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How NAAQS Revisions Can Affect Your Facility

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

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  1. 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

  2. Presentation Outline • Background – • What are NAAQS? • How are they established / revised? • Expected Timeline - More Revisions • How do NAAQS revisions affect me? • General Case Study

  3. 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”

  4. 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:

  5. NAAQS Revisions in Progress • The following are currently proposed or being planned by EPA: • In 3 years from 2008, all NAAQS may be new!

  6. Proposed Ozone NAAQS

  7. 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).

  8. There’s a Map for That…

  9. 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)!

  10. Expedited Timeline * Schedule for Primary Std., possible schedule for Secondary Std.

  11. 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

  12. 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?

  13. 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

  14. Revised NO2 NAAQS

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

  16. 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

  17. 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

  18. Revised SO2 NAAQS

  19. 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

  20. Sources of SO2 Pollution Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/sulfurdioxide/pdfs/SO2proposalbriefing.pdf)

  21. 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

  22. 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

  23. 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…

  24. 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

  25. 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?

  26. Case Study: NO2 and SO2 Impacts

  27. Simple SCREEN Results (1 of 2) • Individual emission unit impacts only • Downwash included for typical building size

  28. 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

  29. Questions?

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