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ENV-06-149 An Insightful NSR Case Study

Luis Comas-Montalvo, Sunoco Environmental Services and Albert Hatto, ERM

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member, Special/Temporary Member - $0.00
Government, NonMember - $25.00

Description:

This case study takes a practical look at a real-world, but typical fluidized catalytic cracking unit (FCCU) expansion project, in which the permitting effort is currently underway. It walks through the Prevention of Significant Deterioration (PSD) and Non-Attainment NSR (NA-NSR) applicability approaches, and highlights the methodologies available with and without NSR Reform to determine if PSD applies to the project. At the heart of the case study is the actual-to-projected-actual applicability test and related netting analysis for a project that only involves existing emission units. Under this test, the permittee compares past actual emissions to future projected actual emissions (after adjusting for demand growth) to determine if PSD applies. In lieu of using the projected actual emissions, the permittee has the discretion to use potential to emit. The case study also looks at the potential benefits and pitfalls of implementing the NSR Reform options vs. using the pre-Reform applicability rules. In addition to the challenges created by NSR Reform, the new 8-hour Ozone standard, and the PM2.5 NAAQS create additional uncertainties. The case study discusses the project team’s struggle to help the state agency understand and implement these standards. Through a real-world case study, this paper and presentation will provide practical knowledge that will be useful to any refinery that is developing an air permitting strategy for virtually any project.

Product Details:

Product ID: ENV-06-149
Publication Year: 2006