Flexible Permitting

Workshop
Presented by:
U.S. EPA Region 4
Air Permits Section

FINAL PRESENTATION 1-24-05

PSD Scope
What triggers PSD applicability?
New Major stationary sources
constructed in attainment areas
Major Modifications to existing
major stationary sources in
attainment areas

Attainment areas are those areas

that are meeting the various
NAAQS
SO2, NOX, PM10, CO, Ozone, Lead and
now PM2.5

PSD Scope
What is a major stationary source
under PSD?
One of 28 listed major source categories
with PTE > 100 tons per year (after control)
of any pollutant regulated by the CAA
including fugitive emissions (52.21(b)(1)(i)
(a))
Any stationary source (other than the listed
28) with PTE > 250 tons per year of any
pollutant regulated by the CAA excluding
fugitive emissions (52.21(b)(1)(i)(b))

PSD Scope
What is a major modification?
Any physical change in or change in
the method of operation of a major
stationary source that would result
in a significant net emissions
increase of any pollutant subject to
regulation under the Act (52.21(b)
(2)(i))

PSD Significant Emission Rates

Pollutant

Major Modification
Threshold

Particulate Matter (TSP)

25 tpy

Particulate Matter < 10 microns (PM10)

15 tpy

Sulfur Dioxide (SO2)

40 tpy

Oxides of Nitrogen (NOX)

40 tpy

Volatile Organic Compounds (VOC)

40 tpy

Carbon Monoxide (CO)

100 tpy

Lead (Pb)

0.6 tpy

Fluorides

3 tpy

Sulfuric Acid Mist

7 tpy

Hydrogen Sulfide (H2S)

10 tpy

Total Reduced Sulfur (TRS)

10 tpy

Any increase resulting in a > 1 g/m3 24 hour concentration if the source is

within 10 km of a Class I area

Determining PSD Applicability

Review and define the entire project
(i.e., new/modified equipment and
affected equipment)
What project is being proposed?
What new equipment will be added?
Is the project part of previous changes?
Is the project part of future changes?
Will the operation or emissions from
other facility emissions units be affected
by the change (i.e., de-bottlenecking)?
Will existing equipment be
changed/removed?

Determining PSD Applicability

If the proposed change does not
affect other emissions units or if the
affected emissions units do not emit
regulated PSD pollutants:
The project is limited to the change
only

If the proposed change affects other

emissions units:
The project will include both the
change and the equipment affected by
the change

Determining PSD
Applicability
Evaluate the project-related
emissions
Determine whether the project by itself (i.e.,
emissions from new or modified emissions
unit plus incremental changes in emissions
from affected units) will emit regulated PSD
pollutants
Determine baseline actual emissions
Determine potential emissions increase
following the modification
Determine the project-related emissions
from new, modified and affected emissions
units

Determining PSD Applicability

Evaluate the project emissions to
determine if the project is a major
modification using the actual to
potential test
Actual emissions = average emissions (tpy)
over 2 years preceding the project
o Fugitive emissions must be quantified for 28 listed
source categories

Potential emissions = PTE of the project (tpy)

o Project potential emissions include PTE of
new/modified sources and incremental increases at
affected sources

Potential emissions minus actual emissions =

project emission increase

Determining PSD Applicability

If project emission increases are not
significant, the project does not trigger
PSD
If project emission increases are
significant, evaluate contemporaneous
changes in emissions
Contemporaneous changes are site-wide
increases or decreases in actual emissions
that have occurred at the site in the 5 years
preceding the project

Determine whether the net change in

emissions is significant

PSD Permit Application

Content
Description of proposed project
Summary of applicable
requirements
Emissions inventory
Determination and defense of best
available control technology
(BACT) evaluation
Air quality impact analyses
Other Class II impacts analysis

What is BACT?
Any major stationary source or
major modification subject to PSD
must conduct an analysis to ensure
the application of best available
control technology (BACT)
BACT is defined at 40 CFR 52.21(b)
(12)
BACT is fundamentally an emissions
limitation

BACT Applicability (40 CFR

52.21(j))
(2) A new major stationary source shall
apply BACT for each PSD-regulated
pollutant that it would have the
potential to emit in significant amounts
(3) A major modification shall apply BACT
for each PSD-regulated pollutant for
which it would result in a significant net
emissions increase at the source. This
requirement applies to each proposed
emissions unit at which a net emissions
increase in the pollutant would occur as
a result of a physical change or change
in the method of operation in the unit.

NSR Revision - Background

Why was NSR Revised?
General industry concern over NSR
regarding:
o Complicated applicability determinations
o Extended permit preparation and review
timelines
o Volumes of precedent decisions, policy
memos, and guidance documents
pertaining to NSR

NSR Revision discussions began in

the early 1990s
EPA initially proposed changes in
1996

NSR Revision - Final Rules

Most of the proposed Revisions were
finalized and published in the Federal
Register on December 31, 2002
Effective in delegated States March 3,
2003
SIP approved States have 3 years to
incorporate revisions into SIP rules
(Region 4 States are SIP approved)

The Routine Maintenance, Repair, and

Replacement (RMRR) Rule was
Published in the Federal Register on
October 27, 2003

NSR Revision - Final Rules

How are the NSR Revisions
characterized by EPA?
These changes are intended to
provide greater regulatory certainty,
administrative flexibility, and permit
streamlining, while ensuring the
current level of environmental
protection and benefit derived from
the program and, in certain respects,
resulting in greater environmental
protection.

Final NSR Revisions

Revised Baseline Actual Emission
Calculation Procedure
New Actual-to-Projected-Actual
Applicability Test
Actuals Based Plantwide Applicability
Limits (PALs)
New Clean Unit Designation Vacated
June 2005
Pollution Control Project Exclusion
Vacated June 2005
Routine Maintenance, Repair, and
Replacement (October 27, 2003)-Vacated

Baseline Actual Emissions

Revised Baseline Calculus for
Non-Electric Utility Steam
Generating Units (Non-EUSGUs)
The facility may use the annual
average emissions that occurred
during any consecutive 24-month
period in the past 10 years
Emissions must be adjusted to
reflect current emission
factors/control requirements
Baseline emissions cannot exceed
applicable standards/limits

Baseline Actual Emissions

Revised Baseline Calculus for
Non-Electric Utility Steam
Generating Units (Non-EUSGUs)
Adequate emissions data must be
available
All emissions units are subject to
same 24-month period for a given
pollutant
Different 24-month periods may be
used for different pollutants (Note:
some state rules may require a common
24-month period)

Actual-to-Projected-Actual
Applicability Test
New applicability determination
option for all emissions units
Baseline emissions are compared to
projected actual emissions following
the change
o Facility must project post change actual
annual emissions by source for 5 years (10
years post change if change increases units
PTE or capacity)
o Emissions that the unit could accommodate
pre-change may be excluded (i.e., demand
exclusion)
o Facility must maintain records of actual
annual emissions for 5 or 10 years, and

Plantwide Applicability
Limits
What is a PAL?
An annual, facility-wide, pollutant specific,
emission limitation under which the facility
can make any changes without triggering
NSR for that pollutant

PALs ,as defined in 40 CFR Part 52, are:

Set using actual facility baseline emissions
Pollutant-specific
Issued for a 10-year term
Renewable

Actuals Plantwide
Applicability Limits
Who is eligible for an Actuals Plantwide
Applicability Limit (PAL)?
Existing major stationary sources that meet
certain additional criteria

How does a PAL benefit a major facility?

Modifications under a PAL are not
considered major modifications for the
PAL pollutant
Modifications do not have to be approved
through the major NSR program
Facility changes are not dictated by major
NSR concerns

Actuals PALs
How does a facility obtain a PAL?
Interested facilities must submit a
complete permit application specifically
requesting a PAL or PALs
Minimum application requirements
include:
o Listing of emissions units
o Size of emissions units (small, significant or
major)
o All Federal/State applicable requirements
o Emission limits/work practice requirements
o Baseline actual emissions
o Supporting documentation

Actuals PALs
What type of application is required
for a PAL?
PALs must be established via a
federally enforceable permit
o Minor NSR construction permit
o Major NSR permit (i.e., PSD permit)
o SIP-approved operating permit program

Regulatory authority must provide

opportunity for public participation
o 30-day public notice
o Opportunity for public comment

Actuals PALs
How are PAL levels established?
Establish baseline emissions - select any
consecutive 24-month period within the 10year period preceding the PAL (5-year
period for EUSGUs)
o Only one 24-month period may be used per
pollutant
o Differing baseline periods may be used for
different pollutants

Identify all emissions units that were

included in the baseline period
Identify any emissions units constructed
since the baseline period

Actuals PALs
How are PAL levels established?
(cont.)

For each emissions unit that existed

during the baseline period:
o Calculate the average rate, in tons per
year, at which each of the emissions units
emitted the PAL pollutant

Sum the baseline actual PAL pollutant

emission rates of each emissions unit
at the source
Add an amount equal to the
applicable significant level for the PAL
pollutant

Actuals PALs
How are PAL levels established?
(cont.)

Subtract baseline PAL pollutant

emissions associated with emissions
units that have been permanently shut
down since the baseline period
o Shutdowns of more than 2 years or that
have resulted in the removal of the source
from the States inventory are presumed to
be permanent

Add potential PAL pollutant emissions

from units from which construction
began after the baseline period

Actuals PALs
How are PAL levels established?
(cont.)

Baseline PAL pollutant emissions

cannot exceed emission limits allowed
by your permit or newly applicable
requirements at the time the PAL is set
Adjust baseline PAL pollutants to
reflect applicable requirements since
the baseline period
o RACT, NSPS, BACT, LAER, etc.

Actuals PAL Example

Surface coating facility with 7
emissions units defined as Units A
through G
PAL pollutant is VOC
New State requirement in 1999
affected Unit D
Unit F was permanently shut down
in 2000
Unit G was added in 2004
Unit C allowable VOC is 60 tpy

Actuals PAL Example

Choose representative baseline period
(1997-1998)
Year

Unit A

Unit B

Unit C

Unit D

Unit E

Unit F

Unit G

Total

Baseline

1995

52

10

50

199

19

54

384

---

1996

46

12

52

200

23

51

384

384

1997

42

16

681

205

22

54

399

392

1998

45

15

651

201

23

50

394

397

1999

49

20

60

210

23

30

392

393

2000

55

21

59

210

20

30

395

394

2001

45

16

59

19

22

161

278

2002

44

18

671

18

22

162

162

2003

45

16

651

16

23

160

161

2004

46

17

621

17

20

40

200

180

Emissions in excess of 60 tons are subtracted

from baseline
1

Actuals PAL Example

Correct Unit D for new applicable
requirement (90% VOC control) and reevaluate baseline periods

A
B

Year

Unit A

Unit B

Unit C

Unit D

Unit E

Unit F

Unit G

Total

Baseline

1995

52

10

50

20

19

54

205

---

1996

46

12

52

20

23

51

204

204

1997

42

16

681

21

22

54

215

209

1998

45

15

651

20

23

50

213

214

1999

49

20

60

21

23

30

203

208

2000

55

21

59

21

20

30

206

205

2001

45

16

59

19

22

161

184

2002

44

18

671

18

22

162

162

2003

45

16

651

16

23

160

161

2004

46

17

621

17

20

40

200

180

Emissions in excess of 60 tons are subtracted

from baseline
1

Actuals PAL Example

Calculate PAL level - A

Highest baseline = 214 tpy (1997/1998)

Subtract Unit F baseline emissions (52
tons) = 162 tons
Add PTE of new Unit G (40 tons) = 202 tons
Add major modification threshold (40 tons)
= 242 tons

Evaluate Alternative Baseline Period B

Baseline = 205 tpy (1999/2000)

Subtract Unit F baseline emissions (30
tons) = 175 tons
Add PTE of new Unit G (40 tons) = 215 tons
Add major modification threshold (40 tons)
= 255 tons

Actuals PAL Example

Proposed VOC PAL = 255 tons
Is a 255 tpy PAL viable?
Recent actual emissions are well below
baseline
Abatement equipment was added to Unit
D
Facility plans to switch to powder and/or
waterborne coatings on Units A and C
within 5 years resulting in lower
emissions

A 255 tpy PAL is viable for this facility

PAL Permits
What does a PAL permit look like?
PAL permits must include:
o Identification of PAL pollutant(s) and
limits(s)
o PAL effective and expiration dates
o PAL renewal/transition provisions
o Requirement to include emissions from
start-ups, shutdowns,and malfunctions in
compliance calculations
o Requirement to comply with PAL
expiration requirements

PAL Permits
PAL permits must include
(continued)
o PAL calculation procedures
o Monitoring requirements
o Record retention requirements
o Reporting requirements
o Other necessary requirements

PAL Permits
How long are PALs and PAL
permits good for?
The effective period for a PAL is 10
years

Can PALs be re-opened by the

regulatory authority?
Yes - mandatory reopening of PAL
permits to:
o Correct errors
o Reduce PAL for creditable reductions
o Revise to reflect a PAL increase

PAL Permits
Do PALs/PAL permits expire?
Yes PALs/PAL permits not renewed expire
at the end of their effective period (10
years)

What happens if a PAL is allowed to

expire?
New emission limits are established
o Source proposes distribution of PAL emissions
to each emissions unit that existed under the
PAL
o The reviewing authority decides the ultimate
distribution of PAL emissions to emissions units

PAL Permits
PAL emissions are distributed
to individual emissions units if
the PAL expires
Emissions Unit

PAL Level (tons)

Emissions at PAL
Expiration (tpy)

61.7

24.5

255

70.6

25.0

25.5

47.4

In this example, emissions were apportioned

to individual emissions units at PAL expiration
based on the distribution of emissions during
the baseline period
1

PAL Permits
PAL Expiration Notes
Compliance with new enforceable tpy
limits is based on a 12-month rolling basis
Required monitoring systems may be
similar to those under PALs
Compliance with a site-wide emissions
cap, equivalent to the previous PAL, is
required until a revised permit is issued
Physical changes or changes in the
method of operation are subject to major
NSR if change is a major modification
State or federal requirements (BACT,
LAER, RACT, NSPS, etc.) remain applicable

PAL Permits
Are PALs adjusted when they are
renewed?
Yes PALs are evaluated at renewal using the
same process used to set the original PALs
If the new PAL level is > or = 80% of existing
PAL level, PAL may be reset at original level
The reviewing authority has discretion in
setting a new PAL level to :
o Be more representative of actual emissions
o Be in accordance with local air quality needs
o Accommodate anticipated economic growth
o Represent advances in air pollution control
technology

PAL Permits
PAL renewal adjustment notes:
The new PAL may not exceed the
facility PTE
New PAL cannot exceed original PAL
level unless undergoing PAL
modification (increase) procedure
The PAL must reflect all requirements
that became applicable during PAL
term and that PAL was not adjusted
for

PAL Permits
How can PAL levels be increased?
An application for a PAL increase is required
that:
o Identifies all emissions units contributing to the
increase
o Demonstrates a PAL exceedance after inclusion of
proposed new/modified emissions units and an
assumption of current BACT equivalent controls
on all units

A major NSR permit is required for

emissions units associated with the
increase, regardless of the magnitude of
the emissions increase
o Facility must comply with any resulting
BACT/LAER requirements

PAL Permits
How is a higher PAL level established?
The regulatory authority establishes a
higher PAL level based on:
The sum of the allowable emissions from
new/modified emissions units - PLUS The sum of the baseline actual emissions from
all significant/major emissions units assuming
BACT control - PLUS The sum of baseline actual emissions from small
emissions units

The end result - the magnitude of the

proposed increase is minimized by the
potential PAL decreases by assuming
BACT control on significant and major
emissions units

PAL Permits
What type of monitoring
requirements are specified in PAL
permits?
PAL general monitoring requirements
specify that:
o PAL monitoring systems must be based
on sound science
o Must meet minimum legal requirements
for admissibility in a judicial proceeding
to enforce the PAL permit
o Emissions must be quantifiable on an
ongoing basis

PAL Permits
Acceptable PAL monitoring techniques
include:
Mass Balance Calculations
o For sources using paints, coatings, and solvents

Continuous Emission Monitoring Systems (CEMS)

Continuous Parameter Monitoring Systems
(CPMS)
Predictive Emission Monitoring Systems (PEMS)
Emission Factors
Alternative methods as approved by the
administrator

PAL Permits
Mass Balance Calculations
Requirements include:
o A demonstrated means to validate
pollutant content in material(s)
o Assumption that emissions unit emits all
of a pollutant if the pollutant cannot be
accounted for
o The use of the highest value of a
pollutant where a range of the pollutant
content is published

Mass balance calculations are

acceptable and are widely used for
activities using coatings or solvents

PAL Permits
Continuous Emission Monitoring
Systems (CEMS)
Requirements
o Systems must meet applicable Part
60, Appendix B Performance
Specifications
o Systems must sample, analyze, record
data once every 15 minutes of
operation

PAL Permits
Continuous Parameter Monitoring
Systems (CPMS) and Predictive
Emission Monitoring Systems
(PEMS)
Requirements
o The CPMS/PEMS system must demonstrate
a correlation between monitored
parameters and PAL pollutant emissions
across the range of unit operation
o The CPMS/PEMS system must sample,
analyze, record data once every 15 minutes
of operation

PAL Permits
Emission Factors
Requirements
o If appropriate, factors must be adjusted for
the uncertainty or limitations in the
factors development
o Emissions units must operate within the
range of the factors development
o If technically practicable, the emission
factors for significant units must be revalidated within 6 months of the PAL
permit issuance
Unless reviewing agency determines that testing
is not required

PAL Permits
How is missing monitoring data handled
under a PAL?
Sources must record and report maximum
potential emissions without considering
enforceable limitations or operating
restrictions

What happens when a source operates at

non-correlated operating ranges?
A default value representing the highest
potential emissions must be established and
used, or
The source is deemed in violation when the
unit is operating outside of a correlated
parametric range

PAL Permits
Do emissions monitoring systems under a
PAL ever have to be re-validated?
Yes - data re-validation is required once every
5-years for all methods of monitoring
Re-validation is accomplished by emission
testing or or other scientifically valid means
The PAL applicant may want to consider
including a re-validation protocol with the PAL
application addressing each type of
monitoring and the proposed re-validation
procedures

PAL Permits
How long must PAL related compliance
records be retained?
Records necessary to demonstrate
compliance with the PAL regulations must
be retained for five (5) years from the date
of the record
Other PAL related records must be
retained for the duration of PAL plus 5
years
o PAL application
o PAL revision applications
o Annual Title V certifications

PAL Permits
Received multiple PAL
applications under NSR
Reforms
Paper mill, chemical mfg.,
commercial printer/laminator,
automobile assembly
Others in development
Is it right for your Facility?

PSD-PALs
What are PSD-PALs?
A flexible permitting option that
combines the permitting of a new
major source or a major modification
at an existing facility with an
application for a PAL
The PALs are based on a
combination of baseline emissions
and projected future actual
emissions
PSD-PALs are issued through a SIP
approved NSR permitting program

PSD-PALs
There are currently two PSDPALs in Region 4
Saturn Corporation - Spring Hill,
Tennessee
BMW Greenville, South Carolina

The PSD-PAL discussion is

based predominantly on EPA
Region 4 experience with these
two sources

PSD-PALs
What type of facility is ideal for a PSDPAL permit?
Complex, well-controlled existing or new
facilities with multiple, inter-dependant
processes

o New facilities are excluded from NSR PAL rules

Facilities subject to frequent changes with:

o A high potential to emit for one or more PSD
regulated pollutants
o Well characterized emissions
o Effective monitoring systems

Examples include automobile

manufacturers, chemical
manufacturers, and Kraft pulp mills
These types of facilities are well
represented in Region 4

PSD-PALs
PSD-PAL Level equals:
Baseline emissions from all unaffected emissions
units (including shutdown sources where
applicable)
PLUS
PTE from new or modified emissions units
MINUS
Baseline emissions from sources permanently
shutdown

PSD-PALs
Unit 1

Unit 2

Unit 3

Unit 4

Unit 51

Unit 61

Unit 72

Unit 82

Unit 92

Total

Unaffected

Affected

Affected

Unaffected

Down

Down

New

New

New

Corrected

Year

VOC (tons)

VOC
(tons)

VOC
(tons)

VOC (tons)

VOC
(tons)

VOC
(tons)

VOC
(tons)

VOC
(tons)

VOC
(tons)

VOC3
(tons)

1995

52

50

19

19

54

87

----

----

----

212

1996

46

52

20

23

51

85

----

----

----

205

1997

42

60

21

22

54

82

----

----

----

200

1998

45

58

20

23

50

88

----

----

----

206

1999

49

62

21

23

30

97

----

----

----

199

2000

55

68

21

20

30

90

----

----

----

195

2001

45

59

19

22

89

----

----

----

156

2002

44

67

18

22

88

----

----

----

154

2003

45

65

16

23

90

----

----

----

158

2004

46

62

17

20

92

----

----

----

158

Baseline

52

N/A

N/A

21.5

30

93.5

N/A

N/A

N/A

197

Projected
Actual at BACT

N/A

85

25

N/A

75

50

50

285

Last BACT

1995

1995

2000

1995

N/A

N/A

2005

2005

2005

Unit 5 shut down in late 2000, Unit 6 shut down in late 2004
Units 7, 8, and 9 are new units
3
Total corrected VOC excludes emissions from affected units
1
2

PSD-PALs
Unit

Establish PAL
Contributions
Unaffected source baseline
o 73.5 tons

New/affected sources
o 285 tpy
Shut-down sources in
baseline
o 123.5 tpy

Status

PAL Contribution (tons)

Unaffected

52

Affected

85

Affected

25

Unaffected

21.5

Shutdown

93.5

Shutdown

30

New

75

New

50

New

50
Total

482

PSD-PALs
Compute the PSD-PAL level:
Baseline emissions from unaffected
emissions units
= 73.5 tons
Baseline emissions from shutdown
sources = 123.5 tons
Projected actual emissions from new
and affected sources = 285 tons
Compute PAL
o73.5 tons + 123.5 tons + 285 tons 123.5
tons = 358.5 tons

PAL LEVEL = 358.5 TONS PER

ROLLING 12-MONTH PERIOD

PSD-PALs
Can PSD-PALs be written with
Flexibility provisions?
Yes - PSD-PALs may include flexibility
provisions
Flexibility provisions are those conditions
that reduce the administrative friction costs, time, delay, uncertainty, and risks
experienced by sources and permitting
authorities when implementing a permit or
making certain changes under a permit
Flexibility provisions are in addition to the
inherent PAL benefits

PSD-PALs
What do flexible provisions include?
Pre-approved NSR
o Ability to add new emissions units
o Ability to make physical changes or changes in
the method of operation

Certain requirements may be subsumed

o For example, compliance with PAL levels may
be deemed to also be in compliance with:
Individual BACT emission limits
State SIP emission limits

Flexibility provided in PSD-PAL permits is

largely dependent upon regulatory
authority policy and is generally
negotiated

PSD-PALs
Flexible components must include
safeguards
Examples of safeguards include:
o BACT on all new units > significance level
o Minor source BACT or Best Available
Technology (BAT) on all new units <
significance level
o Streamlined registration and public
notice for all new major units
o Requirement to operate and monitor air
pollution control systems relied on for
BACT
o Requirement to comply with NAAQS and
PSD increments

PSD-PALs
What type of monitoring
procedures are required under a
PSD-PAL?
In general, monitoring procedures
that are equivalent to those required
under an NSR actuals PAL
o Mass Balance Calculations
o Credible Emission Factors
o Continuous Emission Monitors (CEMs)
o Continuous Parameter Monitoring
Systems (CPMS)
o Approved alternative monitoring methods

PSD-PALs
What level of air pollution control
device monitoring is required?
In general, air pollution control device
monitoring and recordkeeping should be
equivalent to CAM requirements
Effective air pollution control device
monitoring could be essential to flexibility
provisions
o Compliance with unit specific BACT requirements
is based on compliance with PAL limits
o BACT compliance is contingent upon proper
operation of air pollution control equipment
o An effective monitoring system is therefore
essential to BACT/PAL compliance

PSD-PALs
Emission calculation procedures
The applicant should develop and propose
emission calculation procedures to convert
monitoring data to a mass emission basis
Calculations should be based on sound
scientific/engineering principles and
should compute emissions (tons) on a
monthly basis
Monthly emissions (tons) are summed with
the preceding 11 months worth of monthly
data to demonstrate PAL compliance on t
rolling 12-month basis
Calculations should be replicable

PSD-PALs
A draft PSD-PAL permit is recommended
as part of a PSD-PAL application
Benefits of a draft permit in the application
o Starting point for negotiating conditions
o Clearly articulates source expectations and
commitments
o Compresses regulatory agency review time

Draft permit components include:

o PAL conditions
o Monitoring requirements
o Recordkeeping requirements
o Calculations
o Flexibility provisions

Case Study A Saturn PSD/PAL

Overview of the PSD/PAL Permit for the
Saturn Spring Hill, Tennessee Facility
The Saturn facility is comprised of three
business units:
o Body Systems - body panels, body fabrication
and paint shop
o Vehicle Systems - vehicle interior systems and
final vehicle assembly
o Powertrain - machining, engine assembly, and
final dress

Production of Saturn vehicles began in

July of 1990
The original PSD permit had 54 separate
permitted emissions units and 333
separate permit conditions

Case Study A Saturn PSD/PAL

Planned facility changes for 2001
New vehicle assembly lines
Modified coating lines/conveyor changes
New engine machining/assembly
operations
New AA stamping press
Overall facility production capacity
increase from 360,000 to 595,350
vehicles per year

Case Study A Saturn PSD/PAL

Critical facility air permitting issues:

Initial projects triggered PSD applicability

Facility projects are subject to frequent
scope/schedule changes
NSR Revision status was in a state of flux in
1999

Saturn air permit objectives:

Obtain an innovative permit regardless of

NSR Revision status
Base flexible permit on the PAL concept
Obtain allowable emissions adequate for
595,350 vehicles/yr or more
Accommodate scope/schedule changes
without triggering the need for a new permit
Simplify compliance demonstration

Case Study A Saturn PSD/PAL

Final air permitting concept:
Innovative permit obtained through
traditional PSD permitting process
PSD permit with BACT levels combined
to establish multi-pollutant PALs
Streamlined monitoring and
compliance determination
Expedited treatment of additional new
units
Authorized changes to existing units
provided PALs are not exceeded

Case Study A Saturn

PSD/PAL
PSD-PAL permit application
Common PSD Components (BACT, modeling,
etc.)
Innovative Components
o Proposed PALs based on a combination of baseline
and potential emissions for criteria pollutants
o Single emissions unit for all combustion related
emissions
o Documentation of BACT equivalent technology for
unaffected emissions units (e.g., clean units)
o Sample draft permit language incorporating
proposed PALs and other innovative provisions

Submitted application to TDEC in October 1999

Received final PSD/PAL permit in June 2000

Case Study A Saturn PSD/PAL

Emissions Summary, Tons/yr.

Previous allowable emissions represent conditions from Saturns original

operating/construction permits and subsequent modifications.
b
Baseline actual is the average 1995/1996 annual emission rate
c
Net change represents the difference between baseline emission rates and PAL levels.
The project triggered PSD review for VOC, NOx, and PM10.
d
Saturn utilizes natural gas as the sole fuel on-site. There are no provisions for
alternative or back-up fuels.
a

Case Study A Saturn

PSD/PAL
Permit Innovations

Operational Flexibility
o Pre-approved new major emissions
units
Registration and BACT requirement
Saturn may begin construction when BACT is
approved (i.e., 45 days)

o Pre-approved new minor emissions

units
Registration and mBACT requirement
Saturn may begin construction when mBACT
is approved (i.e., 30 days)

o Changes to existing emissions units do

not require TDEC approval

Case Study A Saturn PSD/PAL

Permit Innovations
Clear monitoring and
recordkeeping requirements
Ability to increase PALs through
the PSD permitting process
Termination provision with
return to traditional permit
Streamlined compliance
requirements

Case Study A Saturn

PSD/PAL
Old PSD Versus New PSD/PAL
Conditions

Case Study A Saturn PSD/PAL

Summary
The PAL permit provides significant
operational flexibility to Saturn within
current regulatory bounds
The permit streamlines compliance
determinations for the facility, TDEC, and
the public
VOC emissions per vehicle produced has
declined since PAL issuance
The PSD/PAL permit has improved the
environmental performance of the facility
The original PAL permit limits and flexibility
are retained in the Title V operating permit

Case Study C Non-attainment

PAL
Overview of a proposed PAL for an
adhesive coating facility in Pennsylvania
The facility includes boilers, reactor vessels,
mixing and formulation, multiple adhesive
coaters and dryers, and research and
development facilities
Facility emissions include VOC, PM10, HAPs,
and products of combustion (NOx and CO)
The facility is well controlled using a vent
condenser and two existing regenerative
thermal oxidizers to abate VOC and vHAP
emissions

Case Study C Non-attainment

PAL
Critical facility air permitting issues:
NSR Revisions became effective in March
2003 for attainment pollutants
The facility is located in an area classified
as moderately non-attainment for ozone
due to its location in the Northeast Ozone
Transport Region
Permitting timelines and redundant NSR
applicability analyses
Projects in the pipeline that include
expedited installation schedules

Case Study C Non-attainment

PAL
Final air permitting concept:

Acquire a VOC PAL through the

Pennsylvania minor NSR program
Since facility is well controlled, use the 40
ton major NSR modification threshold to
establish a VOC PAL
Ensure expedited state review and approval
of facility modifications by eliminating
required non-attainment NSR applicability
determinations
Allow the facility to decide where and how
VOC emissions are controlled within the
facility in accordance with Pennsylvania
Best Available Technology (BAT)
requirements

Case Study C Non-attainment

PAL
Minor Pennsylvania NSR permit
application
BAT analysis not required since no
emissions units were being modified
Emissions inventory
o Baseline calculation - PA PAL policy requires the
use of the most recent two calendar years to
develop baseline emission rates or an alternative
two year period within the past five year if the
most recent two years is not representative
o PAL calculation - The PAL was established by
adding an amount slightly less than the major
modification threshold (i.e., 39 tons for VOC) to
the baseline minus allowable emission increases
since 1991

Case Study C Non-attainment

PAL
Non-attainment VOC PAL Calculation

Calculation Steps

Emissions
(tpy)

2002 Calendar Year Actual Emissions (from emissions statement)

25.06

2003 Calendar Year Actual Emissions (from emissions statement)

21.91

Two-year average baseline emissions

ADD - Moderate Non-attainment major modification threshold (- 0.5 tons)
SUBTRACT - Allowable increases in VOC since 1991
PROPOSED NON-ATTAINMENT VOC PAL

23.49
39.5
(0.79)
62.6

Case Study C Non-attainment

PAL
Innovative Components
o Proposed site wide VOC PAL set using
baseline VOC emissions plus adjusted
NSR major modification threshold
o The facility is well controlled and the
VOC PAL provides a considerable growth
cushion
o For this facility, the ability to manage
growth internally via a VOC PAL is
sufficiently innovative

Submitted application in October

2004
A proposed draft permit is currently
under review by DEP and the facility