Project Columbus: Permitting EGGER Wood Product’s First US Plant

摘要

EGGER is an Austrian wood products company with manufacturing facilities in eight countries. A Prevention of Significant Deterioration (PSD) permit was issued in November 2018 for EGGER’s first US plant, located near Lexington North Carolina. Since the new facility will incorporate several processes unique to EGGER, the identification of applicable New Source Performance Standards (NSPS) and comparable processes for the Best Available Control Technology (BACT) analysis required research into previous US Environmental Protection Agency (USEPA), North Carolina Division of Air Quality (NCDAQ) and other state applicability determinations to support the selected NSPS and BACT. Correctly identifying the applicable NSPS and comparable processes for the BACT analysis avoided the application of inappropriate emission controls as well as recordkeeping and reporting requirements. This paper discusses the approach that was taken to gain agreement on the determinations from both the USEPA and the NCDAQ. The paper also describes several innovative and evolving methodologies that were used to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) for Nitrogen Dioxide (NO2), ozone (O3) and fine particulate matter (PM2.5) as well as the PSD increments for NO2 and PM2.5. In particular, the EPA’s draft guidance on quantifying the relationships between emissions that are precursors to O3 and secondary PM2.5, including appendices with example Modeled Emission Rates for Precursors (MERPs) values was applied to the assessment of the effect that proposed sulfur dioxide (SO2), oxides of nitrogen (NOX) and volatile organic compounds (VOC) emissions may have on existing O3 and PM2.5 concentrations for comparison with the NAAQS and the PM2.5 PSD increment. In addition to using the MERPs to estimate the contribution that the proposed emissions would have on secondary formation of ozone and PM2.5, they were also used to estimate the expansion in the PM2.5 PSD increment associated with the shutting down of a coal fired power plant in the vicinity of the proposed facility. This approach can be used throughout the US using the applicable MERPs and is especially beneficial for accounting for increment expansion associated with reductions in precursor emissions. Because the use of the information in the MERPs Guidance in a first tier screening approach is new and evolving, early and frequent conversations with the NCDAQ and coordination with the Regional EPA and EPA’s Office of Air Quality Standards and Planning (OAQPS) were essential elements for the timely development and approval of the methodology.