Louisiana application for Approval of Emissions of Air Pollutants from Part 70 Sources Instructions


Existing Prevention of Significant Deterioration (PSD) /Nonattainment New Source Review (NNSR) Limitations



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Existing Prevention of Significant Deterioration (PSD) /Nonattainment New Source Review (NNSR) Limitations

Indicate if the emission source(s) represented in this permit application operates under one or more NSR permits by choosing “yes” or “no.”
If “yes,” complete the table provided; if “no,” enter “N/A” into the table. Group all limitations by permit.
Permit Number – Enter the permit number of each PSD permit issued to the facility. For process unit-specific permits, only those PSD permits issued to the process unit of concern should be noted.
Date Issued - List the date that the permit action was issued. This will be the date that the appropriate official at LDEQ signed the document.
Emission Point ID No. - Enter the Emission Point ID No. for each source as displayed on the EIQ forms submitted with this application.
Pollutant – Enter the pollutant or other criteria affected by the limitation entered in the previous column.
BACT/LAER Limit – Enter each currently applicable limitation imposed by each PSD/NNSR permit. Limitations that have been superseded by subsequent PSD/NNSR permits should not be listed. Group the limitations by permit.
Typically, PSD/NNSR permit limitations are expressed in terms of an operating parameter, such as heat input, power output, or production rate. If such a limit exists, it must be stated in this table. It will be necessary to review all of the text in the permit document to list all applicable limitations.
Averaging Period - Enter the averaging period over which compliance must be determined in order to comply with the BACT/LAER limits listed in the previous column.
Description of Control Technology/Work Practice Standard­ – Enter a brief description of the control technology and/or work practice standard used to comply with the BACT/LAER limit previously stated.


  1. Air Quality Dispersion Modeling

Any facility or process unit seeking a PSD permit with this application must submit recent Air Quality Dispersion Modeling results as required by LAC 33:III with this application. Any application seeking a PSD permit that does not contain the required modeling may not be deemed technically complete. The purpose of Air Quality Dispersion Modeling is to show compliance with the Louisiana Toxic Pollutant Ambient Air Standard and/or National Ambient Air Quality Standard (NAAQS).
Answer the two questions provided. If the answer to both questions is “no,” enter “none” in the table. If the answer to either question is “yes,” then complete the table using the most recent Air Quality Dispersion Modeling data available.
Enter the date that the most recent Air Quality Modeling Results as required by LAC 33:III were submitted. Enter “none” if modeling results for the facility or process unit have never been submitted to the department.
Pollutant – Enter each pollutant for which modeling was performed.
Time Period – Enter the averaging period of the standard for which modeling was performed to demonstrate compliance with the Louisiana Toxic Pollutant Ambient Air Standard or National Ambient Air Quality Standard (NAAQS). Most pollutants have more than one averaging period associated with them. If modeling for more than one averaging period for a pollutant was conducted, enter each averaging period on a separate line.
Calculated Maximum Ground Level Concentration – Enter the maximum ground level concentration, expressed in µg/m3 (micrograms per cubic meter), that was shown in the modeling results.
Louisiana Toxic Pollutant Ambient Air Standard or (National Ambient Air Quality Standard {NAAQS}) – Enter the standard, expressed in µg/m3 (micrograms per cubic meter), against which the concentration entered in the previous column was compared to show compliance. A NAAQS standard should be placed in parentheses. Other standards should not be in parentheses.


  1. General Condition XVII Activities

Enter all activities to be considered as General Condition XVII Activities as appropriate. Expand each table as necessary to accommodate all such activities. If the facility does not have General Condition XVII Activities, check “No”.
Very small emissions to the air resulting from routine operations that are predictable, expected, periodic, and quantifiable; that are submitted by the permitted facility; and that are approved by the Air Permits Division are considered authorized discharges. To be approved as an authorized discharge, these very small releases must:


  1. Generally be less than 5 TPY;

  2. Be less than the minimum emission rate (MER) for each Toxic Air Pollutant (TAP);

  3. Be scheduled daily, weekly, monthly, etc., or

  4. Be necessary prior to plant startup or after shutdown [line or compressor pressuring/depressuring for example].


Work Activity – Enter a descriptive name of the activity to be considered.
Schedule – Enter the frequency at which the activity will take place.
Emission Rates – TPY – Enter the emissions generated by the proposed activity in tons per year (tpy). Include calculations to support the emissions estimates stated. If calculations are not provided, the application will not be considered to be technically complete.


  1. Insignificant Activities

Enter all proposed Insignificant Activities in this table. Expand each table as necessary. If no Insignificant Activities are proposed, check “No”. See LAC 33:III.501.B.5 to determine what types of activities can be considered insignificant. EIQ forms are not required to be submitted for insignificant activities. If they are submitted, please note on the EIQ sheet itself that the source represented on the EIQ sheet is a proposed insignificant activity.
In some cases, the aggregate emissions of all Insignificant Activities of a certain type (i.e., storage tanks) must not exceed five (5) tons per year (tpy). If the applicable Insignificant Activity exemption criterion provides for this restriction, supporting emissions calculations must be submitted for each Insignificant Activity claimed under that exemption provision. Per LAC 33:III.501.B.5 “aggregate emissions shall mean the total emissions from a particular insignificant activity or group of similar insignificant activities (e.g., A.1, A.2, etc.) within a permit per year.”
Though they are not required, LDEQ may request, on a case-by-case basis, that supporting emissions calculations be provided to show the appropriateness of the designation of Insignificant Activity.
In all cases, calculations should be submitted for any activity that is proposed to be declared insignificant per LAC 33:III.501.B.5.D. If an activity is clearly classified by a citation other than LAC 33:III.501.B.5.D, this other citation must be used. An activity will not be granted Insignificant Activity status under LAC 33:III.501.B.5.D if activity is clearly classified by another citation.
It is not necessary to list LAC 33:III.501.B.5 – Table B or Table C activities in an air permit application.
Each time a permit application is submitted this list should show ALL Insignificant Activities, including any that were approved in previous permits or Case-by-case Insignificant Activity notifications.
Emission Point ID No.: - If Insignificant Activities were a permitted source in previous permit for the facility, enter the Emission Point ID No. by which it was formerly known. If the source does not have an Emission Point ID No. associated with it, enter “N/A”.
Description – Enter a descriptive name of the activity to be considered. Also enter sufficient data to determine whether or not this activity can be considered insignificant. Specifically, for engines, list the horsepower or heat input rating and the hours of operation. For tanks, list the volume and the contents of the tank. For boilers, list the heat input rating.
Physical/Operating Data – Enter the pertinent operating parameters that are required to determine whether or not the proposed activity qualifies as an Insignificant Activity. For example, if claiming that a storage tank as insignificant under LAC 33:III.501.B.5.A.3, supply the volume of the tank.
Citation – Enter the specific regulatory citation that provides for the proposed activity to be considered insignificant. All citations will begin with LAC 33:III.501.B.5. For example, a piece of external combustion equipment with a design rate of less than 1 million BTU per hour would require the citation of “LAC 33:III.501.B.5.A.5.”


  1. Regulatory Applicability for Commonly Applicable Requirements

Answer each question by checking either “yes” or “no.” For each “yes” answer, address the applicability for the regulations referenced in the paragraph in which the question appears. Applicability should be addressed in Section 22 of this application.
It is not necessary to state all applicable requirements for 40 CFR 61, Subpart M, or for 40 CFR 82, Subpart F in Section 22 of this application. Simply state whether or not these regulations are applicable. This simplistic approach should not be taken for any other state or federal regulations.


  1. Applicable Regulations, Air Pollution Control Measures, Monitoring, and Recordkeeping

For each table, add additional rows to accommodate all emission points and emission sources.
Table 1 – The purpose of Table 1 is to provide a summary of the applicability or non-applicability of the regulations to each emission point or emission source.

.

Emission Point ID No. – Enter the Emission Point ID No. for each source as displayed on the EIQ forms.


Descriptive Name of the Source – For each Emission Point ID No. enter the Descriptive name of the equipment served by the stack or vent for each source as displayed on the EIQ form for that source.
Where each Emission Point ID No. row in the table intersects with each regulation displayed in the column headings, place a 1, 2, or 3 in the column beneath the heading, or leave the column blank. Use the Key To Matrix guidance found underneath Table 1 as a reference for this task. Alter the regulations referenced in the column headings in order to address all applicable regulations. Add columns as necessary to address all applicable regulations. To accommodate additional Emission Point ID Nos. add additional rows to the table.
For entries that are clearly subject to ANY requirement of a regulation, a “1” should be entered in the column. Even if a piece of equipment or activity is only subject to monitoring, recordkeeping, and/or reporting requirements, a “1” should be entered in the appropriate column.
For entries that are subject to a regulation, but are completely exempted due to a specific exemption statement within the regulation, a “2” should be entered into the column. This means that the source is completely exempt from any provisions of the regulation, including monitoring, recordkeeping, and/or reporting requirements. If a piece of equipment or activity is not completely exempt from a regulation, then “2” is not the appropriate entry.
For entries that are subject to a regulation, but do not have ANY applicable requirements, a “3” should be entered into the column. For example, a new boiler with a heat input capacity of 10 million BTU/hr or less that fires only gaseous fuels is subject to 40 CFR 63, Subpart DDDDD. However, this regulation does not impose ANY requirements on this type of source. When entering such a source in this table, a “3” would be placed under the 40 CFR 63, Subpart DDDDD column.
For entries that are not subject to a specific regulation due to meeting a specific criterion, a “3” should be entered into the column. For example, if a fossil-fuel fired steam generating boiler was constructed or modified prior to August 17, 1971, it is not subject to 40 CFR 60, Subpart D. When entering such a source in this table, a “3” would be placed under the 40 CFR 60, Subpart D column.
Leave the appropriate space blank under a column when the regulation clearly does not apply to the emissions source. For example, LAC 33:III.2103 – Storage of Volatile Organic Compounds would never apply to a steam generating boiler under any circumstances.
Table 2 – The purpose of Table 2 is to show how the regulations apply to each emission point or emission source. If this form is not completed such that it addresses all regulations that apply to each emission point or emission source, as well as the entire facility or process unit to be permitted, the application will not be deemed to be technically complete.
Emission Point ID No. – Enter the Emission Point ID No. for each source as displayed on the EIQ forms.
Applicable Requirement - For each emission point or emission source represented in the application, list applicable state and federal regulations and pollution abatement programs. Clearly identify federal requirements from state requirements for each emission point or emission source.
Compliance Method/Provision - List the proposed air pollutant control measures that will be employed to limit emissions in accordance with the regulations listed in the previous column. For each emission point or emission source, arrange the regulatory requirements for each applicable regulation according to the type of requirement specified by the regulation.
All requirements for each applicable regulation that impose emissions limitations (i.e., lb/MMBTU, percent opacity, parts per million, etc.) should be grouped together under the heading Requirements that limit emissions or operations.”
All requirements for each applicable regulation related to the frequency and/or duration of monitoring activities should be grouped together under the heading “Requirements that specify monitoring.”
All requirements for each applicable regulation that require records to be kept and all regulations that require records to be retained should be grouped under the heading “Requirements that specify records to be kept and requirements that specify record retention time.”
All requirements for each applicable regulation that require reports to be submitted according to a certain timeframe should be grouped together under the heading “Requirements that specify reports to be submitted.”
All requirements for each applicable regulation that require performance testing to be performed should be grouped together under the heading “Requirements that specify performance testing.”
If the regulations allow a number of different compliance methods from which to choose, indicate which compliance method will be used. The difference between Reporting and Notification requirements is that Reporting requirements are required to be satisfied on a periodic basis. Notification requirements are satisfied by a one-time submittal of information. No other submittals will be required to satisfy a Notification requirement. Notification requirements that have been satisfied should be addressed in Section 16 of this application.
Compliance Citation – Enter the specific regulatory citation that allows for the method of compliance stated in the previous column. General citations such as “40 CFR 60 Subpart A” are not acceptable. An example of an acceptable citation is “40 CFR 60.8(a).” If the requirement originates from an enforcement action, settlement agreement, or consent decree listed in Section 14, cite the proper action and the page(s) on which the requirement appears here.
Averaging Period/Frequency – Enter the averaging period over which compliance must be determined or the frequency with which the activity prescribed by the regulation must be performed in order to demonstrate compliance. If the regulation allows the applicant to choose an averaging period or frequency to demonstrate compliance, the choice should be indicated in the column.
State-Only Requirement – If the requirement is a State-Only Requirement, note it in this column. For a condition to be considered State-Only, it must not be required by any federally enforceable regulation. Also, it must not be used to avoid applicability of any federally enforceable regulation. (Any regulation established for this purpose is also considered federally enforceable.) See the Louisiana Guidance for Air Permitting Actions for a more thorough discussion of requirements that can be considered State-Only.
Table 3 – The purpose of Table 3 is to show how a given emission point or emission source is exempt from the regulations or how the regulations do not apply to a given emission point or emission source.
Emission Point ID No. – Enter the Emission Point ID No. for each source as displayed on the EIQ forms.
Requirement – List the requirement for which an exemption or non-applicability is being claimed.
Exempt or Does Not Apply – Enter “Exempt” if the source is exempt from the regulation listed in the previous column or “Does Not Apply” if the regulation listed in the previous column is not applicable to the source. To be exempt from a regulation means that the emission point or emission source would otherwise be subject to the regulation, except for a certain criterion. For example, when determining the applicability of LAC 33:III.2103 to a storage tank, the tank would be exempt if it stored JP-4 fuels in horizontal underground tanks. The same regulation would not apply if the storage tank were less than 250 gallons in volume.
Explanation – Give the reasoning behind the exemption or non-applicability determination.
Citation Providing for Exemption or Non-applicability – Give a specific regulatory citation that provides for the exemption or statement of non-applicability.
Table 4 – The purpose of Table 4 is to show how any emissions from various pieces of equipment are routed to a common point of emission, or which sources are members of an Emissions Cap. This includes both sources that are represented in the permit and sources that are elsewhere not represented in the permit. See the instructions for Section 23 to determine what sources should be otherwise represented as a permitted source.
Emission Point ID No. – Enter the Emission Point ID No. for each source as displayed on the EIQ forms. If the listed source is not represented on an EIQ form included with this application, assign an Emission Point ID No. to this source.
Description - Enter a descriptive name for this source. This name should describe the contents, throughput, fuel(s), etc. of this source, as appropriate.
For example:


  • If the source is a diesel tank with a throughput of 10,000 gallons per year, the entry for this field can be “10,000 gal/yr Diesel Tank.”




  • If the source is a boiler that uses natural gas as a fuel source, the entry for this field can be “Natural gas-fired boiler.”


Construction Date – Enter the date that the equipment described in the previous column was constructed.
Routes to: - Enter the Emission Point ID No. of the emission point to which this source routes its emissions. An EIQ sheet must be submitted for the Emission Point ID No. listed in this column.
Operating Rate/Volume – Enter the operating rate of the source. If the source is a storage tank, enter the volume of the tank.
Applicable Requirement(s)? – Choose “yes” or “no” to indicate whether or not there are any requirements that are applicable to the emissions source noted in this row. If “yes”, address the appropriate regulations in Tables 1 and 2 of this section.



  1. Emissions Inventory Questionnaire (EIQ) Forms

An EIQ form should be completed for each emission point and emission source at the facility or process unit (for process unit specific permits) that does not qualify as a General Condition XVII Activity or an Insignificant Activity. Emissions sources that are routed to a common control device or point source may submit one EIQ sheet for the common emissions point. Equipment that route their emissions to the common emissions point should be included in Table 4 of the application.
The EIQ form exists as a separate Microsoft Excel document contained within the package of electronic files that comprise the Louisiana Application for Approval of Emissions of Air Pollutants from Part 70 Sources. The information from each emission point and emission source should be saved in a separate Excel file and the file name should contain the emission point’s or emission source’s Emission Point ID Number. Fill in each blank as applicable. If fields are left blank when the guidance below indicates that an entry should be made, the application may not be deemed technically complete.
Continuity of successive EIQs

Each time the type or quantity of air pollutants emitted changes due to a change in facility operations, a new EIQ and permit application must be submitted. Over the course of many permit modifications, this may lead to a number of EIQ sheets being submitted for the same emission point or emission source. It is important that each new EIQ flows logically from any previously submitted EIQ and that together all of the EIQs that are submitted for any emission point or emission source describe adequately the progressive changes to the emission point or emission source (either actual or planned). The most recently received EIQ form for a given emission point or emission source will be considered to be the current EIQ. It will completely supersede any previously submitted EIQ for the purposes of stating current operational parameters and emissions data.


Successive EIQs should use consistent terminology and employ a numbering system for emission points or emission sources (Emission Point ID No.) that maintains continuity. Changes and new information should be clearly noted. See the line-by-line guidance for the EIQ form for more details.
Emissions CAPs

For a group of emissions sources subject to an emissions cap, one “CAP EIQ” should be submitted for sources subject to the cap. This “CAP EIQ” must show the Average lb/hr and Tons per year emissions for all sources encompassed by the emissions cap. In general, an individual EIQ should also be submitted for each point source included in the CAP. The EIQ for each point source included in the CAP should show the Maximum lb/hr for each pollutant that will be attributed to the source, but should show no other emissions.



Acceptable answers

If any fields in the EIQ form are not applicable (such as Shell Height for a steam generating boiler), indicate "none" or "not applicable" (N/A). Terms such as "not significant," "nil," "trace," etc. are not appropriate for any field. The use of absolute zero or 100% control efficiency is not appropriate. The names of certain pollutants have been pre-entered into the form.


Please attach additional sheets if more space is needed.
Significant Figures
In selecting the number of digits and decimal places in a lb/hr or TPY emission rate calculation, it is necessary that (1) there is sufficient detail to determine if an applicable requirement applies and (2) there is an adequate and meaningful reference to assist in demonstrating compliance after permit issuance. It is also appropriate that an emission rate adhere to the concept of significant figures.
It is not necessary to list or speciate a pollutant as being emitted by a given source if the pollutant is emitted in a quantity less than 0.0005 tons per year (TPY). The only exceptions to this rule are chlorinated dibenzofurans and chlorinated dibenzo-p-dioxins, each of which has a Minimum Emission Rate (MER) of 0.0001 lbs/year.
Non-TAPs. Non-TAPs (e.g., criteria pollutants such as NOx), have applicable requirements for sources or facilities on the order of tens of tons per year or more. For these pollutants, no useable information is provided with numerous decimal places. In general, and despite the discussion above, list annual (i.e., TPY) emissions to 2 decimal places. If the emission rate does not round to 0.01 TPY, list emissions as < 0.01 TPY. Also list hourly (i.e., average lb/hr and maximum lb/hr) emissions to 2 decimal places unless the emission rate does not round to 0.01 lb/hr. If the hourly emissions rate rounds to 0.001, 0.002, 0.003, 0.004, or 0.005, list emissions as such. If the hourly emissions rate does not round to 0.001, list emissions as < 0.001.
Examples include:
lb/hr or TPY rates greater than one


    • 25.444 would be reported as 25.44

    • 25.445 would be reported as 25.45


lb/hr rates less than one


    • 0.25 would be reported as 0.25

    • 0.244 would be reported as 0.24

    • 0.058 would be reported as 0.06

    • 0.005 would be reported as 0.01

    • 0.0045 would be reported as 0.005

    • rates less than 0.001 lb/hr would be reported as < 0.001


TPY rates less than one


    • 0.115 would be reported as 0.12

    • 0.114 would be reported as 0.11

    • 0.005 would be reported as 0.01

    • rates less than 0.005 TPY would be reported as < 0.01


Toxic Air Pollutants. The annual emission rate in tons per year (TPY) should generally be listed to two (2) decimal places according to the guidance above, with the following exceptions: 1) Chlorinated dibenzofurans and chlorinated dibenzo-p-dioxins, which have a Minimum Emission Rate (MER) of 0.0001 lbs/year, must be rounded to eight (8) or more decimal places; and 2) all other TAPs that have an MER of 50 lbs/year or less must be rounded to three decimal places.
Examples include:
lb/hr rates for TAPS with an MER greater than 50 lbs/yr
Follow the guidance shown above for Non-TAPs
lb/hr rates less than one for TAPS with an MER less than or equal to 50 lbs/yr

    • 0.0045 would be reported as 0.005

    • 0.0044 would be reported as 0.004

    • rates less than (<) 0.001 lb/hr would be reported as < 0.001


TPY rates for TAPS with an MER greater than 50 lbs/yr
Follow the guidance shown above for Non-TAPs
TPY rates less than one for TAPS with an MER less than or equal to 50 lbs/yr


    • 0.0045 would be reported as 0.005

    • 0.0044 would be reported as 0.004

    • rates less than (<) 0.001 TPY would be reported as < 0.001

Polynuclear Aromatic Hydrocarbons (PAH) are a grouping of pollutants that are classified collectively as a Class II Toxic Air Pollutant (TAP). They are part of a larger set of pollutants known as Polycyclic Organic Matter (POM), which is otherwise not regulated by the Office of Environmental Services, Air Permits Division. When it is impossible to separate PAH from POM in order to report emissions, POM should be reported instead of PAH. POM will then be regulated as a surrogate for PAH.


Facility Emission Rate Totals. In general, when combining individual source emission rates to obtain facility totals, consider the "less than" rates to be the shown digit(s), i.e., < 0.01 would be added as 0.01. However, if all the sources for a particular pollutant are small and include "less than" rates, it may be preferable to sum in a manner reflecting facility specific process knowledge to avoid the incorrect conclusion that there is a quantifiable (and perhaps significant) total emission, when there is not. Finally, in rounding off total emission rates, utilize the same protocols as described above (e.g., 24.51 lb/hr + 0.002 lb/hr = 24.512 lb/hr would be reported as 24.51 lb/hr).


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