Air & Waste Management Association Puget Sound Chapter

Transcription

1 Air & Waste Management Association Puget Sound Chapter Developments in NSR Air Permitting Professional Workshop April 17, :00 am - 5:00 pm Swedish Club 1920 Dexter Ave. N. Seattle, WA :00-9:15 Welcome Stockholm Hall Lanka DeSilva, Ramboll, A&WMA Puget Sound Chapter Chair 9:15-10:00 Air Permitting 101 and NSR Introduction Stockholm Hall Aaron Day, Trinity Consultants 10:00-10:50 Keynote: Recent Developments in EPA New Source Review Policies David Bray, Associate Director of Air, Office of Air and Waste, U.S. EPA Region 10 Stockholm Hall 11:00-12:00 Session A Stockholm Hall EPA Region 10 Update Doug Hardesty, U.S. EPA Region 10 BACT Analysis, Updates, and Strategies Laurel Peterson, SLR International Session B New Source Review Update: Air Quality Impact Analysis Dustin Pittman, ERM Vasa Room 12:00-1:00 Lunch (Free for Attendees and Presenters) 3 Crowns Room 1:00-2:00 Session C Stockholm Hall Washington Rule Updates- SSM and Public Notices Al Newman, WA Department of Ecology Air Toxics Permitting in Oregon: Update on the Cleaner Air Oregon Rulemaking Effort Keith Johnson, OR Department of Environmental Quality Session D Far-field and Class I Air Modeling Vasa Room 1

2 2:00-4:00 Session E: Washington State and Oregon Case Studies Ranil Dhammapala, WA Department of Ecology Tom Wood, Stoel Rives Phil Allen, OR Department of Environmental Quality; Andrew Rogers and Geoff Scott, Maul Foster & Alongi Stockholm Hall 4:00-5:00 Session F: NSR Panel Stockholm Hall Moderator: Jay McAlpine, U.S. EPA Region 10 Panel: Ranil Dhammapala, WA Department of Ecology Doug Hardesty, U.S. EPA Region 10 Agata McIntyre, Northwest Clean Air Agency Tom Wood, Stoel Rives Phil Allen, OR Department of Environmental Quality Thanks to our sponsor! 2

3 Developments in NSR Air Permitting Professional Workshop Seminar Abstracts Plenary Session Air Permitting 101 and NSR Introduction Aaron Day, Trinity Consultants This presentation will cover the basics of New Source Review (NSR) air permitting, including the following topics: Types of projects that may require NSR permitting Different NSR permit programs Applicability of state minor NSR permitting Exemptions from minor NSR permitting Key elements of air permit applications Keynote: Recent Developments in EPA New Source Review Policies David Bray, Associate Director of Air, Office of Air and Waste, US EPA Region 10 Nearly 200 parties provided comments on Clean Air Act permitting in response to the U.S. Department of Commerce s Request for Information on Streamlining Permitting and Reducing Regulatory Burdens. David will provide an update and assessment of recent developments in EPA new source review policies, including recent and upcoming rulemakings, and its plans for streamlining permitting and addressing issues raised in the comments to Commerce. Session A EPA Region 10 Update Doug Hardesty, US EPA Region 10 From applicability of NSR to emission inventories and state oversight, this presentation will share what is happening in Region 10 (and beyond) and what is currently on the minds of EPA permit staff. BACT Analysis, Updates, and Strategies Laurel Peterson, SLR International This presentation will include a step-by-step review of the best available control technology (BACT) analysis for those new to PSD/NSR permitting. The presentation will also include more in depth discussions on complex situations and strategies. 3

4 Session B New Source Review Update: Air Quality Impact Analysis Dustin Pittman, ERM The United States Environmental Protection Agency (USEPA) under the authority of the Clean Air Act established National Ambient Air Quality Standards (NAAQS) that apply for ambient air throughout the country. Each project must demonstrate that it does not contribute to exceedances of the NAAQS in the surrounding area using state or local agency modeling guidance or USEPA s Appendix W to 40 Code of Federal Regulations (CFR) Part 51. This presentation will cover the different standards and terms of an air quality impact analysis and provide an overview of how to perform a Class II air dispersion modeling demonstration. Session C Washington Rule Updates- SSM and Public Notices Al Newman, WA Department of Ecology Ecology is finalizing updates to its General Regulation, WAC , to address requirements stemming from EPA s 2015 Start up, shut down, and Malfunctions SIP Call. Changes to the rule will result in changes in operations and compliance requirements for excess emission events at sources in Washington. These changes will affect all sources in the state, especially those that have relied on WAC to address excess emissions during emission unit start up and shutdown. What you and your regulator will need to do in response to these changes will be discussed. Changes to the public notice provisions will change how public notice of comment periods on permits, and orders is issued will also be given an overview. Air Toxics Permitting in Oregon: Update on the Cleaner Air Oregon Rulemaking Effort Keith Johnson, OR Department of Environmental Quality The Cleaner Air Oregon rulemaking was launched in mid-2016 by Governor Kate Brown to close the gaps in the federal air toxics regulations. Working in close collaboration with a diverse group of stakeholders, Oregon regulators designed a new risk-based permitting program to address emissions of air toxics from industrial and commercial facilities. The proposed rules require reporting of over 600 air toxics, as well as risk assessment and, if necessary, risk reductions. In addition to the rulemaking effort, the Oregon state legislature recently passed a bill authorizing the program and setting parameters for its implementation. Session D Far-field and Class I Air Modeling The basics of modeling for Class I PSD increments and Air Quality Related Values (visibility degradation, acid deposition) will be introduced, and the fundamental guidance touched on. The status of CALPUFF, and particularly CALMET vs. MMIF, will be discussed in light of EPA s de-listing of CALPUFF from 40 CFR 51 Appendix W (the Guideline on Air Quality Models). The use of Photochemical Grid Models like CAMx and CMAQ in single source mode in place of CALPUFF will be summarized. 4

5 Session E Case Study. Permitting 300+ Backup Diesel Generators: A NSR Case Study from Quincy, WA Ranil Dhammapal, WA Department of Ecology The city of Quincy, a mostly agricultural community of 7,500 people is located about 120 miles eastsoutheast of Seattle. Quincy has been a magnet for high tech data centers over the past decade because of the availability of cheap and reliable power supply, and wide bandwidth fiber optic connectivity. To date 110 diesel generators providing 264 MW backup power have been installed at seven data centers in Quincy and these numbers are expected to triple in the next few years. This presentation discusses the Washington State Department of Ecology s approach to NSR permit modeling conducted in Quincy, to help manage residents cumulative exposure to diesel PM and NO2. Case Study. Clean Fuels Project at the BP Cherry Point Refinery The Clean Fuels Project at the BP Cherry Point Refinery was a PSD project to support the Federallymandated mobile source fuel specifications for diesel and gasoline. To make ultra-low sulfur diesel, a new hydrogen plant and a new diesel hydro-desulfurization unit were permitted and constructed. BP also replaced the burners on one of the heaters in the hydrocracker with ultra-low NOx burners, substantially reducing the NOx and CO emissions. The near-field and far-field NSR modeling approach will be summarized, as well as extra modeling done to assess the impacts in Canada, and impacts to regional ozone concentrations. Case Study. NSR Oregon Style Tom Wood, Stoel Rives Major new source review in Oregon is a bit different from other states. In this presentation, Tom will walk you through some of the more confusing basics of major NSR under the Oregon program and share case studies of how much of these unique permitting features have played out for Oregon sources. Case Study. Problems & Solutions for Air Quality Modeling Meteorology Phil Allen, OR Department of Environmental Quality; Andrew Rogers and Geoff Scott, Maul Foster & Alongi This presentation will focus on the challenge of selecting representative metrological data for air dispersion modeling in situations where NWS data from a nearby airport are not available or topographically representational, and the cost and schedule delay for an on-site metrological tower is prohibitive. Appendix W does allow for the use of prognostic weather forecast model data, which are available for the state of Oregon. The presentation will cover the challenges in obtaining representative data, what prognostic data are available, and provide suggested data assessments to justify their use. 5