Variability analyses of input variables to determine Potential-to-Emit (PTE) pollutants for United States Air Force stationary sources (Standardization of air emissions Potential to Emit (PTE) and default capacity rates)

Date
2012
Authors
Castaneda, Francisco, III
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Abstract

Stationary sources are any relatively immobile piece of equipment, building, structure, facility, or installation which emits regulated air pollutants. The Potential-to-Emit (PTE) for a stationary source is the worst-case estimate of air emissions while Likely-to-Emit (LTE) is the credible estimate of air emissions. A source's PTE and LTE are used to determine the applicability of various federal, state and local rules and regulations. The way PTE is calculated can have a direct impact on a regulated entity's compliance obligations, applicable rules, permit application content and type of permit needed. However, there is no consistent method for calculating PTE and LTE that can be applied to all federal and state rules resulting in excessive estimations and therefore unnecessary regulatory requirements.

This research has shown that through the development of standardized methodologies and analyses of historic air emissions inventory data, probable and factual PTE and LTE values can be derived that can potentially reduce unwarranted regulated compliance obligations.

A review and analysis of the United States Air Force's top stationary sources (i.e., emergency generators, boilers, and fire training) was performed to evaluate potential constraints that would directly impact PTE and LTE. Both statistical analysis and investigation of physical and operational design constraint were employed, resulting in clear evidence that the current PTE standard practice of assuming 8,760 hrs/yr operations is excessive and a physical impossibility for all three stationary sources evaluated. Effectively, the identifiable physical and operational design constraints of these sources restrict their actual usage and/or capacity rates by as much as 50%.

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Keywords
Air Emissions, Air Quality, Clean Air Act, NEPA, Potential to Emit, Stationary Source
Citation
Department
Civil and Environmental Engineering