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Modeled NAAQS Non-compliance in NE Minnesota and Proposed Path Forward

Modeled NAAQS Non-compliance in NE Minnesota and Proposed Path Forward. Summary. Modeled non-compliance for 1-hr SO 2 and 1-hr NO 2 NAAQS in NE Minnesota Identified during modeling required for PolyMet’s environmental review

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Modeled NAAQS Non-compliance in NE Minnesota and Proposed Path Forward

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  1. Modeled NAAQS Non-compliance in NE Minnesota and Proposed Path Forward

  2. Summary • Modeled non-compliance for 1-hr SO2 and 1-hr NO2 NAAQS in NE Minnesota • Identified during modeling required for PolyMet’s environmental review • Modeling indicates that nearby sources, not PolyMet, are culpable • 2 EGUs, 3 Taconites • Proposing path forward to Risk Managers

  3. 1-hr SO2 Culpable Sources (number of receptors exceeded) • Minnesota Power Laskin (2) • US Steel Minntac(10) • Northshore Peter Mitchell Pit (15) • ArcelorMittal (23) • Virginia Public Utilities (28)

  4. Receptors in Red Exceed the Standard

  5. 1-hr NO2 Culpable Sources (number of receptors exceeded) • Northshore Peter Mitchell Pit (1) • Virginia Public Utilities (30) • ArcelorMittal (791) • US Steel Minntac (853)

  6. Receptors in Red Exceed the Standard

  7. MPCA Guidance • 12/19/12 Memo to Resolve non-project NAAQS/MAAQS Exceedances • Goal: resolve modeled exceedancesvia enforceable conditions • The project manager, modeler and permit engineer prioritize list of culpable sources and recommend actions to the Risk Managers for approval

  8. EPA Guidance • Each receptor showing an exceedance is equal and must be addressed • Environmental review must consider the ramifications of a NAAQS violation and possible non-attainment • Non-PSD permits can be issued, if they don’t exceed the SIL • PSD permits can not be issued without an enforceable, detailed plan with timelines in place for all facilities contributing to exceedance

  9. Why now? • PolyMetEIS must contain a description of the path forward for the culpable sources by March 2013 • PolyMetis a non-PSD source, therefore it is not necessary to resolve the NAAQS non-compliance in order for permitting

  10. Why now? • There will be future PSD permits submitted in the region, as soon as mid-year 2013 • Solutions will be iterative and time intensive, so advantageous to start ASAP • PolyMet modeling shows exceedances only within its receptor grid – not the full extent of the impacts • Likely to rely on concurrent, parallel efforts

  11. Proposed Resolution Team Lead: Air Policy Staff with modeling, enfocement, and permitting support • Letter to all culpable facilities putting them on notice of modeled exceedances • Require submittal of a plan within 45 days including actions to resolve modeled exceedances • Iterative steps, based on facility-specific plan, to get to final action • MPCA conducts cumulative modeled to confirm actions will result in compliance prior to becoming enforceable • Final action, via permit or enforceable agreement, must be taken by late-2013

  12. Proposed Resolution • If facility does not submit plan, does not submit adequate plan, or is not cooperative, the MPCA would issue a unilateral enforcement action requiring the facility to take action • MPCA may need to specify needed emission reductions

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