Workshop Q Kentucky: Major Air Permitting, Regulatory & Compliance Developments Tuesday, March 21, 2017 2 p.m. to 3:15 p.m.
Biographical Information Sean Alteri, Director, Kentucky Division for Air Quality 300 Sower Blvd, Frankfort, KY 40601 502.782.6541 Office Sean.Alteri@ky.gov Mr. Alteri is currently serving as the Director of the Division for Air Quality. The Division is comprised of 166 full-time employees divided into 4 technical branches and 20 specialized sections and is responsible for carrying out the Clean Air Act requirements on behalf of the Commonwealth. During his 20-year career with the Division, Mr. Alteri worked as a permit engineering assistant, Regulation Development Supervisor, Technical Services Branch Manager, and the Assistant Director. Currently, Sean is also serving as the President of the Association of Air Pollution Control Agencies (AAPCA) a national, non-partisan, consensus- driven organization focused on improving air quality and is a board member of the Southeastern States Air Resources Managers (SESARM). Mr. Alteri is a graduate of the University of Kentucky College of Engineering (BS Chemical, 1997) and resides on a family farm in Anderson County. Philip A. Imber, Manager Air Section, Environmental Affairs, LG&E and KU 220 W. Main St, Louisville, KY 40202 502-627-4144 Fax: 502-217-2809 philip.imber@lge-ku.com Philip started his career in the chemical process industry with American Synthetic Rubber Company (ASRC), a subsidiary of Michelin North America. Philip spent five years with ASRC in chemical engineering and operations roles. He joined LG&E and KU (LKE) in 2001 as a chemical engineer and was promoted to Manager of Major Capital Projects in 2010. During his first fifteen years at LG&E, Philip developed, permitted, and constructed large capital projects across LKE’s electric generating fleet, including the fleet Flue Gas Desulfurization, Selective Catalytic Reduction, Trimble County Unit 2, the Sulfuric Acid Mist Mitigation, the Cane Run 7 Natural Gas Combined Cycle Unit, and Pulse Jet Fabric Filters. Philip recently managed the construction of the Mill Creek Environmental Air Compliance Project, the largest and most complex air quality control project in the history of the LG&E and Kentucky Utilities. Mill Creek Generation Station's air compliance project was named the 2016 Coal-Fired Project of the Year by Power Engineering and Renewable Energy World magazines. In 2016, Philip transitioned to the Environmental Affairs department at LKE to manage the team responsible for the company’s regulatory compliance and strategy for Air Programs. Philip holds a B.S. in Chemical Engineering from the University of Michigan and a M.S. in Business from Bellarmine University. Carolyn M. Brown, Partner, Dinsmore & Shohl LLP 250 West Main Street, Suite 1400, Lexington, KY 40507 859.425.1092 Office carolyn.brown@dinsmore.com Carolyn Brown is a partner with Dinsmore & Shohl LLP and chairs the firm’s Environmental Practice Group. Her practice focuses on all areas of environmental law and includes counseling on regulatory requirements, permitting and transactional issues as well as environmental litigation. She received her B.S. from the University of Kentucky in 1979 and her J.D. from the University of Kentucky in 1982. She has served on the Kentucky Chamber of Commerce Board of Directors and currently chairs the Chamber’s Energy and Environment Policy Council. She previously chaired the Energy, Environment and Resources Law Section of the Kentucky Bar Association and has served on the Commerce Lexington Public Policy Council. She is a fellow in the American College of Environmental Lawyers and serves on the Executive Committee. Carolyn is resident in the firm’s Lexington office.
Sustainability and Environmental, Health & Safety Symposium Sean Alteri, Director Kentucky Division for Air Quality March 21, 2017 To Protect and Enhance Kentucky’s Environment
Mission To protect human health and the environment by achieving and maintaining acceptable air quality through: • Operation of a comprehensive air monitoring network; • Creating effective partnerships with air pollution sources and the public; • Timely dissemination of accurate and useful information and data; • Judicious use of program resources; and • Maintenance of a reasonable and effective compliance program. 2
Kentucky’s Air Quality 3
Kentucky’s Air Quality DAQ Actual Emissions CY2003‐CY2015 (Criteria Pollutants) 1,000,000 900,000 800,000 Emissions (tons) 700,000 600,000 500,000 400,000 300,000 200,000 100,000 0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year CO NO2 SO2 VOC PT 4
Kentucky Division for Air Quality • Organizational Changes • Significant Air Quality Improvements – SO 2 and NO x • “Good Neighbor” Provision and Interstate Transport Obligations • Permitting and Compliance Update
Organizational changes Kentucky Division for Air Quality 300 Sower Blvd., 2 nd Floor Frankfort, KY 40601 John Gowins Technical Services Branch 502-782-6625 Manager 6
Organizational changes
Organizational changes Name Position Direct Extension Sean Alteri Director 502-782-6541 Melissa Duff Assistant Director 502-782-6597 Jarrod Bell Environmental Consultant 502-782-6552 Rick Shewekah Environmental Consultant 502-782-6768 John Gowins Technical Services Branch Manager 502-782-6625 Roberta Burnes Education/Outreach Coordinator 502-782-6571 Brandii Allen Administrative Assistant 502-782-7230
Air Quality Improvements Are Projected to Continue Sulfur Dioxide 350 1,000,000 900,000 300 800,000 250 700,000 600,000 200 500,000 tons ppb 150 400,000 300,000 100 200,000 50 100,000 0 0 1980 1982 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020 Statewide Average of 99th Percentile 1-Hour Ambient SO2 Concentrations (ppb) Predicted Statewide Average of 99th Percentile 1-Hour Ambient SO2 Concentrations (ppb) Statewide SO2 Emissions based upon Actual SO2 Emission Averages (tons) Predicted Statewide SO2 Emission Averages (tons) 9
Air Quality Improvements in Kentucky 10
KY SO 2 Emissions from EGU’s 2000‐2016 11
KY NO x Emissions from EGUs 2000‐2016 12
Cross-State Air Pollution Rule (CSAPR) • Background • CSAPR History • Transport SIP Obligations • CSAPR Ozone Season Budgets 13
Interstate Air Pollution Transport Interstate air pollution transport , or air transport, refers to emissions from upwind sources that impacts air quality in a given location downwind. The total pollution in any area forms from the combination of local emissions and emissions from upwind. Emissions of sulfur dioxide (SO 2 ) and nitrogen oxides (NO X ) can react in the atmosphere to form fine particle (soot) pollution. Similarly, NO X emissions can react in the atmosphere to create ground-level ozone (smog) pollution. These pollutants can travel great distances affecting air quality and public health regionally. The transport of these pollutants across state borders makes it difficult for downwind states to meet health-based air quality standards for PM 2.5 and ozone . (https://www.epa.gov/airmarkets/interstate-air-pollution-transport) 14
The "Good Neighbor" Provision The Clean Air Act's " good neighbor " provision requires EPA and states to address interstate transport of air pollution that affects downwind states' ability to attain and maintain National Ambient Air Quality Standards (NAAQS). Specifically, Clean Air Act section 110(a)(2)(D)(i)(I) requires each state in its State Implementation Plan (SIP) to prohibit emissions that will significantly contribute to nonattainment of a NAAQS, or interfere with maintenance of a NAAQS, in a downwind state. The Act requires EPA to backstop state actions by promulgating Federal Implementation Plans (FIPs) in the event that a state fails to submit or EPA disapproves good neighbor SIPs. 15
EPA's Actions Under The "Good Neighbor" Provision • NO X Budget Trading Program (2003-2008) • Clean Air Interstate Rule (2009-2014) • Cross-State Air Pollution Rule (2015-present) • Cross-State Air Pollution Rule Update (2017) – Updates the CSAPR ozone season NO X program. 16
Cross State Air Pollution Rule (CSAPR) • Originally designed for the 1997 PM 2.5 and 1997 Ozone NAAQS • Proposed update to address transport for the 2008 Ozone NAAQS • Determine upwind states and their contributions to nonattainment areas or interference with maintenance areas • Only controls emissions from EGUs
Cross-State Air Pollution Rule (CSAPR) January 22, 2015 - EPA memo identifies KY as a significant (>1%) contributor to downwind ozone under the 2008 ozone NAAQS and the need for a “Good Neighbor SIP” SIGNIFICANT SIGNIFICANT CONTRIBUTION CONTRIBUTION NONATTAINMENT MAINTENANCE KY Harford MD Camden NJ Gloucester NJ Richmond NY Philadelphia PA 18
Summary of Memo Information SIGNIFICANT SIGNIFICANT CONTRIBUTION CONTRIBUTION NONATTAINMENT MAINTENANCE KY Harford MD Camden NJ Gloucester NJ Richmond NY Philadelphia PA 19
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