Prevention of Significant Deterioration (PSD) Program

1. Part of NSR Program Applicable to Major Sources in Areas Attaining the NAAQS Prevention of Significant Deterioration (PSD) Program

2. Re-cap of Permitting Process • Description of PSD Program Requirements • Main Requirements Summary Presentation Outline

3. Start Are the source proposed emissions ≥ applicable thresholds or emission rates? (per pollutant, may include fugitives) Is source in an area that is attaining or nonattaining the NAAQS? Is the permit for a new source or a modification to an existing source? Is the source exempted? Source not subject to NSR No APPLICABILITY Permitting Process Simplified Public hearing Yes • Reviewing authority reviews: • Application • Proposed/Required Control • Technologies • Compliance with other • applicable requirements Source owner submits permit application Draft permit developed Final permit Issued 30 day comment period APPLICATION After appeal process ends, permit is finally approved or revoked. Usually appealed within 30 days of final permit decision EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. End APPEALS

4. Applicability: New and Modified Sources • New sources locating in attainment areas with air emissions equal to or higher than 100 or 250 tons per year (tpy), higher thresholds for Greenhouse Gases (GHGs) • Modifications to existing sources in attainment areas with a net emissions increase higher than the Significant Emissions Rate • Regulated pollutants: NAAQS, GHGs and other pollutants • NAAQS: Carbon Monoxide (CO), Lead (Pb), Nitrogen Dioxide (NO2), Ozone, Particulate Matter (PM), and Sulfur Dioxide (SO2) • Greenhouse Gases: Carbon dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O), Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs) and Sulfur Hexafluoride (SF6) • Other Pollutants Include: Sulfuric Acid Mist (H2SO4), Hydrogen Sulfide (H2S) • Excludes Air Toxics: Mercury (Hg), Cadmium (Cd), Benzene (C6H6), etc.

5. Applicability: Thresholds Attainment Areas

6. Applicability: New Sources • Emissions calculations are based on Potential to Emit, includes fugitive emissions if the source is part of the 28 source category list • It can also consider limitations on source operation and emission controls • Thresholds: 250 tpy for most source categories, 100 tpy for 28 listed source categories (same categories for which fugitives are accounted for) • Higher thresholds for GHGs Determine source’s Potential to Emit (PTE) (per pollutant, may include fugitives) Is PTE ≥ applicable threshold? (per pollutant) Source not subject to PSD Start No Source subject to PSD Yes

7. Applicability: Modifications • Emissions calculations are based on Actual Emissions – “day-to-day” emissions at the source • Actual emissions = projected emissions after the change – baseline emissions before the change (actual-to-projected actual test) • Baseline emissions: average of any 24 consecutive months of emissions within 10 yrs prior to project (5 yrs for electric utilities) • Projected emissions: max. annual emissions (tpy) that will occur during any one of 5 yrs after project • If unit was unpermitted or is added, emission increase based on PTE • Includes fugitive emissions if source is part of the 28 source category list

8. Applicability: Modifications (Continued) Major modification = one that results in (1) a significant emissions increase from the project and (2) a significant net emissions increase (NEI) • Significant Emission Rate (SER) – emissions rate limit in tpy, by pollutant • NEI = Sum of contemporaneous emissions increases and decreases to the proposed modification emissions increase/decrease • Under PSD, contemporaneous period starts 5 years before the source commences construction and ends when the source commences operation Are Proposedmodification emissions ≥ SER?(per pollutant) Determine Source’s Net Emissions Increase (NEI), (per pollutant) Modification is a major modification and subject to Major NSR Is the NEI ≥ SER? Start Yes Yes No Modification not subject to Major NSR No

9. Applicability: Steps • As with the Tribal NA NSR program, NSR applicability is determined for all new and modified units at the source • New units – applicability based on PTE • Modified units – applicability based on actual emissions • Includes all regulated NSR pollutants that the source emits • Source emissions are calculated using: • On-site measurement (e.g. stack testing) • Vendor design capacity or rated capacity information • Material (i.e. mass balance) balance calculations • Emission factors • The annual maximum emissions from all production processes/equipment are added for each regulated NSR pollutant

10. Applicability: PSD Thresholds for GHGs

11. Applicability: GHG Emissions Calculations • The following example illustrates the method to calculate GHG emissions on both a mass basis and CO2e basis • A proposed emissions unit emits five of the six GHG compounds in the following amounts (Global Warming Potentials for each compound included in parenthesis): • 50,000 TPY of CO2 (GWP = 1) • 60 TPY of methane (GWP = 21) • 1 TPY of nitrous oxide (GWP = 310) • 5 TPY of HFC-32 (a hydrofluorocarbon) (GWP = 650) • 3 TPY of PFC-14 (a perfluorocarbon) (GWP = 6,500) • GHGs mass-based emissions: • 50,000 TPY + 60 TPY + 1 TPY + 5 TPY + 3TPY = 50,069 TPY • CO2e-based emissions: • (50,000 TPY x 1) + (60 TPY x 21) + (1 TPY x 310) + (5 TPY x 650) + (3 TPY x 6,500) = 50,000 + 1,260 + 310 + 3,250 + 19,500 = 74,320 TPY CO2e

12. Applicability: Other Circumstances New Source or Modified Source Might be Subject to PSD • Concept known as “Major for One Major for All” • Mainly Applicable to New Sources Determine PTE of other pollutants that are below thresholds (per pollutant) Is PTE ≥ applicable SER? (per pollutant) Source is major for PSD for one pollutant Pollutant not subject to PSD Start No Pollutant subject to PSD Yes

13. Applicability: New or Modified Source not Subject to PSD • PTE less than thresholds • Source is “grandfathered” • Source opted for “synthetic minor” permit Major Source Threshold

14. Start Are the source proposed emissions ≥ applicable thresholds or emission rates? (per pollutant, may include fugitives) Is source in an area that is attaining or nonattaining the NAAQS? Is the permit for a new source or a modification to an existing source? Is the source exempted? Source not subject to NSR No APPLICABILITY Permitting Process Simplified Public hearing Yes • Reviewing authority reviews: • Application • Proposed/Required Control • Technologies • Compliance with other • applicable requirements Source owner submits permit application Draft permit developed Final permit Issued 30 day comment period APPLICATION After appeal process ends, permit is finally approved or revoked. Usually appealed within 30 days of final permit decision EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. End APPEALS

15. Application: PSD Program Requirements • Main requirements: • Install Best Available Control Technology (BACT) • Perform air quality analysisto assess impacts on air quality • Performclass I area analysis toassess impacts onnational parks and wilderness areas • Perform additional impacts analysis • Allow for opportunities for public involvement

16. Application: Best Achievable Control Technology (BACT) • Pollutant specific emissions limit, case-by-case • Takes into account energy, environmental, or economic impacts • Limit must be at least as stringent as applicable: • New Source Performance Standard (NSPS) and/or • National Emission Standard for Hazardous Air Pollutants (NESHAP) • Selected by “Top Down” BACT analysis • Identify all available control technologies • Eliminate technically infeasible control options • Rank remaining control technologies by its effectiveness (considers economic, energy and environmental impacts) • Evaluate most effective controls and document results • Select BACT

17. Application: Air Quality Impact Analysis (AQIA) • Pollutant specific analysis that involves: • An assessment of existing air quality and • Modeling estimate of ambient concentrations from proposed project and future growth associated with project • Purpose is to determine if new plus existingemissions will cause or contribute to a violation of a: • NAAQS and/or • PSD increment

18. Application: AQIA for Increment Compliance • A new source or modification cannot cause or contribute to significant deterioration of air quality in attainment areas • Maximum amount of deterioration allowed is called an increment • Increments exist for: • 3 pollutants (PM--PM10 and PM2.5, SO2 and NO2) • Various averaging periods (annual, 1-hour) • 3 area classifications (Class I, Class II, Class III)

19. Application: AQIA for Increment Compliance (Continued) • Change in air quality measured against a certain baseline • Not all sources consume increment • Two important concepts apply: • Baseline area • All portions of the attainment area in which the PSD applicant proposes to locate and/or would have a significant ambient impact (i.e. higher than Significant Impact Level) • Limited to intrastate areas: baseline areas not triggered across state lines • Baseline date • When increment consumption starts, pollutant specific

20. Application: AQIA for Increment Compliance (Continued) • Baseline Date(s) - when increment consumption starts, pollutant specific Minor Source Baseline Date when actual emission changes from all sources affect the available increment Date of first complete permit application Major Source Baseline Date when actual emissions associated with construction at a major source affect increment SO2 and PM - Jan. 6, 1975 NOx - Feb. 8, 1988 Start

21. Application: AQIA for NAAQS Compliance • A new source or modification cannot cause or contribute to a violation of any NAAQS in any area • Compliance with any NAAQS is based on proposed source and all other sources in baseline area • No baseline dates exist • Analysis requirements similar to increment analysis • NAAQS analysis independent from increment analysis

22. Application: AQIA Steps • Compliance determined by using air quality models • Preliminary analysis (significant impact analysis) • Screening type models • Representative meteorology • Only proposed source emissions • Refined receptor grids • Full impact analysis (cumulative impact analysis) • Refined model • Representative meteorology • All applicable increment affecting sources • More refined receptor grids (smaller grid spacing)

23. Application: Class I Area Impact Analysis • Evaluation of NAAQS, PSD increments and Air Quality Related Values (AQRVs) when a major source’s emissions may affect a Class I area • Class I Area – areas reserved for special air quality protection, usually national parks and wilderness areas • AQRVs – feature or property of a Class I Area that may be affected by a change in air quality; differ for each Class I area • Generally for sources within 100 km of Class I area, not always • Federal Land Manager (FLM) must be notified of potential impacts • Determines data and analyses needed

24. Application: Additional Impact Analysis • Assesses potential effects of increased air, ground and water pollution from proposed source and associated growth on: • Soils and Vegetation • Visibility • Pollutant specific • Performed within the impact area of the proposed source

25. Application: Public Involvement • Reviewing authority is required to provide: • Public notice to the affected community and the general public on the draft permit • At least a 30 day public comment period on the draft permit • Opportunity for public hearing on draft permit, if requested by public • All public comments must be considered before a final permit is developed • A Technical Support Document (TSD), generally including responses to comments, may also be available with the final permit

26. Start Are the source proposed emissions ≥ applicable thresholds or emission rates? (per pollutant, may include fugitives) Is source in an area that is attaining or nonattaining the NAAQS? Is the permit for a new source or a modification to an existing source? Is the source exempted? Source not subject to NSR No APPLICABILITY Permitting Process Simplified Public hearing Yes • Reviewing authority reviews: • Application • Proposed/Required Control • Technologies • Compliance with other • applicable requirements Source owner submits permit application Draft permit developed Final permit Issued 30 day comment period APPLICATION After appeal process ends, permit is finally approved or revoked. Usually appealed within 30 days of final permit decision EPA issued permits may be appealed through EPA’s Environmental Appeals Board (EAB). After EAB process, permits may be appealed in Federal Court. End APPEALS

27. Appeals • Provisions for permit appeals available under the program, same as Tribal NA NSR and minor NSR program • Appeals are conducted through the EPA’s Environmental Appeals Board (EAB) • If all remedies for permit appeal through the EAB are exhausted, person may appeal to Federal Court

28. Key Points to Remember:PSD • Program for major sources located in attainment areas (generally for emissions at or higher than 100 or 250 tpy) • Pollutants regulated: NAAQS, GHGs, other pollutants • Main requirement: Best Available Control Technology (BACT) • Permits are usually issued no later than 1 year after the date the permit application is deemed complete

29. Appendix

30. 28 PSD Source Categories

31. Significant Emission Rates (SERs) SER– a rate of emissions that would equal or exceed any of the following rates: Notwithstanding the above, any emissions rate or any net emissions increase associated with a major stationary source or major modification, which could construct within 10 km of a Class I area, and have an impact on such area equal to or greater than 1 g/m3 (24-hour average)