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NETTING

NETTING. NETTING. Rick Goertz, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2013. NETTING!. The Netting Zone!. Why Do Netting?. How do you know if a modification is a “major modification” triggering major NSR?

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NETTING

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  1. NETTING NETTING Rick Goertz, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2013

  2. NETTING!

  3. The Netting Zone!

  4. Why Do Netting? How do you know if a modification is a “major modification” triggering major NSR? You conduct a “netting” exercise.

  5. About Netting • Applies to existing major sources only. • Ensures smaller projects do not add up to be a major modification. • An evaluation of : • The current project, plus • Increases and decreases within the contemporaneous period (netting window).

  6. Contemporaneous PeriodNetting Window Five years before start of construction Proposed start of operation

  7. NettingContemporaneous Period

  8. Netting Window • Modifications identified within the contemporaneous period may be based on: • The date the modification was authorized, or • The date the change is operated. • Must be used consistently. • Indicate which method is used.

  9. Creditable Emissions • Occurs during the contemporaneous period. • Cannot have been relied upon in issuing a major NSR permit for the source. • Sources/activities authorized by the major NSR permit are not in operation when the current increase is authorized. • Rely on Emissions Inventory.

  10. Creditable Increases • The new level of emissions exceeds the baseline actual emission rate. (PTE – Baseline = Increase) • Does not include emission increases at facilities under a plant-wide applicability limit (PAL).

  11. Creditable Decreases • The baseline actual emission rate exceeds the new level of emissions. • Enforceable at and after the time that project modification begins to operate. (Must be enforceable and real before the unit starts operation).

  12. Creditable EmissionsCont’d • Identify increases and decreases in TCEQ Table 3F. • The project number that authorized the modification • Provide an explanation if a project is not included in the evaluation. • Eachcreditable decrease should be accompanied by TCEQ Table 4F.

  13. Determining Increases and Decreases • Increases and decreases for each project within the contemporaneous period are determined based on a comparison of the following: • Baseline actual emission rate, and • The PTE of that project (projected actuals are not used in this step except for the current project).

  14. Baseline Actual Emission Rate • 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.

  15. Using an Allowable to Allowable Comparison Situation #1: the baseline actual > current PTE Situation #2: a new facility is within 2years of its initial start-up date

  16. Netting Window Example

  17. Net Emissions Increase Project increase + Non-project source-wide creditable contemporaneous emission increases • Source-wide creditable contemporaneous emission decreases The amount that exceeds zero

  18. Triggering Major NSR • Compare the net increases to the appropriate significant emission rate. • If the increase is greater than or equal to the significant emission rate for the pollutant, major NSR is required.

  19. Time for some examples!

  20. Example 1 Company is a named major source, in a serious nonattainment area. • Current PTE = 50 Tons/year NOX • Proposed PTE = 60 Tons/year NOX • Baseline Actual = 47 Tons/year NOX • Project Increase = 13 Tons/year NOX (Proposed PTE – Baseline Actual) Current PTE = 50 Tons/year NOX Proposed PTE = 60 Tons/year NOX Baseline Actual = 47 Tons/year NOX Project Increase= 13 Tons/year NOX (Proposed PTE-Baseline Actual)

  21. Example 1Cont’d Emission increase exceeds the netting significance level of 5 Tons/year. Netting is required! Major Source, Serious Nonattainment, Current PTE = 50, Proposed PTE = 60, Baseline Actual = 47, Project Increase = 13

  22. Example 1Table 3F NOx

  23. Example 1Finding Total Increase Current Project 13 Tons/year increase 11/2010 Project 5 Tons/year increase 10/2011 Project 0.25 Tons/year increase - 4.25 Tons/year decrease Total Increase: 14 Tons/year Current Project 13 Tons/year increase 11/2010 Project 5 Tons/year increase 10/2011 Project 0.25 Tons/year increase - 4.25 Tons/year decrease Total Increase: 14 Tons/year

  24. Example 1Nonattainment? The major modification significant emission rate for a severe nonattainment area is 25 Tons/year. Net project increase is 14 Tons/year. The project is not a “major modification” and major NSR (nonattainment review) is not required.

  25. Check Your Calculations!

  26. Example 2 Company is a named major source located in a serious nonattainment area. Company has four steam boilers operating under a cap. Boiler 1: 25 Tons/year NOX Boiler 2: 25 Tons/year NOX Boiler 3: 25 Tons/year NOX Boiler 4: 25 Tons/year NOX Current PTE: 100 Tons/year NOX

  27. Example 2Cont’d Company request : • Increase firing rate of one boiler, its NOX emissions increase by 3 Tons/year. • New contribution of one boiler is now 28 Tons/year NOX.

  28. Example 2More Data Current PTE = 100 Tons/year NOX Proposed PTE = 103 Tons/year NOX Baseline Actual = 90 Tons/year NOX

  29. Example 2Is Netting Required? Is the project increase significant such that netting is required? Company proposes: 28 Tons/year – 25 Tons/year = 3 Tons/year NOX increase Is this a valid approach?

  30. Example 2Answer NNNooooooooooo ! It’s not a valid approach... Should we ask why ?

  31. Example 2Explanation • The cap is increased from 100 Tons/year to 103 Tons/year. • The cap is being increased for “all boilers.” • Increasing the cap means relaxing a federally enforceable emission limit. • All units under the increased cap are modified.

  32. Example 2Is Netting Required? Is the project increase significant? 103 Tons/year (Proposed PTE) – 90 Tons/year (Baseline actual) 13 Tons/year NOX increase The project increase is significant (increase> 5 Tons/year) so... Netting is required!

  33. Example 2An Alternate Approach • Set a separate enforceable limit for the affected boiler. • Project increases are determined based on the individual boiler rather than for all the boilers. • Netting may be avoided.

  34. Example 3 A small tank farm with three emission points has three projects (modifications) within the contemporaneous period, including the current project.

  35. Example 3 Current Proposal Table Using the traditional method, the total increase would be 35 tpy (8+17+10). Of that 35 tpy, 28 tpy (8+10+10) are attributable to EPN1.

  36. Example 3Cont’d The increase is greater than the final allowable emission rate (26 tpy) indicating that portions of the increase have been counted more than once. Increases in emissions can be better reflected by using the endpoints method for EPN 1.

  37. Increase or Decrease Increase = Final PTE – Baseline actuals from earliest project. Net increase is 16 tpy (26 tpy – 10 tpy). Method can only be used when determining net emissions increase. Baseline always used to determine project increase.

  38. Example 3Endpoints Netting Using endpoints netting: The contribution of EPN 1 = 16 tpy The total project net increase = 23 tpy

  39. Example 3 Table 3F

  40. Now you are ready Now you are ready to go out into the world and NET! Disclaimer: The presenter does not guarantee the hearing of sound effects during the performance of actual netting exercises.

  41. THE END Thank You, Thank You Very Much.

  42. Contacts JOHNNY VERMILLION (512) 239-1292 Or Rick Goertz (512)239-5606

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