Prevention of Significant Deterioration (PSD)/Nonattainment ...

Prevention of Significant Deterioration (PSD)/Nonattainment ...

PSD/NONATTAINMENT APPLICABILITY EXAMPLES Xuan Zhao, Ph.D. Air Permits Division TCEQ Autumn Environmental Conference and Expo 2018 OVERVIEW Federal Applicability Concepts Terminologie s Test Examples Additional information can be found in the speaker notes.

BASIS Legislative Clean Air Act: Title 1 Part C: (PSD) Part D: (NNSR) Texas Health and Safety Code: Chapter 382: Texas Clean Air ACT BASIS Regulatory Code of Federal Regulations 40 CFR 51.165 (NNSR) 40 CFR 52.21 (PSD) Texas Administrative Code 30 TAC 116.150, 151 (NNSR) 30 TAC 116.160-163 (PSD) CONCEPTS PSD OR NNSR Pollutant Specific NNSR: criteria pollutants PSD: regulated pollutants Area Specific: Design Value vs. NAAQS Attainment: below NAAQS

Nonattainment: at/over NAAQS Additional information can be found in the speaker notes. Bexar County City of El Paso Dallas/Fort Worth (DFW): Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties Portions of: Titus County Panola County Rusk County Anderson County Freestone County CURRENT NONATTAINMENT AREAS IN TEXAS Houston/Galveston/Brazoria (HGB): Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty,

Montgomery, and Waller Counties APPLICABILITY LOGIC Pollutant Attainment or nonattainment Greenfield/ Existing Minor Source If PI < MS If PI MS No Federal Review Federal Review Additional information can be found in the speaker notes.

Existing Major Source If PI < MM If PI MM Netting If NI < Significant No Federal Review If NI Significant No Federal Review Federal Review TERM MAJOR SOURCE

Greenfield: an undeveloped site Source: A point of origin of air contaminants Major Source (MS): Any stationary source that emits, or has the potential to emit, a threshold quantity of emissions or more of air contaminants Site wide PTE of the target pollutant MS threshold of the target pollutant Additional information can be found in the speaker notes. TERM MODIFICATIONS Modifications Add new facilities Physical change Change in method of operation Increase efficiency

Debottlene ck Exceptions in [30 TAC 116.12(20)(B)] o Routine maintenance, repair, and replacement Additional information can be found in the speaker notes. TERM MAJOR MODIFICATIONS Major Modifications (MM) Causes significant project emissions increase and a significant net emission increase At existing minor source, the increase itself Major Source At existing major source, the increase Significant Additional information can be found in the speaker notes. PSD MS THRESHOLDS Major Source

250 tpy 100 tpy Regulated Source Category Pollutant All Un-Named All Named [40 CFR 52.21(b)(l)(i)] PSD MM THRESHOLDS (NOT INCLUSIVE) Major Modification 100 tpy 40 tpy 25 tpy 15 tpy 10 tpy 0.6 tpy 10 tpy

* GHGs only trigger PSD review if 7 tpy at least one other federally 3 tpy regulated pollutant triggers PSD 75,000 tpy review anyway. Regulated Pollutant CO VOC, NOx, or SO2 PM PM10 Direct PM2.5 Pb TRS (includes H2S) H2SO4 Fluoride (excludes HF) Greenhouse Gases* (CO2e) NNSR OZONE Major Major Netting Texas Area Classification Source Modification Threshold 11/28/2016

Extreme 10 tpy 10 tpy -- N/A Severe 25 tpy 25 tpy 5 tpy HGB (VOC & NOx) Serious 50 tpy 25 tpy

5 tpy DFW (VOC & NOx) Moderate 100 tpy 40 tpy 40 tpy N/A Marginal 100 tpy 40 tpy 40 tpy N/A NNSR-OZONE (CONT.) Major Major Netting Classification

Texas Area Source Modification Threshold Extreme 10 tpy 10 tpy -- N/A Severe 25 tpy 25 tpy 5 tpy N/A Serious 50 tpy

25 tpy 5 tpy N/A 40 tpy HGB, DFW (VOC & NOx) pending 40 tpy Bexar County, as of 9/24/2018 Moderate Marginal 100 tpy 40 tpy 100 tpy 40 tpy DISTINCT

APPLICABILITY LOGIC Pollutant Attainment or nonattainment Additional information can be found in the speaker notes. Greenfield/ Existing Minor Source If PI < MS Existing Major Source If PI MS If PI < DeMinimis No Federal Review

Federal Review If PI DeMinimis Netting If NI < Significant No Federal Review If NI Significant No Federal Review Federal Review NNSR OTHER POLLUTANTS IN TEXAS Pollutant Classification PM10

Moderate Pb nonattainment SO2 MS MM Netting Threshold 100 tpy 15 tpy 15 tpy Texas Area City of El Paso 100 tpy 0.6 0.6 tpy Portion of Collin Collin County, Attainment (2008County lead

tpy (Frisco, NW Dallas) standard, 9/27/2017 nonattainment 100 tpy 40 tpy 40 tpy Portions of Freestone, Anderson, Rusk, Panola, and Titus Counties APPLICABILITY LOGIC Pollutant Attainment or nonattainment Additional information can be found in the speaker notes. Greenfield/ Existing Minor Source

If PI < MS If PI MS No Federal Review Federal Review Existing Major Source If PI < MM If PI MM Netting If NI < Significant No Federal Review

If NI Significant No Federal Review Federal Review PROJECT INCREASE Includes all modified and affected facilities Affected facilities have an increase in emissions without a physical change or change in method of operation at the facility Project increase looks at increases without regard to decreases Additional information can be found in the speaker notes. PROJECT INCREASE (CONT.) For New Facility: PI = Potential to Emit (PTE) For Existing Facilities: PI = PTE (or PAE) BAE o PTE is based on design capacity o PAE is based on projection

o PAE PTE Additional information can be found in the speaker notes. BASELINE ACTUAL EMISSIONS (BAE) Any consecutive 24 months from last 10 years or 5 years for electric utilities (Energy Section) Different baseline period is allowed for different pollutants For the same pollutant, use the same 2-year within a single project 201 2008 10-year window5for selecting BAE Additional information can be found24-month in the speaker 201 201 6 7 201

8Jan 1, Application Submittal APPLICABILITY LOGIC WITH NETTING Pollutant Attainment or nonattainment Greenfield/ Existing Minor Source If PI < MS If PI MS No Federal Review Federal Review Additional information can be found in the speaker

notes. Existing Major Source If PI < MM If PI MM Netting If NI < Significant No Federal Review If NI Significant No Federal Review Federal Review

NETTING FOR EXISTING MAJOR SOURCES Start of Current Operation Ju ly, 20 13 Ju ly, 20 14 Ju ly, 20 15 Ju ly, 20 16 Ju ly,

20 17 Ju ly, 20 18 Oc to be r, 20 19 Project Project increase in contemporaneous window (TCEQ Table 2F) Identify & sum Creditable increases and decreases in the window (TCEQ Table 3F) Additional information can be found in the speaker

CREDITABLE Occurs during the contemporaneous period Cannot have been relied upon in issuing a major NSR permit for the source Rely on Emissions Inventory Additional information can be found in the speaker CREDITABLE INCREASE The new level of emissions exceeds the Baseline Actual Emission Rate Proposed PTE Baseline Actual = PI Does not include emission increases at facilities under a plant-wide applicability limit (PAL) (PAL: see 116.180) CREDITABLE DECREASE The Baseline Actual exceeds the new level of emissions Enforceable at and after the project modification begins operation (must be enforceable and real before the unit starts operation) Reductions to comply with current or new requirements (e.g., policy change, SIP) dont count INCREASE AND DECREASES

Identify increases and decreases in TCEQ Table 3F and include: The project number that authorized the change, and An explanation of those changes not included and why Each creditable decrease should be accompanied by TCEQ Table 4F Additional information can be found in the speaker NETTING INCREASES AND DECREASES For each project within the window, based on a comparison of: Baseline Actual Emission Rate and PTE of that project (cannot use projected actuals except for the current project) 2015 Project BAE 2013 2014 10 years 2015 2016

Current Project 2017 2018 2019 Start of Operation PSD AND NNSR Similarities Applicability logic Terms (PI, BAE, etc.) Existing Project Increase Major MS / MM ? Source No No No Yes Creditability criteria

Netting/calculation method Yes Yes No Yes conduct netting Federal NSR Applies? No Yes no netting allowed No Yes if net increase > MM PSD VS. NNSR Differences MS, MM, netting

thresholds MS determinations o PSD: Major source for one pollutant, major source for all pollutants o NNSR: Major source for one pollutant, not necessarily major source for other pollutants PSD VS. NNSR Differences MS, MM, netting thresholds MS determinations Creditable effects Once a project triggers federal review: o PSD: wipe the slate clean o NNSR: wipe the major project only, offsets PSD VS. NNSR Differences

MS, MM, netting thresholds MS determinations Creditable effects Level of control o PSD: Best Available Control Technology (BACT) o NNSR: Lowest Achievable Emission Rate (LAER) PSD VS. NNSR Differences o PSD: No offset requirement; MS, MM, netting thresholds o NNSR: Offset ratio is based on classification. MS determinations Classification

Extreme Severe Serious Moderate Marginal Creditable effects Level of control Offset or not Offset Ratio 1.50 to 1 1.30 to 1 1.20 to 1 1.15 to 1 1.10 to 1 EXAMPLE 1 Site A is a major named source in an attainment area. Current PTE = 200 tpy NOx; Proposed PTE = 210 tpy NOx; BAE = 190 tpy NOx.

Question: Will Site A need a federal NSR permit? NOx attainment Existing Major Source PI = PTE - BAE = 210 tpy - 190 tpy = 20 tpy MM of NOx= 40 tpy No Federal Review EXAMPLE 2 Site B is an existing named minor source of NOx in an attainment area.

NOx attainment Current PTE = 80 tpy Proposed Project 1: PI1 = 120 (PTE1) 60 (BAE1) = 60 tpy Question 1: Will Site A need a federal NSR permit? Existing Minor Source PI = 60 tpy MS = 100 tpy No Federal Review EXAMPLE 2 (CONT.) Site B is an existing named minor source of NOx in an attainment area.

NOx attainment PTE = 80 tpy Proposed Project 1: PI1 = 120 (PTE1) 60 (BAE1) = 60 tpy Question 2: Three years later, PI2 = 60 tpy. Will Site A need a federal NSR permit now? Existing Major Source PI = 60 tpy MM = 40 tpy Netting EXAMPLE 3 Site C is a major source of VOC in serious nonattainment area.

Permit 123456 production unit Permit 456789 loading facilities Sought authorization of new facilities and affected facilities, PI = 12 tpy VOC Serious nonattainment Existing Major Source PI = 12 tpy Question: Will Site C need a federal NSR permit? Additional information can be found in the speaker Netting threshold = 5 tpy Netting

EXAMPLE 3 (CONT.) TABLE 3F EXAMPLE 3 (CONT.) VOC Serious nonattainment Existing Major Source PI = 12 tpy Offset = 1.2*12 = 14.4 tpy NNSR Required Significant of VOC = 25 tpy NI = 27 tpy Netting threshold = 5 tpy

Nettin g Additional information can be found in the speaker EXAMPLE 4 In November 2015, proposal to build a new unnamed site in Harris County. What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PTE (tpy) CO 315 NOx 50 VOC 31

SO2 21 EXAMPLE 4 In November 2015, proposal to build a new unnamed site in Harris County. What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PTE (tpy) CO 315 NOx 50 VOC 31 SO2

21 VOC, NOx severe nonattainment 1997- (8-hr ozone) Greenfield MS (NOx) = 25 tpy MS (VOC) = 25 tpy NNSR Review for Both Offset (NOx) = 1.3 * 31 tpy = 40.3 tpy Offset (VOC) = 1.3 * 50 tpy = 65 tpy EXAMPLE 4 CO, NO2,SO2 In November 2015, proposal to build a new unnamed site in Harris County. Attainment

(unnamed source) What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PTE (tpy) Greenfield CO 315 NOx 50 VOC 31 SO2 21

MS =250 tpy PSD Review for CO No Federal Review for SO2 MM (SO2, NOx) = 40 tpy PSD Review for NO2 EXAMPLE 5 In November 2017, proposal to build a new unnamed site in Harris County. What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PTE (tpy) CO 315 NOx

50 VOC 31 SO2 21 EXAMPLE 5 (CONT.) In November 2017, proposal to build a new unnamed site in Harris County. What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PTE (tpy) CO 315 NOx 50

VOC 31 SO2 21 VOC, NOx Moderate nonattainment 2008 - (8hr ozone) Greenfield MS (NOx) = 100 tpy MS (VOC) = 100 tpy No Federal Review for either EXAMPLE 5 (CONT.) In November 2017, proposal to build a new unnamed site in Harris County. What federal permitting programs would be triggered

for each pollutant? Pollutant Proposed PTE (tpy) CO 315 NOx 50 VOC 31 SO2 21 CO, SO2, NO2 Attainment (unnamed source) Greenfield MS = 250 tpy PSD Review

for CO No Federal Review for SO2 MM (SO2, NOx) = 40 tpy PSD Review for NO2 EXAMPLE 6 In November 2017, XYZ company, proposal to expand their (already major) unnamed site in Nueces County. What federal permitting programs would be triggered for each pollutant? Pollutant Proposed PI (tpy) CO 315 NOx 50 VOC

SO2 31 21 EXAMPLE 6 (CONT.) In November 2017, XYZ company, proposal to expand their (already major) unnamed site in Nueces County. CO, NOx,VOC, SO2 Attainment (unnamed source) Existing Major What federal permitting Source programs would be triggered for MM (CO) = 100 tpy MM (VOC) = 40 tpy each pollutant? MM (NOx) = 40 tpy MM (SO2) = 40 tpy

Pollutant Proposed PI (tpy) CO NOx 315 50 VOC SO2 31 21 No Federal Review for VOC and SO2 Netting triggered for NOx and CO REFERENCES Federal NSR Applicability Preliminary Determination Summary

PSD/NNSR Fact Sheets Additional information can be found in the speaker CONTACTS Xuan Zhao (512) 239-1664 Jesse Lovegren (512) 239-1284 Rick Goertz (512) 239-5606 Air Permit Division TCEQ P.O. Box 13087, MC 163 Austin, TX 78711-3087

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