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Prevention of Significant Deterioration/Nonattainment Review The Basics Richard (Rick) Goertz, P.E. Air Permits Division Texas Commission on Environmental.

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Presentation on theme: "Prevention of Significant Deterioration/Nonattainment Review The Basics Richard (Rick) Goertz, P.E. Air Permits Division Texas Commission on Environmental."— Presentation transcript:

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2 Prevention of Significant Deterioration/Nonattainment Review The Basics Richard (Rick) Goertz, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014

3 NAAQS Criteria pollutants  CO, NO X, SO 2, Ozone (NO X /VOC)  PM 10, PM 2.5, and Pb Primary NAAQS  protect public health Secondary NAAQS  protect public welfare

4 Important Terms Attainment  In compliance with NAAQS Nonattainment  Out of compliance with NAAQS

5 Current Nonattainment Areas Wise HGB Ozone Nonattainment Area – 1997 Severe – 2008 Marginal DFW Ozone Nonattainment Area – 1997 Serious – 2008 Moderate Lead Nonattainment Area Moderate PM 10 Nonattainment Area Wise County (DFW) – Ozone Nonattainment Area Attainment Moderate (Effective 7/20/12)

6 Minor and Major NSR Federal (Major) NSR PSD Nonattainment State (Minor) NSR NSR permit Standard permit PBR De minimis Federal (Major) NSR PSD Nonattainment

7 PSD Program New major sources Major modifications of existing major sources Criteria pollutants that are in attainment Certain non-criteria pollutants

8 PSD Program Major source definition:  Named Source > 100 tpy (includes fugitives)  Un-named Source > 250 tpy

9 PSD Program Major Modification Significant Emission Rates for Criteria Pollutants: CO≥100tpy NO X ≥40tpy SO 2 ≥40tpy VOC≥40tpy PM≥25tpy PM 10 ≥15tpy PM 2.5 ≥10tpy Pb≥0.6tpy

10 PSD Program Major Modification Significant Emission Rates for Non-Criteria Pollutants: Fluorides≥3 tpy Sulfuric acid mist≥7 tpy Hydrogen sulfide≥10 tpy Total reduced sulfur≥10 tpy Plus others

11 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 PM 10, PM 2.5 include filterable & condensable

12 Nonattainment Program Applies only to pollutants for which the area is designated as nonattainment New major sources Major modifications of existing major sources Most commonly encountered area - ozone  regulated through NO X and VOC

13 Nonattainment Area Limits DFW - Serious Major Source ≥ 50 TPY Major Mod. ≥ 25 TPY Wise County (DFW) - Moderate Major Source ≥ 100 TPY Major Mod. ≥ 40 TPY Wise HGB - Severe Major Source ≥ 25 TPY Major Mod. ≥ 25 TPY

14 Nonattainment Program Nonattainment Review Requires (for ozone)... Must be a major source or major modification for either NO X or VOC NO X and VOC are evaluated independently Application of LAER Application of offsets

15 Nonattainment Program Offset: An actual emission reduction, greater than or equal to the project’s potential emission increase The amount of offset depends on the nonattainment classification

16 Nonattainment Areas Offset Ratios DFW - Serious Major Source ≥ 50 TPY Major Mod. ≥ 25 TPY Offset Ratio = 1.2 to 1 Wise County (DFW) - Moderate Major Source ≥ 100 TPY Major Mod. ≥ 40 TPY Offset Ratio = 1.15 to 1 HGB - Severe Major Source ≥ 25 TPY Major Mod. ≥ 25 TPY Offset Ratio = 1.3 to 1 Wise

17 PSD and Nonattainment Review Is it possible to trigger both PSD and nonattainment for the same pollutant?  Yes, it is. NO X is an ozone precursor and has a NAAQS of its own.

18 Location of New or Modified Equipment Where is the equipment located?  In an attainment or nonattainment area?  At a grassroots or an existing minor source?  At an existing major source?

19 Location of New or Modified Equipment To trigger major NSR at a grassroots or existing minor source, the potential project increase must be major in and of itself.

20 Example 1 Company B is a minor un-named source in a severe nonattainment area. Current PTE = 20 tpy NO X Proposed PTE = 40 tpy NO X Baseline Actual = 25 tpy NO X Current PTE=20 tpy NO x Proposed PTE=40 tpy NO x Major Source =25 tpy NO x Current PTE=20 tpy NO x Proposed PTE=40 tpy NO x Major Source =25 tpy NO x

21 Example 1 Current PTE = 20 tpy Proposed PTE = 40 tpy Major Source = 25 tpy The project potential increase is: 40 tpy – 20 tpy = 20 tpy The project is not a major source in and of itself {greater than or equal to 25 tpy for a severe nonattainment area}. Major NSR is not triggered, but minor NSR permitting requirements do apply.

22 Location of New or Modified Equipment To trigger major NSR at an existing major source, the net project emission increase must be greater than or equal to the major modification significant emission rate for the pollutant

23 Determine Emissions Determine the project increase for each pollutant. Compare project increase to netting significance levels. If the increase is greater than the netting significance levels, netting is required. If net project increase exceeds significance levels, major NSR is triggered.

24 Determine Emissions Project Emission Increase + Planned Emission Rate (project increases only) -Baseline Actuals (affected facilities) = Project Emission Increase

25 Determine Emissions Planned Emission Rate Either the...  Potential to emit, or  Projected actual emission rate

26 Determine Emissions Baseline Actual Emission Rate Emissions, in tons per year, actually emitted during a consecutive 24-month period out of...  The previous 10 years, or  The previous 5 years for electric utilities

27 Determine Emissions 2014 Jan 1, Application Submittal year window for selecting 24-month Baseline Actual Emission Rate

28 Determine Emissions Netting Netting is required if the project increase equals or exceeds the netting significance level for the pollutant. Planned Emission Rate minus Baseline Actual ≥ Netting Significance Level

29 Determine Emissions Netting Significance Levels PSD: same as PSD major modification significance levels Nonattainment:  Serious & Severe: ≥ 5 tpy  Moderate: ≥ 40 tpy

30 NETTING!

31 About Netting Applies to existing major sources only Applicability step to determine if major NSR has been triggered Ensures smaller projects do not add up to be a major modification

32 About Netting Conducted for each pollutant in which netting is triggered An evaluation of :  The current project, plus  Increases and decreases within the contemporaneous period (netting window)

33 Contemporaneous Period Netting Window Five years before start of construction to Proposed start of operation

34 Netting Contemporaneous Period

35 Netting Window Modifications identified within the contemporaneous period may be based on:  The date the modification was authorized, or  The date the change is operated Must be used consistently Indicate which method is used

36 Creditable Emissions Occurs during the contemporaneous period Cannot have been relied upon in issuing a major NSR permit for the source Sources/activities authorized by the major NSR permit are not in operation when the current increase is authorized Rely on Emissions Inventory

37 Creditable Increases The new level of emissions exceeds the Baseline Actual Emission Rate (PTE – Baseline = Increase) Does not include emission increases at facilities under a plant-wide applicability limit (PAL)

38 Creditable Decreases The Baseline Actual Emission Rate exceeds the new level of emissions Enforceable at and after the time that project modification begins to operate. (Must be enforceable and real before the unit starts operation)

39 Determining Increases and Decreases Increases and decreases for each project within the contemporaneous period are determined 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 except for the current project)

40 Baseline Actual Emission Rate Emissions, in tons/year, actually emitted during a consecutive 24-month period out of the previous 10 years (previous 5 years for electric utilities) from the date the project is authorized or modifications are operated

41 Using an Allowable to Allowable Comparison Situation #1: the Baseline Actual > current PTE Situation #2: a new facility is within two years of its initial start up date

42 Netting Window Example

43 Net Emissions Increase Project increase +Non-project source-wide creditable contemporaneous emission increases -Source-wide creditable contemporaneous emission decreases (including the current project) The amount that exceeds zero

44 Triggering Major NSR Compare the net increases to the appropriate significant emission rate If the increase is greater than or equal to the significant emission rate for the pollutant, major NSR is required

45 Time for some examples!

46 Example 2 Company C is a named major source in a severe nonattainment area. Current PTE = 50 tpy NO X Proposed PTE = 52 tpy NO X Baseline Actual = 48 tpy NO X Project Increase = 4 tpy NO X Current PTE=50 tpy NO x Proposed PTE=52 tpy NO x Baseline Actual=48 tpy NO x Project Increase =4 tpy NO x Current PTE=50 tpy NO x Proposed PTE=52 tpy NO x Baseline Actual=48 tpy NO x Project Increase =4 tpy NO x

47 Example 2 Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 52 tpy Baseline Actual = 48 tpy Project Increase = 4 tpy Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 52 tpy Baseline Actual = 48 tpy Project Increase = 4 tpy The project increase of 4 tpy does not exceed the netting significance level of 5 tpy for a serious nonattainment area. Netting is not required.

48 Example 3 Company is a named major source in a serious nonattainment area. Current PTE = 50 tpy NO X Proposed PTE = 60 tpy NO X Baseline Actual = 47 tpy NO X Project Increase = 13 tpy NO X (Proposed PTE-Baseline Actual) Current PTE= 50 tpy NO x Proposed PTE= 60 tpy NO x Baseline Actual= 47 tpy NO x Project increase= 13 tpy NO x ( Proposed PTE-Baseline Actual) Current PTE= 50 tpy NO x Proposed PTE= 60 tpy NO x Baseline Actual= 47 tpy NO x Project increase= 13 tpy NO x ( Proposed PTE-Baseline Actual)

49 Example 3 Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 60 tpy Baseline Actual = 47 tpy Project Increase = 13 tpy Major Source, Serious Nonattainment Area Current PTE = 50 tpy Proposed PTE = 60 tpy Baseline Actual = 47 tpy Project Increase = 13 tpy Emissions increase exceeds the netting significance level of 5 tpy. Netting is required!

50 Example 3 Table 3F NO x

51 Example 3 Finding Total Increase Current Project 13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase tons/year decrease Total Increase: 14 tons/year Current Project13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase 4.25 tons/year decrease Total Increase: 14 tons/year Current Project13 tons/year increase 11/2010 Project 5 tons/year increase 10/2011 Project 0.25 tons/year increase 4.25 tons/year decrease Total Increase: 14 tons/year

52 Example 3 Nonattainment? The major modification significant emission rate for a severe nonattainment area is 25 tpy. Net project increase is 14 tpy. The project is not a “major modification” and major NSR (nonattainment review) is not required.

53 Check Your Calculations!

54 Contacts JOHNNY VERMILLION (512) Or Rick Goertz (512)


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