PSD/NNSR Applicability Examples Terms: BAE – baseline actual emissions DFW - 10 county Dallas, Forth Worth area Facility - TCEQ definition (unit) HGD – 8 county Houston, Galveston, Brazoria area Mod – modification NA- nonattainment NNSR – nonattainment new source review NSR – new source review PAE – projected actual emissions PSD – Prevention of Significant Deterioration (outside nonattainment areas) PTE – potential to emit Source - EPA definition, in Title 30 Texas Administrative Code (30 TAC) §122 CO = carbon monoxide NOX = oxides of nitrogen SO2 = sulfur dioxide VOC = volatile organic compound PM10 = particulate matter less than or equal to 10 microns in diameter PM2.5 = particulate matter less than or equal to 2.5 microns in diameter Pb = lead NAAQS = National Ambient Air Quality Standards Matt Earnest, Ph.D. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014

Applicability Flow Chart Go though flowchart, pollutant by pollutant. 1-is source in nonattainment area for the pollutants? 2-is the source an existing major source? (major for one, major for all) 3-increases only, no decreases at this step. Ensure the change is a modification. 4- a major mod occurs when increases > significant emission rates 5- are the project increases > than major source thresholds? 6- include all increases and creditable decreases in contemporaneous window. Go though flowchart, pollutant by pollutant. 1-is source in nonattainment area for the pollutants? 2-is the source an existing major source? (major for one, major for all) 3-increases only, no decreases at this step. Ensure the change is a modification. 4- a major mod occurs when increases > significant emission rates 5- are the project increases > than major source thresholds? 6- include all increases and creditable decreases in contemporaneous window.

Does PSD/NNSR Apply? There are only five scenarios of applicability - a new minor source (not applicable), a new major source (applicable), a new minor source at an existing minor source (not applicable), a new major source at an existing minor source (applicable), and an expansion at a major source (might be applicable depending on netting, Steps 2 and 3).

Major Source Thresholds PSD Criteria Named 100 tpy Un-named 250 tpy Ozone NNSR Marginal 100 tpy Moderate Wise Co. Serious 50 tpy DFW Severe 25 tpy HGB Extreme 10 tpy PM10 NNSR Marginal 100 tpy Moderate El Paso Co. Serious 70 tpy tpy = tons per year (tons/year) Named source – emissions greater than or equal to 100 tons/year (includes fugitive emissions) Un-named source – emissions greater than or equal to 250 tons/year ≥

Example: New Major Source (Type 1) Will the following “unnamed” source, proposed to be built in a severe ozone nonattainment area (HGB), be major for NNSR and/or PSD? If so, for which pollutants? Pollutant NOX CO PM10 Source PTE (tpy) 91 315 52 NNSR: Yes, major source because NOX≥25 tpy A different but similar example from the guidance: A project is being considered in a severe ozone nonattainment area. The project will affect the emissions of NOX, CO, and PM10. The PTE from all facilities at the source, for these pollutants, were determined and were summed to provide the values in the table below. Pollutant NOX, 88 tpy CO, 310 tpy PM10, 55 tpy Question: Is the source a major source for purposes of nonattainment applicability? Answer: Yes, the source is a major source for NOX for the purposes of nonattainment applicability. When determining the source PTE for purposes of nonattainment review, remember that each pollutant is evaluated independently. Both NOX and VOC are regulated as precursors to ozone. In this case, the source emits NOX. The PTE for NOX is 88 tpy and exceeds the major source significant emission rate of 25 tpy for severe nonattainment areas. Question: Is the source a major source for the purposes of PSD applicability? Answer: Yes, the source is a major source for the purposes of PSD applicability. When determining whether the source is a major source for PSD, consider the emissions of all federally regulated NSR pollutants at the source. A review of the emissions from the source in this example shows that the PTE for CO is 310 tpy. Since the current PTE for CO (310 tpy) exceeds the major source significant emission rate for criteria pollutants emitted in an attainment area (100 tpy for named sources, and 250 tpy for un-named sources), the source is a major source. Remember, that under PSD applicability requirements, if the source is a major source for one criteria pollutant, then the source is a major source for all criteria pollutants. This is different than nonattainment applicability, where the determination of a source being a major source is conducted on a pollutant by pollutant basis. PSD: Yes, major source for all pollutants because CO≥250 tpy

Project Increase at Major Source (Type 2) Is Project Increase ≥ PSD Significant Emission Rate? Window can be based on actual start of construction or project submittal (§116.12). Project increases only count emission increases. PSD Significant Emission Rates (SERs) PM10 = 15 tpy SO2 = 40 tpy NOX = 40 tpy VOC = 40 tpy CO = 100 tpy Pb = 0.6 tpy TRS/ H2S = 10 tpy H2SO4 = 7 tpy Project Increase = Planned Emissions - Baseline Actual

Example: Base Line (Type 2) A site is considering a throughput increase in 2014. What is the baseline actual emission rate, given EPN D was built in 2013 with an allowable of 50 tpy? Year EPN A EPN B EPN C EPN D (tpy) 2004 50 20 19 2005 52 23 2006 60 21 22 2007 61 2008 2009 2010 59 2011 18 2012 16 2013 17 BAE 21.5 Right example-correct way to calculate BAE by using emissions from all EPNs from years 2007 and 2008 Must be same time period for all facilities for common pollutant. Adjust baseline if: < 24-month operation Compliance issues EPN = emission point number See example #8 from APDG 5881, Major New Source Review - Applicability Determination (March 2013) for more in-depth discussion. APDG 5881 can be found on the TCEQ website at http://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/fnsr_app_determ.pdf.

Planned Emissions EPN A is operating far below it’s PTE. What are the project increases given the following? EPN A Baseline Actual Emissions (BAE) = 61 tpy EPN A Potential to Emit (PTE) = 201 tpy EPN A Projected Actual after project (PAE) = 72 tpy Project increase: Based on Projected Actual: PAE – BAE = 72 – 61 = 11 tpy Based on Potential to Emit: PTE – BAE = 201 – 61 = 140 tpy Use of Projected Actuals may require additional record keeping. Using projected actuals, this project would net out of PSD, and moderate NA (Wise) but not out of serious/severe NA (HGB, DFW).

Table 2F Table 2F is used to convey project increases to the agency. “Correction” discussed in later presentation.

Contemporaneous Window Type 2 applicability test uses a ten-year window. Type 3 has a contemporaneous window of five years. Each project in the window has a baseline actual within its own ten-year window.

Example: Netting (Type 3) A company is considering a major project at EPN B that requires netting. The source has been affected by the following unrelated projects within the last five years. What is the contemporaneous change? 2010: PTE = 15 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy PAST See example #19 from APDG 5881, Major New Source Review - Applicability Determination (March 2013) for more in-depth discussion. APDG 5881 can be found on the TCEQ website at http://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/fnsr_app_determ.pdf. 2014: PTE = 20 tpy Proposed PTE = 30 tpy Baseline Actuals = 15 tpy Project Change: 30 - 15 = 15 tpy Net: 15 + 10 + 10 + 10 = 45 tpy CURRENT

3F: Contemporaneous Change

Contemporaneous Window This example has overlapping projects in the contemporaneous window.

Example: End Points (Type 3) A company is considering a major project at EPN B that requires netting. The source has been affected by the following unrelated projects within the last five years. What is the contemporaneous change? 2010: PTE = 15 tpy Proposed PTE = 25 tpy Baseline Actuals = 15 tpy Project Change: 25 - 15 = 10 tpy 2011: PTE = 25 tpy 2014: PTE = 20 tpy Proposed PTE = 30 tpy Project Change: 30 - 15 = 15 tpy Net: 15 + 10 + 10 + 10 = 45 tpy No...Year 2011 is not considered in the calculation to determine the contemporaneous change; 45 tons/year is not the correct answer 2010: Baseline Actuals = 15 tpy, 2011, 2011, 2014: Proposed PTE = 30 tpy, Net: 30 – 15 = 15 tpy Baseline Actuals = 15 tpy 2011: 2014: Proposed PTE = 30 tpy Net: 30 - 15 = 15 tpy See example #8 from APDG 5881, Major New Source Review - Applicability Determination (March 2013) for more in-depth discussion. It would net out of PSD, and moderate NA (Wise) but not out of serious/severe NA (HGB, DFW). APDG 5881 can be found on the TCEQ website at http://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/fnsr_app_determ.pdf.

3F: Contemporaneous Change Modifications identified within the contemporaneous period may be based on: -The date the modification was authorized, or -The date the change is operated. This must be used consistently, and the method must be indicated in the application.

Items to Double Check Project aggregation Site definition Inclusion of fugitives Differences with power generation Demand growth exclusion Retrospective reviews Ensure these categories are checked before submission.

Thank you For more information: See Guidance: APDG 5881, Major New Source Review - Applicability Determination (March 2013) APDG 6241v1, Fact Sheet – PSD and Nonattainment (Revised 07/14) APDG 5881 can be found on the TCEQ website at http://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/fnsr_app_determ.pdf). APDG 6241v1, Fact Sheet – PSD and Nonattainment (Revised 07/14) can be found on the TCEQ website at http://www.tceq.texas.gov/assets/public/permitting/air/factsheets/factsheet-psd-na.pdf.

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