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Overview of Regional Haze in the Upper Midwest

Overview of Regional Haze in the Upper Midwest. Michael Koerber Lake Michigan Air Directors Consortium December 6, 2010. Overview. Background (CAA requirements) Conceptual Model of Haze Technical Basis for Visibility-Related Analyses Reasonable Progress Evaluation Summary.

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Overview of Regional Haze in the Upper Midwest

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  1. Overview of Regional Haze in the Upper Midwest Michael Koerber Lake Michigan Air Directors Consortium December 6, 2010

  2. Overview • Background (CAA requirements) • Conceptual Model of Haze • Technical Basis for Visibility-Related Analyses • Reasonable Progress Evaluation • Summary

  3. Visibility Requirements Section 169A of Clean Air Act Amendments of 1977 requires “as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in Class I areas which impairment results from manmade air pollution.” EPA’s visibility regulations (July 1, 1999) require “reasonable progress” to achieving natural conditions by the year 2064

  4. Isle Royale National Park, Michigan

  5. Chicago, Illinois

  6. CAA also requires…. Each implementation plan must contain measures necessary to make reasonable progress toward meeting the national visibility goal, including… (1) a requirement that each major stationary source (in existence in 1977, but not in operation before 1962) which may reasonably be anticipated to cause or contribute to any impairment of visibility in any Class I area shall procure, install, and operate … the best available retrofit technology …for controlling emissions … for the purpose of eliminating or reducing visibility impairment, and (2) a long-term strategy for making reasonable progress toward meeting the national visibility goal.

  7. Process for Establishing BART Emission Limitations Step 1: States identify those sources which meet the definition of “BART-eligible source” Step 2: States determine whether such sources “emit any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility (in a Class I area)” • A source which fits this description is “subject to BART” Step 3: For each source subject to BART, States then identify the appropriate type and the level of control for reducing emissions

  8. Which sources are BART-eligible? • Start-up Date: “in existence” on Aug 8, 1977, and “in operation” on or after Aug 8, 1962 • Source Category: One of 26 specified categories • Emissions: Potential to emit > 250 TPY of any visibility impairing pollutant (SOx, NOx, PM, VOC, NH3)

  9. Which BART-eligible sources are subject to BART? • Option 1: Consider all BART-eligible sources are subject to BART • Option 2: Consider exempting some or all BART-eligible sources from BART review • Individual source attribution approach • Model plant approach • Cumulative modeling approach

  10. So, what did we do….. • EGUs (State-by-State decision) • USEPA BART Rulemaking (July 6, 2005): “CAIR achieves greater progress than BART and may be used by States as a BART substitute.” • Non-EGUs • Individual source attribution approach: CALPUFF modeling of SO2 and NOx emissions (LADCO modeling protocol) • Model plant approach: Calculated Q/d values (Note: EPA criteria consistent with Q/d = 10) • Cumulative modeling approach: CAMx modeling of VOC and PM emissions

  11. CALPUFF Individual Source Modeling Q/d=100 Q/d=8 A source is “subject to BART” if it causes (>1.0 dv) or contributes (>0.5 dv) to visibility impairment in any Class I area

  12. Long Term Strategy States must set reasonable progress goals (10-year increments) In determining reasonable progress, states shall consider: • costs of compliance, • time necessary for compliance, • energy and non-air quality environmental impacts of compliance, • remaining useful life of existing sources subject to such requirements • uniform rate of visibility improvement (needed to attain natural visibility conditions by 2064) – i.e., “glide path”

  13. Visibility “Glide Paths” Baseline Conditions 20% worst visibility days Natural Conditions 20% best visibility days Baseline Conditions

  14. September 18, 2007 Letter: “Minnesota asks the five other significantly contributing states (IL, IA, MO, ND, and WI) to make these same commitments for further evaluation and implementation of reasonable control measures.” July 30, 2007 Letter: Included a “Statement” that outlines the MANE-VU States’ initial request for a course of action by states outside of the MANE-VU region toward assuring reasonable progress at their Class I areas) Arkansas/Missouri: Held several conference calls in spring/summer 2007. Apparently planning to set RPGs based on existing controls. September 20, 2007 Letter: “Kentucky does not find a need to request additional emission reductions from Midwest sources at this time”

  15. Conceptual Model of Haze

  16. Light Extinction (Visibility) 20% best days 20% worst days

  17. Light Extinction (Visibility) 20% best days 20% worst days 2018 Emissions NOx NH3 SO2

  18. 20% Worst Visibility Days – BOWA

  19. Composite Back Trajectory: 20% Worst Visibility Days

  20. Technical Basis for Visibility-Related Analyses

  21. Key Parameters Baseline Conditions = Average visibility value for the 20% most (or least) impaired days for the period 2000-2004 Natural Conditions = National visibility goal set forth in section 169A (“prevention of any future and the remedying of any existing impairment of visibility… from man-made air pollution”)

  22. Key Parameters Baseline Conditions 20% worst visibility days Natural Conditions 20% best visibility days Baseline Conditions

  23. EPA Guidance Documents

  24. http://vista.cira.colostate.edu/IMPROVE/ http://vista.cira.colostate.edu/views/

  25. Reasonable Progress Evaluation

  26. Regional Air Quality Modeling Model: CAMx Domain/Grid: Eastern U.S. (36 km), Midwest (12 km) Year: 2002, 2005 (full year) - PM/haze, 36 km 2002, 2005 (summer) - O3, 12 km 12 km 36 km

  27. Modeling Process • Base Year Analysis (2002, 2005) • Purpose: evaluate model performance • Future Year Analyses (2009, 2012, 2018) • Purposes: assess candidate control measures and provide attainment demonstration

  28. Existing Control Programs • On-Highway Mobile Sources • Tier II/Low sulfur fuel • Inspection/Maintenance programs (nonattainment areas) • Reformulated gasoline (nonattainment areas) • Off-Highway Mobile Sources • Federal control programs incorporated into NONROAD model (e.g., nonroad diesel rule), plus the evaporative Large Spark Ignition and Recreational Vehicle standards • Heavy-duty diesel (2007) engine standard/Low sulfur fuel • Federal railroad/locomotive standards • Federal commercial marine vessel engine standards • Power Plants • Title IV (Phases I and II) • NOx SIP Call • Clean Air Interstate Rule • Other Point Sources • VOC 2-, 4-, 7-, and 10-year MACT standards • Combustion turbine MACT • Industrial boiler/process heater/RICE MACT • Miscellaneous consent decrees and settlement agreements • Area Sources • Aerosol coatings (new rule) • Architectural and industrial maintenance (AIM) coatings (amendments) • Household and institutional consumer products (amendments) • Portable fuel containers (Mobile Source Air Toxics rule)

  29. Regional Emissions (TPD) VOC NOx SO2

  30. Voyageurs, MN Boundary Waters, MN Seney, MI Isle Royale, MI

  31. Statutory Factors • Cost of compliance • Time required for compliance • Energy and non-air quality environmental impacts • Remaining useful life • Strategies of Interest • “On the books” measures • Possible additional controls (sector-level) • Possible additional controls (individual facilities) • Geographic Areas of Interest • 3-state region: MI, MN, WI • 9-state region: MI, MN, WI, plus IA, IL, IN, MO, ND, SD

  32. Geographic Areas of Interest

  33. Summary • CAA sets a very difficult goal with respect to visibility impairment in federal Class I areas • “prevention of any future, and the remedying of any existing impairment of visibility…from manmade air pollution” • Midwest States have consulted and worked with other states, FLMs, and tribes to address visibility impairment • Intra-regionally to address Class I areas in LADCO region • Inter-regionally to address Class I areas outside LADCO region • Technical analyses were conducted to assess baseline (current) and projected (future year) visibility levels • Current levels well above natural conditions • Projected levels (through 2018) are close to “glide path” (uniform rate of progress), but are still above natural conditions • Continued progress needed to meet natural conditions goal

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