Impact of PSD Regulations on Air Permit Applications

摘要

The foregoing simple scrutiny using the GP and the author's ammoniated phosphate air permit application cases shows that the PSD applicability analysis can be accomplished with different objectives in mind that may be guided by corporate goals and philosophy and or immediate project requirements. The demand growth exclusion concept is admittedly predicated upon market conditions showing some demonstrable steady growth and is ideally applicable to the baseline being the ninth and tenth years of the look back period, in other words the most recent 2 years, and the growth projection is substantiated by '.. .the company's greatest projections of business activity...' per §52.21 (b)(41 )(a). In reality, such text book like ideal conditions may not prevail. In the WEPCO case , the baseline agreed upon was for years 1983 and 84 for determinations done in 1988 and 89, citing plant utilization disruption by physical problems as an apparent reason. The coal burned used a forecast and upper maximum forecast that differ in the 1995 through 2009 period from 15 to 30 percent. The WEPCO case also mentioned that calculation of estimated, future and actual emissions based on control technology performance levels were acceptable only if such items were made federally-enforceable; otherwise the calculations would need to be made with existing federally-enforceable limits in SIP, NSPS which would result in greater projected future emissions and would affect PSD findings. In the ammoniated phosphate example in this paper, the greatest production in the ten (10) year look back period is used in the projected actual emissions calculation. The use of control technology performance levels can be a complex task in a plant with a number of individual venturi, packed bed, impact spray and such devices configured in parallel/series serving different processing steps. These plants can have single or multiple stack emissions data that need to be then evaluated accordingly. The use of annual stack test or five (5) year averages of stack test results is likely a good measure of fluctuations of individual pollution control devices in a plant, as is the use of the ten (10) year maximum production for projections when no firm demand growth is available, and, overall, striving for emissions increase close to the PSD SER appears to be a sensible goal. The approach to accomplish a PSD applicability analysis appears to be based on average and maximum values of production and stacks test data. Because PSD rules are tied to the concept of baseline emissions obtained by the two (2) year average within the ten (10) year look back period, it may be worthwhile to extend such analysis to be based on the modeled performance of pollution control equipment and market demand functions. For instance, double absorption sulfuric acid plants can be expected to show a SO_2 control efficiency dependent upon the approximately 18 month turnaround cycle when the catalyst is changed and other necessary repairs done plus some overall plant deterioration function over the period of its planned lifetime. Data, including equations and production stack test data, could be used as inputs to optimization programs such as General Algebraic Modeling System (GAMS) using object function formulations to provide insights relating to corporate goals and project requirements.