Air Quality Pursuant to the Clean Air Act (CAA), EPA established National Ambient Air Quality Standards (NAAQS) to control a limited number of widely occurring Criteria Pollutants, including carbon monoxide (CO), nitrogen dioxide, ozone, PM of a diameter of less than 2.5 micrometers (PM2.5), PM of a diameter of less than 10 micrometers (PM10), and sulfur dioxide.
Primary air quality standards were developed for these pollutants to protect public health—including sensitive populations such as children, elderly, and asthmatics—and secondary standards were developed to protect the nation’s welfare, including protection against decreased visibility and damage to animals, crops, and vegetation.
- EPA has concluded that the current NAAQS protect the public health, including the at-risk populations of older adults, children, and people with asthma, with an adequate margin of safety.
- The airshed that contains the project site in St. Joseph County is in attainment for NAAQS, meaning none of the ambient concentrations of criteria pollutants exceed the air quality standards
To protect air quality, several permitting programs under the CAA regulate point-source air emissions. Under the New Source Review (NSR) permitting program, a major stationary source is one of 28 listed facility types that has the potential to emit 100 tons per year (tpy) or more of a regulated NSR pollutant or is an unlisted facility that has the potential to emit 250 tpy or more of a regulated NSR pollutants. A Prevention of Significant Deterioration (PSD) permit is required for new major sources or a major source making a major modification in areas that are in attainment for all the NAAQS.
- The proposed battery manufacturing facility is not considered a new major stationary source because it is not one of the 28 listed facility types, nor does it have the potential to emit 250 tpy of a regulated NSR pollutant.
- The Spring Hill, TN Ultium facility applied to receive a minor NSR permit to construct the emission sources located at the facility. The Tennessee Department of Environment and Conservation (TEDC) administer this permitting program and issues the permit to construct and operate the facility.
- TEDC issues Ultium a permit to Construct/Modify Air Contaminant Sources.
- Since the potential to emit from the facility exceeds 100 tpy, the facility will be subject to the CAA Title V Operating Permit Program. A Title V Operating Permit will be received after completion of construction
Emissions The magnitude of potential annual reductions in gallons of petroleum would depend on the number of EVs using the manufactured battery cells. At full capacity, the Project would produce enough batteries to supply more than 595,000 vehicles annually, assuming a 125-kilowatt-hour battery pack is used for each vehicle. Therefore, the petroleum displaced (i.e., saved) is calculated to be 246.4 million gallons per year (based on annual mileage of 12,000 miles and current 2021 average fuel economy of 29 miles per gallon for light-duty vehicles)
The annual avoided CO2 is calculated from the Project’s annual fuel consumption savings (246.4 million gallons) multiplied by the U.S. Energy Information Administration’s Fuel Emission factor of 19.54 pounds CO2/gallon for gasoline. Therefore, the use of battery cells produced by the Project and used in EVs would support a reduction of approximately 2,407,328 tons of CO2 per year. In general, the potential benefits associated with reducing CO2 emissions would support a reduction in GHG concentrations and reduce the associated climate change impacts (e.g., increases in atmospheric temperature, changes in precipitation, increases in the frequency and intensity of extreme weather events, rising sea levels).
Noise The Project would generate temporary noise during construction from heavy machinery, such as bulldozers, graders, excavators, dump trucks, and cement trucks, as well as smaller tools, such as jack hammers and nail guns. Noise and sound levels would be typical of new construction activities and be intermittent and temporary.
The industrial process/manufacturing operations at the facility operations would not add to the local ambient noise levels because the manufacturing processes would be conducted within an enclosed building and consistent with the current Industrial-zoned land use. The facility is located adjacent to an existing manufacturing facility, so the vehicular traffic from commuting workers and trucks, both receiving and shipping materials, would not represent a new source of noise in the area.
Source: Department of Energy Environmental Assessment
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