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New Source Review Intro. Tribal Permit Training Fond du Lac Reservation June 11, 2013. CAA provides framework for permitting. What will this presentation cover?. Permitted pollutants Attainment and non-attainment areas Definitions of “major source” and “major modification”
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New Source Review Intro Tribal Permit Training Fond du Lac Reservation June 11, 2013
What will this presentation cover? • Permitted pollutants • Attainment and non-attainment areas • Definitions of “major source” and “major modification” • Permitting calculations • Control requirements • Reporting and recordkeeping requirements
registered Pollutants • Criteria pollutants • Particulate matter (PM) • Nitrogen oxides (NOx) • Sulfur dioxide (SO2) • Carbon monoxide (CO) • Lead (Pb) • Volatile Organic Compounds (VOC’s) • Greenhouse Gases • CO2, methane, N2O, HFS’c, PFC’s, SF6 expressed as CO2 equivalent
Attainment Status • If area meets National Ambient Air Quality Standards, it is in attainment • If the area can’t demonstrate compliance with standards, it is in non-attainment • Demonstrations made through modeling or monitoring
What is NSR? • Pre-construction permitting program • Major new sources • Major modifications to existing sources • Covers criteria pollutants • Needed in both attainment and non-attainment areas
Major Sources (attainment areas) • Major sources are those who emit… • More than 100 tons/year of any criteria pollutant if one of “28 source categories” • More than 250 tpy of any criteria pollutant if any other source category • More than 10 tpy of any toxic, or more than 25 tpy of a mixture of toxics • More than 100,000 tpy of GHG • Use Potential to Emit calculation to compare to thresholds • PTE is the maximum capacity that a source is capable of emitting • Federally enforceable limits can be included in the calculation
PTE Calculation example • A facility in one of the “28 source categories” can emit 30 lbs of NOx per hour at maximum capacity • If they operate for 24 hrs/day, 7 days/week, that’s 8,760 hrs/year 30 lbs/hr * 8,760 hrs/year = 262,800 lbs/yr 262,800 lbs/yr/2,000 lb/ton = 131.4 tpy If operations are limited to 6,000 hrs/yr, PTE = 90 tpy Facilities must do this exercise for each criteria pollutant emitted
Major Modifications A modification is subject to NSR if… • Modification is made to a major source • Net emissions increase of modification is “significant” (see table) • It constitutes a physical or operational change in method of operation of the source
Major Modification, example Expected emissions from modification: CO = 90 tpy NOx = 38 tpy SO2 = 25 tpy PM = 40 tpy PM-10 = 18 tpy VOC = 10 tpy Pb = 0.01 tpy GHG = 30,000 tpy Does this qualify as a major modification???
Major sources (non-attainment areas) • In non-attainment areas, major sources emit…
Major modification example, n/a area Area is Non-Attainment for NOx (serious) and PM2.5 (moderate). Attainment for all other pollutants. Source is not in one of the “28 source categories” Expected emissions from modification: CO = 90 tpy NOx = 38 tpy SO2 = 25 tpy Total PM = 73 tpy PM10 = 40 tpy PM2.5 = 40 tpy VOC = 35 tpy Pb = 0.01 tpy GHG = 30,000 tpy Does this qualify as a major modification???
other NSR requirements in attainment areas • Ambient air quality analysis • Analyze impacts to soils, vegetation, and visibility • Not adversely affect a Class I area • Undergo public participation
Control technology Requirements • Best Available Control Technology (BACT) • Lowest Achievable Emission Rate (LAER)
Best Available Control Technology • Required under NSR in attainment areas • Pollutant-specific emission 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) • National Emission Standard for Hazardous Air Pollutants (NESHAP) • Selected by “Top Down” BACT analysis • ID all available control technologies • Eliminate technically infeasible control options • Rank remaining control technologies by effectiveness • Evaluate most effective controls and document results • Select BACT
Lowest Achievable Emission Rate • Required under NSR in non-attainment areas • Pollutant-specific emission limit and rate, case-by-case • Considers only technical feasibility • Limits must be at least as stringent as • The most stringent limit in any SIP for any similar source • The most stringent limit achieved in practice by any similar source • Any applicable NSPS • Can require looking at emerging technology • Source must also obtain offsets from other sources in the area • Source must certify CAA compliance at all other facilities • Visibility impacts must be considered
Emissions netting • Considers previous and upcoming emissions changes at a facility for permitting purposes • With applicable reductions, source can “net out” of PSD • Emissions increases/decreases must be “creditable” and contemporaneous • Consideration of contemporaneous changes only allowed for existing major sources • Netting must take place at the same source and with same pollutant • Netting exercise is required, not optional
Reporting and recordkeeping reqmts • To prove facility did not exceed limits taken in permitting • To prove compliance with standards (NSPS, NESHAPs, BACT, LAER, etc) • Examples include • Fuel consumption • Material throughput • Continuous emissions monitoring data • Control equipment operating parameters • Hours of operation • Stack test data • Need to submit data to permitting agency and keep on-site for 5 years
Tribal NSR • Enacted to correct gaps in Indian Country New Source Review Major NSR in Attainment Areas
Conclusions • New major sources or modifications need to undergo permitting • Thresholds apply for both attainment and non-attainment areas • Control requirements must be set • Reporting and recordkeeping demonstrate compliance • Gaps existed in Indian Country, now closed