Implications of Greenhouse Gas
(GHG), Volatile Organic
Compounds (VOC), and Fine
Particulate (PM2.5)
to Air Quality Permit...
Agenda





Overview of New Source Review (NSR)
Major Modification
VOC, GHG, and PM2.5 Emissions Under NSR
• VOC
• GHG
...
New Source Review


Construction permits for major new sources or
major modifications fall under the “Major New
Source Re...
NAAQS Summary
Averaging Period

NAAQS (µg/m3)

1-Hour

40,000

8-Hour

10,000

Ozone

8-Hour

75 ppb

Pb

3-Month Rolling
...
NSR Applicability


NSR can apply to:
• New major sources.
• Modifications to existing major sources.
• Modifications to ...
NSR Major Modification


Major modification means any physical change in
or change in the method of operation of a major
...
Assessing VOC Permitting




NNSR applies for non-attainment areas and areas
in the Ozone Transport Region.
NNSR signifi...
Assessing GHG Permitting


8

May 2010: Prevention of Significant Deterioration
(PSD) and Title V Greenhouse Gas Tailorin...
Assessing GHG Permitting


July 2012: Step 3 amendments and streamlining
options.
• Step 1 and Step 2 PSD and Title V GHG...
GHG Permitting


Currently must address GHG in all applications.
• Demonstrate PSD status.
• Best Available Control Techn...
GHG Standards


NSPS/NESHAP requirements for energy efficiency.
• Output based standard in current EGU proposal.




Qu...
PM2.5 PSD Permitting








PM2.5 emissions may not have been quantified
previously.
Precursor emissions (NOX and SO2...
PM2.5 NNSR Permitting


NNSR pollutants trigger only that pollutant for
NNSR permitting.
• Facility 100 tpy PM2.5 – Signi...
PM2.5 Emission Testing


Method 201A for sizing of particulate.
• Difficult to use on wet sources.
• May need to utilize ...
Future Planning


Strategic planning for facility future must consider
implications of both new air rule applicability an...
PAL Option






16

“Plantwide Applicability Limitation” (PAL) is an
available regulatory option that can potentially
...
PAL Planning Approach







17

Develop historic facility-wide baseline emission
rates and potential PAL levels.
Addr...
Questions/Comments

John Slade| jslade@all4inc.com | (610) 933-5246 x136
Dan Holland | dholland@all4inc.com | (610) 933-52...
Upcoming SlideShare
Loading in …5
×

Implications of Greenhouse Gas (GHG), Volatile Organic Compounds (VOC), and Fine Particulate (PM2.5)

1,116 views
878 views

Published on

John Slade and Dan Holland of All4 Inc. present "Implications of Greenhouse Gas (GHG), Volatile Organic Compounds (VOC), and Fine Particulate (PM2.5) to Air Quality Permitting". The presentation provides an overview of the implication of newly adopted rules to New Source Review (NSR), major modifications, emissions under NSR, and flexibility in air permitting.

Published in: Technology
0 Comments
0 Likes
Statistics
Notes
  • Be the first to comment

  • Be the first to like this

No Downloads
Views
Total views
1,116
On SlideShare
0
From Embeds
0
Number of Embeds
337
Actions
Shares
0
Downloads
15
Comments
0
Likes
0
Embeds 0
No embeds

No notes for slide

Implications of Greenhouse Gas (GHG), Volatile Organic Compounds (VOC), and Fine Particulate (PM2.5)

  1. 1. Implications of Greenhouse Gas (GHG), Volatile Organic Compounds (VOC), and Fine Particulate (PM2.5) to Air Quality Permitting John Slade | jslade@all4inc.com | (610) 933-5246 x136 Dan Holland |dholland@all4inc.com | (610) 933-5246 x115 November 6, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324
  2. 2. Agenda    Overview of New Source Review (NSR) Major Modification VOC, GHG, and PM2.5 Emissions Under NSR • VOC • GHG • PM2.5  2 Flexibility in Air Permitting Your environmental compliance is clearly our business.
  3. 3. New Source Review  Construction permits for major new sources or major modifications fall under the “Major New Source Review (NSR)” rules. There are 2 types: • Prevention of Significant Deterioration (PSD) permits in attainment areas. • Non-attainment New Source Review (NNSR) permits in non-attainment areas.  3 Major NSR permits are required prior to commencing construction. Your environmental compliance is clearly our business.
  4. 4. NAAQS Summary Averaging Period NAAQS (µg/m3) 1-Hour 40,000 8-Hour 10,000 Ozone 8-Hour 75 ppb Pb 3-Month Rolling 0.15 PM10 24-Hour 150 24-Hour 35 Annual 12 1-Hour 188 Annual 100 1-Hour 196 3-Hour 1,300 Pollutant CO PM2.5 NO2 SO2 4 Your environmental compliance is clearly our business.
  5. 5. NSR Applicability  NSR can apply to: • New major sources. • Modifications to existing major sources. • Modifications to existing minor sources.   5 Major source criteria is based on “potential to emit”. Major modification criteria is based on “net emissions increase”. Your environmental compliance is clearly our business.
  6. 6. NSR Major Modification  Major modification means any physical change in or change in the method of operation of a major stationary source that would result in: • a significant emissions increase (as defined in paragraph (b)(40) of this section) of a regulated NSR pollutant (as defined in paragraph (b)(50) of this section) and • a significant net emissions increase of that pollutant from the major stationary source. 6 Your environmental compliance is clearly our business.
  7. 7. Assessing VOC Permitting   NNSR applies for non-attainment areas and areas in the Ozone Transport Region. NNSR significance levels are less than PSD levels. • Precursor pollutant (NOX).  Degree of non-attainment is considered. • 25 tons for VOC and NOX in severe non-attainment areas. • Emission Reduction Credits (ERCs) required at a ratio of 1.3 to 1.  7 Lowest Achievable Emission Rate (LAER). Your environmental compliance is clearly our business.
  8. 8. Assessing GHG Permitting  8 May 2010: Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule (GHG Tailoring Rule). • January 2011: Step 1 - GHG air permitting began for facilities that would otherwise require permitting. • July 2011: Step 2 - GHG permitting began for all facilities that would emit more than 100,000 tons of CO2e per year and facilities that undergo modification that would increase emissions by 75,000 tons of CO2e per year. • July 2012: Step 3 amendments and streamlining options. Your environmental compliance is clearly our business.
  9. 9. Assessing GHG Permitting  July 2012: Step 3 amendments and streamlining options. • Step 1 and Step 2 PSD and Title V GHG thresholds not changed. • Revisions to 40 CFR Part 52 for better implementation of establishing PALs for GHG emissions. 9 Your environmental compliance is clearly our business.
  10. 10. GHG Permitting  Currently must address GHG in all applications. • Demonstrate PSD status. • Best Available Control Technology (BACT) analysis.  Full GHG emission inventories required in renewal applications. • “Major source” label for another pollutant.  Tailoring Rule Step 4 by April 2016. • Thresholds could be lowered. 10 Your environmental compliance is clearly our business.
  11. 11. GHG Standards  NSPS/NESHAP requirements for energy efficiency. • Output based standard in current EGU proposal.   Questionable GHG control technologies. Energy efficiency requirements. • Introduced in “Boiler MACT.” • Could be part of Step 4. • Could be added to existing standards. 11 Your environmental compliance is clearly our business.
  12. 12. PM2.5 PSD Permitting     PM2.5 emissions may not have been quantified previously. Precursor emissions (NOX and SO2) need to be considered. Significance Level for PM2.5 is 10 tpy. Air quality modeling for PM2.5 is difficult. • No “exemption” modeling via SILs. • May trigger ambient monitoring requirements. 12 Your environmental compliance is clearly our business.
  13. 13. PM2.5 NNSR Permitting  NNSR pollutants trigger only that pollutant for NNSR permitting. • Facility 100 tpy PM2.5 – Significance Level 10 tpy. • Facility 100 tpy NOX – Significance Level 40 tpy. • Facility 100 tpy SO2 - Significance Level 40 tpy.  Must offset PM2.5 increase with emission reduction credits (ERCs). • ERCs are difficult to find and expensive to secure. • May need to demonstrate ERCs can be used.  13 Lowest Achievable Emission Rate (LAER) Control Technology is required. Your environmental compliance is clearly our business.
  14. 14. PM2.5 Emission Testing  Method 201A for sizing of particulate. • Difficult to use on wet sources. • May need to utilize Method 5 and scale results.  Method 202 for condensable particulate matter. • Blank correction requires extended sampling times. • Artifact formation may occur with long sampling times.  Other test methods allowed. • API Wet Stack Method. • U.S. EPA Conditional Test Method 039. 14 Your environmental compliance is clearly our business.
  15. 15. Future Planning  Strategic planning for facility future must consider implications of both new air rule applicability and air permitting implications: • New rules likely require facility changes. • No exemption for pollution control projects. • Permitting issues can impact project design. 15 Your environmental compliance is clearly our business.
  16. 16. PAL Option    16 “Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease air permitting PSD cycle. Federal PSD rule provides for PALs based on historic actual emissions. PALs are pollutant specific and could be a critical part of a facility strategic plan. Your environmental compliance is clearly our business.
  17. 17. PAL Planning Approach     17 Develop historic facility-wide baseline emission rates and potential PAL levels. Address potential NAAQS issues. Consider new rules, facility operations plans, potential energy efficiency improvements, new technologies, low hanging fruit for emissions reductions. Weigh value of PAL for each pollutant. Your environmental compliance is clearly our business.
  18. 18. Questions/Comments John Slade| jslade@all4inc.com | (610) 933-5246 x136 Dan Holland | dholland@all4inc.com | (610) 933-5246 x115 www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324

×