June 4, 2019
Minimizing Project Emission Increases and Taking Advantage of NSR Policies
Laura Blohm, Sr. Project Manager, TRICORD Consulting, LLC and Joe Ibanez, TRICORD Consulting, LLC
Often a relatively minor physical modification, such as the addition of new piping, can provide a facility with much needed operational flexibility or improved reliability. However, when including upstream and downstream actual emission increases related to the change, your project may trigger netting and/or federal permitting. This presentation will discuss how to move project increases from the significant column to the insignificant column, thus minimizing project emission increases via accepted calculation methodologies (Projected Future Actual, Incremental Increases, etc.) and other more policy-based methods (Accommodated Emissions and Demand Growth Exclusion). Furthermore, the TCEQ’s and LDEQ’s interpretation of other recent NSR developments such as the EPA’s recent reconsideration of the 2009 Project Aggregation Rule will be discussed in light of minimizing your project emission increases and avoiding major source permitting.