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There are a number of ways to evaluate and document excludable emissions from an emissions unit that vary in complexity depending upon the nature of the unit.
Typically for an industrial process, the use of a peak month of production during the 24-month baseline period is selected and the production associated with that month is annualized, (i.e., multiplied by 12) and then adjusted to reflect realistic annual operating rates (i.e., accounting for “normal” maintenance downtime and outages).
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The notice predicted that a post-project emissions increase would occur, but that the increase in emissions was unrelated to the project and should be excluded as the result of increased demand. EPA asserted that the facility was required to obtain a pre-construction permit from MDEQ because the project was a major modification under the Michigan NSR regulations and that the source’s notice to MDEQ was untimely and deficient, stating that the notice included no explanation of why emissions were excluded. EPA’s concern that sources could manage emission to pre-construction projections for five (5) years and then increase emissions thereafter.
The project was completed in June 2010, the units associated with the project restarted shortly thereafter, and the facility initiated post-project recordkeeping in accordance with the Michigan SIP requirements. The utility asserted that the enforcement action was premature because less than one (1) year of actual emissions monitoring for the unit was available and the only way to definitely determine if the project was a major modification was to review at least one (1) year of post-project emissions monitoring. EPA is not categorically prevented from challenging violations of its regulations until long after the modifications are made and the district court’s reading of the regulations is at odds with the CAA. The court stated that the presumption that emissions increases after five (5) years are unrelated to the change could be overcome (e.g., by demonstrating that the pre-construction facility could not handle such an increase) as neither the statute nor the regulation has a time barrier and U. EPA could bring enforcement as long as the increase was traceable to the construction. EPA is entitled to a review of a source’s preconstruction projections to evaluate whether they comply with the rule and indicated that anything beyond a cursory review would be “second guessing”, contradicting the Sixth Circuit’s opinion. EPA and the utility) have been submitting briefs in support of their positions and in response to each other. The outcome of this important appeal could have serious and wide ranging implications for the existing NSR program, major stationary sources evaluating NSR permitting applicability, the U. EPA, and the various state and local regulatory authorities tasked with implementing the NSR program.
The NSR programs were established to ensure that the NAAQS are attained and maintained as major new emissions sources are constructed and as existing emission sources are modified in a manner that increases their emissions as a part of facility expansion projects. Determining whether or not a project at an existing major stationary source will result in a “net significant increase” under the NSR rules at face value does not appear to be a difficult task.
However, it can be a very difficult task to quantify the actual emission increase that will result from the modification being proposed.