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Emissions Exclusion Guidance and Examples

Sean O’Brien Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014. Emissions Exclusion Guidance and Examples. Netting. De minimis threshold test For PSD and Nonattainment NSR Reform added: Definition of ‘project emissions increase’

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Emissions Exclusion Guidance and Examples

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  1. Sean O’Brien Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014 Emissions Exclusion Guidance and Examples

  2. Netting • De minimis threshold test • For PSD and Nonattainment • NSR Reform added: • Definition of ‘project emissions increase’ • Actual-to-projected-actual applicability test • Ability to exclude emissions

  3. Actual-to-Projected-Actual • No longer just PTE • 5 or 10-year recordkeeping • Not for new facilities • Must be verifiable

  4. Emissions Exclusion • Could have accommodated during baseline period • Unrelated to the particular project • Includes increased utilization due to product demand growth

  5. Regulatory Guidance • Minimal: • TCEQ APD 5881 document • Some specific cases in other EPA Regions • Georgia Pacific – EPA Region 4 • No firm rules about: • Time periods • Fuel or material usage vs. production • One industry vs. another

  6. General Guidance • Accommodate: • Not a design capacity • Accounts for bottlenecks • Accommodate proved by actual data: • Indicates non-project PTE • Removes uncertainty

  7. General Guidance • Projected actual: • Less than current allowable or • New PTE • Exclusions limited by: • Existing PTE • Addition of new equipment • New sources of emissions

  8. Necessary Data • Historical operational data • Representations • Expected business activity • Highest projections of business activity • Company's filings with state or federal regulatory authorities • Compliance plans under approved SIP

  9. Past Emissions • Historical data: • Emission, production, and/or fuel usage • Maintenance records • Operating hours • More than a snapshot: • Time period process-specific • 30 days, months, etc.

  10. Demand Growth • Demand growth: • Part of projected actuals • 5 or 10-year forward look • Non-project related increase • More subjective than historical data: • Extrapolation • Disagreement • Debottlenecking not allowed

  11. Debottlenecking • Always part of the project: • Cannot be excluded • Cannot be called demand growth • Determined by past production: • Hard to exclude any emissions • Includes affected units: • Upstream (reactors, etc.) • Downstream (distillation columns, tanks, etc.)

  12. Hypothetical Example Plant produces widgets: • Permitted to produce 200 per year • Has never achieved that level • 24-month baseline = 100 per year • Plans to install production upgrade: • Larger widget dryer (downstream) • Debottlenecking

  13. Hypothetical Example • Pre-project accommodation: • Highest month in baseline annualized: • Let’s assume 10 widgets per month (120/yr) • Excludable = 20 (120-100) widgets per year • Project increase: • Post project = 200 widgets per year • Project increase = 80 (200-20-100) per year

  14. More Examples

  15. Example A • Boiler rebuild at chemical plant: • Improvement project (better efficiency) • Liquid fuel – chemical byproducts: • High ash content • High fuel-bound nitrogen • What could have been accommodated?

  16. Example A • Applicant showed: • Connection? Production vs. fuel supply • Historical data? CEMS, fuel analyses • Length of time? Multiple months • Emissions based on fuel usage: • Steam production maximized • Within 24-month baseline period • Provided 10 years of overall data

  17. Example A • What to look for: • Acidic and corrosive environment: • High maintenance, downtime, etc.? • Anomalies: • Representative month – not outlier • Case specific: • No production increase here • Different facilities – different criteria

  18. Example B • Truck manufacturing increase: • More painting • VOC actual to projected actual > SER • No new facilities needed: • Moving an RTO • Operating hour increase

  19. Example B • Applicant showed: • Connection? Cyclical industry • Historical data? Average daily production • Length of time? 4 months • Anticipating increase in demand: • Improved economy • Previous experience

  20. Difficult Example

  21. Difficult Example • Chemical production increase: • Distillation column throughput increase • Larger reboiler and condenser needed • Changes are part of project: • Affected facilities? Upstream, downstream • Necessary data? For all affected facilities • Demand growth? Hard to justify

  22. Questions?

  23. Contact Information Sean O’Brien (512) 239-1137 sean.obrien@tceq.texas.gov Sean O’Brien (512) 239-1137 sean.obrien@tceq.texas.gov Air Permits Division

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