Part III: Examples

Example 1: Project is neither a Major Source nor a Major Modification

A source (XYZ) located in the Chicago ozone nonattainment area is proposing to install an engine testing facility which will be using gasoline as a fuel. XYZ submitted a complete application to the Agency in January, 1996. The source is a major source for VOM and CO. XYZ is also requesting that permit limits allow for their variability in operation (no gasoline usage limit). The following information was collected after review of their application:

Existing Source Status:

PollutantPTE (TPY)
Nox30
CO852
VOM345

Application requests the following permit limits:

PollutantPTE (TPY)
NOx1.2
CO53
VOM23

XYZ has constructed the following emission units during calendar years 1991 to 1996:

Emission UnitPermit NumberDate IssuedPotential VOM Emissions TPY
Electrocoat coating line--------March, 19918
Spray paint system--------Sept, 199424
   Total32

XYZ has also removed two vapor degreasers (both were removed in 1992) which emitted VOM. The following are the actual emissions associated with the degreasers:

Degreaser # 1:

YearActual VOM Emissions (tpy)
199028
199140
 Total68

Average of actual emissions of representative two years 68/2 = 34 tons

Degreaser # 2:

YearActual VOM Emissions (tpy)
198830
198928
19900
19910
19920
 Total58

Average of actual emissions of representative two years 58/2 = 29 tons

Question: Is this project permittable?

Answer: Perform the netting exercise following the Steps below.

Step 1: Determine the emissions increase from the proposed project alone (in this case 23 tpy of VOM).

Step 2: Determine the beginning and ending date of the contemporaneous period as it relates to the proposed project (Refer to Question 5).

For this example we assume the complete application is submitted to the Agency in January, 1996 and the increase will occur in 1996. Accordingly, the contemporaneous period consist of calendar years 1992,1993,1994, 1995 and 1996.

Step 3: Determine emission increases and decreases during the contemporaneous period.

VOM increase is 32 tpy, and VOM decreases from degreaser # 1 and # 2 are 34 tpy and 29 tpy respectively. All the decreases are voluntary reduction from the removal of existing degreasers.

Step 4: Determine which emissions changes are creditable.

VOM increase of 32 tpy is creditable. VOM decrease from both the degreasers are voluntarily reduction. VOM decrease of 34 tpy from degreaser # 1 is creditable, but 29 tpy of VOM decrease from degreaser # 2 is not creditable because decrease from degreaser occurred prior to the contemporaneous period.

Step 5: Determine on a pollutant-by-pollutant basis, the amount of each contemporaneous and creditable emissions increase and decrease.

Contemporaneous creditable VOM increase is 32 tpy without proposed project. Contemporaneous creditable VOM decrease is 34 tpy.

Step 6: Sum all contemporaneous and creditable increase and decreases with the increased from the proposed modification to determine if a significant net emissions increase will occur.

Contemporaneous and creditable VOM increase including the proposed project is 55 (32 + 23) tpy.

Contemporaneous and creditable VOM decrease is 34 tpy.

Net VOM emissions increase is 21 (55-34) tpy. This 21 tpy increase is less than 25 tpy over the last 5 consecutive calendar years. This is not a significant emission increase per Part 203.209 and the project is not a major modification. Therefore, this project is not subject to NSR.

Review of PTE of this project indicates that CO emissions are 852 tpy. This project would be subject to PSD without the presence of federally enforceable permit conditions which will limit PTE for CO to less than 100 tpy (Significant Emissions Increase threshold for PSD).

Demonstration of Netting Exercise - Example 1

Table 1: VOM Emissions Increase
Total combined VOM increases from the plant during contemporaneous period
Emission unitPermit NumberDate IssuedVOM Emissions TPY
Electrocoat coating line--------March, 19918
Spray paint system--------Sept, 199424
   
  Total32
Table 2: VOM Emissions Decrease
Trichloroethylene usage and VOM emissions from contemporaneous shutdown of degreaser # 1 (Permit # ---------)
YearTrichloroethylene Usage (gallon/year)VOM Emissions (ton/year)
1990513028
1991730940
199200
199300
199400

Degreaser # 1 contemporaneous creditable decrease in emissions are 34 tpy ( (28 + 40) / 2).

Table 3: Net VOM Emission Increase Determination

Total VOM emissions increase during the contemporaneous period including this project = (32 + 23) tpy = 55 tpy

Total net VOM increase during contemporaneous period = (55 - 34) tpy = 21 tpy

Note: This table indicates a net increase of VOM emissions of less than 25 tons over 5 consecutive years including VOM from proposed project. This project also does not result in an increase of 25 tons or more of VOM by itself. The VOM emissions decrease is due to voluntary shutdown of degreaser # 1.

Example 2: Project is neither a Major Source nor a Major Modification

A source in the Chicago ozone nonattainment area is proposing a project which will emit 24 tpy of VOM. During last 5 calendar years VOM increase was 20 tons from a different project. VOM decrease during the last 5 calendar years was 40 tons.

Question: Is this project permittable?

Answer: Perform the netting exercise following the Steps below.

Step 1: Determine the emissions increase from the proposed project (in this case 24 tpy).

Step 2: Determine the beginning and ending date of the contemporaneous period as it relates to the proposed project (Refer to Question 5).

For this example we assume the complete application was submitted to the Agency in January, 1996 and increase will occur in 1996. Accordingly, the contemporaneous period is 1992,1993,1994, 1995 and 1996.

Step 3: Determine emissions increases and decreases during the contemporaneous period.

VOM increase is 20 tpy, VOM decrease is 40 tpy. Most of the decrease (36 tpy) is voluntary reduction from the removal of existing process or from the result of installation of control equipment beyond the control requirement RACT regulation. 4 tpy of the VOM decrease is the result of bringing the process into compliance, a RACT requirement which is not a voluntary reduction.

Step 4: Determine which emissions changes are creditable.

VOM increase of 20 tpy is creditable. VOM decrease of 36 tpy is creditable but 4 tpy of VOM decrease is not creditable because 4 tpy reduction is not voluntary reduction. The source reduced those 4 tpy of VOM to bring the source into compliance (i.e., use of 81% control equipment as per 35 IAC 218 Subpart RR or TT, use of lower VOM content coating to comply with 35 IAC 218.204 regulation).

Step 5: Determine on a pollutant-by-pollutant basis, the amount of each contemporaneous and creditable emissions increase and decrease. Contemporaneous creditable VOM increase is 20 tpy without proposed project. Contemporaneous creditable VOM decrease is 36 (40-4) tpy.

Step 6: Sum all contemporaneous and creditable increases and decreases with the increase from the proposed modification to determine if a significant net emissions increase will occur.

Contemporaneous and creditable VOM increase including the proposed project is 44 (20 + 24) tpy.

Contemporaneous and creditable VOM decrease is 36 (40-4) tpy.

Net VOM emissions increase is 8 (44-36) tpy. This 8 tons increase is less than 25 tons over the last 5 consecutive calendar year. This is not a Significant Net Emission increase as per 35 IAC 203.209 and not a major modification. Therefore, this project is not subject to NSR.

Example 3: Proposed Project itself is not a Major Source but constitutes a Major Modification

A source (MNO Company) located in the Chicago ozone nonattainment area, is proposing a project which will emit 24 tpy of VOM. During the last 5 calendar years, there was a VOM increase of 20 tons from a different project. VOM decreases are 22 tons during the last 5 calendar years. The source had a 4 tpy reduction of VOM to bring them into compliance (i.e., use of 81% control equipment as per 35 IAC 218 Subpart RR or TT, use of lower VOM content coating to comply with 35 IAC 218.204).

Question: Is this project permittable?

Answer: Perform the netting exercise following the Steps below.

Step 1: Determine the emissions increase from the proposed project (in this case 24 tpy). Since the project by itself is < 25 ton, project by itself is not a major source and steps 2 - 6 are necessary to determine if significant net emissions increase occurred.

Step 2: Determine the beginning and ending dates of the contemporaneous period as it relates to the proposed project (Refer to Question 5). Accordingly, the contemporaneous period is 1991,1992,1993,1994 and 1995.

For this example we assume the complete application was submitted to the Agency in January, 1995 and increase occurred during 1995.

Step 3: Determine all increases and decreases during the contemporaneous period.

VOM increase is 20 tpy, and VOM decrease is 22 tpy. Most of the decrease (18 tpy) is voluntary reduction from the removal of existing process or from the result of installation of control equipment beyond the control requirement of RACT regulations. 4 tpy of VOM decrease is the result of bringing the process into compliance, which is a RACT requirement not a voluntary reduction.

Step 4: Determine which emissions changes are creditable.

VOM increase of 20 tpy is creditable. VOM decrease of 18 (22-4) tpy is creditable but 4 tpy of VOM decrease is not creditable because 4 tpy reduction is not voluntary reduction. The facility reduced those 4 tpy of VOM to bring the facility into compliance (i.e., use of 81% control equipment as per 35 IAC 218 Subpart RR or TT, use of lower VOM content coating to comply with 35 IAC 218.204).

Step 5: Determine, on a pollutant-by-pollutant basis, the amount of each contemporaneous and creditable emissions increase and decrease.

Contemporaneous creditable VOM increase is 20 tpy without proposed project. Contemporaneous creditable VOM decrease is 18 (22-4) tpy.

Step 6: Sum all contemporaneous and creditable increases and decreases with the increase from the proposed project to determine if a significant net emissions increase will occur.

Contemporaneous and creditable VOM increase including the proposed project is 44 (20 + 24) tpy.

Contemporaneous and creditable VOM decrease is 18 tpy.

Net VOM emissions increase is 26 (44-18) tpy. This 26 tpy increase is greater than 25 tpy over the last 5 consecutive calendar year. This is a Significant Net Emission increase per 35 IAC Part 203.209 and the project is a major modification of a major source. Therefore, this project is subject to NSR.

Here, the proposed project itself is < 25 tpy, and after the netting exercise, net VOM emissions increase is only 1 ton more than the threshold limit of the major modification. Apparently, it seems that source provides offset for 1.5 tpy (i.e., 1.5 * 1.3 = 1.95), the net emission increase will be 24.5 (26-1.5)tpy. So the facility can be in compliance with 35 IAC 203.209. Unfortunately this is wrong, the source must provide the offset for the whole 24 tpy increase from the proposed project. Therefore, they require 24*1.3 = 31.2 tpy of offset to avoid LAER.

The offset has to be for the same pollutant (i.e. VOM) and be from the same source. This is known as an internal offset.

Example 4: Proposed Project itself is a Major Source but not a Major Modification

A source (ABC) located in Chicago ozone nonattainment area is proposing a project (coating line # 3) which will have maximum emissions of 40 tpy of VOM. ABC submitted a complete application to the Agency in January, 1996. During last 5 calendar years the VOM increase was 20 tons from different projects. VOM decreases were 50 tons during the last 5 years. The following information was collected after review of their application:

Applicant requested the following limits:

ProjectPollutantRequested Permitted Emissions (TPY)
Coating line # 3VOM40

ABC has added the following emission units during 1992 to 1996 and emissions are limited in a federally enforceable permit:

Emission sourcePermit NumberDate IssuedVOM Emissions TPY
Coating Mixing Room93------Jan 199315
Mill # 194------Sep 19945
   Total20

ABC has decreased VOM emissions to bring the source into compliance with current RACT regulations. Also, as a corporate policy they reduced VOM emissions beyond compliance voluntarily:

Existing coating line # 1

YearActual VOM Emissions (tpy)
199198
199294
Total 192

The average of representative two years 192/2 = 96 tons. The applicant shows that 4 tpy of VOM decrease was the result of the RACT compliance (to bring the source into compliance with the lb VOM/ gal coating regulation).

Existing coating line # 2

YearActual VOM Emissions (tpy)
19938
199416
Total 24

Average of representative two years 24/2 = 12 tons.

ABC indicated in the application that they will take federally enforceable limits on existing coating lines # 1 and # 2 and requested a limit of 46 tpy for coating line # 1 and 6 tpy for coating line # 2, respectively.

Question: Is this project permittable?

Answer: Perform the netting exercise by following the steps below.

Step 1: Determine the emissions increase from the proposed project (in this case 40 tpy). Since the project by itself is > 25 ton, project is a major modification and steps 2 - 6 are only necessary if they intend to use 1.3:1 offsets to net out of LAER requirements. In this case it is needed, therefore, continue.

Step 2: Determine the beginning and ending date of the contemporaneous period as it relates to the proposed project (Refer to Question 5).

For this example we assume the complete application was submitted to the Agency in January, 1995 and the increase will occurr in 1995. Accordingly, the contemporaneous period is 1991,1992,1993,1994 and 1995.

Step 3: Determine the increases and decreases during the contemporaneous period.

Over the last 5 years VOM increase is 20 tpy, and VOM decrease is 50 tpy. Most of the decrease (46 tpy) is the result of a voluntary reduction from the removal of existing process or from the result of installation of control equipment beyond the control requirement RACT regulation. And 4 tpy of VOM decrease is the result of bringing the certain process in compliance which is a RACT requirement not a voluntary reduction.

Step 4: Determine which emissions changes are creditable.

VOM increase of 20 tpy is creditable. VOM decrease of 46 tons from coating line #1 is creditable but 4 tons of VOM decrease is not creditable because 4 ton reduction is not voluntary reduction. The source reduced those 4 tons of VOM to bring the source into compliance (i.e. use of lower VOM content coating to comply with 35 IAC 218.204).

The VOM decrease of 6 (12 - 6) tpy from coating line # 2 is creditable because it is voluntary reduction.

Step 5: Determine, on a pollutant-by-pollutant basis, the amount of each contemporaneous and creditable emissions increase and decrease.

Contemporaneous creditable VOM increase is 20 tpy without proposed project. Contemporaneous creditable VOM decrease is 46 (50-4) tpy for coating line # 1.

Contemporaneous creditable VOM decrease is 6 (12-6) tpy for coating line # 2.

Step 6: Sum all contemporaneous and creditable emissions increases and decreases with the increased from the proposed modification to determine if a significant net emissions increase will occur.

Contemporaneous and creditable VOM increase including the proposed project is 60 (20 + 40) tpy.

Contemporaneous and creditable VOM decrease is 46 + 6 = 52 tpy.

Net VOM emissions increase is 8 (60-52) tpy. This 8 tpy increase is less than 25 tpy over the last 5 consecutive calendar years. This is not a significant net emission increase per 35 IAC 203.209 and the project is not a major modification. However, since the proposed project itself is > 25 tpy, this project is a major source per 35 IAC 203.206. Therefore, this project is subject to NSR.

Accordingly, the application should include:

  1. Offsets

  2. LAER demonstration (35 IAC 203.301) or Internal Offsets

  3. Certification of Compliance by existing sources (35 IAC 203.305)

  4. Analysis of alternative (35 IAC 203.306)

The source can take internal offset at 1.3 to 1 ratio to avoid LAER. The required offset for this project is 40*1.3 = 52 ton to avoid LAER demonstration.

This source wants to provide internal offset for VOM. For offset, VOM reduction must be actual reduction. If the permitted limit is 99 tpy of VOM and the actual VOM emissions were 96 tpy and their new VOM emission is 46 tpy. Actual reduction of VOM is 50 (96-46) tpy. During the review it was determined that 4 tpy of VOM decrease came from the facility coming into compliance (because of RACT requirement). Therefore, this 4 tpy of reduction was not voluntary and they shall not get credit for this 4 tpy of decrease. The facility will get a credit for 46 (50-4) tpy of VOM.

(Note: If source reduces VOM emissions over the contemporaneous time period, for base line determination, we can consider the average of actual emissions of last two years or average of actual emissions of representative two years. In either situation, source shall submit detailed documentation demonstrating actual reduction).

Demonstration of Netting Exercise - Example 4

Table 1: Coating Line #1

Total combined emissions and VOM usage from coating line # 1 shall not exceed the following limits:

Coating and Cleanup Solvent VOM Usage (Ton/year)VOM Content (Wt%)Coating and Cleanup Solvent VOM Emissions (ton/year)
925046

Table 2 : Coating Line #2

Total combined emissions and VOM usage from coating line # 2 shall not exceed the following limits:

Coating and Cleanup Solvent VOM Usage (Ton/year)VOM Content by Wt%Coating and Cleanup Solvent VOM Emissions (ton/year)
12506

Table 3 : Offset Demonstration (Emissions are in ton/year)

Emission Unit(s)Representative Historic* Actual VOM EmissionsRACT Adjusted EmissionsFuture potential VOM EmissionsCoating Line #1969246Coating Line #212126   


   52

*Based upon actual VOM emissions from the average of calendar year 1994 and 1995.

Potential VOM emissions from coating line # 3 are 40 tons/year.

Internal offset required to avoid LAER Of 1.3 x 40 = 52 ton/year. Therefore, internal offset requirements are satisfied internally.

An Example of Compliance by existing source

CERTIFICATION OF COMPLIANCE

I am the plant manager, responsible for environmental compliance, at the (Company Name) facility located in (City, Illinois). This facility is a major stationary source owned or operated by (Company Name) in the state of Illinois.

I certify that, to the best of my knowledge, this facility is subject to emission limitations and is in compliance, or on a schedule for compliance, with all applicable emission limitations and standards under the Clean Air Act, as amended by the Clean Air Act Amendments of 1990, 42 U.S.C.$$ 7401-7671(q).

_______________________
Signature

_______________________
Printed Name of Signature

_______________________
Title

_______________________
Date

An example of Analysis of Alternatives

Analysis of Alternatives

The decision to locate the coating line # 3 at the QRS company (QRS), Chicago, Illinois facility involved a number of technological, economic, and environmental considerations. After examining each of these considerations, QRS determined that relocating the coating line # 3 to its Chicago facility provided the greatest economic and environmental benefits.

Alternative Sites

QRS had a wide variety of alternative locations for the coating line # 3. As a major corporation, QRS has option to place this plant in different state of U.S. The decision on where to relocate the coating line # 3 was based on several factors, including: the productivity of the local workforce, the access to raw materials, the ability to distribute products, and the technical knowledge available to the plant site. The coating line # 3 was first constructed in Canada. The coating line # 3 was not fully utilized in Canada because of lack of skill in operation, lack of order, and various other problems. Therefore, QRS has decided to remove the coating line # 3 and to construct in Chicago facility.

Following an examination of these factors, QRS concluded that the coating line # 3 should be located in Chicago, Illinois. This decision was based on economic factor and environmental benefits which would occur at Chicago due to the installation of this coating line # 3.

Sizes

One of the primary reasons that QRS decided to install the coating line # 3 at its Chicago facility was the environmental benefits which would be derived from the coating line. Currently, QRS , Chicago operated 2 coating lines. QRS anticipates that the there would be significant production shift from existing coating line # 1 and 2 to proposed coating line # 3. Proposed coating line # 3 emits less VOM in comparison of existing coating line # 1 and 2 on per ton production basis. Also, proposed coating line # 3 is totally enclosed which offers significant environmental benefits for Chicago facility which would not occur if the proposed coating line # 3 were not installed.

The installation of this coating line # 3 is preferable to the maintenance of the status quo at Chicago for several reasons. First, there are no non-solvent based alternatives available for the products to be manufactured on the coating line # 3. Since, non-solvent or low solvent based alternatives are not an option, the partial production shifting from existing coating line # 1 and # 2 to proposed line # 3 is the most economically and environmentally beneficial means for QRS to improve productivity at the plant while reducing volatile organic material (VOM).

The installation of the coating line # 3 in Chicago facility will be environmentally preferable to the continued operation of the plant in its existing structure.

Production Process

As stated above, the coating line # 3 will have total enclosure. All the replaced coating lines are of an older design and have no enclosure. The total enclosure, which is an integral part of the proposed coating line # 3, will significantly reduce the fugitive emissions from the coating line. This is considered state-of the-art for solvent based coating lines.

This coating line # 3 has very high transfer efficiency . QRS is unaware of any production process which will manufacture these products and will generate less VOM than the proposed coating line # 3.

Finally, the installation of the coating line # 3 will also lead to significant emission reductions at the Chicago facility. The reduction in total emissions at the Chicago facility, created through the proposed coating line # 3 project, will generate several tons of Emission Reduction Credits ("E.C."). A portion of these E.C. will be returned to the state of Illinois for air quality improvement, and a portion will be donated to the city of Chicago for the creation of an "Emission Bank" which will be used for urban development. If the proposed coating line # 3 were not installed in Chicago, neither of these environmentally beneficial actions would occur.

In summary, the installation of the proposed coating line # 3 in Chicago will be environmentally preferable to the continued operation of the plant in its existing structure.

Technological Evaluation

Finally, ABC notes that the coating line # 3 will be operated in an environmentally efficient and practical manner. To determine the several pollution control options including the use of solvent less or low solvent coatings and the installation of pollution control equipment.

First, there are no solvent less or low solvent coating available for use on the proposed coating line # 3. QRS products has very wide variation and it is impossible to utilize any of the solvent less or low solvent technologies. QRS is not aware of any new technology which can produce products that meet the required quality and customer requirements. Since the proposed coating line # 3 must utilize solvent base coatings, QRS next examined the pollution control options available. QRS investigated whether it is technically feasible to control emissions from its operations.

QRS has determined that a thermal oxidizer would be the most appropriate control option. Thermal oxidizers are efficient, producing greater than 95% destruction of VOM emissions and are effective on a wide range of VOM emissions.

QRS also examined carbon adsorption system and condenser system. The use of either of these alternatives, however, would have had higher capital and annual operating costs and would be difficult, if not impossible, to recycle since it would be a mixture of the various solvents that are used in the coating line # 3.

In summary, the products that are to be produced on the proposed coating line # 3 require the use of solvent based coatings. Further, QRS has determined that thermal oxidizer is the most environmentally efficient and practical form of pollution control.