AIR FORCE-SPECIFIC POTENTIAL TO EMIT (PTE) APPROACH

摘要

The EPA defines PTE as the maximum capacity of a stationary source to emit under its physical and operational design. However, this definition does not lend itself to a clear PTE calculation method resulting in the current default interpretation of a continuous capacity rate for the entire year (8,760 hr/yr). To clarify and reduce over estimations of PTE, the Air Force approach expands on the EPA's published guidance for calculating PTE for emergency generators which authorized source owners to make case-by-case historical data-driven PTE estimates. This new approach evaluates Air Force-specific air emission sources for inherent non-equipment limiting factors to ensure, as a minimum, they are included when estimating PTE for major source determinations and establishing permit limits. The inherent non-equipment limiting factors established under this approach are considered by the Air Force as de facto minimum federally enforceable limits for Air Force sources. As such, they are to be considered as the minimum (starting point) federally enforceable limits when establishing new or renewing operating permits and as the minimum default limits when performing a major source determination.