Results you can rely on Wisconsin Manufacturers & Commerce: Federal Air Regulations Update Gale F. Hoffnagle, CCM, QEP Air Quality Consulting Practice Leader TRC Companies, Inc. The New NAAQS • EPA has promulgated a plethora of new NAAQS – Ozone (2008) (2013?) 8 Hour Average – PM 2.5 (2006) Reduced 24 Hour Average (2013) Reduced Annual Average – Sulfur Dioxide (2010) 1 Hour Average – Nitrogen Dioxide (2010) 1 Hour Average – Lead (2008) Quarterly Average These combined make existing and new sources subject to tremendous pressure on emissions. 2 Results you can rely on 1
2008 Ozone NAAQS • Current ozone marginal Non-Attainment for Ozone • Kenosha and Sheboygan • Met 1997 NAAQS 3 Results you can rely on Non-attainment Schedule • Final NAAQS ` 2008 • Final Designations 2012 • Attainment SIPs Due 2015 • Attainment Date: 2015 4 Results you can rely on 2
Designations Expected for 2013 Ozone NAAQS 2012 2013 5 Results you can rely on PM 2.5 2006 NAAQS • Non-Attainment for Milwaukee, Racine and Waukesha 6 Results you can rely on 3
PM 2.5 2012 NAAQS • 2010-2012 Design Values 7 Results you can rely on PM 2.5 2012 NAAQS Non-attainment Schedule • Final Rule December 2012 • State NAA Designation Recommendation to EPA December 2013 • Final EPA Designations December 2014 • Attainment Demonstration SIPs Due 2016 • Attainment Date 2020 8 Results you can rely on 4
NO 2 NAAQS • New NAAQS is 188 µg/m3(or 100ppb) but for a 1 hour average. Depending upon the meteorology of the site this results in a 6.6 times lower threshold to meet. It therefore will be substantially harder to meet. • EPA has provided Guidance that you combine the 98% background from monitored data with the 98% modeled result, making compliance much harder. This is equivalent to a 99.995% chance that the observed will be less than the predicted. 9 Results you can rely on NO 2 NAAQS • Focus of NAAQS is people living adjacent to roadways • States are supposed to add monitoring to areas near roadways (Interstate Highways) • Chances of violations near roadways very high • Non-attainment near such monitors could ensnare nearby industrial sources • Monitoring near industrial facilities advisable to establish compliance and, if necessary, actual background concentrations. 10 Results you can rely on 5
NO 2 NAAQS Other Modeling Issues • What is the NO 2 /NOx ratio exiting the stack • Interim Significant Impact Limit (SIL) of 4 ppb (7.53 µg/m3) • No increments, monitoring limits (monitoring may be required), etc. • EPA has changed lowest wind speed allowable in model and doubles the worst case concentrations • EPA changed model to calculate downwash for GEP stacks 11 Results you can rely on NO 2 NAAQS “Guidance” • Guidance: June 28, 2010, June 29, 2010 and March 1, 2011 – Issue of what is Nitrogen Dioxide (NO 2 ) and subject to the NAAQS and what is Nitrous Oxide (NO) and not subject to the NAAQS – Memo describes a three Tier approach Tier 1: Assume it is all NO 2 Tier 2: Assume that NO 2 /NOx ratio is .80 Tier 3: Use 1979 Ozone Limiting Method or PVMRM as detailed screening technique. Calculates that NOx is converted to NO 2 based on the concentration of ozone. Methods already in AERMOD not acceptable. Assume 50% of what exits stack is NO 2 . Tier 3 requires case-by-case determinations (database) 12 Results you can rely on 6
HOURLY NO 2 /NOx Ratio 13 Results you can rely on SO 2 NAAQS • New primary NAAQS of 196 µg/m3 (75 ppb) as a 1 Hour average results in a 7.7 times more restrictive standard. New standard is 99% over three years. • EPA has provided Guidance that you combine the 98% background from monitored data with the 98% modeled result, making compliance much harder. This is equivalent to a 99.995% chance that the observed will be less than the predicted. • Focus of attainment demonstrations to be on modeling, which is a continuation of past policy with enhanced use. 14 Results you can rely on 7
SO 2 NAAQS • DRAFT Guidance issued for comment in July – Methods to model compliance – Methods to measure compliance – Final Guidance not issued – EPA not approving monitoring protocols until guidance final. • Will States do more SO 2 monitoring? • Interim SIL: 3 ppb (7.84 µg/m3) 15 Results you can rely on SO 2 NAAQS Designation Process • Oneida County 16 Results you can rely on 8
Oneida Non-Attainment Sources • Wausau Paper Mills, LLC 3128 TPY • Red Arrow Foods 4.5 TPY • Packaging Corp. of America 4641 TPY • Final NAAQS June 2010 • Final Designations July 2013 • Attainment Demonstration SIPs Due 2015 • Attainment Date 2018 17 Results you can rely on EPA Working Group Results • For NO 2 (no background added ) : – Steel Mill 3.2 times NAAQS – Ethanol Plant 12.9 times NAAQS – Natural Gas Turbine 4 times NAAQS – Coal Power Plant 2.4 times NAAQS – Refinery 1.9 times NAAQS – Fuel Oil Turbine 4.8 times NAAQS – Asphalt Plant 4.7 times NAAQS – Natural gas Compressor 16.7 times NAAQS – Biomass facility, Landfill gas turbine passed 18 Results you can rely on 9
EPA Working Group Results • For SO 2 (no background added): – Ethanol Plant 2.9 times NAAQS – Pulp and Paper 4.7 times NAAQS – Coal Power Plant 4.6 times NAAQS – Fuel Oil Turbine 1.3 times NAAQS – Flare 1.7 times NAAQS – Refinery 1.4 times NAAQS – Asphalt Plant 19.3 times NAAQS – Cement kiln and landfill gas passed! 19 Results you can rely on Usual Practices Increase stacks or plume rise Stratify multiple stacks Include other control regulations that must be met Buy and fence more land Keep impacts below the SIL Evaluate meteorological data representativeness Evaluate ambient data representativeness Propose to use EMVAP (variable emissions) Change building design Urban version of model 20 Results you can rely on 10
Best Practices NAAQS Example of Detailed Monitoring Data Analysis Day Max Daily Count of Rank (yyyymmd 1-hour valid hourly d) Conc values for (ppb) this day 20130322 99.4 24 1 20130211 44.4 21 2 20130202 42.7 23 3 20130316 36.1 24 4 20130223 30.2 23 5 20130117 29.0 24 6 20130208 27.5 23 7 20130213 26.9 23 8 20130212 26.4 23 9 20130119 25.4 24 10 21 Results you can rely on Evaluations for PM 2.5 • Problem is meeting annual average NAAQS • Must know what your PM 2.5 direct emissions are • Must have monitoring data close by to establish background and your contributions to that monitor • Must identify other sources and their impacts • May be required to perform modeling for the chemical formation of particles in the air after emission due to sulfur oxides, nitrogen oxides and possibly organic vapors and ammonia emissions (secondary formation). • Take advantage of the draft guidance to use the 8 th highest value in 5 years when evaluating 24 hour average. 22 Results you can rely on 11
Modeling for PM 2.5 Secondary Formation CASE PM2.5 NOx &SO2 Direct Secondary Emissions Emissions • 1 <10 TPY <40 TPY None None • 2 >10 TPY <40 TPY AERMOD None • 3 >10 TPY >40 TPY AERMOD Chemistry • 4 <10 TPY >40 TPY None Chemistry • Chemistry means either a Qualitative, Hybrid, or full quantitative photochemical grid modeling. 23 Results you can rely on Chemical Modeling for PM 2.5 • Requires application of “academic” atmospheric chemistry grid models (CAMx or CMAQ). Draft Guidance issued March 25, 2013. • New version of CALPUFF with updated chemistry is not approved by EPA. • Modeling is expensive and time consuming especially when dealing with huge data files. 24 Results you can rely on 12
Ozone 25 Results you can rely on PM 2.5 26 Results you can rely on 13
SO 2 27 Results you can rely on The Beat Goes On • EPA proposed but withdrew secondary standards for SOx and NOx to protect against acid rain. Environmentalists suing to reinstate proposal. • EPA proposed and then withdrew secondary standards for visibility in urban areas (reduce PM 2.5 even more), Environmentalists suing to reinstate proposal. • EPA requires SO 2 monitors to report 5 minute average data in anticipation of a 5 minute average NAAQS. • Act says to review and revise as necessary NAAQS every 5 years. Environmentalists sue to ensure that EPA does. 28 Results you can rely on 14
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