ns r reforms

Flexible Permitting Workshop

Presented by:U.S. EPA Region 4Air Permits Section

FINAL PRESENTATION 1-24-05

PSD ScopeWhat triggers PSD applicability?New Major stationary sources constructed in attainment areasMajor Modifications to existing major stationary sources in attainment areasAttainment areas are those areas that are meeting the various NAAQSSO2, NOX, PM10, CO, Ozone, Lead and now PM2.5


PSD ScopeWhat is a major stationary source under PSD?One of 28 listed major source categories with PTE > 100 tons per year (after control) of any pollutant regulated by the CAA including fugitive emissions (52.21(b)(1)(i)(a))Any stationary source (other than the listed 28) with PTE > 250 tons per year of any pollutant regulated by the CAA excluding fugitive emissions (52.21(b)(1)(i)(b))


PSD ScopeWhat is a major modification?Any physical change in or change in the method of operation of a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act (52.21(b)(2)(i))


PSD Significant Emission Rates


Determining PSD ApplicabilityReview and define the entire project (i.e., new/modified equipment and affected equipment)What project is being proposed?What new equipment will be added?Is the project part of previous changes?Is the project part of future changes?Will the operation or emissions from other facility emissions units be affected by the change (i.e., de-bottlenecking)?Will existing equipment be changed/removed?


Determining PSD ApplicabilityIf the proposed change does not affect other emissions units or if the affected emissions units do not emit regulated PSD pollutants:The project is limited to the change onlyIf the proposed change affects other emissions units:The project will include both the change and the equipment affected by the change


Determining PSD ApplicabilityEvaluate the project-related emissionsDetermine whether the project by itself (i.e., emissions from new or modified emissions unit plus incremental changes in emissions from affected units) will emit regulated PSD pollutants Determine baseline actual emissionsDetermine potential emissions increase following the modificationDetermine the project-related emissions from new, modified and affected emissions units


Determining PSD ApplicabilityEvaluate the project emissions to determine if the project is a major modification using the actual to potential testActual emissions = average emissions (tpy) over 2 years preceding the projectFugitive emissions must be quantified for 28 listed source categoriesPotential emissions = PTE of the project (tpy)Project potential emissions include PTE of new/modified sources and incremental increases at affected sourcesPotential emissions minus actual emissions = project emission increase


Determining PSD ApplicabilityIf project emission increases are not significant, the project does not trigger PSDIf project emission increases are significant, evaluate contemporaneous changes in emissionsContemporaneous changes are site-wide increases or decreases in actual emissions that have occurred at the site in the 5 years preceding the projectDetermine whether the net change in emissions is significant


PSD Permit Application ContentDescription of proposed projectSummary of applicable requirementsEmissions inventoryDetermination and defense of best available control technology (BACT) evaluationAir quality impact analysesOther Class II impacts analysis


What is BACT?Any major stationary source or major modification subject to PSD must conduct an analysis to ensure the application of best available control technology (BACT)BACT is defined at 40 CFR 52.21(b)(12)BACT is fundamentally an emissions limitation


BACT Applicability (40 CFR 52.21(j))(2) A new major stationary source shall apply BACT for each PSD-regulated pollutant that it would have the potential to emit in significant amounts (3) A major modification shall apply BACT for each PSD-regulated pollutant for which it would result in a significant net emissions increase at the source. This requirement applies to each proposed emissions unit at which a net emissions increase in the pollutant would occur as a result of a physical change or change in the method of operation in the unit.


NSR Revision - BackgroundWhy was NSR Revised?General industry concern over NSR regarding:Complicated applicability determinationsExtended permit preparation and review timelinesVolumes of precedent decisions, policy memos, and guidance documents pertaining to NSRNSR Revision discussions began in the early 1990sEPA initially proposed changes in 1996


NSR Revision - Final RulesMost of the proposed Revisions were finalized and published in the Federal Register on December 31, 2002Effective in delegated States March 3, 2003SIP approved States have 3 years to incorporate revisions into SIP rules (Region 4 States are SIP approved)The Routine Maintenance, Repair, and Replacement (RMRR) Rule was Published in the Federal Register on October 27, 2003


NSR Revision - Final RulesHow are the NSR Revisions characterized by EPA?These changes are intended to provide greater regulatory certainty, administrative flexibility, and permit streamlining, while ensuring the current level of environmental protection and benefit derived from the program and, in certain respects, resulting in greater environmental protection.


Final NSR RevisionsRevised Baseline Actual Emission Calculation ProcedureNew Actual-to-Projected-Actual Applicability TestActuals Based Plantwide Applicability Limits (PALs)New Clean Unit Designation Vacated June 2005Pollution Control Project Exclusion Vacated June 2005Routine Maintenance, Repair, and Replacement (October 27, 2003)-Vacated


Baseline Actual EmissionsRevised Baseline Calculus for Non-Electric Utility Steam Generating Units (Non-EUSGUs)The facility may use the annual average emissions that occurred during any consecutive 24-month period in the past 10 yearsEmissions must be adjusted to reflect current emission factors/control requirementsBaseline emissions cannot exceed applicable standards/limits


Baseline Actual EmissionsRevised Baseline Calculus for Non-Electric Utility Steam Generating Units (Non-EUSGUs)Adequate emissions data must be availableAll emissions units are subject to same 24-month period for a given pollutantDifferent 24-month periods may be used for different pollutants (Note: some state rules may require a common 24-month period)


Actual-to-Projected-Actual Applicability TestNew applicability determination option for all emissions unitsBaseline emissions are compared to projected actual emissions following the changeFacility must project post change actual annual emissions by source for 5 years (10 years post change if change increases units PTE or capacity)Emissions that the unit could accommodate pre-change may be excluded (i.e., demand exclusion)Facility must maintain records of actual annual emissions for 5 or 10 years, and report to regulatory authority if projection is exceeded


Plantwide Applicability LimitsWhat is a PAL?An annual, facility-wide, pollutant specific, emission limitation under which the facility can make any changes without triggering NSR for that pollutantPALs ,as defined in 40 CFR Part 52, are:Set using actual facility baseline emissionsPollutant-specificIssued for a 10-year termRenewable


Actuals Plantwide Applicability LimitsWho is eligible for an Actuals Plantwide Applicability Limit (PAL)?Existing major stationary sources that meet certain additional criteriaHow does a PAL benefit a major facility?Modifications under a PAL are not considered major modifications for the PAL pollutantModifications do not have to be approved through the major NSR programFacility changes are not dictated by major NSR concerns


Actuals PALsHow does a facility obtain a PAL?Interested facilities must submit a complete permit application specifically requesting a PAL or PALsMinimum application requirements include:Listing of emissions unitsSize of emissions units (small, significant or major)All Federal/State applicable requirementsEmission limits/work practice requirementsBaseline actual emissionsSupporting documentation


Actuals PALsWhat type of application is required for a PAL? PALs must be established via a federally enforceable permit Minor NSR construction permitMajor NSR permit (i.e., PSD permit)SIP-approved operating permit programRegulatory authority must provide opportunity for public participation30-day public noticeOpportunity for public comment


Actuals PALsHow are PAL levels established?Establish baseline emissions - select any consecutive 24-month period within the 10-year period preceding the PAL (5-year period for EUSGUs)Only one 24-month period may be used per pollutantDiffering baseline periods may be used for different pollutantsIdentify all emissions units that were included in the baseline periodIdentify any emissions units constructed since the baseline period


Actuals PALsHow are PAL levels established? (cont.)For each emissions unit that existed during the baseline period:Calculate the average rate, in tons per year, at which each of the emissions units emitted the PAL pollutantSum the baseline actual PAL pollutant emission rates of each emissions unit at the source Add an amount equal to the applicable significant level for the PAL pollutant


Actuals PALsHow are PAL levels established? (cont.)Subtract baseline PAL pollutant emissions associated with emissions units that have been permanently shut down since the baseline periodShutdowns of more than 2 years or that have resulted in the removal of the source from the States inventory are presumed to be permanentAdd potential PAL pollutant emissions from units from which construction began after the baseline period


Actuals PALsHow are PAL levels established? (cont.) Baseline PAL pollutant emissions cannot exceed emission limits allowed by your permit or newly applicable requirements at the time the PAL is setAdjust baseline PAL pollutants to reflect applicable requirements since the baseline periodRACT, NSPS, BACT, LAER, etc.


Actuals PAL ExampleSurface coating facility with 7 emissions units defined as Units A through GPAL pollutant is VOCNew State requirement in 1999 affected Unit DUnit F was permanently shut down in 2000Unit G was added in 2004Unit C allowable VOC is 60 tpy


Actuals PAL Example1 Emissions in excess of 60 tons are subtracted from baselineChoose representative baseline period (1997-1998)


Actuals PAL ExampleCorrect Unit D for new applicable requirement (90% VOC control) and re-evaluate baseline periods1 Emissions in excess of 60 tons are subtracted from baselineAB


Actuals PAL ExampleCalculate PAL level - AHighest baseline = 214 tpy (1997/1998)Subtract Unit F baseline emissions (52 tons) = 162 tonsAdd PTE of new Unit G (40 tons) = 202 tons Add major modification threshold (40 tons) = 242 tonsEvaluate Alternative Baseline Period - BBaseline = 205 tpy (1999/2000)Subtract Unit F baseline emissions (30 tons) = 175 tonsAdd PTE of new Unit G (40 tons) = 215 tonsAdd major modification threshold (40 tons) = 255 tons


Actuals PAL ExampleProposed VOC PAL = 255 tonsIs a 255 tpy PAL viable?Recent actual emissions are well below baselineAbatement equipment was added to Unit DFacility plans to switch to powder and/or waterborne coatings on Units A and C within 5 years resulting in lower emissionsA 255 tpy PAL is viable for this facility


PAL PermitsWhat does a PAL permit look like?PAL permits must include:Identification of PAL pollutant(s) and limits(s)PAL effective and expiration datesPAL renewal/transition provisionsRequirement to include emissions from start-ups, shutdowns,and malfunctions in compliance calculationsRequirement to comply with PAL expiration requirements


PAL PermitsPAL permits must include (continued)PAL calculation proceduresMonitoring requirementsRecord retention requirementsReporting requirementsOther necessary requirements


PAL PermitsHow long are PALs and PAL permits good for?The effective period for a PAL is 10 yearsCan PALs be re-opened by the regulatory authority?Yes - mandatory reopening of PAL permits to:Correct errorsReduce PAL for creditable reductionsRevise to reflect a PAL increase


PAL PermitsDo PALs/PAL permits expire?Yes PALs/PAL permits not renewed expire at the end of their effective period (10 years)What happens if a PAL is allowed to expire?New emission limits are establishedSource proposes distribution of PAL emissions to each emissions unit that existed under the PALThe reviewing authority decides the ultimate distribution of PAL emissions to emissions units


PAL Permits1 In this example, emissions were apportioned to individual emissions units at PAL expiration based on the distribution of emissions during the baseline period PAL emissions are distributed to individual emissions units if the PAL expires


PAL PermitsPAL Expiration NotesCompliance with new enforceable tpy limits is based on a 12-month rolling basisRequired monitoring systems may be similar to those under PALsCompliance with a site-wide emissions cap, equivalent to the previous PAL, is required until a revised permit is issuedPhysical changes or changes in the method of operation are subject to major NSR if change is a major modificationState or federal requirements (BACT, LAER, RACT, NSPS, etc.) remain applicable


PAL PermitsAre PALs adjusted when they are renewed?Yes PALs are evaluated at renewal using the same process used to set the original PALsIf the new PAL level is > or = 80% of existing PAL level, PAL may be reset at original levelThe reviewing authority has discretion in setting a new PAL level to :Be more representative of actual emissionsBe in accordance with local air quality needsAccommodate anticipated economic growthRepresent advances in air pollution control technology


PAL PermitsPAL renewal adjustment notes:The new PAL may not exceed the facility PTE New PAL cannot exceed original PAL level unless undergoing PAL modification (increase) procedureThe PAL must reflect all requirements that became applicable during PAL term and that PAL was not adjusted for


PAL PermitsHow can PAL levels be increased?An application for a PAL increase is required that:Identifies all emissions units contributing to the increaseDemonstrates a PAL exceedance after inclusion of proposed new/modified emissions units and an assumption of current BACT equivalent controls on all unitsA major NSR permit is required for emissions units associated with the increase, regardless of the magnitude of the emissions increaseFacility must comply with any resulting BACT/LAER requirements


PAL PermitsHow is a higher PAL level established?The regulatory authority establishes a higher PAL level based on:The sum of the allowable emissions from new/modified emissions units - PLUS -The sum of the baseline actual emissions from all significant/major emissions units assuming BACT control - PLUS -The sum of baseline actual emissions from small emissions unitsThe end result - the magnitude of the proposed increase is minimized by the potential PAL decreases by assuming BACT control on significant and major emissions units


PAL PermitsWhat type of monitoring requirements are specified in PAL permits?PAL general monitoring requirements specify that:PAL monitoring systems must be based on sound scienceMust meet minimum legal requirements for admissibility in a judicial proceeding to enforce the PAL permitEmissions must be quantifiable on an ongoing basis


PAL PermitsAcceptable PAL monitoring techniques include:Mass Balance CalculationsFor sources using paints, coatings, and solventsContinuous Emission Monitoring Systems (CEMS)Continuous Parameter Monitoring Systems (CPMS)Predictive Emission Monitoring Systems (PEMS)Emission FactorsAlternative methods as approved by the administrator


PAL PermitsMass Balance CalculationsRequirements include:A demonstrated means to validate pollutant content in material(s)Assumption that emissions unit emits all of a pollutant if the pollutant cannot be accounted for The use of the highest value of a pollutant where a range of the pollutant content is publishedMass balance calculations are acceptable and are widely used for activities using coatings or solvents


PAL PermitsContinuous Emission Monitoring Systems (CEMS)RequirementsSystems must meet applicable Part 60, Appendix B Performance SpecificationsSystems must sample, analyze, record data once every 15 minutes of operation


PAL PermitsContinuous Parameter Monitoring Systems (CPMS) and Predictive Emission Monitoring Systems (PEMS)RequirementsThe CPMS/PEMS system must demonstrate a correlation between monitored parameters and PAL pollutant emissions across the range of unit operationThe CPMS/PEMS system must sample, analyze, record data once every 15 minutes of operation


PAL PermitsEmission FactorsRequirementsIf appropriate, factors must be adjusted for the uncertainty or limitations in the factors developmentEmissions units must operate within the range of the factors developmentIf technically practicable, the emission factors for significant units must be re-validated within 6 months of the PAL permit issuance Unless reviewing agency determines that testing is not required


PAL PermitsHow is missing monitoring data handled under a PAL?Sources must record and report maximum potential emissions without considering enforceable limitations or operating restrictionsWhat happens when a source operates at non-correlated operating ranges?A default value representing the highest potential emissions must be established and used, orThe source is deemed in violation when the unit is operating outside of a correlated parametric range


PAL PermitsDo emissions monitoring systems under a PAL ever have to be re-validated?Yes - data re-validation is required once every 5-years for all methods of monitoringRe-validation is accomplished by emission testing or or other scientifically valid meansThe PAL applicant may want to consider including a re-validation protocol with the PAL application addressing each type of monitoring and the proposed re-validation procedures


PAL PermitsHow long must PAL related compliance records be retained?Records necessary to demonstrate compliance with the PAL regulations must be retained for five (5) years from the date of the recordOther PAL related records must be retained for the duration of PAL plus 5 yearsPAL applicationPAL revision applications Annual Title V certifications


PAL PermitsReceived multiple PAL applications under NSR ReformsPaper mill, chemical mfg., commercial printer/laminator, automobile assemblyOthers in developmentIs it right for your Facility?


PSD-PALsWhat are PSD-PALs?A flexible permitting option that combines the permitting of a new major source or a major modification at an existing facility with an application for a PALThe PALs are based on a combination of baseline emissions and projected future actual emissionsPSD-PALs are issued through a SIP approved NSR permitting program


PSD-PALsThere are currently two PSD-PALs in Region 4Saturn Corporation - Spring Hill, TennesseeBMW Greenville, South CarolinaThe PSD-PAL discussion is based predominantly on EPA Region 4 experience with these two sources


PSD-PALsWhat type of facility is ideal for a PSD-PAL permit?Complex, well-controlled existing or new facilities with multiple, inter-dependant processes New facilities are excluded from NSR PAL rulesFacilities subject to frequent changes with:A high potential to emit for one or more PSD regulated pollutantsWell characterized emissions Effective monitoring systemsExamples include automobile manufacturers, chemical manufacturers, and Kraft pulp millsThese types of facilities are well represented in Region 4


PSD-PALsPSD-PAL Level equals:

Baseline emissions from all unaffected emissions units (including shutdown sources where applicable) PLUSPTE from new or modified emissions units MINUSBaseline emissions from sources permanently shutdown


PSD-PALs1 Unit 5 shut down in late 2000, Unit 6 shut down in late 20042 Units 7, 8, and 9 are new units3 Total corrected VOC excludes emissions from affected units


PSD-PALsEstablish PAL ContributionsUnaffected source baseline 73.5 tonsNew/affected sources 285 tpyShut-down sources in baseline 123.5 tpy


PSD-PALsCompute the PSD-PAL level:Baseline emissions from unaffected emissions units = 73.5 tonsBaseline emissions from shutdown sources = 123.5 tonsProjected actual emissions from new and affected sources = 285 tonsCompute PAL73.5 tons + 123.5 tons + 285 tons 123.5 tons = 358.5 tons

PAL LEVEL = 358.5 TONS PER ROLLING 12-MONTH PERIOD


PSD-PALsCan PSD-PALs be written with Flexibility provisions?Yes - PSD-PALs may include flexibility provisionsFlexibility provisions are those conditions that reduce the administrative friction - costs, time, delay, uncertainty, and risks experienced by sources and permitting authorities when implementing a permit or making certain changes under a permitFlexibility provisions are in addition to the inherent PAL benefits


PSD-PALsWhat do flexible provisions include?Pre-approved NSRAbility to add new emissions units Ability to make physical changes or changes in the method of operationCertain requirements may be subsumedFor example, compliance with PAL levels may be deemed to also be in compliance with:Individual BACT emission limitsState SIP emission limitsFlexibility provided in PSD-PAL permits is largely dependent upon regulatory authority policy and is generally negotiated


PSD-PALsFlexible components must include safeguardsExamples of safeguards include:BACT on all new units > significance levelMinor source BACT or Best Available Technology (BAT) on all new units < significance levelStreamlined registration and public notice for all new major unitsRequirement to operate and monitor air pollution control systems relied on for BACTRequirement to comply with NAAQS and PSD increments


PSD-PALsWhat type of monitoring procedures are required under a PSD-PAL?In general, monitoring procedures that are equivalent to those required under an NSR actuals PALMass Balance CalculationsCredible Emission FactorsContinuous Emission Monitors (CEMs)Continuous Parameter Monitoring Systems (CPMS)Approved alternative monitoring methods


PSD-PALsWhat level of air pollution control device monitoring is required?In general, air pollution control device monitoring and recordkeeping should be equivalent to CAM requirementsEffective air pollution control device monitoring could be essential to flexibility provisionsCompliance with unit specific BACT requirements is based on compliance with PAL limits BACT compliance is contingent upon proper operation of air pollution control equipmentAn effective monitoring system is therefore essential to BACT/PAL compliance


PSD-PALsEmission calculation proceduresThe applicant should develop and propose emission calculation procedures to convert monitoring data to a mass emission basisCalculations should be based on sound scientific/engineering principles and should compute emissions (tons) on a monthly basisMonthly emissions (tons) are summed with the preceding 11 months worth of monthly data to demonstrate PAL compliance on t rolling 12-month basisCalculations should be replicable


PSD-PALsA draft PSD-PAL permit is recommended as part of a PSD-PAL applicationBenefits of a draft permit in the applicationStarting point for negotiating conditionsClearly articulates source expectations and commitmentsCompresses regulatory agency review timeDraft permit components include:PAL conditionsMonitoring requirementsRecordkeeping requirementsCalculationsFlexibility provisions


Case Study A Saturn PSD/PALOverview of the PSD/PAL Permit for the Saturn Spring Hill, Tennessee FacilityThe Saturn facility is comprised of three business units:Body Systems - body panels, body fabrication and paint shopVehicle Systems - vehicle interior systems and final vehicle assemblyPowertrain - machining, engine assembly, and final dressProduction of Saturn vehicles began in July of 1990The original PSD permit had 54 separate permitted emissions units and 333 separate permit conditions


Case Study A Saturn PSD/PALPlanned facility changes for 2001New vehicle assembly linesModified coating lines/conveyor changesNew engine machining/assembly operationsNew AA stamping pressOverall facility production capacity increase from 360,000 to 595,350 vehicles per year


Case Study A Saturn PSD/PALCritical facility air permitting issues:Initial projects triggered PSD applicabilityFacility projects are subject to frequent scope/schedule changesNSR Revision status was in a state of flux in 1999Saturn air permit objectives:Obtain an innovative permit regardless of NSR Revision statusBase flexible permit on the PAL conceptObtain allowable emissions adequate for 595,350 vehicles/yr or moreAccommodate scope/schedule changes without triggering the need for a new permitSimplify compliance demonstration


Case Study A Saturn PSD/PALFinal air permitting concept:Innovative permit obtained through traditional PSD permitting processPSD permit with BACT levels combined to establish multi-pollutant PALsStreamlined monitoring and compliance determinationExpedited treatment of additional new unitsAuthorized changes to existing units provided PALs are not exceeded


Case Study A Saturn PSD/PALPSD-PAL permit applicationCommon PSD Components (BACT, modeling, etc.)Innovative ComponentsProposed PALs based on a combination of baseline and potential emissions for criteria pollutantsSingle emissions unit for all combustion related emissionsDocumentation of BACT equivalent technology for unaffected emissions units (e.g., clean units)Sample draft permit language incorporating proposed PALs and other innovative provisionsSubmitted application to TDEC in October 1999Received final PSD/PAL permit in June 2000


Case Study A Saturn PSD/PALa Previous allowable emissions represent conditions from Saturns original operating/construction permits and subsequent modifications.b Baseline actual is the average 1995/1996 annual emission ratec Net change represents the difference between baseline emission rates and PAL levels. The project triggered PSD review for VOC, NOx, and PM10.d Saturn utilizes natural gas as the sole fuel on-site. There are no provisions for alternative or back-up fuels.

Emissions Summary, Tons/yr.


196

Permit ConditionOriginal PSD PermitPSD/PAL Permit

No. of Individual Permits541

Production Limits610

Fuel Restrictions81

VOC Limits (e.g., TPY, lb/hr, etc.)745

PM Limits (e.g., TPY, gr./dscf, etc.)781

NOx Limits (e.g., TPY, lb/hr, etc.)291

CO Limits (e.g., TPY, lb/hr, etc.)311

SO2 Limits (e.g., TPY, lb/hr, etc.)81

Visible Emissions4444

192

CriteriaVOCNOxCOPM10SO2d

Previous Allowablea2,897380179305N/A

Baseline Actualb949951331631

PAL Levels156318922020539

Net Changec61494874238

Major Modification Threshold40401001540

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Case Study A Saturn PSD/PALPermit InnovationsOperational FlexibilityPre-approved new major emissions unitsRegistration and BACT requirementSaturn may begin construction when BACT is approved (i.e., 45 days)Pre-approved new minor emissions unitsRegistration and mBACT requirementSaturn may begin construction when mBACT is approved (i.e., 30 days)Changes to existing emissions units do not require TDEC approval


Case Study A Saturn PSD/PALPermit InnovationsClear monitoring and recordkeeping requirementsAbility to increase PALs through the PSD permitting processTermination provision with return to traditional permitStreamlined compliance requirements


Case Study A Saturn PSD/PAL Old PSD Versus New PSD/PAL Conditions


Sheet1

Permit ConditionOriginal PSD PermitPSD/PAL Permit

No. of Individual Permits541

Production Limits610

Fuel Restrictions81

VOC Limits (e.g., TPY, lb/hr, etc.)745

PM Limits (e.g., TPY, gr./dscf, etc.)781

NOx Limits (e.g., TPY, lb/hr, etc.)291

CO Limits (e.g., TPY, lb/hr, etc.)311

SO2 Limits (e.g., TPY, lb/hr, etc.)81

Visible Emissions4444

Sheet2

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Case Study A Saturn PSD/PALSummaryThe PAL permit provides significant operational flexibility to Saturn within current regulatory boundsThe permit streamlines compliance determinations for the facility, TDEC, and the publicVOC emissions per vehicle produced has declined since PAL issuanceThe PSD/PAL permit has improved the environmental performance of the facilityThe original PAL permit limits and flexibility are retained in the Title V operating permit


Case Study C Non-attainment PALOverview of a proposed PAL for an adhesive coating facility in PennsylvaniaThe facility includes boilers, reactor vessels, mixing and formulation, multiple adhesive coaters and dryers, and research and development facilitiesFacility emissions include VOC, PM10, HAPs, and products of combustion (NOx and CO)The facility is well controlled using a vent condenser and two existing regenerative thermal oxidizers to abate VOC and vHAP emissions


Case Study C Non-attainment PALCritical facility air permitting issues:NSR Revisions became effective in March 2003 for attainment pollutantsThe facility is located in an area classified as moderately non-attainment for ozone due to its location in the Northeast Ozone Transport RegionPermitting timelines and redundant NSR applicability analysesProjects in the pipeline that include expedited installation schedules


Case Study C Non-attainment PALFinal air permitting concept:Acquire a VOC PAL through the Pennsylvania minor NSR programSince facility is well controlled, use the 40 ton major NSR modification threshold to establish a VOC PALEnsure expedited state review and approval of facility modifications by eliminating required non-attainment NSR applicability determinationsAllow the facility to decide where and how VOC emissions are controlled within the facility in accordance with Pennsylvania Best Available Technology (BAT) requirements


Case Study C Non-attainment PALMinor Pennsylvania NSR permit applicationBAT analysis not required since no emissions units were being modifiedEmissions inventory Baseline calculation - PA PAL policy requires the use of the most recent two calendar years to develop baseline emission rates or an alternative two year period within the past five year if the most recent two years is not representativePAL calculation - The PAL was established by adding an amount slightly less than the major modification threshold (i.e., 39 tons for VOC) to the baseline minus allowable emission increases since 1991


Case Study C Non-attainment PALNon-attainment VOC PAL Calculation


Case Study C Non-attainment PALInnovative ComponentsProposed site wide VOC PAL set using baseline VOC emissions plus adjusted NSR major modification thresholdThe facility is well controlled and the VOC PAL provides a considerable growth cushionFor this facility, the ability to manage growth internally via a VOC PAL is sufficiently innovativeSubmitted application in October 2004A proposed draft permit is currently under review by DEP and the facility


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