Who is a Major Source?

Transcription

1 Operational Excellence & Sustainability Committee Actual vs. Max Actual vs. Potential Emissions Art of determining whether your chemical processing unit is a major stationary source Columbus, OH June 11, 2015 Michael Zimmer, Principal Consultant Trinity Consultants Greater Cincinnati/Northern Kentucky (859) , ext. 103 mzimmer@trinityconsultants.com Who is a Major Source? Page 1

2 How fast did you drive here? Evan Klein, Road and Track culture/a25775/almost infamous 2015 lamborghini huracan/ How fast did you drive here? D Speed R (mi/hr) SPEED LIMIT 25 Time T (hr) SPEED LIMIT 35 EXIT SPEED LIMIT 65 SPEED LIMIT 35 What is the potential to emit (PTE)? Emission Factor (g/mi) CO Emissions (lbs) lb/yr At 4.5 hr/yr Potential Emissions => 9,250 lb/yr At 8,760 hrs/yr 4.6 tpy At 8,760 hrs/yr Page 2

3 How fast did you drive here? D Speed R (mi/hr) SPEED LIMIT 35 Time T (hr) SPEED LIMIT 40 EXIT SPEED LIMIT 80 SPEED LIMIT 40 What is the potential to emit (PTE)? Emission Factor (g/mi) CO Emissions (lbs) lb/yr At 3.7 hr/yr Potential Emissions => 18,112 lb/yr At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr Evan Klein, Road and Track culture/a25775/almost infamous 2015 lamborghini huracan/ Page 3

4 How fast did you drive here? D Speed R (mi/hr) SPEED LIMIT 180 Time T (hr) SPEED LIMIT 180 EXIT SPEED LIMIT 180 SPEED LIMIT 180 What is the potential to emit (PTE)? Emission Factor (g/mi) CO Emissions (lbs) lb/yr At 1.3 hr/yr Potential Emissions => 208,576 lb/yr At 8,760 hrs/yr tpy At 8,760 hrs/yr General Provisions Definitions Per (A) Potential to emit or potential emissions shall mean the amount of emissions of an air contaminant which would be emitted from a source during a 24-hour calendar day or calendar year basis, whichever is applicable, if that source were operated without the use of air pollution control equipment unless such control equipment is, aside from air pollution control requirements, necessary for the facility to produce its normal product or is integral to the normal operation of the source. Potential emissions shall be based on maximum rated capacity. Page 4

5 Permits to Install Definitions Per (BBBBB) Potential to emit means the maximum capacity of an emissions unit or stationary source to emit an air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the emissions unit or stationary source to emit an air pollutant, which includes any federally regulated air pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source. Title V Permits Definitions Per (CC) Potential to emit means the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable or legally and practicably enforceable by the state. Secondary emissions do not count in determining the potential to emit of a stationary source. Page 5

6 How fast did you drive here? D Speed R (mi/hr) Time T (hr) D Speed R (mi/hr) Time T (hr) D Speed R (mi/hr) Time T (hr) Emission Factor (g/mi) CO Emissions (lbs) What is the potential to emit (PTE)? Emission Factor (g/mi) CO Emissions (lbs) Emission Factor (g/mi) CO Emissions (lbs) lb/yr At 4.5 hr/yr lb/yr At 4.5 hr/yr lb/yr At 4 Potential Emissions => 9,250 lb/yr At Potential 8,760 hrs/yr Emissions => 18,112 lb/yr At Potential 8,760 hrs/yr Emissions => 208,576 lb/yr At tpy At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr tpy At 8 Importance of Source Classification First question in determining applicability to air regulations and/or permitting requirements: What is my source classification? Key concepts to understand to answer: Meaning of term source Distinguish between source classification based on date of construction/modification emissions Page 6

7 Definition of Source in Air Regulations Source generally refers to a group of emission units regulated together as one entity, e.g.: Facility Group of similar processes regulated together Individual emission units Typical criteria considered in defining source: Industry classification Equipment proximity (e.g., contiguous/adjacent) Relationship of owners (e.g., common control) Type or size of process Multiple Uses of Term Source Different criteria for different regulatory programs Need to understand the underlying regulation or permitting program being considered In context of air permitting programs, source typically refers to the facility In context of particular air regulations (e.g., NSPS, NESHAP), source typically refers to specific subset of equipment at a facility Page 7

8 Source Classification with Respect to Construction Date Source classification tiers for facilities, processes, or individual emission units: New Source Existing Source, Not Grandfathered Existing Source, Grandfathered Each regulatory program will have its own criteria for defining these classifications Key date is generally when regulation is proposed Source Classification with Respect to Emissions Three general source classification tiers for facilities as a whole: Major Major Source Threshold Synthetic Minor True Minor Major Source Synthetic Minor Source True Minor Source Each regulatory program can have its own thresholds Potential to Emit compared to thresholds Page 8

9 Potential to Emit Maximum capacity to emit May be limited by: Physical and operational limits Air pollution control equipment Restricted hours of operation Type or amount of material combusted, stored, or processed Limitations must be enforceable Enforceable Limitations - How? Two qualifiers Operating and/or emission limits in an air permit undergoing public notice Appropriate testing, monitoring & recordkeeping to ensure compliance can be demonstrated Page 9

10 How to Calculate PTE 1. Conduct a facility-wide inventory of emission sources 2. Identify any legally enforceable limitations 3. Choose emission calculation methodologies 4. Gather necessary process data 5. Calculate PTE for each emission source 6. Calculate total site-wide PTE for the facility 1. Facility-Wide Source Inventory Consider types of emission units at site: Boilers/Fuel Burning Equipment Flares/Incinerators Spray Booths/Surface Coating Storage Tanks/Bins/Silos Dryers/Kilns General Manufacturing Processes Material Handling Activities (e.g., Conveyors, Piles, etc.) Fugitive Emissions Sources Page 10

11 2. Identify Enforceable Limits Operational limits and all other restrictions on the manner in which a source is run Hours of operation Limits on production rate Limits on types of raw materials/additives Restrictions on fuel type Fuel usage rate Air pollution control efficiency 3. Emission Calculation Methodology Performance test/stack test data Continuous Emissions Monitoring (CEM) data Manufacturer s test data or guarantees Heat and material balance data Published emission factors AP-42/FIRE factors Manufacturer s emission factors Industry or trade association factors Page 11

12 4. Gather Key Process Data Design capacity or ratings MMBtu/hr, horsepower rating, fuel usage rate MSDS or vendor technical specifications Performance test results Capture & control efficiency guarantees Fuel analytical data 5. Calculate PTE for Each Source Any emission reduction from air pollution control device included only if its operation is required by a federally enforceable condition Only account for level of control specified by the condition (even if actual performance may be better) Take physical constraints (e.g., equipment bottlenecks ) into account if unchanging and unavoidable Recalculate PTE if bottleneck is subsequently removed Page 12

13 6. Calculate Site-Wide PTE Sum PTE from all individual sources Include stacks, vents, roadways, cooling towers, emergency generators, etc. Treatment of fugitive emissions varies by permitting program Generally only counted towards PTE if facility belongs to specific industry categories Potential to Emit Example - Steam Boiler (1 of 2) Specifications Equipped to fire fuel oil Maximum design heat input rating of 50 MMBtu/hr Equipped with a caustic scrubber Boiler operating and test data PM from stack testing measured at 0.05 lb/mmbtu Boiler fired 2 million gallons of oil in 2010 Oil heating value is MMBtu/gal Permit conditions Boiler is subject to a PM emission standard of 0.1 lb/mmbtu No other restrictions on operations Page 13

14 Potential to Emit Example - Steam Boiler (2 of 2) Does actual fuel usage (utilization) or true emission factor matter? Does actual uptime operating hours matter? Do you have to consider emissions from other fuels? How do you account for PM control from the scrubber? Potential to Emit Example - Steam Boiler Actual PM emissions for 2010: gal MMBtu 0.05 lb ton 7.4 tpy yr gal MMBtu 2000 lb Potential to Emit for PM: 50 MMBtu hr 0.1lb MMBtu 8760 hr yr ton 2000 lb 21.9 tpy Page 14

15 True Minor Source Source s Potential To Emit is less than the major source threshold, even without any federally enforceable limits on emissions and/or operations Sometimes referred to as a natural minor Synthetic Minor Source Actual emissions are less than major source levels but Potential to Emit is greater than major source levels A synthetic minor source is one that has chosen to reduce its PTE to minor source levels from major source levels by accepting enforceable limits on emissions and/or operations Page 15

16 Major Source Source s PTE exceeds major source thresholds Source can not or chooses not to propose limits on emissions and/or operations to reduce its PTE Example: Title V Program Major Source (40 CFR 70.2) Major Source Criteria: Contiguous/adjacent, common control, same 2- digit SIC code Major Source Thresholds: > 100 tpy for any air pollutant, or > 10 tpy for any single HAP, or > 25 tpy in aggregate Fugitives: Include only for certain source categories Page 16

17 Example: Title V Program Major Source (40 CFR 70.2) Update As of June 23, 2014, ** The U.S. EPA will no longer apply or enforce federal regulatory provisions or provisions of the EPA approved Title V programs that require a stationary source to obtain a Title V permit solely because the source emits or has the PTE GHGs above the major source thresholds (e.g., the regulatory provision relating to GHG under the definition of subject to regulation in 40 CFR 71.2) ** See Example: NESHAP Program Major Source (40 CFR 63.2) Major Source Criteria: Stationary source or group of stationary sources located within a contiguous area and under common control Major Source Thresholds: > 10 tpy for any single HAP, or > 25 tpy for any combination of HAPs Fugitives: Include in calculation Page 17

18 Major Stationary Source Under NSR/PSD Program Stationary sources that have potential to emit (PTE) one or more regulated NSR pollutants exceeding: Threshold Criteria 100 tpy If on List of 28 named source categories Hard coded in Clean Air Act at 42 USC 7479 See (NNN), includes Chemical process plants except for ethanol production facilities that produce ethanol by natural fermentation included in NAICS codes or tpy If NOT on List of 28 Note: If major for one pollutant, then plant is treated as a major source for all pollutants List of 28 (100 tpy Threshold) 1. Coal cleaning plants (with thermal dryers) 15. Coke oven batteries 2. Kraft pulp mills 16. Sulfur recovery plants 3. Portland cement plants 17. Carbon black plants (furnace process) 4. Primary zinc smelters 18. Primary lead smelters 5. Iron and steel mills 19. Fuel conversion plants 6. Primary aluminum ore reduction plants 20. Sintering plants 7. Primary copper smelters 21. Secondary metal production plants 8. Municipal incinerators capable of charging 22. Chemical process plants more than 250 tons of refuse per day 9. Hydrofluoric acid plants 23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels 10. Sulfuric acid plants 24. Taconite ore processing plants 11. Nitric acid plants 25. Glass fiber processing plants 12. Petroleum refineries 26. Charcoal production plants 13. Lime plants 27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input 14. Phosphate rock processing plants 28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input Page 18

19 PSD Applies if New Sources: Plant will be a new major stationary source New Source PTE 100 or 250 tpy (depending on List of 28 status) Existing Minor Sources: Make a modification that in itself is major Project emissions increase for one pollutant 100 or 250 tpy Note that in this case, applicability threshold for other pollutants drops to Significant Emission Rates No netting allowed Existing Major Stationary Sources: Make a modification that exceeds PSD Significant Emission Rates 15 tpy for PM 10, 10 tpy for PM 2.5, 40 tpy for VOC, NO X, or SO 2, 100 tpy for CO, etc. May attempt net-out of PSD review with contemporaneous decreases Regulated NSR Pollutant See (NNNNN) Pollutant covered by NAAQS or precursor PM 10, PM 2.5, SO 2, NO X, CO, Pb, O 3, VOC Pollutant covered by a NSPS H 2 S, TRS, H 2 SO 4, Fluorides, etc. Ozone depleting substances Any pollutant that otherwise is subject to regulation under the Act HAPs are excluded unless regulated as constituent or precursor of above categories Page 19

20 Source Classification Emission Thresholds Reference Table Regulatory Program Pollutant Major Source Threshold (tpy)* Notes Ohio Title V Permitting Program ( ) Regulated air pollutants (except HAPs) Attainment Areas 100 Count fugitive emissions only if one of industry categories listed at (X)(2). Non-Attainment Areas (NAA) 100 As Marginal or Moderate NAAs Ozone (VOC or NO X ) 50 As Serious 10 As Severe Ozone Transport Area 50 Ozone (VOC) CO NAA 50 Serious and which significantly contribute PM 10 NAA 70 Serious Any single HAP 10 Count fugitive HAP emissions regardless of industry category. Combined HAPs 25 Count fugitive HAP emissions regardless of industry category. Ohio NSR Permitting Program ( ) Regulated NSR pollutants Attainment Non-Attainment Attainment For industry categories listed at (NNN)(2) & (4), must also include fugitive emissions in total. The 250-tpy threshold applies to facilities not on the list of designated PSD source categories. New Source Performance Standards (40 CFR 60) NA NSPS applicability is based on the type and size of equipment specifically defined in each NSPS. It is not dependent on source classification. National Emission Standards for Hazardous Air Pollutants (40 CFR 63) Any single HAP Combined HAP Count fugitive HAP emissions regardless of industry category. * Based on potential-to-emit. If there are no federally enforceable conditions in an air permit otherwise constraining operations or emissions, potential emissions are those that would occur at the maximum rate, taking into account the physical design limitations of the equipment only. Page 1 of 1 Copyright All rights reserved. Page 20

21 Case Study Examples Assume Your CMPU is Similar D Speed R (mi/hr) Time T (hr) D Speed R (mi/hr) Time T (hr) D Speed R (mi/hr) Time T (hr) Emission Factor (g/mi) CO Emissions (lbs) What is the potential to emit (PTE)? Emission Factor (g/mi) CO Emissions (lbs) Emission Factor (g/mi) CO Emissions (lbs) lb/yr At 4.5 hr/yr lb/yr At 4.5 hr/yr lb/yr At 4 Potential Emissions => 9,250 lb/yr At Potential 8,760 hrs/yr Emissions => 18,112 lb/yr At Potential 8,760 hrs/yr Emissions => 208,576 lb/yr At tpy At 8,760 hrs/yr 9.1 tpy At 8,760 hrs/yr tpy At 8 Page 21

22 Is your CMPU a Major Stationary Source? Scenarios Annual (tpy) PTE at Speed Limit 4.6 PTE at Max Actuals 9.1 PTE at Max Speed of Car Site on "List of 28" Source Classification Part 1 (1 of 2) Resin Manufacturing Plant with following annual emissions, in tons per year: Actuals PTE PM/PM 10 /PM 2.5 : VOC: Individual HAP: Total HAPs: GHGs (as CO 2 e): 1, ,001 Major Title V source? Major HAP source (with respect to NESHAP)? Page 22

23 Source Classification Part 1 Answer (1 of 2) Facility is not a major source under Title V as PTE of a regulated pollutant is below 100 tpy Facility is a minor source of HAP since PTE of HAPs are less than 10 tpy (single) and 25 tpy (combined) Check on applicability of area source NESHAPs (e.g., SUBPART VVVVVV: Chemical Manufacturing Area Sources) Update Prior to the supreme court ruling, meaning earlier than March 2014, this facility would have been required to submit a Title V permit. Source Classification Part 2 (1 of 2) Resin Manufacturing Plant with following annual emissions, in tons per year: Maximum PTE PM/PM 10 /PM 2.5 : VOC: Individual HAP: Total HAPs: GHGs (as CO 2 e): 10, ,001 Major Title V source? Major HAP source (with respect to NESHAP)? Page 23

24 Source Classification Part 1 Answer (2 of 2) Source classification does not depend on maximum actuals!!!!!! Facility is a major source under Title V as PTE of a regulated pollutant is above 100 tpy. Facility is a major source of HAP since PTE of HAPs are greater than 10 tpy (single) and 25 tpy (combined). As a chemical manufacturing company, various NESHAPs could apply: SUBPART EEEE: Organic Liquids Distribution (Non-Gasoline) SUBPART JJJ: Group IV Polymers and Resins Subpart FFFF: Miscellaneous Organic Chemical Manufacturing (MON) Subpart DDDDD: Industrial, Commercial, and Institutional Boilers and Process Heaters Questions & Discussion Contact Information Mike Zimmer, P.E. Trinity Consultants 1717 Dixie Hwy, Suite 900 Covington, Kentucky (859) , Ext 103 mzimmer@trinityconsultants.com or Trinity Consultants 8425 Pulsar Place, Suite 280 Columbus, OH Phone: Page 24