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How NAAQS Revisions Can Affect Your Facility. Michael Ballenger, P.E . and Russell Bailey Central District’s Power Generation Conference July 29, 2010. trinityconsultants.com. Presentation Outline. Background – What are NAAQS? How are they established / revised?.

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How NAAQS Revisions Can Affect Your Facility

Michael Ballenger, P.E.

and Russell Bailey

Central District’s Power Generation Conference

July 29, 2010

trinityconsultants.com


Presentation Outline

  • Background –

    • What are NAAQS?

    • How are they established / revised?

  • Expected Timeline - More Revisions

  • How do NAAQS revisions affect me?

  • General Case Study


Background - NAAQS

  • 6 criteria pollutants used as AQ indicators

  • Maximum ambient concentration levels

    • Adverse effects on human health or public welfare can occur above these levels

    • Florida SIP adopts NAAQS [Rule 62-204.800(1), F.A.C.]

      • More stringent SO2 standards [Rule 62-204.240(1), F.A.C.]

  • Areas where air concentrations exceed NAAQS designated as “nonattainment”


Background – NAAQS Revisions

  • CAA §109(d)(1): EPA must re-evaluate NAAQS on 5-year basis

    • Standards not based on cost!

      • Whitman v. American Trucking

  • * New averaging periods

  • Recent re-evaluations led to the following:


NAAQS Revisions in Progress

  • The following are currently proposed or being planned by EPA:

  • In 3 years from 2008, all NAAQS may be new!


Proposed Ozone NAAQS


Current Proposed Ozone Updates

  • EPA notified D.C. Circuit that they would re-consider 2008 Ozone NAAQS

  • Proposed new standards on Jan. 6, 2010

  • NA Counties 515 to 650 (322 currently)

  • W126 is a “cumulative peak-weighted index” to identify the 3 consecutive months during the ozone season with the highest index value (averaged over 3 years).


There’s a Map for That…


More 3G Coverage…

  • 3rd Generation of the 8-hour Ozone NAAQS to

  • And these maps are just monitors showing NA – do not include Core-Based Statistical Areas (CBSAs)!


Expedited Timeline

* Schedule for Primary Std., possible schedule for Secondary Std.


How Will Ozone Revisions Affect My Facility?

  • 2008 Standard replaced

    • Permitting continues under 0.08 ppm until new designations final

  • Nonattainment designations may be coming even to rural areas

    • Permitting impacts

  • Reductions, new permits

    • Not just new sources and modifications

    • May pull in existing sources


Potential Obligations to Existing Permitted Sources in NA Areas

  • Lower VOC/NOX Title V thresholds

    • Re-evaluate if facility is still minor

  • RACT requirements

    • What units are subject?

    • Permitting requirements

  • Areas of influence

    • Will other counties not included in nonattainment designation be considered area of influence?


Potential Obligations to New or Modified Sources in NA Areas

  • Lower VOC/NOX NSR threshold(s)

    • Small changes may now result in major NSR

  • Fugitive emissions

    • Aggregation for minor changes?

  • Costs

    • Emission reduction credits (ERCs)

    • LAER

    • Alternatives Analysis

    • Compliance issues with other sister sites


Revised NO2 NAAQS


Sources of NOx Pollution

Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/nitrogenoxides/actions.html )


Revisions to NO2 NAAQS

  • Annual Average Standard = 53 ppb (100 µg/m3)

  • Final revisions published in FR on 2/9/2010 (effective 4/12/10)

    • New 1-Hour Standard = 100 ppb hourly expressed as 3-yr average of 98th percentile of annual distribution of max daily1-hour avg

    • No changes to the annual standard or secondary standard (secondary standard currently under review)

  • Changes to NO2 Air Quality Monitoring Network

    • Peak, short-term concentrations primarily near major roadways in urban areas

    • Highest concentrations of NO2 that occur over wider areas

    • Concentrations impacting susceptible and vulnerable groups

  • EPA requiring all NO2 monitors to begin operating no later than January 1, 2013


1-Hour NO2 Standard Implementation

  • April 12, 2010 – Final standard effective

  • January 2011 – States submit designation recommendations to EPA

  • January 2012 – EPA designates most areas “unclassifiable” (because near-road monitors not in place)

  • January 2013 – New near-road monitors in place

  • January 2015 – Next NO2 NAAQS review

  • January 2017/2018 – Non-attainment redesignations

  • January 2022/23 – Attainment date


Revised SO2 NAAQS


Revisions to SO2 NAAQS

  • Final rule published June 2, 2010

    • 1-Hour Standard = 75 ppb on a 3-year average of 99th percentile concentration

  • EffectiveDateAugust23,2010

  • EPA anticipates that new 1-hour standard would prevent concentrations from exceeding current 24-hour standard (140 ppb) and current annual standard (30 ppb) health-based standards

  • New standard to reduce exposure to high, short-term concentrations of SO2 deemed to be greatest health risk in recent health studies

  • EPA revoked both annual and 24-hour current primary SO2 standards and replace with 1-hour standard

  • No change to secondary standard (under separate review)

  • New near source monitoring required by 2013


Sources of SO2 Pollution

Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/sulfurdioxide/pdfs/SO2proposalbriefing.pdf)


Revised SO2 NAAQS Monitoring

  • Current network not primarily configured to monitor high concentration sources

  • EPA proposing two categories of required monitors

    • Monitors required in certain CBSAs based on combination of population and SO2 emissions

    • Additional monitors may be required by the Regional Administrator based on the state’s contribution to national SO2 emissions – specific locations to be determined by states and the Regional Administrator

  • Adjusted network will have a minimum of 163 sites nationwide that are to be operational by 1/1/2013 (from 348 initially proposed)

  • EPA plans to utilize refined modeling results, as part of the attainment designation process


1-Hour SO2 Standard Implementation

  • August 23, 2010 –Final standard effective

  • June 2011 – States submit designation recommendations to EPA

  • June 2012 – Final Area Designations

  • June 2013 – Attainment Demonstration SIPs due

  • August 2017 – Attainment date


Comparing Old v. New (1 of 2)

  • Without considering different forms of the revised standards, comparing the revised standards using SCREEN conversion factors between averaging periods…


Comparing Old v. New (2 of 2)

  • Short-term emission rates > long-term

  • New form of standards

    • Average of 98th / 99th percentile of max daily 1-hr values

  • Different approach to models

    • NO2/NOX ratios and PVMRM

    • New AERMOD or massive post-processing

      • H8H, H4H are close

    • Max monitored value for background

      • Background > standard even in attainment area?

      • E.g., 2007 H1H NO2 in Broward County = 155 ppb


Impacts to My Facility?

  • New PSD Permitting

    • BACT may not be enough (“BACT-Plus”)

    • Ancillary equip. emissions control / taller stack

    • Short-term vs. annual modeled emission rates

    • Startup/shutdown modeled emission rates

  • A nearby facility undergoes PSD Permitting

    • Existing sources included in NAAQS inventory

  • Attainment Demonstrations by DEP

    • SO2 determinations may be based on refined modeling – how will your facility be represented?


Case Study: NO2 and SO2 Impacts


Simple SCREEN Results (1 of 2)

  • Individual emission unit impacts only

  • Downwash included for typical building size


Simple SCREEN Results (2 of 2)

  • Assume cavity on-site, add background

    • Orange County: NO2=0.058 ppm, SO2=0.02 ppm

    • 1-hr NO2 std: 100 ppb; 1-hr SO2 std: 75 ppb


Questions?


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