PSD / Nonattainment Review / Netting Basics

PSD / Nonattainment Review / Netting Basics
PSD NA Applicability PSD / Nonattainment Review / Netting Basics PSD / Nonattainment Review / Netting Basics 5/15/2018 Katherine Quinlan Chemical Section Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2019 Prevention of Significant Deterioration (PSD)/Nonattainment (NA) Review/Netting Katherine Quinlan Chemical Section Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2019 Note: Presentation will be available at the TCEQ ETF and APD websites, which will include links as referenced today. Maximum fee for Federal NSR permit = $75,000 (includes state permit)

Terms and Abbreviations
DRAFT PSD NA Applicability 5/15/2018 Major Source (MS) Potential to Emit (PTE) Baseline Actual Emissions (BAE) Project Increase (PI) Net Emissions Increase (NEI) Abbreviations that will be used throughout the presentation. -Major Stationary Source (MS): 30 TAC §116.12(19) and 40 CFR §52.21(b)(1) -Baseline Actual Emissions (BAE): 30 TAC §116.12(3) and 40 CFR §52.21(b)(48) -Project Emissions Increase (PI): 30 TAC §116.12(32) -Net Emissions Increase (NEI): 30 TAC §116.12(22) and 40 CFR §52.21(b)(3) -Major Modification (MM): 30 TAC §116.12(20) and 40 CFR §52.21(b)(2)(i) Major Modification (MM) Major Modification Threshold = Significant Emission Rate (SER)

What Triggers Federal Review?
PSD NA Applicability 5/15/2018 Major Project? No Major Site? Yes Determine Site PTE & PI Federal NSR Yes Pollutant Federal Modification? PI Significant? Yes No Federal NSR No Yes No No Federal NSR No 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 Determine NEI Yes No Significant NEI?

DRAFT PSD NA Applicability
5/15/2018 Attainment or Undetermined Areas Major Source thresholds Named Sources 100 tpy (including fugitives) Unnamed sources 250 tpy (fugitives not included) PSD: 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 in major source determination For Site Determination: Major for One pollutant, Major for All pollutants Once triggered, review includes Best Available Control Technology (BACT) review using RBLC and TCEQ permits EPA Top Down and TCEQ Tier I-III should end up with same technologies. Major for one pollutant, Major for all pollutants BACT information can be found in the speaker notes)

Current Nonattainment Areas in Texas
Dallas/Fort Worth (DFW): Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise Counties Bexar County Portions of: City of El Paso 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 Current Nonattainment Areas in Texas Here is a map to show the nonattainment/attainment status of various pollutants in Texas. Dallas/Fort Worth (DFW) – 2008 Ozone Standard Wise, Denton, Collin, Parker, Tarrant, Dallas, Rockwall, Kaufman, Johnson, and Ellis Counties Bexar County, effective as of 9/24/2018 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) – attainment (2008 lead standard, 9/27/2017)

Ozone Nonattainment 5/15/2018 Regulated through precursors (VOC and NOx) Classification Major Source (tpy) Major Modification (tpy) Netting (tpy) Marginal (Bexar County) 100 40 Moderate (HGB and DFW) Serious 50 25 5 Severe Extreme 10 -- -ozone nonattainment is regulated through VOC and NOx as precursors. Classifications: Marginal (Bexar County): MS threshold of 100 tpy, major modification threshold of 40 tpy and netting threshold of 40 tpy Moderate (HGB and DFW): MS threshold of 100 tpy, major modification threshold of 40 tpy and netting threshold of 40 tpy. Serious: MS threshold of 50 tpy, major modification threshold of 25 tpy and netting threshold of 5 tpy Severe: MS threshold of 25 tpy, major modification threshold of 25 tpy and netting threshold of 5 tpy. Extreme: MS threshold of 10 tpy, major modification threshold of 10 tpy.

Other Texas Nonattainment Areas
DRAFT PSD NA Applicability Other Texas Nonattainment Areas 5/15/2018 Pollutant Designation Major Source (tpy) Major Modification (tpy) Netting (tpy) Moderate for PM10 (City of El Paso) 100 15 Nonattainment for SO2 (Portions of Titus, Rusk, Panola, Anderson and Freestone Counties) 40 Moderate PM10 (City of El Paso): MS threshold of 100 tpy, major modification threshold of 15 tpy and netting threshold of 15 tpy. SO2 Nonattainment areas: MS threshold of 100 tpy, major modification threshold of 40 tpy and netting threshold of 40 tpy.

Nonattainment Offset Ratios
DRAFT PSD NA Applicability 5/15/2018 Classification Offset Ratio Marginal Ozone (Bexar County) 1.1 to 1 Moderate Ozone (HGB and DFW) 1.15 to 1 Serious Ozone 1.2 to 1 Severe Ozone 1.3 to 1 Extreme Ozone 1.5 to 1 PM10 Moderate (City of El Paso) 1:1 SO2 Nonattainment (Portions of Anderson, Titus, Rusk, Panola, Freestone Counties) Offsets for ozone Marginal: 1.1 to 1 Moderate: 1.15 to 1 Serious: 1.2 to 1 Severe: 1.3 to 1 Extreme: 1.5 to 1 PM10 moderate (City of El Paso): 1 to 1 SO2 nonattainment (portions of Anderson, Titus, Rusk, Panola, and Freestone Counties): 1 to 1

PSD and Nonattainment: Similarities
DRAFT PSD NA Applicability 5/15/2018 Determination of sitewide PTE, BAE, PI Contemporaneous netting window Notice to EPA / Opportunity to Comment Review of RBLC 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) during BACT determination Note: still also review TCEQ permits, and will be no less stringent than state-level BACT. Expanded Review Includes Modeling Protocol, Preliminary Determination Summary Expanded review includes modeling protocol and Preliminary Determination Summary (additional information can be found in the speaker notes)

Federal Review Applicability Flowchart
PSD NA Applicability 5/15/2018 Major Project? No Major Site? Yes Determine Site PTE & PI Federal NSR Yes Pollutant Federal Modification? Federal Modification? PI Significant? Yes No Federal NSR No Yes No No Federal NSR No For changes at existing facilities, it is important to first identify the new, modified, and affected sources in the project. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No Significant NEI?

Modification DRAFT PSD NA Applicability 5/15/2018 Physical change Change in method of operation Causes increase in emissions 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 Does not need to be physically “touched” (additional information can be found in the speaker notes)

Major Modification DRAFT PSD NA Applicability 5/15/2018 Modification that causes both a significant emissions increase and a significant net emissions increase 40 CFR §52.21(a)(2)(iv)(a) 1 Significant emissions increase: PI ≥ netting threshold/SER Major Modification: modification at a major stationary source which causes a significant emissions increase (PI ≥ netting threshold/SER) and significant net emissions increase (NEI ≥ MM threshold/SER). These are often referred to as “Step 1” and “Step 2” of the applicability test. 2 Significant net emissions increase: NEI ≥ MM threshold/SER

Affected Facility DRAFT PSD NA Applicability 5/15/2018 No allowable emission increases Increases in actual emissions which are caused by a change or modification elsewhere Included in project increase and netting Evaluated PI=PTE-BAE Affected Facilities: generally have actual emission increases due to a modification elsewhere, but no allowable emission rate increases. Include PTE-BAE in project increase and netting Example: New process requiring steam from an existing onsite boiler, but boiler allowable emission rates will not increase.

Federal Review Flowchart
PSD NA Applicability 5/15/2018 Major Project? No Major Site? Federal NSR Yes Pollutant Yes Determine Site PTE & PI Yes Determine Site PTE & PI Federal Modification? PI Significant? Yes No Federal NSR No Yes No No Federal NSR No No Federal NSR No If there are no modifications in the project, then federal NSR is not triggered. If there are new, modified or affected facilities in the project, the next step in the flowchart is to determine the site Potential to Emit (PTE) and Project Increase (PI) The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No Significant NEI?

Sitewide PTE DRAFT PSD NA Applicability 5/15/2018 Includes all emissions at the site Routine & MSS case-by-case NSR permits PBRs and Standard Permit Registrations Unregistered PBRs Proposed Site PTE: Include all emissions at the site, including those authorized under: Case-by-case NSR permits PBRs and Standard Permits Unregistered PBRs Standard Exemptions Both routine and MSS emissions must be included in the sitewide PTE. 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) - Standard Exemptions

Table 1F DRAFT PSD NA Applicability 5/15/2018 Pollutants Ozone CO PM10 PM2.5 NOx SO2 Other VOC Existing Site PTE (tpy) # # # # # # # # Record the Existing sitewide PTE for each pollutant on the Table 1F. 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) - List the existing sitewide PTE for each pollutant on Table 1F

Baseline Actual Emissions (BAE)
DRAFT PSD NA Applicability Baseline Actual Emissions (BAE) 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 application is administratively complete. All sources of single pollutant have same 24-month period for a given project. Different pollutants may have a different 24-month period. Exclude non-compliant emissions and emissions exceeding current limitations. 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 application is received. All sources of single pollutant have same 24-month period. Different pollutants may have a different 24-month period. Adjust BAE to exclude non-compliant emissions (if BAE were greater than PTE during baseline period) and any emissions exceeding a current limitation. Definition in 30 TAC §116.12(3) -

Example: BAE Determination
DRAFT PSD NA Applicability Example: BAE Determination 5/15/2018 For each applicable pollutant for a given project: FIN EPN 2014 2015 2016 2017 2018 Tank1 Tank1Vent 14.70 12.70 13.30 12.30 14.60 Tank2 Tank2Vent 16.30 14.20 10.30 14.90 15.00 Heater HeaterVent 9.80 7.10 6.50 9.20 8.30 Totals 40.80 34.00 30.10 36.40 37.90 average: 37.40 Baseline Actual Emissions (BAE) Example from EI Table shown lists Emissions Inventory (EI) data for three sources which will be modified in current project. Table only shows 5 years of data, but can actually extend back up to 10 years (except for electric utility steam generating units) BAE is consecutive 24-month average over 10 years preceding the project If any of these reported EI emissions exceeded a limitation (e.g., allowable emission rate) in place at the time, actual emissions for that year must be adjusted downward. For example, if Tank 2 had an allowable emission rate of tpy in 2014, the average for could not be = It should instead be =14.85. Must use same 24-month period for each pollutant for each project, but different pollutants can use different baseline dates. Note that (unauthorized) emissions events are NOT included in the BAE. More information regarding TCEQ Emissions Inventory can be found at average: 32.05 average: 33.25 baseline period can extend back 10 years average: 37.15

Project Increase (PI) 5/15/2018 PI = Proposed PTE - BAE Table 2F Increases only Provide Table 2F for each pollutant Summarize results on Table 1F PI = Proposed PTE- Current PTE only if: Project Emissions Increase (PI) Show calculation of PI on Table 2F, and summarize results of each Table 2F on the Table 1F. PI = Proposed 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 Equipment leak fugitives Baselines ≥ current PTE New facility within 24 months of initial startup Equipment leak fugitives

PSD NA Applicability 5/15/2018 Major Project? No Major Site? Major Site? Pollutant Yes Determine Site PTE & PI Federal NSR Yes Federal Modification? PI Significant? Yes No Federal NSR No Yes No No Federal NSR No After determining the sitewide PTE and PI, determine whether the site is a major source. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No Significant NEI?

Major Source/Site Determination
DRAFT PSD NA Applicability 5/15/2018 PSD Nonattainment Any regulated pollutant designated as “attainment” or “unclassifiable” in an area Named Sources: 100 tpy Unnamed Sources: 250 tpy Major for one pollutant, major for all pollutants Only in NA Area for NA pollutant Thresholds based on NA classification for county Major source determined for each pollutant individually Major Site? PSD Major Source: Applies to all of the pollutants for which the county has not be designated as “nonattainment” If the site is a major source for one PSD pollutant, the site is considered major for all PSD pollutants. If this is the case, PI and NEI of all pollutants are compared against their respective SERs. 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 and Marginal nonattainment areas for ozone: 100 tpy NOX or VOC Moderate nonattainment area for PM10: 100 tpy Nonattainment area for SO2: 100 tpy Determine MS applicability for each pollutant (e.g., a site can be a major source for VOCs, but a minor source for NOx)

Major Source/Site Determination
DRAFT PSD NA Applicability Major Source/Site Determination 5/15/2018 Current Nonattainment MS Thresholds Applicable in Texas Ozone: Moderate (HGB and DFW): 100 tpy NOx or VOC Marginal (Bexar County): 100 tpy NOx or VOC Moderate NA Area for PM10 (City of El Paso): 100 tpy SO2 (portions of Titus, Rusk, Panola, Anderson and Freestone Counties) : 100 tpy Major Site? Nonattainment Major Source: Only in nonattainment area Only for nonattainment pollutant Moderate nonattainment area for ozone: 100 tpy NOX or VOC Marginal nonattainment area for ozone: 100 tpy NOX or VOC Moderate nonattainment area for PM10: 100 tpy Nonattainment area for SO2: 100 tpy

PSD NA Applicability 5/15/2018 Major Project? No Major Project? No Major Site? Federal NSR Yes Federal NSR Yes Pollutant Yes Determine Site PTE & PI Federal Modification? PI Significant? Yes No Federal NSR No No Federal NSR No Yes No No Federal NSR No If the site is an existing minor source, major NSR can still be triggered if the project is considered a “major project”. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No Significant NEI?

Major Projects 5/15/2018 New Major Source. For existing minor sources, PI is compared to MS threshold to determine if federal review is required (i.e., if it is a “major project”). Netting not performed. For PSD, if PI of one pollutant ≥ MS threshold, PI of all remaining pollutants are compared to MM thresholds/SER. Major Projects New Major Source Existing minor sources which have a project that is major “in and of itself” (i.e., the PI is greater than the major source threshold for that pollutant). Netting is not performed for pollutants where PI > MS threshold. Requires modeling protocol to be approved by Air Dispersion Modeling Team (ADMT) prior to completing Air Quality Assessment (AQA)

Example: New Major Site
DRAFT PSD NA Applicability Example: New Major Site 5/15/2018 Sitewide PTE = PI Greenfield site “named” source (40 CFR §52.21(b)(1)(iii)) MS threshold = 100 tpy Crude oil tank farm Proposed 500,000 bbls capacity PSD Example Attainment county = nonattainment review not applicable Greenfield site (sitewide PTE = PI) Crude oil tank farm > 300,000 bbls = named source for PSD, so MS threshold is 100 tpy. NNSR not applicable Attainment county

Example: New Major Site
DRAFT PSD NA Applicability 5/15/2018 Pollutant PTE = PI (tpy) PSD Major Modification Threshold (tpy) PSD review required? NOX 60 CO 75 VOC 120 PM/PM10/PM2.5 30 SO2 45 GHGs 13,000 40 Yes 100 No - Yes 25/15/10 Yes Example of a new Major Site. Attainment county = nonattainment review not applicable Greenfield site (sitewide PTE = PI) Crude oil tank farm > 300,000 bbls = named source for PSD Proposed PTE is equal to the Project Increase, and is: 60 tpy NOx 75 tpy CO 120 tpy VOC 30 tpy PM/PM10/PM2.5 45 tpy SO2, and 13,000 tpy of CO2 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. Major modification thresholds/SERs: 40 tpy NOx, 100 tpy CO, N/A for VOC (since it is a major project), 25 tpy PM, 15 tpy PM10, 10 tpy PM2.5, 40 tpy SO2, 75,000 tpy CO2 equivalents for Greenhouse Gases (GHGs) PSD review is required for VOCs, NOx, PM, PM10, PM2.5, SO2. PSD review is not required for CO and GHGs. 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 GHGs= greenhouse gases - For greenhouse gases (GHGs), PSD review must be triggered for another pollutant in order for PSD review to be potentially applicable for GHGs. 40 Yes 75,000 No At least one pollutant > 100 tpy major source threshold

Example: Major NNSR Project
DRAFT PSD NA Applicability 5/15/2018 Moderate nonattainment ozone area Existing minor source for VOCs and NOx Proposed one new facility and modification of one existing facility. There will also be one affected facility. For VOCs: Source New Facility Modified Facility Affected Facility Total Existing PTE (tpy) BAE (tpy) Proposed PTE (tpy) PTE Increase (tpy) PI (tpy) Example: Moderate NA area for ozone Existing minor source for VOCs and NOx Project involves one new source, one modified source, and one affected source Table showing Project Potential to Emit ( PTE), Baseline Actual Emissions (BAE) for one contaminant (VOCs): -New Source: Existing PTE is 0 tpy, BAE is 0 tpy, Proposed PTE is 30 tpy, PTE Increase is 30 tpy, Project Increase is 30 tpy. -Modified Source: Existing PTE is 50 tpy, BAE is 20 tpy, Proposed PTE is 60 tpy, PTE Increase is 10 tpy, and Project Increase is 40 tpy. -Affected Source: Existing PTE is 45 tpy, BAE is 20 tpy, Proposed PTE is 55 tpy, PTE Increase is 10 tpy, and Project Increase is 35 tpy. -Total Proposed PTE from all sources is 145 tpy, PTE Increase from all sources is 50 tpy, and PI from all sources is 105 tpy. VOC = volatile organic compounds NOX = oxides of nitrogen 50 45 95 20 40 30 60 55 145 30 10 50 30 40 35 105

Example: Major NNSR Project
DRAFT PSD NA Applicability Example: Major NNSR Project 5/15/2018 Moderate nonattainment ozone area Existing minor source for VOCs and NOx ratio: 1.15 to 1 For VOCs: Source PI (tpy) New Facility 30 Modified Facility 40 Affected Facility 35 Total 105 Since the site is an existing minor source for VOCs, major NSR review will only be triggered if the project is a major source “in and of itself” (i.e., it is a major project). Therefore, the project increase is compared against the major source threshold of 100 tpy, and it is determined that the project triggers nonattainment review for VOCs. Since the project is in a moderate ozone nonattainment area, the project increase of 105 tpy will be offset at a ratio of 1.15 to 1, which means that tpy of offsets will be required. This applicability determination will need to be repeated for NOx to determine whether nonattainment review is required for that pollutant. Additionally, the project will require a PSD applicability analysis for the applicable pollutants. VOC = volatile organic compounds NOX = oxides of nitrogen MS (tpy) 100 NA Review? Yes Offsets (tpy) 120.8

PSD NA Applicability 5/15/2018 Major Project? No Major Site? Pollutant Yes Determine Site PTE & PI Federal NSR Yes Federal Modification? PI Significant? Yes PI Significant? Yes No Federal NSR No Yes No No No Federal NSR No If the site is an existing major source, major NSR will be triggered if the project is a major modification. The first step in determining if the project is a major modification is to determine whether the project increase is significant by comparing to the netting thresholds for each pollutant. If the project increase is not significant, federal NSR is not triggered. If the project increase is significant, continue through the flowchart. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No Significant NEI?

PSD Significant Emission Rates (SERs)
DRAFT PSD NA Applicability 5/15/2018 Pollutant PSD SER (tpy)* NOx 40 CO 100 SO2 VOC PM 25 PM10 15 PM2.5 10 Pollutant PSD SER (tpy)* Pb 0.6 Fluorides 3 H2SO4 7 H2S 10 TRS GHG** 75,000 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

Example: Determining Project Increase (PI)
DRAFT PSD NA Applicability 5/15/2018 Named source Attainment area Project involves two modified facilities Pollutant Current Sitewide PTE (tpy) NOx 135 CO 131 VOC 51 PM/PM10/PM2.5 6.2 SO2 276 Site-wide PTE of at least one pollutant ≥ 100 tpy  Existing major source for all PSD pollutants. Example: Existing named source in attainment area Proposed project involving two modified facilities Since the current sitewide PTE of at least one pollutant is > 100 tpy (PSD MS Threshold for named sources), the site is considered an existing major source for all PSD pollutants. 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.

DRAFT PSD NA Applicability Example: Determining Project Increase (PI) 5/15/2018 Named source Attainment area Project involves two modified facilities Set BAE=0 to evaluate worst-case scenario Pollutant Facility 1 Facility 2 BAE Proposed PTE NOx CO VOC PM/PM10/PM2.5 SO2 ? 3.6 10.2 12.3 5.9 ? 5.3 4.5 8.9 3.2 7.5 A worst-case approach can be taken to determine that PSD review is not triggered for any pollutant: Assume BAE are zero PI=Proposed PTE-BAE (zero) This is, in-effect, demonstrating that if the total proposed PTE of all new, modified, and affected facilities for the project is less than the netting trigger or SER, netting and PSD review could not be triggered. 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

DRAFT PSD NA Applicability Example: Determining Project Increase (PI) 5/15/2018 Named source Attainment area Project involves two modified facilities PI = Proposed PTE - BAE Pollutant Facility 1 Facility 2 PI (tpy) BAE Proposed PTE NOx CO VOC PM/PM10/PM2.5 SO2 3.6 10.2 12.3 5.9 5.3 4.5 8.9 3.2 7.5 8.9 14.7 21.1 3.2 13.4 A worst-case approach can be taken to determine that PSD review is not triggered for any pollutant: Assume BAE are zero PI=Proposed PTE-BAE (zero) Table shows: All baseline actual emissions are zero Proposed PTE of facility 1: 3.6 tpy NOx, 10.2 tpy CO, 12.3 tpy VOC, 0 tpy PM/PM10/PM2.5, 5.9 tpy SO2 Proposed PTE of facility 2: 5.3 tpy NOx, 4.5 tpy CO, 8.9 tpy VOC, 3.2 tpy PM/PM10/PM2.5, and 7.5 tpy of SO2 Since PI = Proposed PTE-BAE and BAE have been set at a worst-case value of zero, the project increases are equal to the sum of the proposed PTE from the two facilities (8.9 tpy NOx, 14.7 tpy CO, 21.1 tpy VOC, 3.2 tpy PM/PM10/PM2.5, and 13.4 tpy SO2). 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

DRAFT PSD NA Applicability Example: Determining Project Increase (PI) 5/15/2018 Named source Attainment area Project involves two modified facilities PI < SER, PSD review is not required Pollutant PI (tpy) PSD MM Threshold/SER (tpy) PSD Review Triggered? NOx 8.9 40 CO 14.7 100 VOC 21.1 PM/PM10/PM2.5 3.2 25/15/10 SO2 13.4 No Project increases of 8.9 tpy NOx, 14.7 tpy CO, 21.1 tpy of VOC, 3.2 tpy of PM/PM10/PM2.5, and 13.4 tpy SO2 are below the PSD major modification thresholds of 40 tpy NOx, 100 tpy CO, 40 tpy VOC, 25 tpy PM, 15 tpy PM10, 10 tpy PM2.5, and 40 tpy SO2, so it can be concluded that PSD review is not required for any pollutant. This is, in effect, saying that if the total PTE of all new, modified, and affected facilities in the current project are less than the PSD major modification thresholds, the project increase could not be large enough to trigger netting or PSD review. This is just a worst-case approach. BAE can be used to determined the real Project Increase (PI=PTE-BAE). 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

NA Significant Emission Rates
DRAFT PSD NA Applicability 5/15/2018 Area Pollutant Current Designation Netting Trigger (tpy) SER (tpy) HGB and DFW Ozone as NOX or VOC Moderate 40 Bexar County Marginal El Paso PM10 15 Anderson County, et al SO2 Nonattainment 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

Example: Significant Project
DRAFT PSD NA Applicability Example: Significant Project 5/15/2018 Existing site Moderate ozone NA area Unnamed source major source for all PSD pollutants major source for one PSD pollutant Pollutant Current sitewide PTE (tpy) MS Threshold NA PSD NOx 300 100 250 CO 275 - VOC 50 PM/PM10/PM2.5 30 SO2 45 Major Source? NA PSD Yes - No Yes Example of a major modification: Existing site in a moderate ozone NA area. Unnamed source for PSD Current sitewide PTE of at least one PSD pollutant is greater than 250 tpy. Therefore, site is an existing major source for all PSD pollutants. We evaluate major source status for nonattainment separately. Since PTE of NOx is greater than 100 tpy MS threshold, site is an existing major source for NOx. Sitewide PTE of VOCs is less than the major source threshold, so the site is an existing minor source for VOCs. Important to note: NOx is regulated as a precursor to ozone, and through the NO2 NAAQS. Therefore, in an ozone nonattainment area, the federal applicability analysis should address NOx for both nonattainment and PSD. It is possible to trigger both NA and PSD review for NOx in the same project (NOx as a precursor to ozone, and NO2 NAAQS). 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 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 -

DRAFT PSD NA Applicability 5/15/2018 Existing site Moderate ozone NA area Unnamed source Project: one modified source (“Source 1”), one new source (“Source 2”) Pollutant NOx CO VOC PM/PM10/PM2.5 SO2 Source 1 Source 2 Total PI BAE 50 75 5 20 PTE 60 90 75 8 30 PI 10 15 25 3 BAE PTE 50 65 60 5 15 PI 50 65 60 5 15 60 80 85 8 25 For this example, the project involves one modified source (“source 1”), and one new source (“source 2”). The table shows source one with the following emissions: For NOx: BAE = 50 tpy, PTE = 60 tpy, and PI = 10 tpy. For CO: BAE = 75 tpy, PTE = 90 tpy, and PI = 15 tpy. For VOCs: BAE = 50 tpy, PTE = 75 tpy, and PI = 25 tpy. For PM/PM10/PM2.5: BAE = 5 tpy, PTE = 8 tpy, and PI = 3 tpy. For SO2: BAE = 20 tpy, PTE = 30 tpy, and PI = 10 tpy. Baseline actual emissions for all pollutants from source 2 are zero since it is a new source. Source 2 proposed PTE (and also the project increase of source 2) is: 50 tpy NOx 65 tpy CO 50 tpy VOC 5 tpy PM/PM10/PM2.5 15 tpy SO2 Total Project Increase (PI) is the addition of the project increase of both sources: 60 tpy NOX, 80 tpy CO, 85 tpy VOC, 8 tpy PM/PM10/PM2.5, and 25 tpy SO2. NOx = 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

DRAFT PSD NA Applicability Example: Significant Project 5/15/2018 First, determine whether the project is a major project for VOCs Use MS threshold instead of netting or major modification thresholds Pollutant PI (tpy) NOx 60 CO 80 VOC 85 PM/PM10/PM2.5 8 SO2 25 NA MS Threshold Major NA Project for VOCs? First, since we determined that the site is an existing minor source of VOCs for ozone nonattainment, we need to determine whether the project is a major project for VOCs. To do this, compare the project increase against the moderate ozone nonattainment threshold of 100 tpy. Since the project increase of 85 tpy is less than the major source threshold of 100 tpy, the project is not a major project, and nonattainment review is not required for VOCs. 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 100 No

DRAFT PSD NA Applicability Example: Significant Project 5/15/2018 Next, determine whether the project is significant for remaining pollutants Compare PI against MM threshold/SER for each pollutant Pollutant PI (tpy) Netting Trigger Netting Triggered? NA PSD NOx 60 CO 80 VOC 85 N/A - PM/PM10/PM2.5 8 SO2 25 40 - 40 100 25/15/10 Yes - Yes No 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

PSD NA Applicability 5/15/2018 Major Project? No Major Site? Pollutant Yes Determine Site PTE & PI Federal NSR Yes Federal Modification? PI Significant? Yes No Federal NSR No Yes No No Federal NSR No For all pollutants which have a project increase greater than the netting threshold, determine the net emissions increase using contemporaneous netting. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes Determine NEI Yes No Significant NEI?

Contemporaneous Netting
DRAFT PSD NA Applicability Contemporaneous 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 ≥ Netting threshold For PSD, netting threshold = MM threshold/SER Netting Ensures smaller projects do not add up to be a major modification Applies to existing major sources only IF Project Emissions Increase ≥ netting threshold/Significant Emission Rate (SER) Per pollutant Emission changes within contemporaneous period Emissions changes: Now may consider decreases Includes current project Conducted per pollutant Emission changes within contemporaneous period (additional information can be found in the speaker notes)

Contemporaneous Period
DRAFT PSD NA Applicability 5/15/2018 Start of Contemporaneous Period End of Contemporaneous Period Application Received 2015 2019 2020 2022 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.

Creditable Increases and Decreases
DRAFT PSD NA Applicability 5/15/2018 Increases During contemporaneous period Confirmed by Emissions Inventory Include planned projects prior to SOO Not previously relied upon in issuing Major NSR Permit During contemporaneous period Decreases Only amount that new PTE is less than BAE. 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: Can only claim reduction in the amount that BAE exceeds new PTE. Not Required to Meet Permit / State Implementation Plan (SIP) Must Be Enforceable if facility is authorized by NSR permit, reduce allowable emission rate if facility authorized by SP or PBR, complete APD-CERT or PI-7 CERT 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. Must be real and enforceable prior to SOO Not required to meet Permit / SIP Not previously relied upon in issuing Major NSR Permit (PSD or NA) or used as an offset

Project Contemporaneous Changes
DRAFT PSD NA Applicability 5/15/2018 Table 3F Demonstrate on Table 3F All increases and decreases within netting window, including current project Project Contemporaneous Changes All Increases and Decreases, Including Current Project Include emission point numbers (EPNs), Project Numbers, Permit Numbers, and baseline period used for each project Table 3F can be found on the TCEQ web site at Include EPNs, Project and Permit Nos., and Baseline Period(s)

Creditable Decreases DRAFT PSD NA Applicability 5/15/2018 Table 4F Complete a Table 4F for each decrease. 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 Statements verify that claimed decreases are creditable.

Contemporaneous and BAE Period
DRAFT PSD NA Applicability Contemporaneous and BAE Period 5/15/2018 Application Received 2019 Prior Project SOC 2020 SOO 2022 Current project 24-month BAE 2015 10-year BAE period for prior project Prior Project 24-month BAE Contemporaneous Period 2006 2010 Contemporaneous and Baseline Actual Emissions (BAE) Period -established as five years prior to the proposed start of construction of the current project through to the proposed start of operation of the current project. Sum all creditable increases and decreases within the contemporaneous period. Baseline actual emissions are established as the actual emissions from a consecutive 24-month period within the 10 years prior to the project. For the current project, this is the 10 years from the date an application is administratively complete. For prior projects which appear within the netting window, this is the 10 years from the date the project is authorized or modifications are operated. 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. Baseline period for electric generating units (EGUs) is limited to last five years. 10-year BAE period for current project

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

PSD NA Applicability 5/15/2018 Major Project? No Major Site? Pollutant Yes Determine Site PTE & PI Federal NSR Yes Federal Modification? PI Significant? Yes No Federal NSR No Yes Yes No No Federal NSR No The last step in the flowchart is to compare the NEI to the major modification threshold for each pollutant. If the NEI is less than the MM threshold, Federal NSR is not required. If the NEI is greater than the MM threshold, Federal NSR is required for that pollutant. The original flowchart can be found in the Federal NSR Applicability Guidance Document on the TCEQ web site located at Determine NEI Yes No No Significant NEI? Significant NEI?

Example: Netting DRAFT PSD NA Applicability 5/15/2018 Adding new tanks, loading dock, and control device to existing site Attainment for all pollutants Existing named major source Pollutant NOX CO VOC PM/PM10/PM2.5 SO2 GHGs Netting Triggered? NEI (tpy) PI (tpy) PSD SER PSD Review Required? 70 110 52 30 45 85,500 40 100 25/15/10 75,000 Yes N/A 56 73 47 27 32 N/A Yes No Example: Netting Addition of new tanks, loading dock, and control device to existing site. Attainment for all pollutants. Existing named major source for PSD Show calculation of PI on Table 2F, and calculation of NEI on Table 3F (for each pollutant). Project increases of 70 tpy NOx, 110 tpy CO, 52 tpy VOC, 30 tpy PM/PM10/PM2.5, and 45 tpy SO2. Compare PI against PSD SER of 40 tpy NOx, 100 tpy CO, 40 tpy VOC, 25 tpy PM, 15 tpy PM10, 10 tpy PM2.5, and 40 tpy SO2 to show that netting is triggered for each pollutant. Net emission increases of 56 tpy NOx, 73 tpy CO, 47 tpy VOC, 27 tpy PM/PM10/PM2.5, and 32 tpy of SO2 are compared against the same significant emission rates to determine whether PSD review is required. Result is PSD review required for NOx, VOC, PM, PM10, and PM2.5, but not for CO and SO2. Since PSD review has been triggered for a non-GHG pollutant, we now compare the GHG project increase of 85,500 CO2 equivalents to the PSD significant emission rate of 75,000 tpy CO2 equivalents to see that PSD review has been triggered for GHGs as well. Note: in this case, PM=PM10=PM2.5, but emissions of each of these species is compared against it’s own SER. NEI = Net Emissions Increase SER = Significant Emission Rate 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 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 Yes

PSD and Nonattainment Review
DRAFT PSD NA Applicability 5/15/2018 Additional requirements for PSD or Nonattainment reviews: Review of RBLC Database Additional notification requirements Preparation of Preliminary Determination Summary (reviewer) PSD: Nonattainment: BACT evaluation Additional modeling requirements LAER evaluation Alternative site analysis Tables 4N, 6N and 9N Obtain offsets If PSD or NA review is triggered: Additional notification requirements Preparation of Preliminary Determination Summary (PDS) by the permit reviewer. Review requires RBLC database search Note: also look at TCEQ permits. BACT and LAER will not be less stringent than state-level determinations. If PSD review is triggered: BACT control determination Additional modeling requirements If Nonattainment review is triggered: Must meet LAER Obtain offsets before start of operation Provide an alternative site analysis, and Submit Tables 4N, 6N, and 9N

Contacts 5/15/2018 Katherine Quinlan Cheryl Covone Contacts: Katherine Quinlan Cheryl Covone Note that additional details on this presentation are available in the Speaker Notes and Expanded Outlines.

PSD / Nonattainment Review / Netting Basics

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