FINAL PRESENTATION 1-24-051 Flexible Permitting Workshop Presented by: U.S. EPA Region 4 Air Permits Section

FINAL PRESENTATION 1-24-05 1

Flexible Permitting Flexible Permitting WorkshopWorkshop

Presented by:Presented by:

U.S. EPA Region 4U.S. EPA Region 4

Air Permits SectionAir Permits Section

http://www.epa.gov/


PSD ScopePSD Scope

• What triggers PSD applicability?What triggers PSD applicability?New “Major” stationary sources New “Major” stationary sources

constructed in attainment areasconstructed in attainment areas““Major Modifications” to existing Major Modifications” to existing

major stationary sources in major stationary sources in attainment areasattainment areas

• Attainment areas are those areas Attainment areas are those areas that are meeting the various that are meeting the various NAAQSNAAQSSOSO22, NO, NOXX, PM10, CO, Ozone, Lead and , PM10, CO, Ozone, Lead and

now PM2.5now PM2.5


PSD ScopePSD Scope

• What is a major stationary source What is a major stationary source under PSD?under PSD?One of 28 “listed” major source categories One of 28 “listed” major source categories

with PTE > 100 tons per year (after control) with PTE > 100 tons per year (after control) of any pollutant regulated by the CAA of any pollutant regulated by the CAA including fugitive emissions (52.21(b)(1)(i)including fugitive emissions (52.21(b)(1)(i)(a))(a))

Any stationary source (other than the listed Any stationary source (other than the listed 28) with PTE > 250 tons per year of any 28) with PTE > 250 tons per year of any pollutant regulated by the CAA excluding pollutant regulated by the CAA excluding fugitive emissions (52.21(b)(1)(i)(b))fugitive emissions (52.21(b)(1)(i)(b))


PSD ScopePSD Scope

• What is a major modification?What is a major modification?Any Any physical change in or change in physical change in or change in

the method of operationthe method of operation of a major of a major stationary source stationary source that would result that would result in a significant net emissions in a significant net emissions increaseincrease of any pollutant subject to of any pollutant subject to regulation under the Act (52.21(b)regulation under the Act (52.21(b)(2)(i))(2)(i))


PSD Significant Emission RatesPSD Significant Emission RatesPollutant Major Modification

Threshold

Particulate Matter (TSP) 25 tpy

Particulate Matter < 10 microns (PM10) 15 tpy

Sulfur Dioxide (SO2) 40 tpy

Oxides of Nitrogen (NOX) 40 tpy

Volatile Organic Compounds (VOC) 40 tpy

Carbon Monoxide (CO) 100 tpy

Lead (Pb) 0.6 tpy

Fluorides 3 tpy

Sulfuric Acid Mist 7 tpy

Hydrogen Sulfide (H2S) 10 tpy

Total Reduced Sulfur (TRS) 10 tpy

Any increase resulting in a > 1 µg/m3 24 hour concentration if the source is within 10 km of a Class I area


Determining PSD ApplicabilityDetermining PSD Applicability• Review and defineReview and define the entire project the entire project

(i.e., new/modified equipment and (i.e., new/modified equipment and affected equipment)affected equipment)What project is being proposed?What project is being proposed?What new equipment will be added?What new equipment will be added? Is the project part of previous changes?Is the project part of previous changes? Is the project part of future changes?Is the project part of future changes?Will the operation or emissions from Will the operation or emissions from

other facility emissions units be affected other facility emissions units be affected by the change (i.e., de-bottlenecking)?by the change (i.e., de-bottlenecking)?

Will existing equipment be Will existing equipment be changed/removed?changed/removed?


Determining PSD ApplicabilityDetermining PSD Applicability

• If the proposed change does not If the proposed change does not affect other emissions units or if affect other emissions units or if the affected emissions units do the affected emissions units do not emit regulated PSD pollutants:not emit regulated PSD pollutants:The project is limited to the change The project is limited to the change

onlyonly

• If the proposed change affects If the proposed change affects other emissions units:other emissions units:The project will include The project will include both the both the

change and the equipment affected change and the equipment affected by the changeby the change


Determining PSD Determining PSD ApplicabilityApplicability

• Evaluate the project-related Evaluate the project-related emissionsemissionsDetermine whether the project by itself Determine whether the project by itself

(i.e., emissions from new or modified (i.e., emissions from new or modified emissions unit plus incremental changes in emissions unit plus incremental changes in emissions from affected units) will emit emissions from affected units) will emit regulated PSD pollutants regulated PSD pollutants

Determine baseline actual emissionsDetermine baseline actual emissionsDetermine potential emissions increase Determine potential emissions increase

following the modificationfollowing the modificationDetermine the project-related emissions Determine the project-related emissions

from new, modified and affected emissions from new, modified and affected emissions unitsunits



• Evaluate the “project” emissions to Evaluate the “project” emissions to determine if the project is a major determine if the project is a major modification using the “modification using the “actual to actual to potential testpotential test””Actual emissions = average emissions (tpy) Actual emissions = average emissions (tpy)

over 2 years preceding the projectover 2 years preceding the projecto Fugitive emissions must be quantified for 28 Fugitive emissions must be quantified for 28

listed source categorieslisted source categoriesPotential emissions = PTE of the project Potential emissions = PTE of the project

(tpy)(tpy)o Project potential emissions include PTE of Project potential emissions include PTE of

new/modified sources and incremental increases new/modified sources and incremental increases at affected sourcesat affected sources

PotentialPotential emissions minus emissions minus actualactual emissions emissions = project emission increase= project emission increase



• If project emission increases are not If project emission increases are not significant, the project does not trigger significant, the project does not trigger PSDPSD

• If project emission increases are If project emission increases are significant, evaluate significant, evaluate “contemporaneous” changes in “contemporaneous” changes in emissionsemissionsContemporaneous changes are site-wide Contemporaneous changes are site-wide

increases or decreases in actual emissions increases or decreases in actual emissions that have occurred at the site in the 5 years that have occurred at the site in the 5 years preceding the projectpreceding the project

• Determine whether the “net” change in Determine whether the “net” change in emissions is significantemissions is significant


PSD Permit Application PSD Permit Application ContentContent

• Description of proposed projectDescription of proposed project• Summary of applicable Summary of applicable

requirementsrequirements• Emissions inventoryEmissions inventory• Determination and defense of best Determination and defense of best

available control technology available control technology (BACT) evaluation(BACT) evaluation

• Air quality impact analysesAir quality impact analyses• Other Class II impacts analysisOther Class II impacts analysis


What is BACT?What is BACT?

• Any major stationary source or Any major stationary source or major modification subject to PSD major modification subject to PSD must conduct an analysis to ensure must conduct an analysis to ensure the application of the application of best available best available control technologycontrol technology (BACT) (BACT)

• BACT is defined at 40 CFR 52.21(b)BACT is defined at 40 CFR 52.21(b)(12)(12)

• BACT is fundamentally an BACT is fundamentally an emissions limitation emissions limitation


BACT Applicability (40 CFR BACT Applicability (40 CFR 52.21(j))52.21(j))

• (2) A new major stationary source shall (2) A new major stationary source shall apply BACT for each PSD-regulated apply BACT for each PSD-regulated pollutant that it would have the pollutant that it would have the potential to emit in significant amounts potential to emit in significant amounts

• (3) A major modification shall apply (3) A major modification shall apply BACT for each PSD-regulated pollutant BACT for each PSD-regulated pollutant for which it would result in a significant for which it would result in a significant net emissions increase at the source. net emissions increase at the source. This requirement applies to each This requirement applies to each proposed emissions unit at which a proposed emissions unit at which a net net emissions increaseemissions increase in the pollutant in the pollutant would occur as a result of a would occur as a result of a physical physical change or change in the method of change or change in the method of operation in the unit.operation in the unit.


NSR Revision - BackgroundNSR Revision - Background

• Why was NSR Revised?Why was NSR Revised?General industry concern over NSR General industry concern over NSR

regarding:regarding:o Complicated applicability determinationsComplicated applicability determinationso Extended permit preparation and review Extended permit preparation and review

timelinestimelineso Volumes of precedent decisions, policy Volumes of precedent decisions, policy

memos, and guidance documents memos, and guidance documents pertaining to NSRpertaining to NSR

• NSR Revision discussions began in NSR Revision discussions began in the early 1990’sthe early 1990’s

• EPA initially proposed changes in EPA initially proposed changes in 1996 1996


NSR Revision - Final RulesNSR Revision - Final Rules

• Most of the proposed Revisions were Most of the proposed Revisions were finalized and published in the finalized and published in the Federal Register on December 31, Federal Register on December 31, 20022002Effective in delegated States March 3, Effective in delegated States March 3,

20032003SIP approved States have 3 years to SIP approved States have 3 years to

incorporate revisions into SIP rules incorporate revisions into SIP rules (Region 4 States are SIP approved)(Region 4 States are SIP approved)

• The Routine Maintenance, Repair, The Routine Maintenance, Repair, and Replacement (RMRR) Rule was and Replacement (RMRR) Rule was Published in the Federal Register on Published in the Federal Register on October 27, 2003October 27, 2003


NSR Revision - Final RulesNSR Revision - Final Rules

• How are the NSR Revisions How are the NSR Revisions characterized by EPA?characterized by EPA?““These changes are intended to These changes are intended to

provide greater regulatory certainty, provide greater regulatory certainty, administrative flexibility, and permit administrative flexibility, and permit streamlining, while ensuring the streamlining, while ensuring the current level of environmental current level of environmental protection and benefit derived from protection and benefit derived from the program and, in certain the program and, in certain respects, resulting in greater respects, resulting in greater environmental protection.”environmental protection.”


Final NSR RevisionsFinal NSR Revisions

• Revised Baseline Actual Emission Revised Baseline Actual Emission Calculation ProcedureCalculation Procedure

• New “Actual-to-Projected-Actual” New “Actual-to-Projected-Actual” Applicability TestApplicability Test

• Actuals Based Plantwide Applicability Actuals Based Plantwide Applicability Limits (PALs)Limits (PALs)

• New “Clean Unit” Designation – Vacated New “Clean Unit” Designation – Vacated June 2005June 2005

• Pollution Control Project Exclusion – Pollution Control Project Exclusion – Vacated June 2005Vacated June 2005

• Routine Maintenance, Repair, and Routine Maintenance, Repair, and Replacement (October 27, 2003)-VacatedReplacement (October 27, 2003)-Vacated


Baseline Actual EmissionsBaseline Actual Emissions

• Revised Baseline Calculus for Revised Baseline Calculus for Non-Electric Utility Steam Non-Electric Utility Steam Generating Units (Non-EUSGUs)Generating Units (Non-EUSGUs)The facility may use the annual The facility may use the annual

average emissions that occurred average emissions that occurred during during any consecutive 24-month any consecutive 24-month period in the past 10 yearsperiod in the past 10 years

Emissions must be adjusted to Emissions must be adjusted to reflect current emission reflect current emission factors/control requirementsfactors/control requirements

Baseline emissions cannot exceed Baseline emissions cannot exceed applicable standards/limitsapplicable standards/limits


Baseline Actual EmissionsBaseline Actual Emissions

• Revised Baseline Calculus for Revised Baseline Calculus for Non-Electric Utility Steam Non-Electric Utility Steam Generating Units (Non-EUSGUs)Generating Units (Non-EUSGUs)Adequate emissions data must be Adequate emissions data must be

availableavailableAll emissions units are subject to All emissions units are subject to

same 24-month period for a given same 24-month period for a given pollutantpollutant

Different 24-month periods may be Different 24-month periods may be used for different pollutants used for different pollutants (Note: (Note: some state rules may require a common some state rules may require a common 24-month period)24-month period)


Actual-to-Projected-Actual Actual-to-Projected-Actual Applicability TestApplicability Test

• New applicability determination New applicability determination option for all emissions unitsoption for all emissions unitsBaseline emissions are compared to Baseline emissions are compared to

projected actual emissions following projected actual emissions following the changethe changeo Facility must project post change actual Facility must project post change actual

annual emissions by source for 5 years (10 annual emissions by source for 5 years (10 years post change if change increases unit’s years post change if change increases unit’s PTE or capacity)PTE or capacity)

o Emissions that the unit could accommodate Emissions that the unit could accommodate pre-change may be excluded (i.e., demand pre-change may be excluded (i.e., demand exclusion)exclusion)

o Facility must maintain records of actual Facility must maintain records of actual annual emissions for 5 or 10 years, and annual emissions for 5 or 10 years, and report to regulatory authority if projection report to regulatory authority if projection is exceededis exceeded


Plantwide Applicability Plantwide Applicability LimitsLimits

• What is a PAL?What is a PAL?An annual, facility-wide, pollutant specific, An annual, facility-wide, pollutant specific,

emission limitation under which the facility emission limitation under which the facility can make any changes without triggering can make any changes without triggering NSR for that pollutantNSR for that pollutant

• PALs ,as defined in PALs ,as defined in 40 CFR Part 5240 CFR Part 52, , are:are:Set using Set using actualactual facility baseline emissions facility baseline emissionsPollutant-specificPollutant-specific Issued for a 10-year termIssued for a 10-year termRenewableRenewable


““Actuals” Plantwide Actuals” Plantwide Applicability LimitsApplicability Limits

• Who is eligible for an Actuals Plantwide Who is eligible for an Actuals Plantwide Applicability Limit (PAL)?Applicability Limit (PAL)?Existing major stationary sources that meet Existing major stationary sources that meet

certain additional criteriacertain additional criteria

• How does a PAL benefit a major facility?How does a PAL benefit a major facility?Modifications under a PAL are not Modifications under a PAL are not

considered “major modifications” for the considered “major modifications” for the PAL pollutantPAL pollutant

Modifications do not have to be approved Modifications do not have to be approved through the major NSR programthrough the major NSR program

Facility changes are not dictated by major Facility changes are not dictated by major NSR concernsNSR concerns


““Actuals” PALsActuals” PALs

• How does a facility obtain a PAL?How does a facility obtain a PAL? Interested facilities must submit a Interested facilities must submit a

complete permit application specifically complete permit application specifically requesting a PAL or PALsrequesting a PAL or PALs

Minimum application requirements Minimum application requirements include:include:o Listing of emissions unitsListing of emissions unitso Size of emissions units (small, significant or Size of emissions units (small, significant or

major)major)o All Federal/State applicable requirementsAll Federal/State applicable requirementso Emission limits/work practice requirementsEmission limits/work practice requirementso Baseline actual emissionsBaseline actual emissionso Supporting documentationSupporting documentation



• What type of application is required What type of application is required for a PAL?for a PAL? PALs must be established via a PALs must be established via a

federally enforceable permitfederally enforceable permit o Minor NSR construction permitMinor NSR construction permito Major NSR permit (i.e., PSD permit)Major NSR permit (i.e., PSD permit)o SIP-approved operating permit programSIP-approved operating permit program

Regulatory authority must provide Regulatory authority must provide opportunity for public participationopportunity for public participationo 30-day public notice30-day public noticeo Opportunity for public commentOpportunity for public comment



• How are PAL levels established?How are PAL levels established?Establish baseline emissions - select any Establish baseline emissions - select any

consecutive 24-month period within the consecutive 24-month period within the 10-year period preceding the PAL (5-year 10-year period preceding the PAL (5-year period for EUSGUs)period for EUSGUs)o Only one 24-month period may be used per Only one 24-month period may be used per

pollutantpollutanto Differing baseline periods may be used for Differing baseline periods may be used for

different pollutantsdifferent pollutants

Identify all emissions units that were Identify all emissions units that were included in the baseline periodincluded in the baseline period

Identify any emissions units constructed Identify any emissions units constructed since the baseline periodsince the baseline period



• How are PAL levels established? How are PAL levels established? (cont.)(cont.)For each emissions unit that existed For each emissions unit that existed

during the baseline period:during the baseline period:o Calculate the Calculate the average rateaverage rate, in tons per , in tons per

year, at which each of the emissions year, at which each of the emissions units emitted the PAL pollutantunits emitted the PAL pollutant

Sum the baseline actual PAL Sum the baseline actual PAL pollutant emission rates of each pollutant emission rates of each emissions unit at the source emissions unit at the source

Add an amount equal to the Add an amount equal to the applicable significant level for the applicable significant level for the PAL pollutantPAL pollutant



• How are PAL levels established? How are PAL levels established? (cont.)(cont.)Subtract baseline PAL pollutant Subtract baseline PAL pollutant

emissions associated with emissions emissions associated with emissions units that have been permanently shut units that have been permanently shut down since the baseline perioddown since the baseline periodo Shutdowns of more than 2 years or that Shutdowns of more than 2 years or that

have resulted in the removal of the source have resulted in the removal of the source from the State’s inventory are presumed to from the State’s inventory are presumed to be permanentbe permanent

Add Add potentialpotential PAL pollutant emissions PAL pollutant emissions from units from which construction from units from which construction began after the baseline periodbegan after the baseline period



• How are PAL levels established? How are PAL levels established? (cont.)(cont.) Baseline PAL pollutant emissions Baseline PAL pollutant emissions

cannot exceed emission limits allowed cannot exceed emission limits allowed by your permit or newly applicable by your permit or newly applicable requirements at the time the PAL is setrequirements at the time the PAL is set

Adjust baseline PAL pollutants to Adjust baseline PAL pollutants to reflect applicable requirements since reflect applicable requirements since the baseline periodthe baseline periodo RACT, NSPS, BACT, LAER, etc.RACT, NSPS, BACT, LAER, etc.


““Actuals” PAL ExampleActuals” PAL Example

• Surface coating facility with 7 Surface coating facility with 7 emissions units defined as Units emissions units defined as Units A through GA through G

• PAL pollutant is VOCPAL pollutant is VOC• New State requirement in 1999 New State requirement in 1999

affected Unit Daffected Unit D• Unit F was permanently shut Unit F was permanently shut

down in 2000down in 2000• Unit G was added in 2004Unit G was added in 2004• Unit C allowable VOC is 60 tpyUnit C allowable VOC is 60 tpy



Year Unit A Unit B Unit C Unit D Unit E Unit F Unit G Total Baseline

1995 52 10 50 199 19 54 0 384 ---

1996 46 12 52 200 23 51 0 384 384

1997 42 16 681 205 22 54 0 399 392

1998 45 15 651 201 23 50 0 394 397

1999 49 20 60 210 23 30 0 392 393

2000 55 21 59 210 20 30 0 395 394

2001 45 16 59 19 22 0 0 161 278

2002 44 18 671 18 22 0 0 162 162

2003 45 16 651 16 23 0 0 160 161

2004 46 17 621 17 20 0 40 200 180

1 1 Emissions in excess of 60 tons are subtracted Emissions in excess of 60 tons are subtracted from baselinefrom baseline

Choose representative baseline period Choose representative baseline period (1997-1998)(1997-1998)



Year Unit A Unit B Unit C Unit D Unit E Unit F Unit G Total Baseline

1995 52 10 50 20 19 54 0 205 ---

1996 46 12 52 20 23 51 0 204 204

1997 42 16 681 21 22 54 0 215 209

1998 45 15 651 20 23 50 0 213 214

1999 49 20 60 21 23 30 0 203 208

2000 55 21 59 21 20 30 0 206 205

2001 45 16 59 19 22 0 0 161 184

2002 44 18 671 18 22 0 0 162 162

2003 45 16 651 16 23 0 0 160 161

2004 46 17 621 17 20 0 40 200 180

CorrectCorrect Unit D for new applicable Unit D for new applicable requirement (90% VOC control) and re-requirement (90% VOC control) and re-evaluate baseline periodsevaluate baseline periods

1 1 Emissions in excess of 60 tons are subtracted Emissions in excess of 60 tons are subtracted from baselinefrom baseline

AA

BB


““Actuals” PAL ExampleActuals” PAL Example• Calculate PAL level - ACalculate PAL level - A

Highest baseline = 214 tpy (1997/1998)Highest baseline = 214 tpy (1997/1998)Subtract Unit F baseline emissions (52 Subtract Unit F baseline emissions (52

tons) = 162 tonstons) = 162 tonsAdd PTE of new Unit G (40 tons) = 202 tonsAdd PTE of new Unit G (40 tons) = 202 tons Add major modification threshold (40 tons) Add major modification threshold (40 tons)

= = 242 tons242 tons• Evaluate Alternative Baseline Period -

BBaseline = 205 tpy (1999/2000)Baseline = 205 tpy (1999/2000)Subtract Unit F baseline emissions (30 Subtract Unit F baseline emissions (30

tons) = 175 tonstons) = 175 tonsAdd PTE of new Unit G (40 tons) = Add PTE of new Unit G (40 tons) = 215 tons215 tonsAdd major modification threshold (40 tons) Add major modification threshold (40 tons)

= = 255 tons255 tons


““Actuals” PAL ExampleActuals” PAL Example• Proposed VOC PAL = 255 tonsProposed VOC PAL = 255 tons• Is a 255 tpy PAL viable?Is a 255 tpy PAL viable?

Recent actual emissions are well below Recent actual emissions are well below baselinebaseline

Abatement equipment was added to Unit Abatement equipment was added to Unit DD

Facility plans to switch to powder and/or Facility plans to switch to powder and/or waterborne coatings on Units A and C waterborne coatings on Units A and C within 5 years resulting in lower within 5 years resulting in lower emissionsemissions

• A 255 tpy PAL is viable for this A 255 tpy PAL is viable for this facilityfacility


PAL PermitsPAL Permits

• What does a PAL permit look like?What does a PAL permit look like?PAL permits must include:PAL permits must include:

o Identification of PAL pollutant(s) and Identification of PAL pollutant(s) and limits(s)limits(s)

o PAL effective and expiration datesPAL effective and expiration dateso PAL renewal/transition provisionsPAL renewal/transition provisionso Requirement to include emissions from Requirement to include emissions from

start-ups, shutdowns,and malfunctions in start-ups, shutdowns,and malfunctions in compliance calculationscompliance calculations

o Requirement to comply with PAL Requirement to comply with PAL expiration requirementsexpiration requirements



PAL permits must include PAL permits must include (continued)(continued)o PAL calculation proceduresPAL calculation procedureso Monitoring requirementsMonitoring requirementso Record retention requirementsRecord retention requirementso Reporting requirementsReporting requirementso Other “necessary” requirementsOther “necessary” requirements


PAL PermitsPAL Permits• How long are PALs and PAL How long are PALs and PAL

permits good for?permits good for?The effective period for a PAL is 10 The effective period for a PAL is 10

yearsyears

• Can PALs be re-opened by the Can PALs be re-opened by the regulatory authority?regulatory authority?YesYes - mandatory reopening of PAL - mandatory reopening of PAL

permits to:permits to:o Correct errorsCorrect errorso Reduce PAL for creditable reductionsReduce PAL for creditable reductionso Revise to reflect a PAL increaseRevise to reflect a PAL increase


PAL PermitsPAL Permits• Do PALs/PAL permits expire?Do PALs/PAL permits expire?

YesYes – PALs/PAL permits not renewed – PALs/PAL permits not renewed expire at the end of their effective period expire at the end of their effective period (10 years)(10 years)

• What happens if a PAL is allowed to What happens if a PAL is allowed to expire?expire?New emission limits are establishedNew emission limits are established

o Source proposes distribution of PAL Source proposes distribution of PAL emissions to each emissions unit that existed emissions to each emissions unit that existed under the PALunder the PAL

o The reviewing authority decides the ultimate The reviewing authority decides the ultimate distribution of PAL emissions to emissions distribution of PAL emissions to emissions unitsunits



11 In this example, emissions were apportioned In this example, emissions were apportioned to individual emissions units at PAL expiration to individual emissions units at PAL expiration based on the distribution of emissions during based on the distribution of emissions during the baseline periodthe baseline period

PAL emissions are “distributed” PAL emissions are “distributed” to individual emissions units if to individual emissions units if the PAL expiresthe PAL expires

Emissions Unit PAL Level (tons) Emissions at PAL Expiration (tpy)

A 61.7

B 24.5

C 255 70.6

D 25.0

E 25.5

G 47.4


PAL PermitsPAL Permits• PAL Expiration NotesPAL Expiration Notes

Compliance with new enforceable tpy Compliance with new enforceable tpy limits is based on a 12-month rolling basislimits is based on a 12-month rolling basis

Required monitoring systems may be Required monitoring systems may be similar to those under PALssimilar to those under PALs

Compliance with a site-wide emissions Compliance with a site-wide emissions “cap,” equivalent to the previous PAL, is “cap,” equivalent to the previous PAL, is required until a revised permit is issuedrequired until a revised permit is issued

Physical changes or changes in the Physical changes or changes in the method of operation are subject to major method of operation are subject to major NSR if change is a major modificationNSR if change is a major modification

State or federal requirements (BACT, State or federal requirements (BACT, LAER, RACT, NSPS, etc.) remain applicableLAER, RACT, NSPS, etc.) remain applicable



• Are PALs adjusted when they are Are PALs adjusted when they are renewed?renewed?Yes Yes – PALs are evaluated at renewal using the – PALs are evaluated at renewal using the

same process used to set the original PALssame process used to set the original PALs If the new PAL level is > or = 80% of existing If the new PAL level is > or = 80% of existing

PAL level, PAL level, PAL may be reset at original levelPAL may be reset at original levelThe reviewing authority has discretion in The reviewing authority has discretion in

setting a new PAL level to :setting a new PAL level to :o Be more representative of actual emissionsBe more representative of actual emissionso Be in accordance with local air quality needsBe in accordance with local air quality needso Accommodate anticipated economic growthAccommodate anticipated economic growtho Represent advances in air pollution control Represent advances in air pollution control

technologytechnology



• PAL renewal adjustment notes:PAL renewal adjustment notes:The “new” PAL may not exceed the The “new” PAL may not exceed the

facility PTE facility PTE New PAL cannot exceed original PAL New PAL cannot exceed original PAL

level unless undergoing PAL level unless undergoing PAL modification (increase) proceduremodification (increase) procedure

The PAL must reflect all The PAL must reflect all requirements that became requirements that became applicable during PAL term and that applicable during PAL term and that PAL was not adjusted forPAL was not adjusted for


PAL PermitsPAL Permits• How can PAL levels be increased?How can PAL levels be increased?

An application for a PAL increase is An application for a PAL increase is required that:required that:o Identifies all emissions units contributing to the Identifies all emissions units contributing to the

increaseincreaseo Demonstrates a PAL Demonstrates a PAL exceedanceexceedance after inclusion after inclusion

of proposed new/modified emissions units of proposed new/modified emissions units and and an assumption of current BACT equivalent an assumption of current BACT equivalent controls on all unitscontrols on all units

A major NSR permit is required for A major NSR permit is required for emissions units associated with the emissions units associated with the increase, increase, regardless of the magnitude of regardless of the magnitude of the emissions increasethe emissions increaseo Facility must comply with any resulting Facility must comply with any resulting

BACT/LAER requirementsBACT/LAER requirements


PAL PermitsPAL Permits• How is a higher PAL level established?How is a higher PAL level established?

The regulatory authority establishes a The regulatory authority establishes a higher PAL level based on:higher PAL level based on:• The sum of the The sum of the allowableallowable emissions from emissions from

new/modified emissions units - PLUS -new/modified emissions units - PLUS -• The sum of the The sum of the baseline actualbaseline actual emissions from emissions from

all significant/major emissions unitsall significant/major emissions units assuming assuming BACT controlBACT control - PLUS - - PLUS -

• The sum of The sum of baseline actualbaseline actual emissions from emissions from small emissions unitssmall emissions units

The end result - the magnitude of the The end result - the magnitude of the proposed increase is minimized by the proposed increase is minimized by the potential PAL decreases by assuming potential PAL decreases by assuming BACT control on significant and major BACT control on significant and major emissions unitsemissions units



• What type of monitoring What type of monitoring requirements are specified in PAL requirements are specified in PAL permits?permits?PAL general monitoring requirements PAL general monitoring requirements

specify that:specify that:o PAL monitoring systems must be based PAL monitoring systems must be based

on “sound science”on “sound science”o Must meet “minimum legal requirements Must meet “minimum legal requirements

for admissibility in a judicial proceeding for admissibility in a judicial proceeding to enforce the PAL permit”to enforce the PAL permit”

o Emissions must be quantifiable on an Emissions must be quantifiable on an ongoing basisongoing basis



• Acceptable PAL monitoring Acceptable PAL monitoring techniques include:techniques include:Mass Balance CalculationsMass Balance Calculations

o For sources using paints, coatings, and solventsFor sources using paints, coatings, and solvents

Continuous Emission Monitoring Systems Continuous Emission Monitoring Systems (CEMS)(CEMS)

Continuous Parameter Monitoring Systems Continuous Parameter Monitoring Systems (CPMS)(CPMS)

Predictive Emission Monitoring Systems (PEMS)Predictive Emission Monitoring Systems (PEMS)Emission FactorsEmission FactorsAlternative methods as approved by the Alternative methods as approved by the

administratoradministrator



• Mass Balance CalculationsMass Balance CalculationsRequirements include:Requirements include:

o A demonstrated means to validate A demonstrated means to validate pollutant content in material(s)pollutant content in material(s)

o Assumption that emissions unit emits Assumption that emissions unit emits allall of a pollutant if the pollutant cannot be of a pollutant if the pollutant cannot be accounted for accounted for

o The use of the highest value of a The use of the highest value of a pollutant where a range of the pollutant pollutant where a range of the pollutant content is publishedcontent is published

Mass balance calculations are Mass balance calculations are acceptable and are widely used for acceptable and are widely used for activities using coatings or solventsactivities using coatings or solvents



• Continuous Emission Continuous Emission Monitoring Systems (CEMS)Monitoring Systems (CEMS)RequirementsRequirements

o Systems must meet applicable Part Systems must meet applicable Part 60, Appendix B Performance 60, Appendix B Performance SpecificationsSpecifications

o Systems must sample, analyze, Systems must sample, analyze, record data once every 15 minutes record data once every 15 minutes of operationof operation



• Continuous Parameter Monitoring Continuous Parameter Monitoring Systems (CPMS) and Predictive Systems (CPMS) and Predictive Emission Monitoring Systems Emission Monitoring Systems (PEMS)(PEMS)RequirementsRequirements

o The CPMS/PEMS system must demonstrate The CPMS/PEMS system must demonstrate a correlation between monitored a correlation between monitored parameters and PAL pollutant emissions parameters and PAL pollutant emissions across the range of unit operationacross the range of unit operation

o The CPMS/PEMS system must sample, The CPMS/PEMS system must sample, analyze, record data once every 15 analyze, record data once every 15 minutes of operationminutes of operation


PAL PermitsPAL Permits• Emission FactorsEmission Factors

RequirementsRequirementso If appropriate, factors must be adjusted for If appropriate, factors must be adjusted for

the uncertainty or limitations in the the uncertainty or limitations in the factor’s developmentfactor’s development

o Emissions units must operate within the Emissions units must operate within the range of the factor’s developmentrange of the factor’s development

o If technically practicable, the emission If technically practicable, the emission factors for significant units must be re-factors for significant units must be re-validated within 6 months of the PAL validated within 6 months of the PAL permit issuancepermit issuance

• Unless reviewing agency determines that Unless reviewing agency determines that testing is not requiredtesting is not required


PAL PermitsPAL Permits• How is How is missing monitoring datamissing monitoring data

handled under a PAL?handled under a PAL?Sources must record and report maximum Sources must record and report maximum

potential emissions without considering potential emissions without considering enforceable limitations or operating enforceable limitations or operating restrictionsrestrictions

• What happens when a source operates What happens when a source operates at at non-correlatednon-correlated operating ranges? operating ranges?A default value representing the highest A default value representing the highest

potential emissions must be established potential emissions must be established and used, orand used, or

The source is deemed in violation when the The source is deemed in violation when the unit is operating outside of a correlated unit is operating outside of a correlated parametric rangeparametric range



• Do emissions monitoring systems under Do emissions monitoring systems under a PAL ever have to be re-validated?a PAL ever have to be re-validated?YesYes - data re-validation is required once - data re-validation is required once

every 5-years for every 5-years for all methods of monitoringall methods of monitoringRe-validation is accomplished by emission Re-validation is accomplished by emission

testing or or other scientifically valid meanstesting or or other scientifically valid meansThe PAL applicant may want to consider The PAL applicant may want to consider

including a re-validation protocol with the including a re-validation protocol with the PAL application addressing each type of PAL application addressing each type of monitoring and the proposed re-validation monitoring and the proposed re-validation proceduresprocedures



• How long must PAL related How long must PAL related compliance records be retained?compliance records be retained?Records necessary to demonstrate Records necessary to demonstrate

compliancecompliance with the PAL regulations with the PAL regulations must be retained for must be retained for five (5) yearsfive (5) years from from the date of the recordthe date of the record

Other PAL related recordsOther PAL related records must be must be retained for the retained for the duration of PAL plus 5 duration of PAL plus 5 yearsyearso PAL applicationPAL applicationo PAL revision applications PAL revision applications o Annual Title V certificationsAnnual Title V certifications


PAL PermitsPAL Permits• Received multiple PAL

applications under NSR Reforms

• Paper mill, chemical mfg., commercial printer/laminator, automobile assembly

• Others in development• Is it right for your Facility?


PSD-PALsPSD-PALs• What are PSD-PALs?What are PSD-PALs?

A flexible permitting option that A flexible permitting option that combines the permitting of a new combines the permitting of a new major source or a major major source or a major modification at an existing facility modification at an existing facility with an application for a PALwith an application for a PAL

The PALs are based on a The PALs are based on a combination of baseline emissions combination of baseline emissions and projected future actual and projected future actual emissionsemissions

PSD-PALs are issued through a SIP PSD-PALs are issued through a SIP approved NSR permitting programapproved NSR permitting program


PSD-PALsPSD-PALs

• There are currently two PSD-There are currently two PSD-PALs in Region 4PALs in Region 4Saturn Corporation - Spring Hill, Saturn Corporation - Spring Hill,

TennesseeTennesseeBMW – Greenville, South CarolinaBMW – Greenville, South Carolina

• The PSD-PAL discussion is The PSD-PAL discussion is based predominantly on EPA based predominantly on EPA Region 4 experience with these Region 4 experience with these two sourcestwo sources


PSD-PALsPSD-PALs• What type of facility is ideal for a PSD-What type of facility is ideal for a PSD-

PAL permit?PAL permit?Complex, well-controlled existing or new Complex, well-controlled existing or new

facilities with multiple, inter-dependant facilities with multiple, inter-dependant processes processes o New facilities are excluded from NSR PAL rulesNew facilities are excluded from NSR PAL rules

Facilities subject to frequent changes with:Facilities subject to frequent changes with:o A high potential to emit for one or more PSD A high potential to emit for one or more PSD

regulated pollutantsregulated pollutantso Well characterized emissions Well characterized emissions o Effective monitoring systemsEffective monitoring systems

• Examples include automobile Examples include automobile manufacturers, chemical manufacturers, chemical manufacturers, and Kraft pulp millsmanufacturers, and Kraft pulp millsThese types of facilities are well These types of facilities are well

represented in Region 4represented in Region 4


PSD-PALsPSD-PALs

• PSD-PAL Level equals:PSD-PAL Level equals:

Baseline emissions from all unaffected Baseline emissions from all unaffected emissions units (including shutdown sources emissions units (including shutdown sources where applicable)where applicable)

PLUSPLUS

PTE from new or modified emissions unitsPTE from new or modified emissions units

MINUSMINUS

Baseline emissions from sources permanently Baseline emissions from sources permanently shutdownshutdown


PSD-PALsPSD-PALs Unit 1 Unit 2 Unit 3 Unit 4 Unit 51 Unit 61 Unit 72 Unit 82 Unit 92 Total

Unaffected Affected Affected Unaffected Down Down New New New Corrected

Year VOC (tons) VOC (tons)

VOC (tons)

VOC (tons) VOC (tons)

VOC (tons)

VOC (tons)

VOC (tons)

VOC (tons)

VOC3 (tons)

1995 52 50 19 19 54 87 ---- ---- ---- 212

1996 46 52 20 23 51 85 ---- ---- ---- 205

1997 42 60 21 22 54 82 ---- ---- ---- 200

1998 45 58 20 23 50 88 ---- ---- ---- 206

1999 49 62 21 23 30 97 ---- ---- ---- 199

2000 55 68 21 20 30 90 ---- ---- ---- 195

2001 45 59 19 22 0 89 ---- ---- ---- 156

2002 44 67 18 22 0 88 ---- ---- ---- 154

2003 45 65 16 23 0 90 ---- ---- ---- 158

2004 46 62 17 20 0 92 ---- ---- ---- 158

Baseline 52 N/A N/A 21.5 30 93.5 N/A N/A N/A 197

Projected Actual at BACT N/A 85 25 N/A 0 0 75 50 50 285

Last BACT 1995 1995 2000 1995 N/A N/A 2005 2005 2005

1 1 Unit 5 shut down in late 2000, Unit 6 shut down in late 2004Unit 5 shut down in late 2000, Unit 6 shut down in late 20042 2 Units 7, 8, and 9 are new unitsUnits 7, 8, and 9 are new units3 3 Total corrected VOC excludes emissions from affected unitsTotal corrected VOC excludes emissions from affected units


PSD-PALsPSD-PALs

•Establish PAL Establish PAL ContributionsContributions

Unaffected source baselineUnaffected source baselineo 73.5 tons73.5 tons

New/affected sourcesNew/affected sourceso 285 tpy285 tpy

Shut-down sources in Shut-down sources in baselinebaseline

o 123.5 tpy123.5 tpy

Unit StatusPAL Contribution

(tons)

11 UnaffectedUnaffected 5252

22 AffectedAffected 8585

33 AffectedAffected 2525

44 UnaffectedUnaffected 21.521.5

55 ShutdownShutdown 93.593.5

66 ShutdownShutdown 3030

77 NewNew 7575

88 NewNew 5050

99 NewNew 5050

TotalTotal 482482


PSD-PALsPSD-PALs

•Compute the PSD-PAL level:Compute the PSD-PAL level:Baseline emissions from unaffected Baseline emissions from unaffected emissions units emissions units = = 73.5 tons73.5 tonsBaseline emissions from shutdown Baseline emissions from shutdown sources = sources = 123.5123.5 tonstonsProjected actual emissions from new Projected actual emissions from new and affected and affected sources = sources = 285 tons285 tonsCompute PALCompute PAL

o73.5 tons + 123.5 tons + 285 tons – 123.5 73.5 tons + 123.5 tons + 285 tons – 123.5 tons = tons = 358.5 tons358.5 tons

PAL LEVEL = 358.5 TONS PER ROLLING 12-MONTH PERIOD


PSD-PALsPSD-PALs

• Can PSD-PALs be written with Can PSD-PALs be written with “Flexibility” provisions?“Flexibility” provisions?YesYes - PSD-PALs may include flexibility - PSD-PALs may include flexibility

provisionsprovisionsFlexibility provisions are those conditions Flexibility provisions are those conditions

that reduce the administrative “friction” - that reduce the administrative “friction” - costs, time, delay, uncertainty, and risks costs, time, delay, uncertainty, and risks experienced by sources and permitting experienced by sources and permitting authorities when implementing a permit authorities when implementing a permit or making certain changes under a permitor making certain changes under a permit

Flexibility provisions are in addition to the Flexibility provisions are in addition to the inherent PAL benefitsinherent PAL benefits


PSD-PALsPSD-PALs• What do flexible provisions include?What do flexible provisions include?

Pre-approved NSRPre-approved NSRo Ability to add new emissions units Ability to add new emissions units o Ability to make physical changes or changes in Ability to make physical changes or changes in

the method of operationthe method of operation

Certain requirements may be subsumedCertain requirements may be subsumedo For example, compliance with PAL levels may For example, compliance with PAL levels may

be deemed to also be in compliance with:be deemed to also be in compliance with:• Individual BACT emission limitsIndividual BACT emission limits• State SIP emission limitsState SIP emission limits

Flexibility provided in PSD-PAL permits is Flexibility provided in PSD-PAL permits is largely dependent upon regulatory largely dependent upon regulatory authority policyauthority policy and is generally and is generally negotiatednegotiated


PSD-PALsPSD-PALs• Flexible components must include Flexible components must include

safeguardssafeguardsExamples of safeguards include:Examples of safeguards include:

o BACT on all new units > significance levelBACT on all new units > significance levelo Minor source BACT or Best Available Minor source BACT or Best Available

Technology (BAT) on all new units < Technology (BAT) on all new units < significance levelsignificance level

o Streamlined “registration” and public Streamlined “registration” and public notice for all new major unitsnotice for all new major units

o Requirement to operate and monitor air Requirement to operate and monitor air pollution control systems relied on for pollution control systems relied on for BACTBACT

o Requirement to comply with NAAQS and Requirement to comply with NAAQS and PSD incrementsPSD increments


PSD-PALsPSD-PALs

• What type of monitoring procedures What type of monitoring procedures are required under a PSD-PAL?are required under a PSD-PAL?In general, monitoring procedures that In general, monitoring procedures that

are equivalent to those required under are equivalent to those required under an NSR “actuals” PALan NSR “actuals” PALo Mass Balance CalculationsMass Balance Calculationso Credible Emission FactorsCredible Emission Factorso Continuous Emission Monitors (CEMs)Continuous Emission Monitors (CEMs)o Continuous Parameter Monitoring Systems Continuous Parameter Monitoring Systems

(CPMS)(CPMS)o Approved alternative monitoring methodsApproved alternative monitoring methods


PSD-PALsPSD-PALs

• What level of air pollution control What level of air pollution control device monitoring is required?device monitoring is required? In general, air pollution control device In general, air pollution control device

monitoring and recordkeeping should be monitoring and recordkeeping should be equivalent to CAM requirementsequivalent to CAM requirements

Effective air pollution control device Effective air pollution control device monitoring could be essential to flexibility monitoring could be essential to flexibility provisionsprovisionso Compliance with unit specific BACT requirements Compliance with unit specific BACT requirements

is based on compliance with PAL limits is based on compliance with PAL limits o BACT compliance is contingent upon proper BACT compliance is contingent upon proper

operation of air pollution control equipmentoperation of air pollution control equipmento An effective monitoring system is therefore An effective monitoring system is therefore

essential to BACT/PAL complianceessential to BACT/PAL compliance


PSD-PALsPSD-PALs• Emission calculation proceduresEmission calculation procedures

The applicant should develop and The applicant should develop and propose emission calculation procedures propose emission calculation procedures to convert monitoring data to a mass to convert monitoring data to a mass emission basisemission basis

Calculations should be based on sound Calculations should be based on sound scientific/engineering principles and scientific/engineering principles and should compute emissions (tons) on a should compute emissions (tons) on a monthly basismonthly basis

Monthly emissions (tons) are summed Monthly emissions (tons) are summed with the preceding 11 months worth of with the preceding 11 months worth of monthly data to demonstrate PAL monthly data to demonstrate PAL compliance on t rolling 12-month basiscompliance on t rolling 12-month basis

Calculations should be replicableCalculations should be replicable


PSD-PALsPSD-PALs

• A draft PSD-PAL permit is A draft PSD-PAL permit is recommended as part of a PSD-PAL recommended as part of a PSD-PAL applicationapplicationBenefits of a draft permit in the applicationBenefits of a draft permit in the application

o Starting point for negotiating conditionsStarting point for negotiating conditionso Clearly articulates source expectations and Clearly articulates source expectations and

commitmentscommitmentso Compresses regulatory agency review timeCompresses regulatory agency review time

Draft permit components include:Draft permit components include:o PAL conditionsPAL conditionso Monitoring requirementsMonitoring requirementso Recordkeeping requirementsRecordkeeping requirementso CalculationsCalculationso Flexibility provisionsFlexibility provisions


Case Study A – Saturn PSD/PALCase Study A – Saturn PSD/PAL• Overview of the PSD/PAL Permit for the Overview of the PSD/PAL Permit for the

Saturn Spring Hill, Tennessee FacilitySaturn Spring Hill, Tennessee FacilityThe Saturn facility is comprised of three The Saturn facility is comprised of three

business units:business units:o Body Systems - body panels, body fabrication Body Systems - body panels, body fabrication

and paint shopand paint shopo Vehicle Systems - vehicle interior systems Vehicle Systems - vehicle interior systems

and final vehicle assemblyand final vehicle assemblyo Powertrain - machining, engine assembly, Powertrain - machining, engine assembly,

and final dressand final dress

Production of Saturn vehicles began in Production of Saturn vehicles began in July of 1990July of 1990

The original PSD permit had 54 The original PSD permit had 54 separate permitted emissions units and separate permitted emissions units and 333 separate permit conditions333 separate permit conditions


Case Study A – Saturn PSD/PALCase Study A – Saturn PSD/PAL

• Planned facility changes for 2001Planned facility changes for 2001New vehicle assembly linesNew vehicle assembly linesModified coating lines/conveyor Modified coating lines/conveyor

changeschangesNew engine machining/assembly New engine machining/assembly

operationsoperationsNew AA stamping pressNew AA stamping pressOverall facility production capacity Overall facility production capacity

increase from 360,000 to 595,350 increase from 360,000 to 595,350 vehicles per yearvehicles per year


Case Study A – Saturn PSD/PALCase Study A – Saturn PSD/PAL• Critical facility air permitting issues:Critical facility air permitting issues:

Initial projects triggered PSD applicabilityInitial projects triggered PSD applicabilityFacility projects are subject to frequent Facility projects are subject to frequent

scope/schedule changesscope/schedule changesNSR Revision status was in a state of flux NSR Revision status was in a state of flux

in 1999in 1999• Saturn air permit objectives:Saturn air permit objectives:

Obtain an innovative permit regardless of Obtain an innovative permit regardless of NSR Revision statusNSR Revision status

Base flexible permit on the PAL conceptBase flexible permit on the PAL conceptObtain allowable emissions adequate for Obtain allowable emissions adequate for

595,350 vehicles/yr or more595,350 vehicles/yr or moreAccommodate scope/schedule changes Accommodate scope/schedule changes

without triggering the need for a new without triggering the need for a new permitpermit

Simplify compliance demonstrationSimplify compliance demonstration



• Final air permitting concept:Final air permitting concept: Innovative permit obtained through Innovative permit obtained through

traditional PSD permitting processtraditional PSD permitting processPSD permit with BACT levels combined PSD permit with BACT levels combined

to establish multi-pollutant PALsto establish multi-pollutant PALsStreamlined monitoring and Streamlined monitoring and

compliance determinationcompliance determinationExpedited treatment of additional new Expedited treatment of additional new

unitsunitsAuthorized changes to existing units Authorized changes to existing units

provided PALs are not exceededprovided PALs are not exceeded


Case Study A – Saturn Case Study A – Saturn PSD/PALPSD/PAL

• PSD-PAL permit applicationPSD-PAL permit applicationCommon PSD Components (BACT, modeling, Common PSD Components (BACT, modeling,

etc.)etc.) Innovative ComponentsInnovative Components

o Proposed PALs based on a combination of baseline Proposed PALs based on a combination of baseline and potential emissions for criteria pollutantsand potential emissions for criteria pollutants

o Single emissions unit for all combustion related Single emissions unit for all combustion related emissionsemissions

o Documentation of BACT equivalent technology for Documentation of BACT equivalent technology for unaffected emissions units (e.g., clean units)unaffected emissions units (e.g., clean units)

o Sample draft permit language incorporating Sample draft permit language incorporating proposed PALs and other innovative provisionsproposed PALs and other innovative provisions

Submitted application to TDEC in October 1999Submitted application to TDEC in October 1999Received final PSD/PAL permit in June 2000Received final PSD/PAL permit in June 2000



a Previous allowable emissions represent conditions from Saturn’s 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.

Criteria VOC NOx CO PM10 SO2d

Previous Allowablea

2,897 380 179 305 N/A

Baseline Actualb

949 95 133 163 1PAL Levels 1563 189 220 205 39

Net Changec

614 94 87 42 38Major Modification Threshold 40 40 100 15 40

Emissions Summary, Tons/yr.Emissions Summary, Tons/yr.



• Permit InnovationsPermit InnovationsOperational FlexibilityOperational Flexibility

o Pre-approved new “major” emissions Pre-approved new “major” emissions unitsunits

• Registration and BACT requirementRegistration and BACT requirement• Saturn may begin construction when BACT Saturn may begin construction when BACT

is approved (i.e., 45 days)is approved (i.e., 45 days)

o Pre-approved new “minor” emissions Pre-approved new “minor” emissions unitsunits

• Registration and mBACT requirementRegistration and mBACT requirement• Saturn may begin construction when Saturn may begin construction when

mBACT is approved (i.e., 30 days)mBACT is approved (i.e., 30 days)

o Changes to existing emissions units Changes to existing emissions units do not require TDEC approval do not require TDEC approval



• Permit InnovationsPermit InnovationsClear monitoring and Clear monitoring and

recordkeeping requirementsrecordkeeping requirementsAbility to increase PALs through Ability to increase PALs through

the PSD permitting processthe PSD permitting processTermination provision with Termination provision with

return to “traditional” permitreturn to “traditional” permitStreamlined compliance Streamlined compliance

requirementsrequirements



Permit Condition Original PSD Permit PSD/PAL PermitNo. of Individual Permits 54 1Production Limits 61 0Fuel Restrictions 8 1VOC Limits (e.g., TPY, lb/hr, etc.) 74 5PM Limits (e.g., TPY, gr./dscf, etc.) 78 1NOx Limits (e.g., TPY, lb/hr, etc.) 29 1CO Limits (e.g., TPY, lb/hr, etc.) 31 1

SO2 Limits (e.g., TPY, lb/hr, etc.) 8 1

Visible Emissions 44 44

““Old” PSD Versus New PSD/PAL Old” PSD Versus New PSD/PAL ConditionsConditions



• SummarySummaryThe PAL permit provides significant The PAL permit provides significant

operational flexibility to Saturn within operational flexibility to Saturn within current regulatory boundscurrent regulatory bounds

The permit streamlines compliance The permit streamlines compliance determinations for the facility, TDEC, and determinations for the facility, TDEC, and the publicthe public

VOC emissions per vehicle produced has VOC emissions per vehicle produced has declined since PAL issuancedeclined since PAL issuance

The PSD/PAL permit has improved the The PSD/PAL permit has improved the environmental performance of the facilityenvironmental performance of the facility

The original PAL permit limits and The original PAL permit limits and flexibility are retained in the Title V flexibility are retained in the Title V operating permitoperating permit


Case Study C – Non-attainment Case Study C – Non-attainment PALPAL

• Overview of a Overview of a proposedproposed PAL for an PAL for an adhesive coating facility in Pennsylvaniaadhesive coating facility in PennsylvaniaThe facilityThe facility includes boilers, reactor vessels, includes boilers, reactor vessels,

mixing and formulation, multiple adhesive mixing and formulation, multiple adhesive coaters and dryers, and research and coaters and dryers, and research and development facilitiesdevelopment facilities

Facility emissions include VOC, PM10, HAPs, Facility emissions include VOC, PM10, HAPs, and products of combustion (NOx and CO)and products of combustion (NOx and CO)

The facility is well controlled using a vent The facility is well controlled using a vent condenser and two existing regenerative condenser and two existing regenerative thermal oxidizers to abate VOC and vHAP thermal oxidizers to abate VOC and vHAP emissionsemissions



• Critical facility air permitting issues:Critical facility air permitting issues:NSR Revisions became effective in March NSR Revisions became effective in March

2003 for 2003 for attainmentattainment pollutants pollutantsThe facility is located in an area classified The facility is located in an area classified

as moderately non-attainment for ozone as moderately non-attainment for ozone due to its location in the Northeast Ozone due to its location in the Northeast Ozone Transport RegionTransport Region

Permitting timelines and redundant NSR Permitting timelines and redundant NSR applicability analysesapplicability analyses

Projects “in the pipeline” that include Projects “in the pipeline” that include expedited installation schedulesexpedited installation schedules



• Final air permitting concept:Final air permitting concept:Acquire a VOC PAL through the Acquire a VOC PAL through the

Pennsylvania Pennsylvania minorminor NSR program NSR programSince facility is well controlled, use the 40 Since facility is well controlled, use the 40

ton major NSR modification threshold to ton major NSR modification threshold to establish a VOC PALestablish a VOC PAL

Ensure expedited state review and Ensure expedited state review and approval of facility modifications by approval of facility modifications by eliminating required non-attainment NSR eliminating required non-attainment NSR applicability determinationsapplicability determinations

Allow the facility to decide where and how Allow the facility to decide where and how VOC emissions are controlled within the VOC emissions are controlled within the facility in accordance with Pennsylvania facility in accordance with Pennsylvania Best Available Technology (BAT) Best Available Technology (BAT) requirementsrequirements



• Minor Pennsylvania NSR permit Minor Pennsylvania NSR permit applicationapplicationBAT analysis not required since no BAT analysis not required since no

emissions units were being modifiedemissions units were being modifiedEmissions inventory Emissions inventory

o Baseline calculationBaseline calculation - PA PAL policy requires the - PA PAL policy requires the use of the most recent two calendar years to use of the most recent two calendar years to develop baseline emission rates or an alternative develop baseline emission rates or an alternative two year period within the past five year if the two year period within the past five year if the most recent two years is not representativemost recent two years is not representative

o PAL calculation PAL calculation - The PAL was established by - The PAL was established by adding an amount slightly less than the major adding an amount slightly less than the major modification threshold (i.e., 39 tons for VOC) to modification threshold (i.e., 39 tons for VOC) to the baseline minus the baseline minus allowable emission increases allowable emission increases since 1991since 1991



Non-attainment VOC PAL CalculationNon-attainment VOC PAL Calculation

Calculation StepsEmissions

(tpy)

2002 Calendar Year Actual Emissions (from emissions statement) 25.06

2003 Calendar Year Actual Emissions (from emissions statement) 21.91

Two-year average baseline emissions 23.49

ADD - Moderate Non-attainment major modification threshold (- 0.5 tons) 39.5

SUBTRACT - Allowable increases in VOC since 1991 (0.79)

PROPOSED NON-ATTAINMENT VOC PAL 62.6



Innovative ComponentsInnovative Componentso Proposed site wide VOC PAL set using Proposed site wide VOC PAL set using

baseline VOC emissions plus adjusted baseline VOC emissions plus adjusted NSR major modification thresholdNSR major modification threshold

o The facility is well controlled and the The facility is well controlled and the VOC PAL provides a considerable VOC PAL provides a considerable growth cushiongrowth cushion

o For this facility, the ability to manage For this facility, the ability to manage growth internally via a VOC PAL is growth internally via a VOC PAL is sufficiently innovativesufficiently innovative

Submitted application in October Submitted application in October 20042004

A proposed draft permit is currently A proposed draft permit is currently under review by DEP and the facilityunder review by DEP and the facility

Documents

FINAL PRESENTATION 1-24-051 Flexible Permitting Workshop Presented by: U.S. EPA Region 4 Air Permits Section