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Implementation of the New Source Review NSR Program for PM2.5 An Industry Perspective

Four Questions. What PM2.5 emission rates should be used when permitting a new source or modifying an existing source?What are NSR BACT implications of various PM2.5 methodologies?What are modeling implications of various PM2.5 methodologies?Are there future compliance and enforcement issues asso

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Implementation of the New Source Review NSR Program for PM2.5 An Industry Perspective

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    1. Implementation of the New Source Review (NSR) Program for PM2.5 “An Industry Perspective”

    2. Four Questions What PM2.5 emission rates should be used when permitting a new source or modifying an existing source? What are NSR BACT implications of various PM2.5 methodologies? What are modeling implications of various PM2.5 methodologies? Are there future compliance and enforcement issues associated with the various PM2.5 methodologies in Minnesota?

    3. Question 1 - Preamble Quote “In response to significant comments on the variability of tests methods available for measuring condensable emissions, we have adopted this transition period approach (until 2011) to allow us to assess the capabilities of the test methods and possibly revise them to improve performance.”

    4. #1 - What PM2.5 emission rates should be used when permitting a new source? PM10 as surrogate Engineering estimates AP42 Ch.1 assumes linear relationship of PM2.5 to sulfur Method 202 – condensable particulate test Sulfate and acid gas artifacts, which can overstate PM2.5 EPA ‘Draft’ OTM 27 and 28 EPA and EPRI effort to improve Method 202 interference Questions remain on accuracy at elevated SO2 emission rates?

    6. Question 2 - Preamble Quote “…this final action does not require regulation of SO2 and NOx as precursors of PM2.5 under PSD until the SIP development period ends. However, for delegated PSD states, SO2 and NOx are regulated as precursors from the effective date of this rule.”

    7. #2 - What are NSR BACT implications of various PM2.5 methodologies? BACT analysis based on AP42 and Method 202 emission rates They may overstate emission rates tripping 10 tpy SER and requiring PM2.5 BACT installation. SO2 and NOx BACT requirements are also triggered as precursors, in Minnesota. Future testing with OTM 28, or other more improved condensable particulate methodology, may disprove initial BACT determination. BACT limits cannot be rescinded. Revised BACT analysis may be problematic.

    8. Question 3 - Preamble Quote “….the degree to which these individual precursors contribute to PM2.5 formation in a given location is complex and variable. There are competing chemical reactions taking place in the atmosphere, and meteorological conditions play a significant role in the size and characteristics of particle formation.”

    9. #3 - What are modeling implications of various PM2.5 methodologies? Accuracy of existing emission inventories that may be based on Method 202 and AP42 SIP attainment demonstrations based on existing emission inventories Increment modeling that trips SILs more easily resulting in need for more refined modeling Model accuracy with secondary particulate formation

    10. Question 4 - Preamble Quote “The EPA acknowledges the legitimate concerns raised by commenters concerning potential exposure to retroactive enforcement and has established rules to address this issue. The EPA will not revisit applicability determinations made in good faith prior to the end of the transition period insofar as the quantity of condensable PM emissions are concerned, unless the applicable implementation plan clearly requires consideration of condensable PM.”

    11. MPCA PM2.5 Implementation Plan “The MPCA will continue to include condensable particulate matter, both organic and inorganic, when evaluating PM2.5 and PM10 for PSD applicability and emission limits.”

    12. #4 - Are there future compliance and enforcement issues associated with the various PM2.5 methodologies? Questionable BACT determinations in the ‘interim’ period that are based on AP42 or Method 202 Permit limits based on AP42 or Method 202 values Revising permit limits once updated test method has been approved. Assuming it addresses artifact interference, PM2.5 emissions should logically decline. However, be warned - mixing logic and environmental requirements can be problematic!

    13. John Seitz, 1997 Interim Implementation of New Source Review Requirements for PM2.5 “Of specific concern is the lack of necessary tools to calculate emissions of PM2.5 and related precursors and project ambient air quality impacts so that sources and permitting authorities can adequately meet the NSR requirements for PM2.5. Any comprehensive system for regulating PM2.5 must take into account not only the fine particles emitted directly by stationary sources but also the various precursors, emitted by certain sources, which result in secondarily-formed fine particles through chemical reactions in the atmosphere. Recent studies suggest that secondary particulate matter may account for over half of total ambient PM2.5 nationwide. Emissions factors for the fine particles emitted directly by stationary sources, and for some important precursors (e.g., ammonia), are largely unavailable at the present time.”

    14. Thank You!!

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