Potential to Emit. Calculating your PTE Jenifer Dixon Public Affairs and Outreach

Transcription

1 Potential to Emit Calculating your PTE Jenifer Dixon Public Affairs and Outreach

2 Topics of Discussion Introduction to Potential to Emit When to Calculate Potential to Emit How to Calculate Potential to Emit Major or Minor Source? How to Avoid Being a Major Source

3 Introduction to Potential to Emit

4 What is potential to emit? Potential to Emit or PTE is defined as: R (n) "Potential to emit" means the maximum capacity of a stationary source to emit an air contaminant under its physical and operational design. Any physical or operational limit on the capacity of the stationary source to emit an air contaminant, including air pollution control equipment and restrictions on the hours of operation or the type or amount of material combusted, stored, or processed, shall be treated as part of its design only if the limit, or the effect it would have on emissions, is legally enforceable. Secondary emissions shall not count in determining the "potential to emit" of a stationary source. For hazardous air pollutants that have been listed pursuant to Section 112(b) of the clean air act, quantifiable fugitive emissions shall be included in determining the potential to emit of any stationary source.

5 Let s break it down PTE is the maximum amount of air contaminants that your facility could emit if all of the following is evaluated: each process is operated at 100% of its design capacity; consider 24 hours/day, 365 days/year; materials emitting the highest amount of air contaminants are used or processed; and air pollution control equipment either is not in use or is turned off.

6 Still Confused? PTE = (max hourly emission rate of pollutant) x (8760 hours)

7 Why PTE not actual emissions? Actual Can change year to year May not be consistent PTE Impartial Consistent Criteria Levels the playing field

8 Regulated Pollutants Carbon Monoxide (CO) Lead (Pb) Ozone (O 3 ), including Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx) - ozone precursors* Nitrogen Oxides (NO x ) Particulate Matter (PM) Particulate Matter < 10 microns in diameter (PM-10) Particulate Matter < 2.5 microns in diameter (PM 2.5) Sulfur Dioxide (SO 2 ) Green House Gases (GHGs)

9 Hazardous Air Pollutants List of 187 currently

10 Other Regulated Pollutants NESHAP National Emission Standards for Hazardous Air Pollutants Such as Asbestos and Benzene NSPS New Source Performance Standards Such as Mercury and Hydrogen Chloride Class I and Class II Pollutants Ozone depleting pollutants (Table 1-4)

11 What is a major source of a pollutant? Type of Pollutant Major Source Threshold Common Sources of Pollutant PM 100 tons/year Dusty activities such as grain handling, milling, sand and gravel operations PM tons/year Dusty activities such as grain handling, milling, sand and gravel operations PM tons/year Fuel burning activities VOCs 100 tons/year Solvent cleaning, painting, fuel storage and transfer CO 100 tons/year Fuel combustion NOx 100 tons/year Fuel combustion SO tons/year Fuel combustion Lead (Pb)* 100 tons/year Wave soldering, lead smelting and recycling HAPs Any single HAP Any combination of HAPs GHGs Any other regulated air contaminant 10 tons/year 25 tons/year 75, ,000 tons/year on a Carbon Dioxide Equivalent (CO 2e ) basis 100 tons/year Solvent cleaning, painting, fuel storage and transfer * Lead compounds are considered HAPs Fuel Combustion

12 When to Calculate Potential to Emit

13 When? When adding a process When removing a process When changing a material When changing a process PTE is not stagnant!

14 How to Calculate Potential to Emit

15 Small Business, Inc. STEP 1: Conduct a facility inventory to identify process equipment. STEP 2: Gather data for each emission source. STEP 3: Categorize emission sources (permitted, grandfathered, or exempt). STEP 4: Identify legally enforceable limitations. STEP 5: Identify the emission calculation methods you will use. STEP 6: Calculate the PTE for each emission source. STEP 7: Calculate the PTE for the facility.

16 Tracking your data The potential to Emit Summary Worksheet (Appendix B)

17 Conduct a facility inventory Step 1

18 Conduct a Facility Inventory Identify the boundaries of your Stationary Source AQD-011 defines this May not just be where the process is Includes contiguous properties Properties under the same owner Properties under the same operational control Belong to the same industrial classification More

19 Conduct a Facility Inventory Identify sources or processes Draw a map if needed Include everything in your stationary source Even nonproduction sources, like welding and clean-up activities

20 Conduct a Facility Inventory Some reminders No stack necessary Not necessary to be in the main building Clean-up solvents Aerosol paint usage Check existing resources: Permits MAERS reports TRI information

21 Do I Need to Include Fugitive Emissions? Cannot reasonably passed through a stack or a building structure valves or flanges dust blowing from rock or coal piles

22 Do I Need to Include Fugitive Emissions? If your processes fall into these categories: Table 2-1: Types of Facilities that Must Include Fugitive Emissions PTE Coal cleaning plants - with thermal dryers Primary zinc smelters Portland cement plants Primary aluminum ore reduction plants Iron and steel mills Primary copper smelters Hydrofluoric, sulfuric, or nitric acid plants Lime plants Coke oven batteries Carbon black plants Fuel conversion plants Secondary metal production plants Fossil-fuel boilers (or combination thereof) totaling more than 250 mmbtu/hr Taconite ore processing plants Charcoal production plants Asphalt concrete plants Secondary lead smelters and refineries Sewage treatment plants Ferro-alloy production plants Stationary gas turbines Kraft pulp mills Municipal incinerators capable of charging more than 250 tons of refuse per day Petroleum refineries Phosphate rock processing plants Sulfur recovery plants Primary lead smelters Sintering plants* Chemical process plants- not including ethanol production by natural fermentation Petroleum storage and transfer units, total storage capacity over 300,000 barrels- or 40,000 gallons Glass fiber processing plants Fossil fuel-fired steam electric plants of more than 250 mmbtu/hr Phosphate fertilizer plants Grain elevators Stationary sources subject to NESHAP for asbestos, beryllium, mercury, vinyl chloride

23 Insignificant Activities Table 2-2: Insignificant Activities at a Stationary Source Repair and maintenance of grounds and structures and repair and maintenance of process and process equipment pursuant to Michigan Rule R (a)-(c). Use of office supplies. Use of housekeeping and janitorial supplies. Sanitary plumbing and associated stacks or vents. Temporary activities related to the construction or dismantlement of buildings, utility lines, pipelines, wells, earthworks, or other structures. Storage and handling of drums or other transportable containers where the containers are sealed during storage and handling. Fire protection equipment, firefighting, and training in preparation for fighting fires. Use, servicing, and maintenance of motor vehicles including cars, trucks, lift trucks, locomotives, aircraft, or water craft, except where those activities are subject to an applicable requirement (e.g., requirement to have a fugitive dust control or operating program). Construction, repair, and maintenance of roads or other paved or unpaved areas, except where those activities are subject to an applicable requirement (e.g., requirement to have a fugitive dust control or operating program). Piping and storage of sweet natural gas, including emergency venting from pressure relief valves or purging of gas lines.

24 Did you forget anything? Look at existing permits Check your MAERS report Check your TRI data

25 Conduct a Facility Inventory Emission Source Description Name your emission 3 spray sources booths appropriately 2,500,000 Btu/hr natural gas fired Use a description that Booth is used accurate for touchup and complete COATING BOOTHS 1-3 OVEN MAINTENANCE BOOTH PRINTING Prints information on product SPECIAL PROJECT BOOTH Spray booth used for special projects COLD CLEANERS 2 cold cleaners for parts washing CLEANUP GRINDER WELDING Facility-wide cleanup solvents Metal parts grinder connected to baghouse (29,000 cfm) Shielded metal arc welding BOILER 10 million Btu/hr natural gas fired boiler GENERATOR Diesel fired emergency generator

26 Gather Data Step 2

27 Gather Data About Each Emission Source Air Permits Safety Data Sheets (SDS) Performance test results Control efficiency of control equipment Manufacturer Specs Maximum capacities Rate of spray guns Heat input capacity of boilers Production rate

28 Categorize Emission Sources Step 3

29 Categorize Emission Sources permitted grandfathered or exempt from Rule 201 permitting requirements

30 Being Exempt Is the equipment mentioned? Is it part of a bigger project? Trigger significance thresholds? DOCUMENT IT!

31 What to Document? When looking at using an exemption: Must pass Rule 278 to use Significant Emissions R278a records and ongoing monthly recordkeeping Date of installation Description of Emission Unit Determination

32 Emission Source Description Permit Status Lega Categorize Emission COATING BOOTHS x Permitted: PTI # Permit 3 spray booths Grandfathered: / / Permit Exempt: R 336. OVEN MAINTENANCE BOOTH PRINTING 287(C) BOOTH COLD CLEANERS CLEANUP GRINDER WELDING BOILER GENERATOR Sources 2,500,000 Btu/hr natural gas fired Booth used for touchup Prints information on product Spray booth used for special projects 2 cold cleaners for parts washing Facility-wide cleanup solvents Metal parts grinder connected to baghouse (29,000 cfm) Shielded metal arc welding 10 million Btu/hr natural gas fired boiler Diesel fired emergency generator x Permitted: PTI # Grandfathered: / / Exempt: R 336. x Permitted: PTI # Grandfathered: / / Exempt: R 336. x Permitted: PTI # Grandfathered: 10/15/1966 Exempt: R 336. Permitted: PTI # Grandfathered: / / Exempt: R (c) x Permitted: PTI # Grandfathered: / / Exempt: R (h) x Permitted: PTI # Grandfathered: / / Exempt: R x Permitted: PTI # Grandfathered: / / Exempt: R (l)(vi)_ x Permitted: PTI # Grandfathered: / / Exempt: R (i) x Permitted: PTI # Grandfathered: / / Exempt: R (b)(i)_ x Permitted: PTI # Grandfathered: / / Exempt: R (g) x None Permit re None (gra Rule: R 33 usage to 2 Rule: R 33 cover be drained Rule: R 33 non-carcin lbs/month Rule: R 33 emission o lbs gas None None None

33 Identify Limitations Step 4

34 Identify Legally Enforceable Limitations Things that may limit your PTE Conditions in a Permit State or Federal Rules

35 Permit Conditions Must be legally and practically enforceable Monitoring and recordkeeping Look for: Emission Limits Requirements to operate an air pollution control device Material Limits Operating Hours Limits Production Limits

36 State and Federal Rules Look for restrictions: Restrict emission types Restrict emission rates Limit the usage of raw materials Restrict operations Require specific control devices

37 PTE Summary Table Legally Enforceable Limitation - Permit limit = 5.6 tons VOC/yr - Permit requires fabric filter None Permit requires fabric filter None (grandfathered) Rule: R (c) limits coating usage to 200 gal/month Rule: R Requires that cover be closed and that parts be drained Rule: R limits emission of noncarcinogenic VOCs to 1,000 lbs/month Rule: R ,Table 31J - limits emission of PM to 0.10 lbs per 1000 lbs gas None None None

38 Identify Calculation Methods Step 5

39 Identify the Emission Calculation Methods Legally enforceable limitations Performance test data Mass balance approach Emissions factors

40 Legally Enforceable Limitations Rules Conditions in your permit Compliance or enforcement documents

41 Performance Test Data Stack test Continuous emission monitoring (CEMS) Manufacturer test data NOTE: may provide emissions information not in an applicable limit in a permit or rule.

42 Mass Balance Approach What goes in, comes out 100 pounds Coating used 75% VOC 75 pounds VOC emitted Used for solvent based processes Painting, printing, clean-up activities Calculation of fugitive emissions separately is not necessary.

43 Emission Factors An average emission rate based on specific industry data Weight of air contaminant/volume or weight of activity Ex. NOx emission factor from gas fired boiler 100lbs/10 6 scf of natural gas or 100 pounds of NOx emitted per million standard feet of burned.

44 Emission Factors Specific and Appropriate to process Watch your units Watch grading Don t be afraid to Google check your factor Does it make sense?

45 Emission Factors - Where to find them AP-42 (epa.gov, search AP-42) Chief (epa.gov, search Chief)

46 Document your calculation method Calculation Method Permit condition Emission Factor Mass balance equation Mass balance equation Limitation in Rule Emission factor Limitation in Rule Limitation in Rule Emission factor Emission factor Emission factor

47 Chart Complete! Emission Source Description Permit Status Legally Enforceable Limitation Calculation Method COATING BOOTHS spray booths Permitted: PTI # Grandfathered: / / Exempt: R Permit limit = 5.6 tons VOC/yr - Permit requires fabric filter Permit condition OVEN 2,500,000 Btu/hr natural gas fired Permitted: PTI # Grandfathered: / / Exempt: R 336. None Emission Factor MAINTENANCE BOOTH Booth used for touchup Permitted: PTI # Grandfathered: / / Exempt: R 336. Permit requires fabric filter Mass balance equation PRINTING Prints information on product Permitted: PTI # Grandfathered: 10/15/1966 Exempt: R 336. None (grandfathered) Mass balance equation 287(C) BOOTH Spray booth used for special projects Permitted: PTI # Grandfathered: / / Exempt: R (c) Rule: R (c) limits coating usage to 200 gal/month Limitation in Rule COLD CLEANERS CLEANUP GRINDER 2 cold cleaners for parts washing Facility-wide cleanup solvents Metal parts grinder connected to baghouse (29,000 cfm) Permitted: PTI # Grandfathered: / / Exempt: R (h) Permitted: PTI # Grandfathered: / / Exempt: R Permitted: PTI # Grandfathered: / / Exempt: R (l)(vi)_ Rule: R Requires that cover be closed and that parts be drained Rule: R limits emission of non-carcinogenic VOCs to 1,000 lbs/month Rule: R ,Table 31J - limits emission of PM to 0.10 lbs per 1000 lbs gas Emission factor Limitation in Rule Limitation in Rule WELDING Shielded metal arc welding Permitted: PTI # Grandfathered: / / Exempt: R (i) None Emission factor BOILER 10 million Btu/hr natural gas fired boiler Permitted: PTI # Grandfathered: / / Exempt: R (b)(i)_ None Emission factor GENERATOR Diesel fired emergency generator Permitted: PTI # Grandfathered: / / Exempt: R (g) None Emission factor

48 PTE for Emission Units Step 6

49 Calculate the PTE for Each Emission Source

50 Things to note. Calculate each pollutant emitted Multiple calculations Keep each pollutant calculation separate Define your assumptions SHOW YOUR WORK!

51 The PTE Equation (maximum hourly emission rate) x (24 hrs/day) x (365 days/yr) Maximum design capacity 24 hours x 365 days, unless otherwise physically restricted Control only considered if in PTI or Rule Material with greatest emissions processes 100% of time Even if you never intend to operate like this.

52 Bottlenecks Physical Limitation Unavoidable Provable * Removing the bottleneck requires an update to the PTE calculation

53 Determining What Pollutants are Emitted Manufacturer specs AP-42 SDS Manufacturers formulation data Any others?

54 Examples Run through various examples from workbook Examples are simple and typical processes

55 Facility PTE Step 7

56 Calculate the PTE for the Facility

57 Tabulate PTE Emission Unit CO (TON/YR) NOx (TON/YR) SOx (TON/YR) PM (TON/YR) VOC (TON/YR) LEAD (TON/YR) Three Coating Booths Two Cold Cleaners One Boiler <0 TOTAL Anything else? We also have one HAP to consider Xylene = 5.6 tons per year.

58 Now What?

59 Major or Minor Source

60 Major Source Requirements Subject to: More regulations More complex More recordkeeping More reporting More oversight

61 Table 3-1 Major Source Thresholds Type of Pollutant Title V Major Source tons/year NESHAP Major Source tons/year PSD Major 1,2 tons/year Particulate Matter (PM) 100/250 Particulate Matter < 10 microns in diameter (PM10) /250 Particulate Matter < 2.5 microns in diameter (PM2.5) /250 Volatile Organic Compounds (VOCs) /250 Carbon Monoxide (CO) /250 Nitrogen Oxides (NOx) /250 Sulfur Dioxide (SO 2 ) / Lead (Pb)* / Hazardous Air Pollutants (HAPs) Any single HAP Any combination of HAPs Greenhouse Gases (GHG) 100,000 on a CO2e basis, and 100 GHGs mass basis *Lead compounds are HAPs 100,000 on a CO2e basis Major Non-attainment 3 tons/year Moderate 100 Serious 70 Marginal 100 Moderate 100 Serious 50 Severe 25 Extreme 10 Moderate 100 Serious 50 Marginal 100 Moderate 100 Serious 50 Severe 25 Extreme 10 Any other regulated air contaminant 100 Page 3-1

62 Once in, always in Actual emissions EVER exceeded major source thresholds, then you are ALWAYS subject.

63 Let s Calculate!! Run through various calculation on their own Based on the ones from the book Need to use a calculator Class participation

64 Exercises

65 That s it for now However There is a potential we may chat again.