Prevention of Significant Deterioration (PSD) Program
description
Transcript of Prevention of Significant Deterioration (PSD) Program
Part of NSR Program Applicable to Major Sources in Areas Attaining
the NAAQS
Prevention of Significant Deterioration (PSD) Program
Presentation Outline
•Re-cap of Permitting Process
•Description of PSD Program Requirements
•Main Requirements Summary
3Permitting Process Simplified
Start
Source not
subject toNSR
Source owner submits permit
application
Reviewing authority reviews:• Application
• Proposed/Required Control Technologies
• Compliance with other applicable requirements
Draft permit
developed
Final permitIssued
End
EPA issued permits may be appealed through EPA’s Environmental Appeals
Board (EAB). After EAB process, permits may be appealed in Federal Court.
APPL
ICAB
ILIT
YAP
PLIC
ATIO
NAP
PEAL
S
Are the source proposed emissions ≥
applicable thresholds or emission rates? (per
pollutant, may include fugitives)
Is the
permit for a new source or a
modification to an existing
source?
Is source in an area
that is attaining or nonattaining the
NAAQS?No
Yes
30 day comment
period
Public hearing
Usually appealed within
30 days of finalpermit decision
After appeal processends, permit is
finally approved orrevoked.
Is thesource
exempted?
4
• New sources locating in attainment areas with air emissions equal to or higher than 100 or 250 tons per year (tpy), higher thresholds for Greenhouse Gases (GHGs)
• Modifications to existing sources in attainment areas with a net emissions increase higher than the Significant Emissions Rate
• Regulated pollutants: NAAQS, GHGs and other pollutants– NAAQS: Carbon Monoxide (CO), Lead (Pb), Nitrogen Dioxide (NO2), Ozone,
Particulate Matter (PM), and Sulfur Dioxide (SO2)– Greenhouse Gases: Carbon dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O),
Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulfur Hexafluoride (SF6)– Other Pollutants Include: Sulfuric Acid Mist (H2SO4), Hydrogen Sulfide (H2S)
– Excludes Air Toxics: Mercury (Hg), Cadmium (Cd), Benzene (C6H6), etc.
Applicability: New and Modified Sources
Applicability: Thresholds Attainment Areas
Regulated NSR Pollutant Major Source Threshold (tpy)
Carbon Monoxide (CO)
100 or 250
Sulfur Dioxide (SO2)
Ozone - Oxides of Nitrogen (NOx)
Ozone - Volatile Organic Compounds (VOC)PMPM-10PM-2.5
LeadFluoridesSulfuric Acid MistHydrogen Sulfide (H2S)
Total Reduced Sulfur (including H2S)
Reduced Sulfur Compounds (including H2S)
Municipal Waste Combustor Emissions
Municipal Solid Waste Landfills Emissions
Greenhouse Gases (Combination of gasesCO2, CH4, N2O, HFC, PFC, SF6)
Higher Thresholds
5
6
• Emissions calculations are based on Potential to Emit, includes fugitive emissions if the source is part of the 28 source category list
• It can also consider limitations on source operation and emission controls
• Thresholds: 250 tpy for most source categories, 100 tpy for 28 listed source categories (same categories for which fugitives are accounted for)– Higher thresholds for GHGs
Applicability: New Sources
Start
Determine source’s
Potential to Emit (PTE)
(per pollutant, may include
fugitives)
Is PTE ≥ applicablethreshold?
(per pollutant)
Source not
subject toPSD
Yes
No
Source subject to
PSD
7
• Emissions calculations are based on Actual Emissions – “day-to-day” emissions at the source– Actual emissions = projected emissions after the change – baseline
emissions before the change (actual-to-projected actual test)– Baseline emissions: average of any 24 consecutive months of
emissions within 10 yrs prior to project (5 yrs for electric utilities)– Projected emissions: max. annual emissions (tpy) that will occur
during any one of 5 yrs after project– If unit was unpermitted or is added, emission increase based on PTE
• Includes fugitive emissions if source is part of the 28 source category list
Applicability: Modifications
8
Applicability: Modifications (Continued)
YesStart
Are Proposed
modification emissions ≥
SER?(per pollutant)
Modification not
subject toMajor NSR
Determine Source’s NetEmissions Increase
(NEI),(per pollutant)
Is the NEI ≥ SER?
Modification is a major
modification and
subject toMajor NSR
Yes
NoNo
Major modification = one that results in (1) a significant emissions increase from the project and (2) a significant net emissions increase (NEI)• Significant Emission Rate (SER) – emissions rate limit in tpy, by pollutant• NEI = Sum of contemporaneous emissions increases and decreases to the
proposed modification emissions increase/decrease• Under PSD, contemporaneous period starts 5 years before the source commences
construction and ends when the source commences operation
9
• As with the Tribal NA NSR program, NSR applicability is determined for all new and modified units at the source– New units – applicability based on PTE– Modified units – applicability based on actual emissions
• Includes all regulated NSR pollutants that the source emits • Source emissions are calculated using:
– On-site measurement (e.g. stack testing)– Vendor design capacity or rated capacity information – Material (i.e. mass balance) balance calculations – Emission factors
• The annual maximum emissions from all production processes/equipment are added for each regulated NSR pollutant
Applicability: Steps
Applicability: PSD Thresholds for GHGs
Applicability: GHG Emissions Calculations
• The following example illustrates the method to calculate GHG emissions on both a mass basis and CO2e basis
• A proposed emissions unit emits five of the six GHG compounds in the following amounts (Global Warming Potentials for each compound included in parenthesis):– 50,000 TPY of CO2 (GWP = 1)– 60 TPY of methane (GWP = 21)– 1 TPY of nitrous oxide (GWP = 310)– 5 TPY of HFC-32 (a hydrofluorocarbon) (GWP = 650)– 3 TPY of PFC-14 (a perfluorocarbon) (GWP = 6,500)
• GHGs mass-based emissions:– 50,000 TPY + 60 TPY + 1 TPY + 5 TPY + 3TPY = 50,069 TPY
• CO2e-based emissions:– (50,000 TPY x 1) + (60 TPY x 21) + (1 TPY x 310) + (5 TPY x 650) + (3 TPY x 6,500) =
50,000 + 1,260 + 310 + 3,250 + 19,500 = 74,320 TPY CO2e
12
• Concept known as “Major for One Major for All”• Mainly Applicable to New Sources
Applicability: Other Circumstances New Source or Modified Source Might be Subject to PSD
Start
Determine PTE of other
pollutants thatare below
thresholds (per pollutant)
Is PTE ≥ applicableSER?
(per pollutant)
Pollutantnot
subject toPSD
Yes
No
Source ismajor for
PSDfor one
pollutant
Pollutantsubject to
PSD
13
• PTE less than thresholds• Source is
“grandfathered”• Source opted for
“synthetic minor” permit
Applicability: New or Modified Source not Subject to PSD
Potential to Emit (PTE)
Actual0
50
100
150
200
250
300
350
Synthetic Minor Source Emissions
Type of Emissions
Emiss
ions
(tpy
)
Major Source Threshold
14Permitting Process Simplified
Start
Source not
subject toNSR
Source owner submits permit
application
Reviewing authority reviews:• Application
• Proposed/Required Control Technologies
• Compliance with other applicable requirements
Draft permit
developed
Final permitIssued
End
EPA issued permits may be appealed through EPA’s Environmental Appeals
Board (EAB). After EAB process, permits may be appealed in Federal Court.
APPL
ICAB
ILIT
YAP
PLIC
ATIO
NAP
PEAL
S
Are the source proposed emissions ≥
applicable thresholds or emission rates? (per
pollutant, may include fugitives)
Is the
permit for a new source or a
modification to an existing
source?
Is source in an area
that is attaining or nonattaining the
NAAQS?No
Yes
30 day comment
period
Public hearing
Usually appealed within
30 days of finalpermit decision
After appeal processends, permit is
finally approved orrevoked.
Is thesource
exempted?
15
• Main requirements:1. Install Best Available Control Technology (BACT)2. Perform air quality analysis to assess impacts on air quality3. Perform class I area analysis to assess impacts on national
parks and wilderness areas 4. Perform additional impacts analysis5. Allow for opportunities for public involvement
Application: PSD Program Requirements
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• Pollutant specific emissions limit, case-by-case– Takes into account energy, environmental, or economic impacts
• Limit must be at least as stringent as applicable:– New Source Performance Standard (NSPS) and/or – National Emission Standard for Hazardous Air Pollutants (NESHAP)
• Selected by “Top Down” BACT analysis1. Identify all available control technologies2. Eliminate technically infeasible control options3. Rank remaining control technologies by its effectiveness (considers economic,
energy and environmental impacts)4. Evaluate most effective controls and document results5. Select BACT
Application: Best Achievable Control Technology (BACT)
17
• Pollutant specific analysis that involves: – An assessment of existing air quality and – Modeling estimate of ambient concentrations from
proposed project and future growth associated with project
• Purpose is to determine if new plus existing emissions will cause or contribute to a violation of a:– NAAQS and/or – PSD increment
Application: Air Quality Impact Analysis (AQIA)
18
• A new source or modification cannot cause or contribute to significant deterioration of air quality in attainment areas
• Maximum amount of deterioration allowed is called an increment
• Increments exist for:– 3 pollutants (PM--PM10 and PM2.5, SO2 and NO2)– Various averaging periods (annual, 1-hour)– 3 area classifications (Class I, Class II, Class III)
Application: AQIA for Increment Compliance
PM2.5 Increments by Area Classification (g/m3) NAAQS (g/m3) Averaging Period Class I Class II Class III
Annual 1 4 8 1524-hr 2 9 18 35
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Application: AQIA for Increment Compliance (Continued)
• Change in air quality measured against a certain baseline
• Not all sources consume increment
• Two important concepts apply: – Baseline area• All portions of the attainment area in which the PSD applicant proposes
to locate and/or would have a significant ambient impact (i.e. higher than Significant Impact Level)
• Limited to intrastate areas: baseline areas not triggered across state lines
– Baseline date• When increment consumption starts, pollutant specific
20
• Baseline Date(s) - when increment consumption starts, pollutant specific
Application: AQIA for Increment Compliance (Continued)
Major Source Baseline Date
Minor Source Baseline Date
SO2 and PM - Jan. 6, 1975 NOx - Feb. 8, 1988
Date of first complete permit application
when actual emission changes from all sources affect the available increment
when actual emissions associated with construction at a major source affect increment
Start
21
• A new source or modification cannot cause or contribute to a violation of any NAAQS in any area
• Compliance with any NAAQS is based on proposed source and all other sources in baseline area– No baseline dates exist– Analysis requirements similar to increment analysis
• NAAQS analysis independent from increment analysis
Application: AQIA for NAAQS Compliance
22
• Compliance determined by using air quality models
• Preliminary analysis (significant impact analysis)– Screening type models– Representative meteorology– Only proposed source emissions – Refined receptor grids
• Full impact analysis (cumulative impact analysis)– Refined model– Representative meteorology– All applicable increment affecting sources– More refined receptor grids (smaller grid spacing)
Application: AQIA Steps
23
• Evaluation of NAAQS, PSD increments and Air Quality Related Values (AQRVs) when a major source’s emissions may affect a Class I area– Class I Area – areas reserved for special air quality protection, usually
national parks and wilderness areas– AQRVs – feature or property of a Class I Area that may be affected by a
change in air quality; differ for each Class I area
• Generally for sources within 100 km of Class I area, not always
• Federal Land Manager (FLM) must be notified of potential impacts– Determines data and analyses needed
Application: Class I Area Impact Analysis
24
• Assesses potential effects of increased air, ground and water pollution from proposed source and associated growth on:– Soils and Vegetation– Visibility
• Pollutant specific
• Performed within the impact area of the proposed source
Application: Additional Impact Analysis
25
• Reviewing authority is required to provide:– Public notice to the affected community and the general public on the
draft permit– At least a 30 day public comment period on the draft permit– Opportunity for public hearing on draft permit, if requested by public
• All public comments must be considered before a final permit is developed
• A Technical Support Document (TSD), generally including responses to comments, may also be available with the final permit
Application: Public Involvement
26Permitting Process Simplified
Start
Source not
subject toNSR
Source owner submits permit
application
Reviewing authority reviews:• Application
• Proposed/Required Control Technologies
• Compliance with other applicable requirements
Draft permit
developed
Final permitIssued
End
EPA issued permits may be appealed through EPA’s Environmental Appeals
Board (EAB). After EAB process, permits may be appealed in Federal Court.
APPL
ICAB
ILIT
YAP
PLIC
ATIO
NAP
PEAL
S
Are the source proposed emissions ≥
applicable thresholds or emission rates? (per
pollutant, may include fugitives)
Is the
permit for a new source or a
modification to an existing
source?
Is source in an area
that is attaining or nonattaining the
NAAQS?No
Yes
30 day comment
period
Public hearing
Usually appealed within
30 days of finalpermit decision
After appeal processends, permit is
finally approved orrevoked.
Is thesource
exempted?
27
• Provisions for permit appeals available under the program, same as Tribal NA NSR and minor NSR program
• Appeals are conducted through the EPA’s Environmental Appeals Board (EAB)
• If all remedies for permit appeal through the EAB are exhausted, person may appeal to Federal Court
Appeals
28
• Program for major sources located in attainment areas (generally for emissions at or higher than 100 or 250 tpy)
• Pollutants regulated: NAAQS, GHGs, other pollutants
• Main requirement: Best Available Control Technology (BACT)
• Permits are usually issued no later than 1 year after the date the permit application is deemed complete
Key Points to Remember: PSD
Appendix
28 PSD Source Categories
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28 source categories1. Coal cleaning plants (with thermal dryers) 15. Coke oven batteries
2. Kraft pulp mills 16. Sulfur recovery plants
3. Portland cement plants 17. Carbon black plants (furnace process)
4. Primary zinc smelters 18. Primary lead smelters
5. Iron and steel mills 19. Fuel conversion plants
6. Primary aluminum ore reduction plants 20. Sintering plants
7. Primary copper smelters 21. Secondary metal production plants
8. Municipal incinerators capable of charging more than 250 tons of refuse per day
22. Chemical process plants
9. Hydrofluoric acid plants 23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels
10. Sulfuric acid plants 24. Taconite ore processing plants
11. Nitric acid plants 25. Glass fiber processing plants
12. Petroleum refineries 26. Charcoal production plants
13. Lime plants 27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU)/hour heat input
14. Phosphate rock processing plants 28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input
Significant Emission Rates (SERs)
31
Pollutant SER (tpy) Pollutant SER (tpy)Carbon Monoxide 100 Sulfuric Acid Mist 7
Nitrogen Oxides 40 Hydrogen Sulfide (H2S) 10
Sulfur Dioxide 40 Total Reduced Sulfur (Includes H2S) 10
Particulate Matter (PM10) 15 Reduced Sulfur Compounds (Includes H2S) 10
Particulate Matter (PM2.5) 10; 40 for VOCs, NOx or SO2
Municipal Waste Combustor Organics 3.5*10-6
Ozone 40 VOCs or NOx Municipal Waste Combustor Metals 15
Lead 0.6 Municipal Waste Combustor for Acid Gases
40
Fluorides 3 Municipal Solid Waste Landfills Emissions 50
SER – a rate of emissions that would equal or exceed any of the following rates:
Notwithstanding the above, any emissions rate or any net emissions increase associated with a major stationary source or major modification, which could construct within 10 km of a Class I area, and have an
impact on such area equal to or greater than 1 g/m3 (24-hour average)