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PSD Permitting in Minnesota. Nonattainment NSR does not applyMinnesota is currently a delegated PSD State40 CFR ?52.21 appliesMPCA may develop a SIP-approved programPM2.5 rule effective July 15, 2008. PM2.5 PSD Rule Implementation in Minnesota. Condensables (Organic and Inorganic) must be includ
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1. PM2.5 Permitting Implementation in MN Steven Pak, P.E.
Minnesota Pollution Control Agency
AWMA-UMS PM2.5 PSD Implementation Workshop
August 27, 2008
2. PSD Permitting in Minnesota Nonattainment NSR does not apply
Minnesota is currently a delegated PSD State
40 CFR §52.21 applies
MPCA may develop a SIP-approved program
PM2.5 rule effective July 15, 2008
3. PM2.5 PSD Rule Implementation in Minnesota Condensables (Organic and Inorganic) must be included in:
Emission calculations and applicability determinations
BACT analyses
Permit emission limits
Stack testing
Dispersion modeling
Only SO2 and NOx are considered PM2.5 precursors
4. PM2.5 Calculations – When are they required? Total Facility Permit Applications (GI-07 and EC forms)
Change/Modification Applications (CH-04 and EC forms)
May also be required if:
AERA/Environmental Review required
Project controversial or concerns exist
Project going to the Citizens Board for any reason
5. PM2.5 Emission Factors – What are the best ones to use? Emission factor means the most accurate and representative emission data available…. (Minn. R. 7005.0100)
EPA: AP-42, FIRE, and PM Calculator
Stack test results (if representative)
Manufacturer guarantees (may not be reliable)
Assume all PM/PM10 is PM2.5
Combinations of the above (e.g., PM2.5/PM10 ratios applied to stack test results)
Supporting documentation for emission factors and calculations is critical!
6. PM2.5 Emission Limits – When will they be included in permits? If a PM2.5 BACT limit is established
If a limit on PTE is established
If required by federal or state rules
Emission limit may also be included in permits:
To avoid issues with modeling the NAAQS or, when finalized, the increment
To reduce health risks estimated through an AERA or risk assessment
7. PM2.5 Stack Testing – When will it be required? Stack testing may be required in the following situations:
To verify compliance with a BACT limit
To verify compliance with a any other permit limit
To establish or verify an emissions factor
8. PM2.5 Stack Testing Methods – What will MPCA accept? Method 202 or Other Test Method (OTM) 28 for condensables
OTM 27 or Conditional Test Method (CTM) 39 for PM2.5
Method 5 and Method 201A assuming everything PM2.5
Other options may exist - Contact MPCA stack testing staff
9. PM2.5 PSD Modeling – When will it be required? Required if a project triggers PSD for PM2.5 (i.e., major modification or new major source)
EPA hasn’t yet finalized increments, SILs & SMCs
Until rule finalized, increment modeling not required
Until rule finalized, MPCA will use most stringent/conservative SILs and SMCs in EPA’s proposed rule:
Class I SIL: 0.04 µg/m3, annual; 0.07 µg/m3, 24-hr
Class II SIL:0.3 µg/m3, annual; 1.2 µg/m3, 24-hr
SMC: 2.3 µg/m3, 24-hr average
10. PM2.5 Modeling – When Else Might It Be Required? Modeling may be required, even if PSD is not triggered, in the following situations:
Environmental Review required
AERA required
Projects going to the Citizens Board for any reason
Concerns exist with PM2.5 NAAQS and, when finalized, the increment
11. MPCA PM2.5 Contacts
12. Additional Resources
MPCA NSR Web Clearinghouse
http://www.pca.state.mn.us/air/permits/nsr/index.html
Air Quality Listserv
http://www.pca.state.mn.us/air/air-techinfo.html