Major Sources Pollutant Federal NSR 112(g) Major Major ROP Major PSD Major Offset Attainment...

Major SourcesMajor Sources

PollutantPollutantFederal NSRFederal NSR

112(g) 112(g) MajorMajor

Major Major ROPROP

Major Major PSDPSD

Major Major OffsetOffset

Attainment Attainment PollutantsPollutants

250 or 250 or 100100

NANA NANA 100100

Non-Attainment Non-Attainment PollutantsPollutants

NANA 100100 NANA 100100

Individual HAPsIndividual HAPs NANA NANA 1010 1010

Aggregate HAPsAggregate HAPs NANA NANA 2525 2525

Insert After -6Insert After Page 1-6

New

Existing

Minor

Major

No PSDNo PSD

But may be subject to But may be subject to minor source permittingminor source permitting

PSD for PSD for modifications that result in modifications that result in

a significant emissions a significant emissions increase increase andand a significant a significant

net emissions increasenet emissions increase

Modifications that Modifications that by by themselvesthemselves exceed exceed the Major Source the Major Source

thresholdthreshold

PSD for each pollutant PSD for each pollutant emitted at greater than the emitted at greater than the

Major Source threshold Major Source threshold and each additional and each additional

pollutant emitted at greater pollutant emitted at greater than its significant than its significant

emissions thresholdemissions threshold

II

IIII

IIIIII

IVIV

PSD Applicability MatrixPSD Applicability Matrix

Insert After -4Insert After Page 2-4

New

Existing

Minor

Major

PSD Applicability MatrixPSD Applicability Matrix

Applicability Applicability determination is based determination is based

on the potential on the potential emissions from the emissions from the

new equipmentnew equipment


on the potential on the potential emissions from the emissions from the



on the potential on the potential emissions increase emissions increase resulting from the resulting from the

modificationmodification


on the emissions on the emissions increase above increase above baseline actual baseline actual

emissionsemissions


on the on the potential potential emissionsemissions from the from the



on the on the potential potential emissionsemissions from the from the



on the on the potential potential emissionsemissions increase increase resulting from the resulting from the

modificationmodification

Insert After Page 2-4Insert After Page 2-4

ApplicabilityApplicabilityNew FacilityNew Facility

60 TPY 60 TPY VOCVOC

600 TPY 600 TPY COCO

350 TPY 350 TPY NONOXX

New FacilityNew Facility

Existing FacilityExisting Facility

Existing FacilityExisting Facility

110 TPY 110 TPY COCO

60 TPY 60 TPY PM10PM10

275 TPY 275 TPY PM10PM10

Minor SourceMinor Source

Major SourceMajor Source

Minor Source Minor Source + Major Source+ Major Source

Major Source Major Source + Sign. Source+ Sign. Source


PSD Applicability MatrixPSD Applicability MatrixQuadrants III and IV – Existing SourcesQuadrants III and IV – Existing Sources

We Must Decide:We Must Decide:

1.1. If the proposed change is a modificationIf the proposed change is a modification

AndAnd

2.2. What is the magnitude of the emissions What is the magnitude of the emissions

increase from the modificationincrease from the modification


What’s a Modification?What’s a Modification?A more complete definitionA more complete definition

• Any physical change in;Any physical change in;• Or change in the method of operation of;Or change in the method of operation of;• An existing major (Q4) source that;An existing major (Q4) source that;• Would result in a significant emissions increase; Would result in a significant emissions increase;

andand• A significant net emissions increase.A significant net emissions increase.

ExcludingExcluding: : • Routine maintenance, repair, and replacement; Routine maintenance, repair, and replacement; • Use of alternative fuels (under certain Use of alternative fuels (under certain

circumstances); circumstances); • Changes of ownership; Changes of ownership; • The addition or replacement of a pollution control The addition or replacement of a pollution control

project;project;• Increases in operating hours or production rate, Increases in operating hours or production rate,

unless either are prohibited by permit conditionunless either are prohibited by permit conditionInsert After Page 2-4Insert After Page 2-4

Quadrants I - IIIQuadrants I - IIIPotential Emissions IncreasesPotential Emissions Increases

Potential emissions Potential emissions BEFORE the modification.BEFORE the modification.

Potential emissions AFTER Potential emissions AFTER the modification.the modification.

Q1 SourcesQ1 Sources

249 TPY After249 TPY After- - 0 TPY Before 0 TPY Before== 249 TPY Increase249 TPY Increase


275 TPY After275 TPY After- - 0 TPY Before 0 TPY Before== 275 TPY Increase275 TPY Increase


498 TPY After498 TPY After- - 249 TPY Before249 TPY Before== 249 TPY Increase249 TPY Increase

No PSDNo PSD

No PSDNo PSD

PSDPSD


Actual to Potential TestActual to Potential Test

The post-change The post-change POTENTIALPOTENTIAL emissions are emissions are compared with compared with the Baseline the Baseline ACTUAL ACTUAL EmissionsEmissions

ACTUAL

POTENTIAL


350 - 270 = 80 TPY > 40 TPY Major350 - 270 = 80 TPY > 40 TPY Major

288 - 270 = 18 TPY < 40 TPY Minor288 - 270 = 18 TPY < 40 TPY Minor

Company A submits an application to modify one of its boilers. Company A submits an application to modify one of its boilers. Company A is an existing major stationary source (Q4) of NOCompany A is an existing major stationary source (Q4) of NOXX. The . The

modification will increase potential NOmodification will increase potential NOXX emissions from 75 lb/hr to 80 emissions from 75 lb/hr to 80

lb/hr. The boilers have consistently operated 7200 hr/yr, but are lb/hr. The boilers have consistently operated 7200 hr/yr, but are permitted to operate 8760 hr/yr (allowed 329 TPY). Using the Actual to permitted to operate 8760 hr/yr (allowed 329 TPY). Using the Actual to Projected Actual Test, is this change subject to PSD?Projected Actual Test, is this change subject to PSD?

ExampleExample

Baseline:Baseline: 75 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 270 TPY75 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 270 TPY

Potential:Potential: 80 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 350 TPY80 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 350 TPY

Projected:Projected: 80 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 288 TPY80 lb/hr x 7200 hr/yr x 1 ton/2000 lb = 288 TPY


ExampleExampleInstead of remaining constant, boiler utilization will continue its Instead of remaining constant, boiler utilization will continue its historical trend of 2% growth per year from 7200 hr/yr. historical trend of 2% growth per year from 7200 hr/yr.

270270270270288288

294294300300

306306312312

318318324324

331331337337

344344

What emissions could the boiler accommodate prior to the change?What emissions could the boiler accommodate prior to the change?

323323

270270275275

281281287287

292292298298 304304

310310316316

11 22 33 44 55 66 77 88 99 1010

75 lb/hr x Projected Utilization (hr/yr)75 lb/hr x Projected Utilization (hr/yr)

Are these emissions independent of the change to 80 lb/hr?Are these emissions independent of the change to 80 lb/hr?Would they have happened anyway?Would they have happened anyway?

7474

Insert Insert After After

Page 4-5Page 4-5

QuestionQuestionSince the boiler was already permitted at 329 Since the boiler was already permitted at 329 TPY, why isn’t the level of excluded emissions TPY, why isn’t the level of excluded emissions equal to 329 TPY? equal to 329 TPY?

270270270270288288

294294300300

306306312312

318318324324

331331337337

344344

323323

270270275275

281281287287

292292298298 304304

310310316316

11 22 33 44 55 66 77 88 99 1010

2121

Because, at the level of projected business activity, the boiler could Because, at the level of projected business activity, the boiler could only have accommodated 323 TPY of emissions, otherwise it would only have accommodated 323 TPY of emissions, otherwise it would

have violated its permit.have violated its permit.

Insert Insert After After

Page 4-5Page 4-5

NettingNetting

For modifications at existing major sources For modifications at existing major sources (Q4), there are two parts to PSD (Q4), there are two parts to PSD

applicability…applicability………determining if determining if

a significant a significant emissions emissions

increase will increase will occuroccur

……determining if determining if a significant a significant netnet emissions emissions increase will increase will occuroccur

Emissions Emissions change from the change from the

projectproject

Emissions Emissions change from the change from the

facilityfacilityInsert After Page 3-6Insert After Page 3-6

In A NutshellIn A Nutshell

Each Emission Unit Each Emission Unit pays for admission pays for admission only once…only once…

……as long as it as long as it complies with the complies with the

terms of its terms of its admissionadmissionThe price of The price of

admission is admission is installing BACT installing BACT controlscontrols

The terms of The terms of admission are the admission are the

permit limits needed permit limits needed to ensure BACTto ensure BACTInsert Before Page 5-Insert Before Page 5-

11

Add-on control devicesAdd-on control devices

Pollution prevention activitiesPollution prevention activities

Work practice standardsWork practice standards

What Are Qualifying What Are Qualifying Controls?Controls?

A monetary investment in theA monetary investment in the

controls is necessary!controls is necessary!

The investment must qualify as a capital The investment must qualify as a capital expense under the IRS filing guidelinesexpense under the IRS filing guidelines

Insert Before Page 5-1Insert Before Page 5-1

How Do I Get In On This?How Do I Get In On This?

Use the Front Door…Use the Front Door…New EUs that install New EUs that install qualifying BACT controls qualifying BACT controls through PSD through PSD automaticallyautomatically get in get in

……Use the Back Door…Use the Back Door…EUs that installed EUs that installed qualifying BACT controls qualifying BACT controls through PSD in past 10 years through PSD in past 10 years automaticallyautomatically get in get in

… … Or Climb in Through the WindowOr Climb in Through the WindowEUs with comparable, or “substantially as EUs with comparable, or “substantially as effective” control technology effective” control technology maymay get in (with a get in (with a demonstration)demonstration)


What Should I Expect?What Should I Expect?

Monitoring, recordkeeping and Monitoring, recordkeeping and reporting requirements reporting requirements adequate to allow on-going adequate to allow on-going demonstration of compliance demonstration of compliance

Emission limits based on, or equal to, BACTEmission limits based on, or equal to, BACT

Permit limits on other terms such as operating Permit limits on other terms such as operating parameters, on which the BACT and CU parameters, on which the BACT and CU determinations were baseddeterminations were based

Permit limits specifying the start and end dates for Permit limits specifying the start and end dates for the CU designationthe CU designation


What to ExpectWhat to Expect

The limit will be a rolling 12-month The limit will be a rolling 12-month total – effective for 10 yearstotal – effective for 10 years

Emissions from all sources of the Emissions from all sources of the PAL pollutant must be monitored, PAL pollutant must be monitored, or a default value usedor a default value used

Records must be kept for life of Records must be kept for life of the PAL plus 5 yearsthe PAL plus 5 years

Semi-annual deviation reports requiredSemi-annual deviation reports required

Annual compliance certification requiredAnnual compliance certification required


What to ExpectWhat to Expect

The new PTI containing the PAL The new PTI containing the PAL conditions must go through the conditions must go through the public noticing requirementspublic noticing requirements

PAL conditions will be rolled into PAL conditions will be rolled into the ROP at its next opportunitythe ROP at its next opportunity


Can the PAL Level Be Can the PAL Level Be Changed?Changed?

Appropriate level Appropriate level based on:based on:

Air Quality NeedsAir Quality Needs

Advances in Control Advances in Control TechnologyTechnology

Anticipated Anticipated Economic Growth in Economic Growth in

the Areathe Area

To Reward or To Reward or Encourage Encourage

Voluntary Emission Voluntary Emission Reductions, etc…Reductions, etc…

At RenewalAt Renewal

Ten steps to Ten steps to determine if an determine if an

increase is increase is allowable.allowable.

Turn to Turn to

Page 6-3Page 6-3

IncreasesIncreases

To correct typos or To correct typos or other errorsother errors

To accommodate the To accommodate the generation of ERCs generation of ERCs

or Offsetsor Offsets

To reflect the impact To reflect the impact of new State or of new State or

federal regulationsfederal regulations

To maintain air To maintain air qualityquality

DecreasesDecreases


How Do I Get Out of the How Do I Get Out of the PAL?PAL?

Divide the PAL tonnage among all Divide the PAL tonnage among all the emission units at the facility the emission units at the facility

These allocations will become the These allocations will become the new permit limits for each new permit limits for each

emission unitemission unit


Am I in?Am I in?A PSD Applicability Summary…A PSD Applicability Summary…

MethodMethod RecordsRecords CalcsCalcs ControlsControls New New EUsEUs

Emission Emission TestsTests

A2PA2P NoNo YesYes NoNo YesYes

A2AA2A YesYes YesYes NoNo NoNo

Alternate Alternate TestsTests

Clean Clean UnitUnit NoNo NoNo YesYes NoNo

PALPAL YesYes NoNo NoNo YesYes

PCPPCP NoNo MaybeMaybe YesYes NoNo


Step 2: Eliminate TechnicallyStep 2: Eliminate TechnicallyInfeasible OptionsInfeasible Options

UNUSUAL CHARACTERISTICSUNUSUAL CHARACTERISTICS

Catalyst Blinding AgentsCatalyst Blinding Agents

Halogenated VOCs and Oxidizers Halogenated VOCs and Oxidizers

Sticky PM and BaghousesSticky PM and Baghouses

Cool Exhaust Temperatures and SCRCool Exhaust Temperatures and SCR


Step 2: Eliminate TechnicallyStep 2: Eliminate TechnicallyInfeasible OptionsInfeasible Options

Nobody Else In Our Industry Has Used ItNobody Else In Our Industry Has Used It

There’s Not Enough Room For The DuctworkThere’s Not Enough Room For The Ductwork

The Roof Won’t Support ItThe Roof Won’t Support It

Consumes a Limited Natural Resource (Natural Consumes a Limited Natural Resource (Natural Gas)Gas)

Will Require Its Own Electrical SubstationWill Require Its Own Electrical Substation

Our Building Contains an Explosive Our Building Contains an Explosive AtmosphereAtmosphere

UNUSUAL CHARACTERISTICSUNUSUAL CHARACTERISTICS

REJECTED

REJECTED


These usually end up in the These usually end up in the Economic AnalysisEconomic Analysis

Step 4: EvaluationsStep 4: EvaluationsEnergy Impact AnalysisEnergy Impact Analysis

Only Unusual Energy Impacts Only Unusual Energy Impacts Should Be ConsideredShould Be Considered


Step 4: EvaluationsStep 4: EvaluationsEnvironmental Impact AnalysisEnvironmental Impact Analysis

This is not NAAQS and IncrementsThis is not NAAQS and Increments

Solid/HazardousSolid/HazardousWaste GenerationWaste Generation

Water DischargesWater DischargesVisibility ImpactsVisibility Impacts

Need to show Need to show unusual/unreasonable impacts unusual/unreasonable impacts

compared to other facilities compared to other facilities where this control option has where this control option has

been usedbeen used


Step 4: EvaluationsStep 4: EvaluationsEconomic Impact AnalysisEconomic Impact Analysis

How can control costs be determined so that How can control costs be determined so that they can be compared among different they can be compared among different

facilities and for different control options?facilities and for different control options?

Dollars per Dollars per Ton of Ton of

Pollutant Pollutant ControlledControlled

Allows comparisons Allows comparisons among companiesamong companies

of different sizesof different sizes

Allows comparisons Allows comparisons among different among different types of companiestypes of companies



Dollars per Ton of Pollutant ControlledDollars per Ton of Pollutant Controlled

1.1. Calculate the Annualized Cost Calculate the Annualized Cost for the control optionfor the control option

2.2. Calculate the Annual Emissions, Calculate the Annual Emissions, in tons that will be reduced by in tons that will be reduced by the control optionthe control option



• Total Capital Investment annualized Total Capital Investment annualized over 10 years at 7% interestover 10 years at 7% interest

• Annual Labor Costs (oper/maint/supv)Annual Labor Costs (oper/maint/supv)

• Annual Energy Costs (fuel/electrical)Annual Energy Costs (fuel/electrical)

• Annual Overhead Costs Annual Overhead Costs (taxes/insurance)(taxes/insurance)

Annualized CostAnnualized Cost



ExampleExample

Assume Recent BACT determinations = $5000 - Assume Recent BACT determinations = $5000 - $6000/ton$6000/ton

Control Option No. 1Control Option No. 1 Control Option No. 2Control Option No. 2

Reduces 142 TPY (EU A & B)Reduces 142 TPY (EU A & B)

TCI = $4,500,000TCI = $4,500,000

10 years @ 7% = $635,400/yr10 years @ 7% = $635,400/yr

Labor = $4000/yrLabor = $4000/yr

Energy/Util = $123,000Energy/Util = $123,000

Overhead = $75,400Overhead = $75,400

Reduces 130 TPY (EU A only)Reduces 130 TPY (EU A only)

TCI = $3,100,000TCI = $3,100,000

10 years @ 7% = $437,720/yr10 years @ 7% = $437,720/yr

Labor = $4500/yrLabor = $4500/yr

Energy/Util = $151,000Energy/Util = $151,000

Overhead = $56,780Overhead = $56,780

Control Cost = Control Cost = $837,800/yr$837,800/yr

$5900/ton for 142 tons$5900/ton for 142 tons





ExampleExample

Assume Recent BACT determinations = $5000 - Assume Recent BACT determinations = $5000 - $6000/ton$6000/ton

Control Option No. 1Control Option No. 1 Control Option No. 2Control Option No. 2




$5000/ton for 130 tons$5000/ton for 130 tonsIncremental CostIncremental Cost

$837,800 - $650,000 = $187,800$837,800 - $650,000 = $187,800

142 tons – 130 tons = 12 tons142 tons – 130 tons = 12 tons

$187,800 / 12 tons = $15,650/ton$187,800 / 12 tons = $15,650/ton


ModelingModeling

WHO? -WHO? - All PSD ApplicantsAll PSD Applicants

WHAT? – All New EmissionsWHAT? – All New Emissions

WHY? –WHY? – To Show They Don’t To Show They Don’t Cause or Contribute to A Cause or Contribute to A Violation of Any NAAQS Violation of Any NAAQS or PSD Incrementor PSD Increment


Modeling for PSD IncrementsModeling for PSD Increments

Triggering Dates Triggering Dates (See MDEQ Website)(See MDEQ Website)

Increment Consuming SourcesIncrement Consuming Sources

Increment Expanding SourcesIncrement Expanding Sources

80% Consumption Allowed80% Consumption Allowed


Only for SOOnly for SO22, NO, NOXX and PM10 and PM10

• Emissions from All Sources Emissions from All Sources having a significant impacthaving a significant impact

• Measured BackgroundMeasured Background

• Source Inventories and Source Inventories and Background Concentrations Background Concentrations Available from MDEQAvailable from MDEQ


Modeling for NAAQSModeling for NAAQS

What Affects Modeling?What Affects Modeling?

Stack HeightStack Height

Building HeightBuilding Height

Terrain HeightTerrain Height

Exhaust Flow Rate (CFM)Exhaust Flow Rate (CFM)

Exhaust TemperatureExhaust Temperature

Stack Exit DiameterStack Exit Diameter


Another View of DispersionAnother View of Dispersion


Building Downwash Building Downwash


Major Sources Pollutant Federal NSR 112(g) Major Major ROP Major PSD Major Offset Attainment...

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