Revised FLAG Document

Document, published October 2010:
Federal Land Managers’ Air Quality Related Values Work Group (FLAG)Phase I Report—Revised (2010)

Trinity summary article:
Trinity Consultants - New FLAG Guidance for Class I Area Modeling

Source Classification Codes (SCC) tool

Here's a nice tool for finding SCCs. It's hosted by the North Carolina Dept. of Environmental and Natural Resources and seems to be easier to use than WebFIRE.

PDS Net Emissions Increase

Joe Lierow asserted that, for particular unit for which utilization would increase due to a a physical or operational change at another unit and where the particular unit would not experience a physical or operational change, you calculate the net emissions increase using past actual and future actual emissions (assuming the 2002 NSR Reform rules do not apply).

I first found this from a policy memo referenced in the Advanced NSR Workshop Volume I book [Sept. 2010; pg. 179; Part 305 - NET EMISSIONS INCREASE--40 CFR 52.21(b)(3); Section 5 - Other Calculations (for modification to existing units); Actual to potential (presumptive approach under 1980 rule)]:

Question 3:

Is the approach of comparing new, allowable emissions to old, actual emissions still appropriate for determining PSD applicability?

Response:

Under the PSD regulations, whether a physical change or change in the method of operation at a source will result in a "net emissions increase" requires a comparison of the "actual emissions" of the source before and after the change. For an existing emissions unit at a source, "actual emissions" before the change equal the average rate in tons per year at which the unit actually emitted the pollutant during the 2-year period (or more representative period) which precedes the change [see 40 CFR 52.21(b)(21)(ii)]. Where the change will affect the normal operations of an existing emissions unit (as in the case of a change which could result in increased use of the unit), "actual emissions" after the change must be assumed to be equal to "potential to emit." [emphasis added] The PSD regulations are quite clear regarding such circumstances [40 CFR 52.21(b)(21)(iv)]:

For any emissions unit that has not yet begun normal operations on the particular date, actual emissions shall equal the potential to emit of the unit on that date.

Where "allowable emissions" are the same as or less than the "potential to emit" for an emissions unit, "allowable emissions" may be used to define the "actual emissions" of that unit after the change. Consequently, for determining PSD applicability, the comparison of prior "actual" versus new "potential" emissions (or "allowable" where appropriate) is the correct methodology to use.

The comparison of prior "actual" to future "potential" emissions is made on a unit-by-unit basis for all emissions units at the source that will be affected by the change. It is done for the emissions unit(s) undergoing the physical change or change in the method of operation and also for any other units at which normal operations could be affected by the change at the source. [emphasis added] This, for example, includes a review for possible emissions increases at process-related emissions units due to a physical change which removed a bottleneck at only one of the units.

1998 EPA Memorandum, pg 3 (4.42.pdf)

But then I found further in the book a section specifically on increased utilization [pg. 194; Section 7]. It references a few policy documents that support Joe's contention. Here's one of the quotes from a relevant policy document:

"...emissions increases should be calculated as the worst case increases that could occur at those existing units [presumably this means the units experiencing a utilization increase] if the new or modified units were to operate at their maximum permitted capacity."

Bakken Breakout 2011

Stories about Bakken Field oil production. (Blog title is the link.) Bison ad on page 25.

Recommendations for Modeling PM2.5

NACAA PM2.5 Modeling Methodology Recommendations

ICE Notification Requirements - NESHAP ZZZZ Modifications 10/2010

Here's a quick analysis of notification, reporting,and recordkeeping requirements in the 8/2010 revision to NESHAP Subpart ZZZZ for RICE (FR 51570 ff.). Rebecca passed along an e-mail reminder from WDEQ that some existing engines require initial notifications to the state and EPA by February 16, 2011. The message also noted that the effective date for applicable requirements is October 19, 2013.

63.6645(a)(2) requires notifications for all existing stationary RICE located at an area source of HAP emissions and existing major source RICE less than 500 HP (site rating), but (a)(5) exempts the following:
-- <100 hp
-- emergency RICE,
-- RICE not subject to any numerical emission standards.

According to Table 2d, these are the only area source SI engines that are subject to numerical emission standards (and so would require notifications):
-- non-emergency; non-black start; 4SRB/LB; >500 HP

According to Table 2c, these are the only major source SI engines that are subject to numerical emission standards (and so would require notifications):
-- non-emergency; non-black start; 4SRB/LB or 2SLB or any engine firing landfill or digester gas; >500 HP

Note that required notifications for CI engines should already have been submitted.

Here are some pertinent sections of the rule revision FR notice (with my highlights and notes).


SUMMARY: EPA is promulgating national emission standards for hazardous air pollutants for existing stationary spark ignition reciprocating internal combustion engines that either are located at area sources of hazardous air pollutant emissions or that have a site rating of less than or equal to 500 brake horsepower and are located at major sources of hazardous air pollutant emissions.

DATES: This final rule is effective on October 19, 2010.

F. What are the reporting and recordkeeping requirements?

The following sections describe the reporting and recordkeeping requirements that are required under this final rule.

Owners and operators of existing stationary emergency SI RICE that do not meet the requirements for nonemergency engines (meaning emergency engines?) are required to keep records of their hours of operation. Owners and operators of existing stationary emergency SI RICE must install a non-resettable hour meter on their engines to record the hours of operation of the engine.

Owners and operators of existing stationary SI RICE located at major sources that are subject to work practices and existing stationary SI RICE located at area sources that are subject to management practices are required to keep records that show that the work or management practices that are required are being met. These records must include, at a minimum: Oil and filter change dates and corresponding engine hours of operation (determined using hour meter, fuel consumption data, or other appropriate methods); inspection and replacement dates for spark plugs, hoses, and belts; and records of other emission-related repairs and maintenance performed.

In terms of reporting requirements, owners and operators of existing nonemergency stationary SI RICE greater than or equal to 100 HP and less than or equal to 500 HP located at major sources of HAP and existing nonemergency 4SLB and 4SRB stationary RICE greater than 500 HP located at area sources of HAP that operate more than 24 hours per calendar year must submit the notifications required in Table 8 of 40 CFR part 63, subpart ZZZZ, which lists the NESHAP General Provisions applicable to this rule. (40 CFR part 63, subpart A) These notifications include an initial notification, notification of performance test, and a notification of compliance for each stationary RICE which must comply with the specified emission limitations. Owners and operators of existing stationary nonemergency SI RICE greater than or equal to 100 HP and less than or equal to 500 HP located at major sources of HAP and existing stationary 4SLB and 4SRB nonemergency SI RICE greater than 500 HP located at area sources of HAP that operate more than 24 hours per calendar year must submit semiannual compliance reports.

Must submit all general rqmnts notifications--including initial notification--and semiannual compliance reports:
** SI, 100 ≤ hp ≤ 500, nonemergency, major source
** 4SLB/RB, ≤500 Hp, nonemergency, area source, operates >24 hr/yr

REVISED NOTIFICATION REGULATORY TEXT

63.6590(b)(3)

(3) The following stationary RICE do not have to meet the requirements of this subpart and of subpart A of this part, including initial notification requirements:

(i) Existing spark ignition 2 stroke lean burn (2SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(ii) Existing spark ignition 4 stroke lean burn (4SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(iii) Existing emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(iv) Existing limited use stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(v) Existing stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions that combusts landfill gas or digester gas equivalent to 10 percent or more of the gross heat input on an annual basis;

(vi) Existing residential emergency stationary RICE located at an area source of HAP emissions;

(vii) Existing commercial emergency stationary RICE located at an area source of HAP emissions; or

(viii) Existing institutional emergency stationary RICE located at an area source of HAP emissions.

Oil and Gas Enviornmental Implications -- R8 EPA 2008 Report

EPA's view of air, water, and solid waste impacts from the industry and discussions of federal, state, and regional efforts to reduce impacts. Billed as a working draft.

An Assessment of the Environmental Implications of Oil and Gas Production: A Regional Case Study