EPA’s Report to the President on New Source Review contains many case studies illustrating the unintended consequences of NSR. Here are just four examples.
- A company in the flexible packaging industry asked its permitting agency to allow it to run a thermal oxidizer only when it runs solvent-based inks and coatings, since the increasingly popular water-based inks and coatings contain materials that can poison the oxidizer’s catalyst. The change would have saved approximately 15,000 cubic feet of natural gas and 650 kWh of electricity each day. However, the company felt EPA would view the request as a change in the plant’s method of operation, triggering NSR, even though actual emissions were expected to be reduced. The project did not go forward.
- A plastics plant wanted to install a heat exchanger that would recover waste heat from one of its natural gas-fired units. As a result, natural gas consumption would have fallen 7.5 percent and emissions of NOX would have fallen by 7.5 percent, SO2 by 5.8 percent, CO by 7.6 percent, particulate matter (PM) by 9 percent, and VOCs by 9.3 percent. However, because the boilers required back-up firing with oil during the winter to ensure operation, the actual-to-future-potential emission test would have caused the project to trigger NSR. To avoid NSR, the company says it is considering burning more fuel oil over the next two years to increase the base level of emissions (actual emissions).
- A pulp and paper mill reported it had planned to install a new overfire air system to allow for more complete combustion of bark fuel, reducing the amount of natural gas required to provide supplemental heat by roughly 200 million cubic feet, for an annual natural gas savings to the company of about $1 million. Annual emissions of NOX, CO, and VOCs would have decreased. However, because the boiler is currently operating below its rated capacity, and the PTE is based on operating at full capacity, the project would have triggered the installation of NSR-required emission controls costing $17 million. The project was dropped.
- A refinery concluded that changes to the Fluid Catalytic Cracking Unit (FCCU) riser design to allow better catalyst-crude mixing would result in more gasoline being produced from the FCCU. While the change would not increase emissions at the FCCU, it would likely increase emissions from the gasoline loading dock and would lower emissions from diesel loading. Analysis has not yet been done to show if the increase would be significant (i.e., > 40 tons/year); however, using the potential-to-emit methodology, the project would trigger the PSD permitting requirement since the facility is under the permit cap limit by more than 40 tons/yr. The project, if completed, would not cause the facility to exceed its state permit facility cap for VOC, NOx, SOx or any other pollutant.
Joseph Bast
Joseph Bast is a Senior Fellow at The Heartland Institute. He cofounded Heartland in 1984, serving as executive director then as president & CEO until January 2018. His research and writing focuses on climate change and energy policy.
