1. PSD / NA Review / netting
PSD NA Applicability
5/15/2018
Laura Gibson, P.E.
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018
Prevention of Significant Deterioration (PSD)/Nonattainment (NA) Review/Netting
Laura Gibson, P.E.
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018
Note: Presentation will be available at the TCEQ ETF and APD websites, which will include links as referenced today.
“Don’t make a federal case out of it!” Phrase originated by Jimmy Durante in 1940s referencing the Federal Government’s use of Tax Evasion Charges to justify going after bootleggers during the Depression.
Maximum fee for Federal NSR permit = $75,000 (includes state permit)
Maximum fee for State only NSR permit = $10,000
Today’s Agenda:
What Triggers Federal Review? See flowchart, we’ll be going through it.
Examples (Simple and Not So Simple)
Image Attribution:
Photo of Jimmy Durante from Public Domain, obtained from

2. What Triggers Federal Review?
PSD NA Applicability
5/15/2018
Pollutant
Federal
Modification?
Major Project?
Significant Net
Emission Increase?
No Federal
NSR
Major Site?
Project
Increase
Significant? No
Yes
Federal NSR
Determine Net Emission Increase
Determine Site PTE & Project Increase
What Triggers Federal Review?
What Triggers Federal Review?
What Triggers Federal Review? It’s complicated!
Each project must be evaluated to determine whether it is subject to PSD or Nonattainment New Source Review (NNSR).
For federally regulated pollutants (criteria & non-criteria)
That meet or exceed Significant Emission Rate
Major NSR projects cannot authorize per permit by rule (PBR) (30 TAC 106), Rule Standard Permits (30 TAC § ), or 30 TAC § (e) (Changes to Qualified Facilities)
The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at

3. PSD Attainment or Undetermined Areas Named sources
PSD NA Applicability
PSD
5/15/2018
Attainment or Undetermined Areas
Named sources
100 tpy (including fugitives)
Unnamed sources
250 tpy (fugitives not included)
Major for One, Major for All
BACT (may use EPA Top-Down, prefer TCEQ Tier I-III)
PSD NA: Differences
Attainment or Undetermined Areas
28 Named sources as in 40 CFR §52.21(b)(1)(i)
i.e., Portland Cement Plants, Carbon Black plants, Chemical Process plants, Fossil fuel-fired steam electric plants > 250 MMBtu/hr heat input
100 tons per year any regulated pollutant (tpy) = Major source
Including fugitives
Unnamed sources:
250 tpy = Major source
Fugitives not included
For Site Determination: Major for One, Major for All
Best Available Control Technology (BACT) [may use Environmental Protection Agency (EPA) Top-Down]
EPA Top Down and TCEQ Tier I-III should end up with same technologies.
Image Attribution:
Photo located at
Photo by Ken Lund.
License can be found at

4. Nonattainment Only for particular pollutants in nonattainment areas
PSD NA Applicability
Nonattainment
5/15/2018
Only for particular pollutants in nonattainment areas
Ozone Moderate Area
100 tpy Major Source
LAER
Offsets for ozone
Moderate: 1.15 to 1
Serious: 1.2 to 1
Severe: 1.3 to 1
PSD NA: Differences
Only for particular pollutants in nonattainment areas
Ozone Moderate Area:
100 tpy Major Source
Lowest Achievable Emission Rate (LAER)
For all new/modified facilities
Not cost dependent
Previously achieved
Offsets for ozone
Moderate: 1.15 to 1
Serious: 1.2 to 1
Severe: 1.3 to 1
Image Attribution:
Photo located at
Photo by Ulrich Thumult.
License can be found at

5. Current Nonattainment Areas in Texas
Portion of Titus County
Portion of Rusk County
Portion of Panola County
Portion of Anderson County
Portion of Freestone County
City of El Paso
Houston/Galveston/Brazoria: Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties
Dallas/Fort Worth: Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties
PSD NA Applicability
5/15/2018
Current Nonattainment Areas in Texas
Current Nonattainment Areas in Texas
Before talking about PSD/NA similarities, let’s point out Current NA Areas in Texas
The second step in determining federal applicability is identifying whether the site is located in a nonattainment area.
Dallas/Fort Worth (DFW) – 2008 Ozone Standard
Wise, Denton, Collin, Parker, Tarrant, Dallas, Rockwall, Kaufman, Johnson, and Ellis Counties
Houston/Galveston/Brazoria (HGB) – 2008 Standard
Harris, Galveston, Brazoria, Chambers, Liberty, Montgomery, Waller, and Fort Bend Counties
City of El Paso – particulate matter equal to or less than ten microns in diameter (PM10)
Portions of Freestone, Anderson, Rusk, Panola, and Titus Counties – Sulfur dioxide (SO2)
Portion of Collin County – Lead (Pb) – re-designated maintenance by EPA, effective 9/27/

6. DC Circuit Ct Decision 2/16/18
PSD NA Applicability
DC Circuit Ct Decision 2/16/18
5/15/2018
Regarding implementation of 2008 NAAQS for Ozone
Decision upheld Implementation in part and vacated in part
Court still has to issue Mandate
TCEQ is monitoring litigation (additional information can be found in the speaker notes)
DC Circuit Court Decision 2/16/2018
Decisions yet to be mandated:
Attainment deadline for 1997 National Ambient Air Quality Standards (NAAQS) cannot be waived
Redesignation substitute for 1997 NAAQS by 2008 NAAQS not allowed (perhaps procedure incorrect & can be redone?)
Inter-basin transfer not allowed or South Coast Air Quality Management District (AQMD) (Los Angeles area, California)
TCEQ mgmt, legal, and State Implementation Plan (SIP) staff still looking into how this affects SIP and permitting

7. PSD NA: Similarities PTE, Baseline Actual Emissions, Project Increases
PSD NA Applicability
PSD NA: Similarities
5/15/2018
PTE, Baseline Actual Emissions, Project Increases
Netting Window and Calculations
Notice to EPA / Opportunity to Comment
Review of RBLC
Expanded Review Includes Modeling Protocol, Preliminary Determination Summary
PSD NA: Similarities
PTE, Baseline Actual Emissions, Project Increases
Netting Window and Calculations
Notice to EPA / Opportunity to Comment
Review of RACT, BACT, LAER Clearinghouse (RBLC)
Expanded Review Includes Modeling Protocol, Preliminary Determination Summary

8. AKA Major Modification Threshold AKA PSD SER
Power Plant Example
PSD NA Applicability
5/15/2018
Attainment county
> 25 MWe
Greenfield site
AKA Major Modification Threshold AKA PSD SER
Major for PSD?
YES
Air Contaminant
PTE (tpy)
NOX
650 CO
2000
VOC
275
PM/PM10/PM2.5
200
SO2
190
H2SO4 85
CO2
5,000,000
PSD Trigger (tpy)
PSD Review? 40
Yes
100
25/15/10 7
75,000
Power Plant Example
Attainment county
> 25 Mega Watts, electric (Mwe)
Greenfield site
Named source, so 100 tpy of any pollutant makes it a major source (Major for one, major for all).
Once major triggered, compare pollutant by pollutant against PSD significant emission rate (SER) to see if PSD review is triggered for that pollutant.
NOx = nitrogen oxides
CO = carbon monoxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
H2SO4 = sulfuric acid
CO2 = carbon dioxide, a greenhouse gas
Image Attribution:
Photo jpeg from Pexels.com

9. Modifications Physical Change Change in Method of Operation
PSD NA Applicability
5/15/2018
Physical Change
Change in Method of Operation
Causes Significant Increase
Need Not Be Physically “Touched”
Modifications
Physical Change
Change in Method of Operation
Causes Significant Increase
Need not be physically “touched”
Exception: Routine Maintenance, Repair, and Replacement
See 30 TAC §116.12(20) -
From APDG 5881v5 pg. 5-6: “The relaxation of a federally enforceable emission rate or restriction is considered a modification… If it is necessary to change an NSR permit condition to allow an operation, the change should be considered a change in method of operation and therefore a potential modification.”
APDG588v5 can be found on the TCEQ web site at

10. New Facility/New Emission Source
PSD NA Applicability
New Facility/New Emission Source
5/15/2018
Federal Modification?
New boiler
New tank
Federal Modification?
Debottle-necking
Increased feedstock
Increased hours of operation
Increase Efficiency
Optimize kiln performance
Change method of control
As-Built Amendment
It depends!
Federal Modification?
Are These Federal Modifications?
New Facility/New Emission Source
New boiler
New tank
Debottlenecking
Increased feedstock
Increased hours of operation
Increase Efficiency
Optimize kiln performance
Change method of control
As-Built Amendment
It depends!

11. Check project increases
PSD NA Applicability
Cement Kiln Example
5/15/2018
As-built amendment
Commissioning and testing of new kiln
Corrective actions under Texas Audit Privilege Act
Change in method of operation
Significant increase?
Check project increases
Cement Kiln Example
As-built amendment = retrospective (if we’d known then what we know now, is it subject to Federal Applicability as it was then?)
Commissioning and testing of new kiln
Corrective actions under Texas Audit Privilege Act
Change in method of operation
Possibly a significant increase
Project increases must be checked

12. Federal NSR Applicability
PSD NA Applicability
5/15/2018
Pollutant
Federal
Modification?
Major Project?
Significant Net
Emission Increase?
No Federal
NSR
Major Site?
Project
Increase
Significant? No
Yes
Federal NSR
Determine Net Emission Increase
Determine Site PTE & Project Increase
Federal NSR Applicability
Federal NSR Applicability
Determine site potential to emit (PTE), also called allowables, and project increase.
The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site at

13. Proposed Site PTE Includes all new, modified, and affected facilities
PSD NA Applicability
Proposed Site PTE
5/15/2018
Includes all new, modified, and affected facilities
Upstream and downstream effects
Proposed Site PTE
Table 1F can be found on the TCEQ web site at
30 TAC §116.12(2) = definition of allowable emissions:
(2) Allowable emissions--The emissions rate of a stationary source, calculated using the maximum rated capacity of the source (unless the source is subject to federally enforceable limits that restrict the operating rate, or hours of operation, or both), and the most stringent of the following:
(A) the applicable standards specified in 40 Code of Federal Regulations Part 60 or 61;
(B) the applicable state implementation plan emissions limitation including those with a future compliance date; or
(C) the emissions rate specified as a federally enforceable permit condition including those with a future compliance date.
30 TAC §116.12(2) -

14. Baseline Actual Emissions
PSD NA Applicability
Baseline Actual Emissions
5/15/2018
Emissions, in tons/year, actually emitted during a consecutive 24-month period out of the previous 10 years (previous 5 years for electric utilities) from the date the project is authorized or modifications are operated.
All sources of single pollutant have same 24-month period.
Different pollutants may have a different 24-month period.
Baseline Actual Emissions
Emissions, in tons/year, actually emitted during a consecutive 24-month period out of the previous 10 years (previous 5 years for electric utilities)
from the date the project is authorized or modifications are operated. All sources of single pollutant have same 24-month period. Different pollutants may have a different 24-month period.
Definition in 30 TAC §116.12(3) -

15. Pruitt Project Emissions Accounting Memo (3/13/18)
PSD NA Applicability
Pruitt Project Emissions Accounting Memo (3/13/18)
5/15/2018
Project Decreases may be considered at Step 1 of review
TCEQ staff still reviewing effects on permitting
Even if Federal Review isn’t triggered, Baseline Actual Emissions must be considered per Texas Clean Air Act
Airshed may still experience an actual increase in emissions
Pruitt Project Emissions Accounting Memo (3/13/18)
Project Decreases may be considered at Step 1 of review.
As of 5/3/2018, TCEQ staff still reviewing effects on permitting.
Even if Federal Review isn’t triggered, Baseline Actual Emissions must be considered per Texas Clean Air Act.
Airshed may still experience actual increase if the site is “over-permitted,” that is, allowables much higher than actuals.
30 TAC 116 defines Project Emissions Increase (PEI), which will govern our reviews
Rulemaking will be required to accommodate Pruitt memo
At this time, for Texas, decreases won’t be considered until netting.
EPA Administrator Pruitt’s memo may be found at

16. BAE Example from TCEQ EI
PSD NA Applicability
5/15/2018
BAE Example from TCEQ EI CO
NOX
PM10
PM2.5
47.952
SO2
VOC
Pollutant
24-month period
BAE (TPY) CO
991.08
NOX
PM10
269.23
PM2.5
72.59
SO2
54.74
VOC
83.22
Baseline Actual Emissions (BAE) Example from TCEQ EI
Assumptions for data shown:
TCEQ Emissions Inventory (EI) shown includes all sources at site; therefore, proposed project baseline includes all sources. While this may not be true, this helps the applicant and reviewer get into the ballpark of what BAE is / could be.
Applicant would actually turn in a more detailed Table 2F to show specific emission point numbers (EPNs) / sources.
Note that (unauthorized) emissions events are NOT included in the BAE.
This example only shows 5 years ( ) of the 10-year potential Baseline Emission Period.
CO = carbon monoxide
NOx = nitrogen oxides
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
VOC = volatile organic compounds
More information regarding TCEQ Emissions Inventory can be found at

17. Project Emissions Increase
PSD NA Applicability
Project Emissions Increase
5/15/2018
PEI = PTE - BAE
Increases only
Allowables to Allowables ONLY if:
Baseline ≥ current PTE, or
New facility within 24 months of initial startup
Project Emissions Increase (PEI)
PEI = Potential to emit (PTE) minus Baseline Actual Emissions (BAE)
Increases only
New, modified, and affected facilities
Associated project decreases will be considered with netting
Allowables to Allowables ONLY if:
Baseline ≥ current PTE, or
New facility within 24 months of initial startup

18. Federal NSR Applicability
PSD NA Applicability
5/15/2018
Pollutant
Federal
Modification?
Major Project?
Significant Net
Emission Increase?
No Federal
NSR
Major Site?
Project
Increase
Significant? No
Yes
Federal NSR
Determine Net Emission Increase
Determine Site PTE & Project Increase
Federal NSR Applicability
Federal NSR Applicability
Determine if site is major.
The original flowchart can be found in the Federal NSR Applicability Guidance Document at

19. Major Site? Only in NA Area Only for NA Pollutant
PSD NA Applicability
5/15/2018
Major Site?
Only in NA Area
Only for NA Pollutant
Moderate NA Area for Ozone: 100 tpy NOx or VOC
Moderate NA Area for PM10: 100 tpy
NA Area for SO2: 100 tpy
Any Regulated Pollutant
Named Sources: 100 tpy
Unnamed Sources: 250 tpy
PSD Major Source
NA Major Source
Major Site?
PSD Major Source:
100 tons per year (tpy) for all named sources-
Any regulated pollutant
28 ‘named’ source categories
Listed at 40 CFR §52.21(b)(1)(i)
i.e., Portland Cement Plants, Carbon Black plants, Chemical Process plants, Fossil fuel-fired steam electric plants > 250 MMBtu/hr heat input
250 tpy for all unnamed sources not listed above.
Nonattainment Major Source:
Only in nonattainment area
Only for nonattainment pollutant
Moderate nonattainment area for ozone: 100 tpy NOX or VOC
Moderate nonattainment area for PM10: 100 tpy
Nonattainment area for SO2: 100 tpy

20. Federal NSR Applicability
PSD NA Applicability
5/15/2018
Pollutant
Federal
Modification?
Major Project?
Significant Net
Emission Increase?
No Federal
NSR
Major Site?
Project
Increase
Significant? No
Yes
Federal NSR
Determine Net Emission Increase
Determine Site PTE & Project Increase
Federal NSR Applicability
Federal NSR Applicability
Determine if project is major.
The original flowchart can be found in the Federal NSR Applicability Guidance Document at

21. Major Projects New Major Source
PSD NA Applicability
Major Projects
5/15/2018
New Major Source
Major Modification of Existing Major Source
At Significant Emission Rate for Federal Review
Requires modeling protocol to be approved by ADMT prior to completing AQA
Major Projects
Last bullet is key for applicants = TRICKY. Not so different for the permit reviewer; project just spends more time with applicant / Air Dispersion Modeling Team (ADMT) being modeled and audited.

22. PSD Significant Emission Rates
PSD NA Applicability
5/15/2018
Pollutant
PSD SER (tpy)*
NOx 40 CO
100
SO2
VOC PM 25
PM10 15
PM2.5 10 Pb
0.6
Fluorides 3
H2SO4 7
H2S
TRS
GHG**
75,000
Once PSD triggered by ANY pollutant, all pollutants may be subject to PSD review!
PSD Significant Emission Rates
Once PSD triggered by ANY pollutant, all pollutants may be subject to PSD review! PSD significant emission rates (SERs) are triggers for netting and review.
NOX = oxides of nitrogen
CO = carbon monoxide
SO2 = sulfur dioxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
Pb = lead
H2SO4 = sulfuric acid
H2S = hydrogen sulfide
TRS = total reduced sulfur
GHG* = greenhouse gas as quantified by CO2e
CO2e = carbon dioxide equivalents based on global warming potentials of methane (CH4) = 25, nitrous oxide (N2O) = 298, sulfur hexaflouride (SF6)=22,800
* Only applicable if PSD is triggered by another pollutant first.
* Trigger for netting and review
** Only if PSD is triggered by another pollutant first

23. Natural Gas Plant Example
PSD NA Applicability
5/15/2018
Natural Gas Plant Example
Existing major source
New flare emissions
Changing flare only
Air Contaminant
Permit PTE (tpy)
Permit BAE (tpy)
Modified Facility PTE (tpy)
NOx
135 ?
3.6 CO
131
9.1
VOC 51
4.7
PM/PM10/PM2.5
6.2
SO2
276
5.2
PSD SER (tpy)
PSD Review? 40 No
100
25/15/10
Natural Gas Plant Example
Existing major source
Alternate operating scenarios
Affecting flare only
NOx = nitrogen oxides
CO = carbon monoxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
Permit BAE < PTE, otherwise wouldn’t be in compliance.

24. NA Significant Emission Rates
PSD NA Applicability
NA Significant Emission Rates
5/15/2018
Area
Pollutant
Current Desig-nation
Current NA Netting Trigger
Current NA SER
HGB
Ozone as NOX or VOC
Moderate 40
DFW
El Paso
PM10 15
Anderson County, et al
SO2
Nonattain-ment
Prior Desig-nation
Prior NA Netting Trigger
Prior NA SER
Severe 5 25
Serious
Nonattainment Significant Emission Rates
HGB = Houston/Galveston/Brazoria
DFW = Dallas/Fort Worth
NOX = oxides of nitrogen
VOC = volatile organic compounds
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
SO2 = sulfur dioxide
Current designations effective December 2016 (see Redesignation discussion).

25. Power Plant NA Example Moderate NA area for ozone
PSD NA Applicability
Power Plant NA Example
5/15/2018
Moderate NA area for ozone
Existing major source
Proposed new EGU, 2 combined cycle gas-fired turbines, and supporting equipment
Air Contaminant
Project PTE* (tpy)
VOC
113
NOX
194
Net Increase* (tpy)
NA SER
NA Review?
113 40
Yes
194
Offsets (tpy)
130
223
* New construction, not modifying existing sources. Assumed BAE of zero.
Power Plant Nonattainment Example
Moderate NA area for ozone
Existing major source
Proposed new electric generating unit (EGU), 2 combined cycle gas-fired turbines, and supporting equipment
VOC = volatile organic compounds
NOX = oxides of nitrogen
The project potential to emit (PTE) is for new construction, no modification of existing sources; assumed baseline actual emissions (BAE) of zero.
Image Attribution:
Turbine photo:

26. Power Plant PSD Example
PSD NA Applicability
Power Plant PSD Example
5/15/2018
Existing named major source
Proposed new EGU, 2 combined cycle gas-fired turbines, and supporting equipment
Air Contaminant
Project PTE* (tpy)
NO2
194 CO
266
VOC
N/A**
PM/PM10/PM2.5
>125
SO2 72
H2SO4 33
GHGs
3,000,000
PSD SER
Netting? 40
Yes
N/A
25/15/10 7
75,000
* New construction, not modifying existing sources. Assumed BAE of zero.
** PSD review not applicable for VOCs in NA area.
Power Plant PSD Example
Existing named major source
Proposed new electric generating unit (EGU), 2 combined cycle gas-fired turbines, and supporting equipment
The project potential to emit (PTE) is for new construction, not modifying existing sources; assumed baseline actual emissions for new sources is zero.
The project PTE , PSD significant emission rate, and PSD review are not applicable for VOCs in a nonattainment area.
NO2 = nitrogen dioxide
CO = carbon monoxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
H2SO4 = sulfuric acid
GHGs = greenhouse gas as quantified by CO2e
CO2e = carbon dioxide equivalents based on global warming potentials of methane (CH4) = 25, nitrous oxide (N2O) = 298, sulfur hexaflouride (SF6)=22,800

27. Federal NSR Applicability
PSD NA Applicability
5/15/2018
Pollutant
Federal
Modification?
Major Project?
Significant Net
Emission Increase?
No Federal
NSR
Major Site?
Project
Increase
Significant? No
Yes
Federal NSR
Determine Net Emission Increase
Determine Site PTE & Project Increase
Federal NSR Applicability
Federal NSR Applicability
Determine net emission increase.
The original flowchart can be found in the Federal NSR Applicability Guidance Document at

28. PSD NA Applicability
Netting
5/15/2018
Ensures smaller projects do not add up to be a major modification
Applies to existing major sources only…..
IF Project Emissions Increase ≥ SER
Per pollutant
Emission changes within contemporaneous period
Netting
Ensures smaller projects do not add up to be a major modification
Applies to existing major sources only
IF Project Emissions Increase ≥ Significant Emission Rate (SER)
Per pollutant
Emission changes within contemporaneous period
Emissions changes:
Now may consider decreases
Includes current project

29. Contemporaneous Period
PSD NA Applicability
Contemporaneous Period
5/15/2018
Start of Cont. Period
End of Cont. Period
Application Received
2013
2017
2018
2020
5 years prior to SOC
Start of Construction
Start of Operation
Contemporaneous Period
Contemporaneous period (netting window):
From five years before start of construction to the proposed start of operation.
If the sum of the projects within the period is greater than or equal to the major modification significant emission rate, major NSR is triggered.

30. Creditable Increases and Decreases: PTE - BAE
PSD NA Applicability
5/15/2018
Creditable Increases and Decreases: PTE - BAE
During Contemporaneous Period
Not Previously Relied Upon
Confirmed by Emissions Inventory
Include Planned Projects Prior to SOO
Increases
Not Required to Meet Permit / SIP
During Contemporaneous Period
Must Be Enforceable
Must Be Real
Must Occur Prior to SOO
Decreases
Creditable Increases and Decreases: Potential to Emit (PTE) minus Baseline Actual Emissions (BAE)
Increases:
During Contemporaneous Period
Not Previously Relied Upon
Confirmed by Emissions Inventory
Include Planned Projects Prior to Start of Operation (SOO)
Decreases:
Not Required to Meet Permit / State Implementation Plan (SIP)
Must Be Enforceable
Must Be Real (that is, a Decrease in Actual Emissions) NOTE a Decrease in PTE only without a Decrease in Actuals is NOT Creditable
Must Occur Prior to SOO
NOTE: Decreases are not creditable if BAE exceeded existing emission limits.

31. Project Contemporaneous Changes
PSD NA Applicability
Project Contemporaneous Changes
5/15/2018
All Increases and Decreases, Including Current Project
Include EPNs, Project and Permit Nos.
Project Contemporaneous Changes
All Increases and Decreases, Including Current Project
Include emission point numbers (EPNs), Project Numbers, and Permit Numbers
Table 3F can be found on the TCEQ web site at

32. Creditable Decreases Don’t forget Table 4F for each Decrease!
PSD NA Applicability
Creditable Decreases
5/15/2018
Don’t forget Table 4F for each Decrease!
Statements verify that claimed decreases are Creditable
Creditable Decreases
Don’t forget Table 4F for each Decrease!
Statements verify that claimed decreases are Creditable
Table 4F can be found on the TCEQ web site at

33. Contemporaneous and BAE Period
PSD NA Applicability
5/15/2018
Contemporaneous and BAE Period
Application Received
2013
2017
2018
2020
2004
2008
Prior Project
Prior Project 24-month BAE
Contemporaneous Period
SOC
SOO
Current Project 24-month BAE
10 year Current Proj. BAE period
10 year Prior Proj. BAE period
Contemporaneous and Baseline Actual Emissions (BAE) Period
Contemporaneous period (netting window):
From five years before start of construction to the proposed start of operation.
If the sum of the projects within the period is greater than or equal to the major modification significant emission rate, major NSR is triggered.
Ten-year potential BAE period; electric generating units (EGUs) limited to last five years.

34. Net Emissions Increase
PSD NA Applicability
5/15/2018
Net Emissions Increase
NEI
Contemp. Increases (including current project)
Contemporaneous Decreases = -
NEI ≥ Major Modification Threshold?
Major NSR is triggered!
Net Emission Increase (NEI)
NEI = Contemporaneous Increases (including current project) minus Contemporaneous Decreases
NEI ≥ Major Modification Threshold? Major NSR is triggered!

35. Cement Kiln PSD Netting Example
Adding 2nd kiln and equipment
Existing named major source
Ozone attainment county
PSD NA Applicability
5/15/2018
Cement Kiln PSD Netting Example
Adding 2nd kiln and equipment
Existing named major source
Ozone attainment county
Air Contam-inant
Project Increase
PSD Netting Trigger
Netting Trig-gered?
NOX
963 40
Yes CO
1071
100
VOC
51.4 PM
293 25
PM10
233 15
PM2.5 74 10
SO2
37.6 No
H2SO4
1.74 7 Pb
0.02
0.6
GHGs
1,223,000
N/A
NEI
PSD SER
PSD Review Triggered?
35.4 40 No
1071
100
Yes
51.4
295 25
234 15 74 10
N/A 7
0.6
75,000
Cement Kiln PSD Netting Example
Adding second kiln and equipment
Existing named major source
Ozone attainment county
NEI = Net Emissions Increase
SER = Significant Emission Rate
Project Increases compared to Baseline Actuals
Netting? Look at 10 years previous projects, supply Tables 2F, 3F, 4F
Note applicant was able to net out of NOX. SO2, H2SO4, Pb did not trigger netting. NOTE: These (non-PSD) pollutants’ increases still have to show acceptable modeling and BACT through state level review!!
NOX = oxides of nitrogen
CO = carbon monoxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
H2SO4 = sulfuric acid
Pb = lead
GHGs* = greenhouse gas as quantified by CO2e
CO2e = carbon dioxide equivalents based on global warming potentials of methane (CH4) = 25, nitrous oxide (N2O) = 298, sulfur hexaflouride (SF6)=22,800

36. Fuel Oil Terminal NA Example
PSD NA Applicability
5/15/2018
Fuel Oil Terminal NA Example
Crude oil throughput increase, new ship dock, new tanks
Aggregated projects begun while county was Severe NA area for ozone
Existing major source for VOCs
Severe
Air Contaminant
Project Increase*
NA Netting Trigger
VOC 56 5
NOX 12
* New construction, not modifying existing sources. Assumed BAE of zero, new facilities.
Fuel Oil Terminal Nonattainment Example
Crude oil throughput increase, new ship dock, new tanks
Aggregated projects begun while county was Severe nonattainment area for ozone
Existing major source for VOCs
VOC = volatile organic compounds
NOX = oxides of nitrogen
The project potential to emit (PTE) is for new construction, no modification of existing sources; assumed baseline actual emissions (BAE) of zero, new facilities.
Image Attribution:
Storage tanks photo:

37. Fuel Oil Terminal NA Example
PSD NA Applicability
Fuel Oil Terminal NA Example
5/15/2018
Netting Example
Fuel Oil Terminal Nonattainment Example
Netting example with Table 3F – Project Contemporaneous Changes.
Note: We need Table 1F, 2F, and 3F when netting applies.

38. Fuel Oil Terminal NA Example
PSD NA Applicability
Fuel Oil Terminal NA Example
5/15/2018
Crude oil throughput increase, new ship dock, new tanks
Aggregated projects begun while county was Severe NA area for ozone
Existing major source for VOCs
Severe
Air Con-taminant
Project Increase*
NA Netting Trigger
VOC 56 5
NOX 12
Net Emissions Increase*
NA SER
NA Review?
56.3 25
Yes
19.5 No
1.3:1 Offsets
73.2 --
* New construction, not modifying existing sources. Assumed BAE of zero, new facilities.
Fuel Oil Terminal Nonattainment Example
Crude oil throughput increase, new ship dock, new tanks
Aggregated projects begun while county was Severe NA area for ozone
Existing major source for VOCs
VOC = volatile organic compounds
NOX = oxides of nitrogen
The project increase and net emissions increase are for new construction, no modification of existing sources; assumed baseline actual emissions (BAE) of zero, new facilities.

39. Fuel Oil Terminal PSD Example
PSD NA Applicability
5/15/2018
Fuel Oil Terminal PSD Example
Existing named major source
Crude oil throughput increase, new ship dock, new tanks
Air Contaminant
Project Increase*
NO2 12 CO 14
VOC** 56
PM/PM10/PM2.5
9.4
SO2
0.3
PSD Trigger / SER
Netting or PSD Review? 40 No
100
N/A
25/15/10
* New construction; assumed BAE of zero.
** PSD review not applicable for VOCs in NA area.
Fuel Oil Terminal PSD Example
NO2 = nitrogen dioxide
CO = carbon monoxide
VOC = volatile organic compounds
PM = total particulate matter suspended in the atmosphere, including particulate matter 10 microns or less and 2.5 microns or less in diameter
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
The project increase is for new construction, no modification of existing sources; assumed baseline actual emissions (BAE) of zero.
PSD review is not applicable for VOCs in nonattainment area.
Remember that state level review, including BACT and acceptable impacts, is still required for all pollutants.

40. NA Offsets Area Pollutant Current Designa-tion Required Offsets HGB
PSD NA Applicability
NA Offsets
5/15/2018
Area
Pollutant
Current Designa-tion
Required Offsets
HGB
Ozone as NOx or VOC
Moderate
1.15:1
DFW
Ozone as NOX or VOC
El Paso
PM10
1:1
Anderson County, et al
SO2
Nonattain-ment
Prior Desig-nation
Required Offsets
Severe
1.3:1
Serious
1.2:1
Nonattainment Offsets
HGB = Houston/Galveston/Brazoria
DFW = Dallas/Fort Worth
NOX = oxides of nitrogen
VOC = volatile organic compounds
PM10 = particulate matter equal to or less than 10 microns in diameter, including particulate matter 2.5 microns or less in diameter
SO2 = sulfur dioxide
Current designations effective December 2016, depending on interpretation of February 2018 DC Circuit Court decision.

41. PSD NA Applicability
Contacts
5/15/2018
Laura Gibson, P.E Chase Perry
Note that additional details on this presentation are available in the Speaker Notes and Expanded Outlines.
Contacts
Laura Gibson, P.E.
Chase Perry