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.

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. Agenda

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
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. 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. 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. 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. 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. 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.

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Lowest Achievable Emission Rate (LAER).
Your environmental compliance is clearly our business.

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. 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. 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. 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. PM2.5 PSD Permitting


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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. 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.

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Lowest Achievable Emission Rate (LAER) Control
Technology is required.
Your environmental compliance is clearly our business.

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. 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. PAL Option


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“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. PAL Planning Approach


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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. 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