BAAQMD Proposed NSR Changes: Case Study for PSD Applicability

(1)

BAAQMD Proposed NSR Changes:

Case Study for PSD Applicability

Oakland, CA ♦ April 5, 2012

(2)

Objectives

˃ Highlight key PSD Applicability Principles ˃ Calculation Basis

˃ Review Case Study Based on Proposed BAAQMD

Regulations

(3)

Proposed PSD Project Definition

˃ A new source or a modified source, or a combination of such new or

modified sources that are part of a single common project that falls into one of the following groups:

 New Sources: Plant will be a major source

(>major source threshold of 100 or 250 tons/year or 100,000 tons/year of GHG (CO2e))

 Existing Minor Sources: Make a modification that in itself is “major”

(>major source threshold of 100 or 250 tons/year or 100,000 tons/year of GHG (CO2e))

 Existing Major Sources: Make a modification that exceeds PSD

Significant Emission Rates (SER)

(4)

Proposed Modified Source Definition

˃ Any physical change, change in method of operation, change in throughput or production, or other similar change at an existing source, that results in an increase in daily or annual emissions in any of the following amounts:

 If the source’s daily and/or annual emissions are subject to an

enforceable permit limit established by NSR requirements (BAAQMD Reg.2, Rule 2, 40 CFR 52.21, or NSR avoidance), an increase in the source’s PTE above such permitted limit.

 If the source’s daily and/or annual emissions are not subject to

any enforceable limit as described above, an increase in the source’s actual physical capacity to emit air pollutants as

installed and operated at the facility, above the lowest of the following:

♦ The maximum operational capacity of the source; ♦ The effective capacity of the source; or

(5)

Project Emission Increase (PEI)

Calculation Basis

˃

New Source EI = PTE

˃

Existing Source EI = Post Project PTE – BE



Baseline Emissions (BE) = average emissions from

a 3 year period prior to complete application



BE adjusted downward to reflect current

permitted limits

˃

PEI =

Σ

New Source EI +

Σ

Existing Source EI

˃

If PEI > SER, evaluate Net Emission Increase

(6)

Net Emission Increase (NEI)

Calculation Basis

˃ If PEI is greater than SER, can attempt to “net-out” of PSD review ˃ Net Emission Increase equals:

Project Emissions Increase minus

source-wide creditable contemporaneous decreases plus

source-wide creditable contemporaneous increases

˃ The contemporaneous period is the period ranging from 5 years

prior to the complete application date to the time normal operation commences for that change

˃ Contemporaneous Increases and Decreases are calculated as Post

Project PTE minus BE

(7)

Proposed BAAQMD Rules

Baseline Emissions = 20 tpy PTE = 50 tpy

Project Emission Increase = 30 tpy PM₁₀SER = 15 tpy

PSD is triggered (unless you can “net-out”)

Comparison of

Federal vs BAAQMD Proposed Rules

Year* PM10Actual Emissions 2009 15 tpy 2010 20 tpy 2011 25 tpy PTE 50 tpy 2015 35 tpy (projected) Year* PM10Actual Emissions 2010 20 tpy 2011 25 tpy 2012 30 tpy (projected) 2013 30 tpy (projected) 2014 32 tpy (projected) 2015/16 33 tpy (projected) Federal Rules

Baseline Actual Emissions = 22.5 tpy Projected Actual Emissions = 33 tpy Project Emission Increase = 10.5 tpy PM₁₀ SER = 15 tpy

(8)

Case Study: Facility Expansion

˃ Facility pre-project PTE: 300 tpy NOx (major PSD source)

˃ Facility proposes the following:

 Physically modify Emission Unit #1 to increase capacity

 Install a new 100 MMBtu/hr natural gas boiler

 Shut-down Emission Unit #2

˃ Historical Permitting:

 2009: Installed Emission Unit #1

˃ Timing:

 Emission Unit #2 will permanently shut-down prior to

modified Emission Unit #1 beginning normal operation.

 The new boiler will begin normal operation concurrent with

(9)

Case Study: Significant Increase

˃ Only include project increases

˃ Assume the following:

 Complete application: 01/2013

 No new permit limits or permit exceedances during baseline period  Example only evaluates NO_x emissions

 EU#1 currently has an annual PTE of 10 tpy NO_xand post project PTE will be 15 tpy

NO_x(therefore, EU#1 is a modified unit)

Emission Unit 2010 2011 2012 BE (tpy) PTE (tpy) Emission Increase (tpy) Emission Unit #1 3 5 7 5 15 10 New Boiler - - - 0 43 43 Totals: 5 58 53 NO_x SER: 40 tpy

(10)

Case Study: Significant Net Increase

˃ Add in all contemporaneous increases and decreases between 01/2008 and 01/2015

˃ Assume the following:

 Complete application: 01/2013  Emission Unit #1 installed: 2009

 Emission Unit #2 shut-down: 12/2014

 Project is complete and operational by 01/2015

 No new permit limits or permit exceedances during baseline period.

 How do you treat separate projects that occur in the contemp. period on the same emission

unit? Separately, as in the example below?

Emission Unit 2012 2013 2014 BE (tpy) PTE (tpy) Emission Increase (tpy)

Significant Increase, Project 5 58 53 EU #1, Initial Installation 0 10 10 EU #2, Shut down 15 17 16 16 0 -16

Total: 14 78 47

(11)

Conclusions/Comments

˃ Pay very close attention to the definition of modified

unit prior to conducting a PSD applicability assessment

˃ The proposed rules are less favorable for determining

baseline emissions for PSD (calculation methodology and adjustment)

˃ It is unclear how to treat multiple contemporaneous

projects that revolve around the same emission unit

˃ Currently, the proposed rules do NOT include a PM SER ˃ PSD Applicability can get very Complicated. Make sure