Continuing Evolution of New Source Review
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This document summarizes the continuing evolution of new source review regulations. It provides an example of how major new source review works through a case study of a modification to an existing combination fuel boiler. Key points discussed include applicability analyses, excluded emissions, tracking emissions against projections, and future permit reporting requirements.
Continuing Evolution of New Source Review
- 1. Continuing Evolution of New Source Review John Egan and Colin McCall All4 Inc. 2010 Mid-Atlantic Environmental and Energy Conference and Trade Show Camp Hill, PA April 14, 2010
- 2. Agenda Brief major new source review primer Case study example of current issues: • Applicability analysis • Excluded emissions • Tracking against projections PM2.5 and GHG meet major NSR Aggregation and offsets for non-attainment 2
- 3. Major NSR Permits Major new source review (NSR) is the air permitting program for major new sources and major modifications. Two different Major NSR programs: • Prevention of Significant Deterioration (PSD) for sources in NAAQS attainment areas • Non-attainment New Source Review (NNSR) for sources in NAAQS non-attainment areas 3
- 4. NAAQS Pollutant Averaging Time Primary Standard Secondary Standard Particulate Matter PM10, 24 hr 150 g/m3 150 g/m3 PM2.5, annual 15 g/m3 15 g/m3 PM2.5, 24 hr 35 g/m3 35 g/m3 Sulfur Dioxide (SO2) annual 80 g/m3 (0.03 ppm) ---- 24 hr 365 g/m3 (0.14 ppm) ---- 3 hr ---- 1,300 g/m3 (0.5 ppm) 1 hr Coming Soon -- Nitrogen Dioxide (NO2) annual 100 g/m3 (0.053 ppm) 100 g/m3 (0.053 ppm) 1 hr 100 ppb (new std form) Ozone (O3) 8 hr 0.075 ppm 0.075 ppm Carbon Monoxide (CO) 8 hr 9 ppm (10 g/m3) ---- 1 hr 35 ppm (40 g/m3) ---- Lead (Pb) 3-month rolling avg. 0.15 g/m3 ---- 4
- 5. NSR Major Modifications In order to trigger a major modification under PSD or NNSR: • Facility must be an existing major source and project must result in a significant emissions increase, or • Project must be a major source Different major source thresholds and significance levels under PSD and NNSR 5
- 6. NSR Major Modifications Major modifications under both PSD and NNSR can include: • New emissions units • Physical changes to existing emissions units or to non-emissions units • Change in the method of operation of existing emissions units (e.g., debottlenecking) • Removal of previous permit restrictions • Use of fuels or raw materials that the unit could not previously use 6
- 7. Example – How Major NSR Works The Project • Existing combination fuel boiler Fires primarily wood and coal • Modification: Increase steam rate (more power) Burn more wood (biomass) Install new over fire air system 7
- 8. Considerations Use NSR Reform: • Actual-to-projected actual calculations For this discussion assume: • Historic decrease in coal use • Only five years of historic data available • No baseline adjustments required • Located in an attainment area • Able to avoid PSD for all pollutants • Focus on SO2 only 8
- 9. SO2 Applicability Analysis Potential to emit (PTE) rate = 500 TPY (no change) Baseline period selected is 2003/2004 Baseline actual emission (BAE) rate = 300 TPY Projected actual emission (PAE) rate = 325 TPY • PAE – BAE = 25 TPY (< 40 TPY PSD significance threshold for SO2) 9
- 10. SO2 Baseline/Future Baseline and Projected Future Actual SO2 Emissions 2003-2018 500 Potential to Emit 450 Project Occurs 2008 400 Baseline + 40 TPY 350 300 Emissions (TPY) Baseline 300 TPY 250 200 150 100 50 0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014-2018 Baseline Actual Emissions YEAR Projected Actual Emissions 10
- 11. Excluded Emissions §52.21(b)(41)(ii)(c) states that in determining PAE the source shall exclude emissions following the project that the unit could have accommodated during the baseline period and that are unrelated to the project, including demand growth. 11
- 12. Excluded Emissions For example if PAE is 380 TPY: PAE – BAE = 380 – 300 = 80 TPY If boiler operated at a rate that resulted in 30 tons of SO2 during May 2004, a reasonable argument may exist that the boiler could have accommodated 360 TPY during baseline period (i.e., 30 tons/month x 12 months) Any increase in SO2 cannot be due to the project 12
- 13. Excluded Emissions Applicability analysis per §52.21(a)(2) and §52.21(b)(41)(ii)(c) definition of PAE: Excluded emissions (EE) = CHA – BAE 360 – 300 = 60 TPY Project increase = PAE – EE – BAE 380 – 60 – 300 = 20 TPY Currently a controversial topic with U.S. EPA 13
- 14. Excluded Emissions Do they matter? • In first case project increase was less than significant regardless of CHA emissions • In second case CHA made project not significant • Also if the project involved other units that emit SO2 they could affect applicability analysis and/or future reporting Note that the rule says “shall exclude” 14
- 15. Permit Language Requirement to monitor, calculate, and record annual boiler SO2 emission rate for 10 years following project due to: • Applicability approach • Increased steaming capacity • Reasonable possibility of significant increase per §52.21(r) due to 25 TPY increase not counting excluded emissions Requirement to submit report if annual emissions exceed BAE by a significant amount and differ from documented projection 15
- 16. Future Tracked Emissions 2009, 2010, 2011 annual SO2 emission rate is less than BAE + 40 TPY: • No report required In 2011 scarcity of biomass results in greater coal use and annual emissions exceed preconstruction projection 16
- 17. Future Tracked Emissions Projected Actual and Actual SO2 Emissions 2009-2012 500 Potential to Emit 450 400 Baseline Baseline + 40 TPY 300 TPY 350 300 Emissions (TPY) Projected Actual 250 Actual 200 150 100 50 0 2009 2010 2011 2012 YEAR 17
- 18. Future Tracked Emissions By 2012 increased coal use results in annual emissions exceeding both the BAE + 40 TPY and preconstruction projection: • Report required • Justification that emissions are within the scope of the project • Possibly use excludable emissions from baseline period to support 18
- 19. Other Thoughts What if in 2012 we decide to fire TDF instead of more coal? • Likely considered a modification if not allowed in permit • New applicability analysis required • Baseline may need to change • CHA emissions may be important • May not be excludable 19
- 20. More Thoughts The more complicated the project the greater the potential for confusion and non-compliance. For example say the project required wood yard upgrades and netting for PM10: • Required to track PM10 for project and could have units greater than and less than projections and not need to report • What happens if one unit included in a multi-unit project isn’t changed? • How does the next project get permitted? 20
- 21. Final Project Thoughts What happens if actual emissions exceed BAE + 40 TPY due to the project? Maybe PTE isn’t so bad… 21
- 22. PSD/NNSR for Fine Particulate (PM2.5) Several unique PSD/NNSR issues: • Difficulty quantifying emissions • PSD air quality modeling challenges • NNSR applicability and offset challenges Impacts to project viability, schedule, and design 22
- 23. Quantifying PM2.5 Emissions PSD/NNSR will require establishing emission limits with a margin of compliance Published emission factors not widely available, particularly for condensables Vendor emission factors are often lacking Test methods available but may not be appropriate in certain instances 23
- 24. PM2.5 PSD Air Quality Modeling Significant impact levels (SILs) not finalized NAAQS demonstration will be difficult: • Adding facility-wide modeled concentrations to nearby monitored concentrations • Current background concentrations are above or near the 24-hour and annual NAAQS level already 24-hour concentrations could be temporally paired in certain situations 24
- 25. PM2.5 NAAQS Considerations NAAQS Level 35 PM2.5 24-hour Concentration ( g/m3 ) 7 g/m3 available for modeling 28 Monitored Background Value 25
- 26. PM2.5 NNSR Applicability Challenges Pennsylvania specific: 10-year deminimis aggregation Projects with minor emission increases must be summed with other increases and decreases that occurred with a 10-year lookback If a project triggers NNSR requirements, the clock is “reset” with respect to aggregation 26
- 27. PM2.5 Deminimis Aggregation Example Major facility with the following historic permitting activities: • New project (2 tpy) • 2007: New storage pile (1.3 tpy) • 2005: New boiler (2.4 tpy) • 2004: Boiler uptime improvement (3.5 tpy) • 2002: New outdoor vent (0.9 tpy) Total of 10.1 tpy would need to be offset Same process applies to SO2 (40 tpy threshold) 27
- 28. PM2.5 Offset Challenges PM2.5 emission reduction credits (ERCs) are in short supply Interpollutant trading will help ERCs are to be obtained from the same nonattainment area of the project location, otherwise air quality modeling is required Significant limits on the spatial separation between the sources generating the PM2.5 ERCs and the project location 28
- 29. ERC Equivalency Demonstration Project Location ERC Location 29
- 30. Finding PM2.5 ERCs Direct PM2.5 ERCs are selling in PA for between $3,000 – $10,000 per ton with very limited sales of ERCs from which to judge Determine the amount of ERCs needed early in their planning process Begin looking for available ERCs as soon as possible Internal reductions of PM2.5 should be given serious consideration 30
- 31. New NAAQS Levels 1-Hour NO2 NAAQS: 100 ppb Extremely stringent for a 1-hour averaging time standard. No proposed SIL, awaiting guidance. Proposed 1-Hour SO2 NAAQS with similar issues as the NO2 NAAQS No grandfathering of PSD permit applications that have not received final approval (even with draft permits) Challenge for NAAQS demonstrations that correspond to Title V renewals 31
- 32. New NAAQS Levels Any major facility will have difficulty demonstrating compliance using facility-wide modeling Strategic approaches to permitting: Look for emission reductions where they are available (to either avoid major source permitting or to decrease modeled impacts) 32
- 33. GHG Tailoring Rule “Major Sources” of GHGs Regulated GHG pollutants PSD implications and timing U.S. EPA will begin regulating GHGs for stationary sources in January 2011 No grandfathering for permit applications that have not been issued Addressing GHGs in construction permit emissions inventories and control technology requirements (BACT, etc.) 33
- 34. Conclusions NSR applicability process is still evolving Implications of new NAAQS are immediate and far reaching GHGs can’t be ignored Environmental considerations will impact planning and design Pay attention to these issues and try not to be surprised 34
- 35. Questions? John and Colin All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x14 and x20 www.all4inc.com jegan@all4inc.com cmccall@all4inc.com 35
Editor's Notes
- #14: Example from U.S. EPA about CHA