD permit had 54 separate permitted emissions units and 333 separate permit conditions The original PSD permit had 54 separate permitted emissions units and 333 separate permit conditions

69 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Planned facility changes for 2001Planned facility changes for 2001 New vehicle assembly lines New vehicle assembly lines Modified coating lines/conveyor changes Modified coating lines/conveyor changes New engine machining/assembly operations New engine machining/assembly operations New AA stamping press New AA stamping press Overall facility production capacity increase from 360,000 to 595,350 vehicles per year Overall facility production capacity increase from 360,000 to 595,350 vehicles per year

70 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Critical facility air permitting issues:Critical facility air permitting issues: Initial projects triggered PSD applicability Initial projects triggered PSD applicability Facility projects are subject to frequent scope/schedule changes Facility projects are subject to frequent scope/schedule changes NSR Revision status was in a state of flux in 1999 NSR Revision status was in a state of flux in 1999 Saturn air permit objectives:Saturn air permit objectives: Obtain an innovative permit regardless of NSR Revision status Obtain an innovative permit regardless of NSR Revision status Base flexible permit on the PAL concept Base flexible permit on the PAL concept Obtain allowable emissions adequate for 595,350 vehicles/yr or more Obtain allowable emissions adequate for 595,350 vehicles/yr or more Accommodate scope/schedule changes without triggering the need for a new permit Accommodate scope/schedule changes without triggering the need for a new permit Simplify compliance demonstration Simplify compliance demonstration

71 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Final air permitting concept:Final air permitting concept: Innovative permit obtained through traditional PSD permitting process Innovative permit obtained through traditional PSD permitting process PSD permit with BACT levels combined to establish multi-pollutant PALs PSD permit with BACT levels combined to establish multi-pollutant PALs Streamlined monitoring and compliance determination Streamlined monitoring and compliance determination Expedited treatment of additional new units Expedited treatment of additional new units Authorized changes to existing units provided PALs are not exceeded Authorized changes to existing units provided PALs are not exceeded

72 FINAL PRESENTATION Case Study A – Saturn PSD/PAL PSD-PAL permit applicationPSD-PAL permit application Common PSD Components (BACT, modeling, etc.) Common PSD Components (BACT, modeling, etc.) Innovative Components Innovative Components oProposed PALs based on a combination of baseline and potential emissions for criteria pollutants oSingle emissions unit for all combustion related emissions oDocumentation of BACT equivalent technology for unaffected emissions units (e.g., clean units) oSample draft permit language incorporating proposed PALs and other innovative provisions Submitted application to TDEC in October 1999 Submitted application to TDEC in October 1999 Received final PSD/PAL permit in June 2000 Received final PSD/PAL permit in June 2000

73 FINAL PRESENTATION Case Study A – Saturn PSD/PAL a Previous allowable emissions represent conditions from Saturn’s original operating/construction permits and subsequent modifications. b Baseline actual is the average 1995/1996 annual emission rate c Net change represents the difference between baseline emission rates and PAL levels. The project triggered PSD review for VOC, NO x, and PM 10. d Saturn utilizes natural gas as the sole fuel on-site. There are no provisions for alternative or back-up fuels. Emissions Summary, Tons/yr.

74 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Permit InnovationsPermit Innovations Operational Flexibility Operational Flexibility oPre-approved new “major” emissions units Registration and BACT requirementRegistration and BACT requirement Saturn may begin construction when BACT is approved (i.e., 45 days)Saturn may begin construction when BACT is approved (i.e., 45 days) oPre-approved new “minor” emissions units Registration and mBACT requirementRegistration and mBACT requirement Saturn may begin construction when mBACT is approved (i.e., 30 days)Saturn may begin construction when mBACT is approved (i.e., 30 days) oChanges to existing emissions units do not require TDEC approval

75 FINAL PRESENTATION Case Study A – Saturn PSD/PAL Permit InnovationsPermit Innovations Clear monitoring and recordkeeping requirements Clear monitoring and recordkeeping requirements Ability to increase PALs through the PSD permitting process Ability to increase PALs through the PSD permitting process Termination provision with return to “traditional” permit Termination provision with return to “traditional” permit Streamlined compliance requirements Streamlined compliance requirements

76 FINAL PRESENTATION Case Study A – Saturn PSD/PAL “Old” PSD Versus New PSD/PAL Conditions

77 FINAL PRESENTATION Case Study A – Saturn PSD/PAL SummarySummary The PAL permit provides significant operational flexibility to Saturn within current regulatory bounds The PAL permit provides significant operational flexibility to Saturn within current regulatory bounds The permit streamlines compliance determinations for the facility, TDEC, and the public The permit streamlines compliance determinations for the facility, TDEC, and the public VOC emissions per vehicle produced has declined since PAL issuance VOC emissions per vehicle produced has declined since PAL issuance The PSD/PAL permit has improved the environmental performance of the facility The PSD/PAL permit has improved the environmental performance of the facility The original PAL permit limits and flexibility are retained in the Title V operating permit The original PAL permit limits and flexibility are retained in the Title V operating permit

78 FINAL PRESENTATION Case Study C – Non-attainment PAL Overview of a proposed PAL for an adhesive coating facility in PennsylvaniaOverview of a proposed PAL for an adhesive coating facility in Pennsylvania The facilityincludes boilers, reactor vessels, mixing and formulation, multiple adhesive coaters and dryers, and research and development facilities The facility includes boilers, reactor vessels, mixing and formulation, multiple adhesive coaters and dryers, and research and development facilities Facility emissions include VOC, PM10, HAPs, and products of combustion (NOx and CO) Facility emissions include VOC, PM10, HAPs, and products of combustion (NOx and CO) The facility is well controlled using a vent condenser and two existing regenerative thermal oxidizers to abate VOC and vHAP emissions The facility is well controlled using a vent condenser and two existing regenerative thermal oxidizers to abate VOC and vHAP emissions

79 FINAL PRESENTATION Case Study C – Non-attainment PAL Critical facility air permitting issues:Critical facility air permitting issues: NSR Revisions became effective in March 2003 for attainment pollutants NSR Revisions became effective in March 2003 for attainment pollutants The facility is located in an area classified as moderately non-attainment for ozone due to its location in the Northeast Ozone Transport Region The facility is located in an area classified as moderately non-attainment for ozone due to its location in the Northeast Ozone Transport Region Permitting timelines and redundant NSR applicability analyses Permitting timelines and redundant NSR applicability analyses Projects “in the pipeline” that include expedited installation schedules Projects “in the pipeline” that include expedited installation schedules

80 FINAL PRESENTATION Case Study C – Non-attainment PAL Final air permitting concept:Final air permitting concept: Acquire a VOC PAL through the Pennsylvania minor NSR program Acquire a VOC PAL through the Pennsylvania minor NSR program Since facility is well controlled, use the 40 ton major NSR modification threshold to establish a VOC PAL Since facility is well controlled, use the 40 ton major NSR modification threshold to establish a VOC PAL Ensure expedited state review and approval of facility modifications by eliminating required non- attainment NSR applicability determinations Ensure expedited state review and approval of facility modifications by eliminating required non- attainment NSR applicability determinations Allow the facility to decide where and how VOC emissions are controlled within the facility in accordance with Pennsylvania Best Available Technology (BAT) requirements Allow the facility to decide where and how VOC emissions are controlled within the facility in accordance with Pennsylvania Best Available Technology (BAT) requirements

81 FINAL PRESENTATION Case Study C – Non-attainment PAL Minor Pennsylvania NSR permit applicationMinor Pennsylvania NSR permit application BAT analysis not required since no emissions units were being modified BAT analysis not required since no emissions units were being modified Emissions inventory Emissions inventory oBaseline calculation - PA PAL policy requires the use of the most recent two calendar years to develop baseline emission rates or an alternative two year period within the past five year if the most recent two years is not representative oPAL calculation - The PAL was established by adding an amount slightly less than the major modification threshold (i.e., 39 tons for VOC) to the baseline minus allowable emission increases since 1991

82 FINAL PRESENTATION Case Study C – Non-attainment PAL Non-attainment VOC PAL Calculation Calculation Steps Emissions (tpy) 2002 Calendar Year Actual Emissions (from emissions statement) Calendar Year Actual Emissions (from emissions statement)21.91 Two-year average baseline emissions23.49 ADD - Moderate Non-attainment major modification threshold (- 0.5 tons)39.5 SUBTRACT - Allowable increases in VOC since 1991(0.79) PROPOSED NON-ATTAINMENT VOC PAL62.6

83 FINAL PRESENTATION Case Study C – Non-attainment PAL Innovative Components Innovative Components oProposed site wide VOC PAL set using baseline VOC emissions plus adjusted NSR major modification threshold oThe facility is well controlled and the VOC PAL provides a considerable growth cushion oFor this facility, the ability to manage growth internally via a VOC PAL is sufficiently innovative Submitted application in October 2004 Submitted application in October 2004 A proposed draft permit is currently under review by DEP and the facility A proposed draft permit is currently under review by DEP and the facility


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