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

3 Permitting Process Simplified Start Source not subject to NSR Source owner submits permit application Reviewing authority reviews: Application Proposed/Required Control Technologies Compliance with other applicable requirements Draft permit developed Final permit Issued End EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. APPLICABILITY APPLICATION APPEALS 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 final permit decision After appeal process ends, permit is finally approved or revoked. Is the source 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 (NO 2 ), Ozone, Particulate Matter (PM), and Sulfur Dioxide (SO 2 ) – Greenhouse Gases: Carbon dioxide (CO 2 ), Methane (CH 4 ), Nitrous Oxide (N 2 O), Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulfur Hexafluoride (SF 6 ) – Other Pollutants Include: Sulfuric Acid Mist (H 2 SO 4 ), Hydrogen Sulfide (H 2 S) – Excludes Air Toxics: Mercury (Hg), Cadmium (Cd), Benzene (C 6 H 6 ), etc. Applicability: New and Modified Sources

Applicability: Thresholds Attainment Areas Regulated NSR PollutantMajor Source Threshold (tpy) Carbon Monoxide (CO) 100 or 250 Sulfur Dioxide (SO 2 ) Ozone - Oxides of Nitrogen (NO x ) Ozone - Volatile Organic Compounds (VOC) PM PM-10 PM-2.5 Lead Fluorides Sulfuric Acid Mist Hydrogen Sulfide (H 2 S) Total Reduced Sulfur (including H 2 S) Reduced Sulfur Compounds (including H 2 S) Municipal Waste Combustor Emissions Municipal Solid Waste Landfills Emissions Greenhouse Gases (Combination of gases CO 2, CH 4, N 2 O, HFC, PFC, SF 6 ) 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 list28 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 ≥ applicable threshold? (per pollutant) Source not subject to PSD 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 list28 source category list Applicability: Modifications

8 Applicability: Modifications (Continued) Yes Start Are Proposed modification emissions ≥ SER? (per pollutant) Modification not subject to Major NSR Determine Source’s Net Emissions Increase (NEI), (per pollutant) Is the NEI ≥ SER? Modification is a major modification and subject to Major NSR Yes No 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 Significant Emission Rate (SER) 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 CO 2 e 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 CO 2 (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 CO 2 e-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, , , ,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 that are below thresholds (per pollutant) Is PTE ≥ applicable SER? (per pollutant) Pollutant not subject to PSD Yes No Source is major for PSD for one pollutant Pollutant subject 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 Major Source Threshold

14 Permitting Process Simplified Start Source not subject to NSR Source owner submits permit application Reviewing authority reviews: Application Proposed/Required Control Technologies Compliance with other applicable requirements Draft permit developed Final permit Issued End EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. APPLICABILITY APPLICATION APPEALS 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 final permit decision After appeal process ends, permit is finally approved or revoked. Is the source exempted?

15 Main requirements: 1.Install Best Available Control Technology (BACT) 2.Perform air quality analysis to assess impacts on air quality 3.Perform class I area analysis to assess impacts on national parks and wilderness areas 4.Perform additional impacts analysis 5.Allow for opportunities for public involvement Application: PSD Program Requirements

16 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 analysis 1.Identify all available control technologies 2.Eliminate technically infeasible control options 3.Rank remaining control technologies by its effectiveness (considers economic, energy and environmental impacts) 4.Evaluate most effective controls and document results 5.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, SO 2 and NO 2 ) – 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/m 3 ) NAAQS (  g/m 3 ) Averaging PeriodClass IClass IIClass III Annual hr291835

19 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 SO 2 and PM - Jan. 6, 1975 NO x - 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; d iffer 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

26 Permitting Process Simplified Start Source not subject to NSR Source owner submits permit application Reviewing authority reviews: Application Proposed/Required Control Technologies Compliance with other applicable requirements Draft permit developed Final permit Issued End EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. APPLICABILITY APPLICATION APPEALS 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 final permit decision After appeal process ends, permit is finally approved or revoked. Is the source 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

2828 PSD Source Categories source categories 1. Coal cleaning plants (with thermal dryers)15. Coke oven batteries 2. Kraft pulp mills16. Sulfur recovery plants 3. Portland cement plants17. Carbon black plants (furnace process) 4. Primary zinc smelters18. Primary lead smelters 5. Iron and steel mills19. Fuel conversion plants 6. Primary aluminum ore reduction plants20. Sintering plants 7. Primary copper smelters21. 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 plants23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels 10. Sulfuric acid plants24. Taconite ore processing plants 11. Nitric acid plants25. Glass fiber processing plants 12. Petroleum refineries26. Charcoal production plants 13. Lime plants27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU)/hour heat input 14. Phosphate rock processing plants28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input

Significant Emission Rates (SERs) 31 PollutantSER (tpy)PollutantSER (tpy) Carbon Monoxide100Sulfuric Acid Mist7 Nitrogen Oxides40Hydrogen Sulfide (H 2 S)10 Sulfur Dioxide40Total Reduced Sulfur (Includes H 2 S)10 Particulate Matter (PM10)15Reduced Sulfur Compounds (Includes H 2 S)10 Particulate Matter (PM2.5)10; 40 for VOCs, NOx or SO 2 Municipal Waste Combustor Organics3.5*10 -6 Ozone40 VOCs or NOxMunicipal Waste Combustor Metals15 Lead0.6Municipal Waste Combustor for Acid Gases 40 Fluorides3Municipal Solid Waste Landfills Emissions50 SER 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/m 3 (24-hour average)