ENV-10-69 Implementing the New Source Review ‘Reasonable Possibility’ Requirements at Petroleum Refinery Projects

Description:

Over the last few years, after local regulatory agencies adopted NSR Reform into their State Implementation Plans (SIPs), petroleum refineries have increasingly used the baseline actual to projected actual emissions provisions to calculate the emissions increase from projects. If the calculated emission increase is less than the major NSR SER, but greater than 50% of the SER, then the reasonable possibility rules require tracking of actual emissions after the project is completed. Compliance with the tracking and recordkeeping provisions of post-project actual emissions requires special attention and poses several interpretive issues. Some of these issues include how to treat the following activities in the reasonable possibility calculus: new units associated with a hybrid project involving both new and existing units (which is a common occurrence with refinery projects); non-modified emissions units affected by the project (i.e., emissions from a boiler if the project requires more steam); the “demand growth” exclusion if used to refine the level of projected actual emissions; and when to submit an agency report This paper focuses on these and other related issues that arise when complying with the reasonable possibility provisions of NSR for petroleum refinery projects.