FLM ISSUES AROUND THE COUNTRY EPA, STATE, LOCAL AIR QUALITY MODELERS WORKSHOP 2016

Transcription

1 FLM ISSUES AROUND THE COUNTRY EPA, STATE, LOCAL AIR QUALITY MODELERS WORKSHOP 2016

2 Disclaimer The following presentation represents the current views and ideas of the federal land management agencies staff and does not necessarily represent the official position of the Department of the Interior, the Department of Agriculture, or the agencies or bureaus of these departments. Editorial comments are those of the presenter and do not necessarily reflect the views or opinions of anyone else. 2

3 Clean Air Act Overview Provides Additional protection for Class I areas National Parks > 6,000 acres Federal Wilderness Areas > 5,000 acres In existence as of

4 Clean Air Act Overview Provides Additional protection for Class I areas SEC 165: FLMs HAVE The Affirmative Responsibility to Preserve and Protect Air Quality and Air Quality Related Values (AQRVs) AQRVs include resources sensitive to air pollution (e.g., soil, water, visibility, plants, animals) SEC 169A; Regional Haze Programs and national visibility goals for Class I areas National Visibility Goal: remedy any existing and prevent any future manmade visibility impairment in mandatory Class I areas 4

5 FLAG

6 CURRENT (2010) SCREENING OUT OF A CLASS I AIR QUALITY RELATED ANALYSIS PER CLASS I AREA EMISSIONS / DISTANCE TO EACH CLASS I AREA(S) IN KILOMETERS (KM) EMISSIONS = MAXIMUM 24 HOUR EMISSION LIMITS FOR: SO 2 + SO 4 + NO X + PMC + PMF + SOA + EC * 8760 / 2000 = TPY IS THE Q/D 10 PER CLASS I AREA? Q/D MAY BE REVISED IN FLAG 20XX BASED ON ADDITIONAL EXPERIENCE AND NEW MODELING GUIDANCE

7 CURRENT SOURCE TYPES CAUSING impacts to USFS NPS FWS BLM NEW MAJOR BROWNFIELD SOURCES / POWER PLANTS-SOME NEEDING ADDITIONAL CONTROLS (simple cycle turbines w/scr) NEW MAJOR GREENFIELD SOURCES / POWER PLANTS OIL and GAS DEVELOPMENT LOWER 48 and ALASKA and PIPELINES IN ALASKA DECREASING MINING ACTIVITIES: COAL, COPPER, GOLD, URANIUM, POTASH

8 MAJOR MODIFICATIONS What emissions go into Q the net increase, the entire facility? Actualto-projected-actual applicability test for projects that only involve existing emissions units. Actual-to-potential test for projects that only involve construction of a new emissions unit(s). Hybrid test for projects that involve multiple types of emissions units. What emissions in screening analysis for AQRV analysis determination: past actuals or current permitted emissions. Actual emissions vs. permitted emissions could make a big difference in the AQRV analysis outcome. Do you look at the entire facility or just the modification when evaluating a permit for a major modification post modification(s), the facility pre-modification and post modification, the difference, all of the above? Visibility do you include all visibility impairing pollutants or just the pollutants for which there is a significant increase- Near-Field- VISCREEN/PLUVUE and Far-Field?

9 Technical Implications & Applications of MOU / (Air Modeling) for Federal Oil & Gas NEPA Decisions Bureau of Land Management U.S. Forest Service Environmental Protection Agency National Park Service Fish & Wildlife Service June

10 NEPA OIL AND GAS AREAS & ISSUES LARGE SCALE AND NUMEROUS GAS PROJECTS MOSTLY IN THE WEST. NEAR NPS, USFS, AND FWS CLASS I and CLASS II AREAS. (Thousands of well for some projects) MT, WY, ND, SD, CO, NM, UT IMPACTS TO VISIBILITY, OZONE, NITROGEN DEPOSITION LEASING OF THE ALASKAN PETROLEUM RESERVE NEAR ANWAR ARCTIC NATIONAL WILDLIFE RESERVE (FWS) NPS units Gates of the ARCTIC & NOATAC PRESERVE (Class II). (CALPUFF WITH MMIF MET) MARCELLUS & UTICA SHALE, increasing field development, pipelines, compressor stations, gas to liquid plant in Ohio FWS work with BOEM (Bureau Ocean Energy Management for offshore development

11 Most Affected Parks: MEVE, HOVE & NABR (In the Paradox Basin, near the San Juan & Raton Basins) CHCU and AZRU (In the San Juan Basin, near the Paradox & Raton Basins) ARCH & CANY; NABR & HOVE (In the Paradox Basin, near the Uinta & Piceance Basins) DINO (in the Uinta Basin, near the Piceance & Green River Basins) THRO, KNRI & FOUS (in the Williston Basin) CAVE & GUMO (in the Permian Basin) Possibly, BADL, WICA, DETO & BICA (downwind of PRB) Others...

12 4km Intermountain West model domain O&G basins in CO, WY, UT, NM Denver-Julesburg Upper Green River Uintah Piceance San Juan A mix of national parks and wilderness areas near O&G development, EGUs, and a large urban area (Denver) 12

13 Offshore Oil and Gas Activity FLM agencies review offshore oil and gas activity following the FLAG guidance Both BOEM and EPA have offshore jurisdictions There are approximately 2400 operations happening in the Gulf of Mexico, some within several kilometers of the Breton Wilderness

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15 Guidance at a Glance First draft released to FS, NPS, and FWS in November Revised draft released in January Recommends a 3-tier screening approach for modeling deposition in the near-field. Tier I (AERMOD) conservative deposition velocities defined for SO 2 and NO x. Tier II (AERMOD) slightly more refined approach, allowing for pollutant specific properties to be considered in deposition analysis. Tier III (CALPUFF) two approaches, based upon sourcereceptor distances, making use of CALPUFF first-order chemical mechanism.

16 Tiers I & II - AERMOD East of Mississippi River: SULFUR or NITROGEN=0.01 Kg/HA/Yr West of Mississippi River: SULFUR or NITROGEN=0.005 Kg/HA/Yr Tier I based upon IWAQM Phase I approach which recommends defining a conservative deposition velocity for both SO 2 and NO x input manually into AERMOD. Tier II approach based upon defining specific deposition parameters. NOx/NO 2 has low deposition velocity, so NOx is treated fully converted to HNO 3 (highest deposition velocity of various N species)

17 Tier III (CALPUFF) Tier III approach uses CALPUFF with first-order chemical mechanism to treat conversion Within 0-20-km, if applicant can adequately demonstrate that steady-state meteorological conditions dominate source-receptor relationships, FLM will consider use of CALPUFF with AERMOD surface and upper air data. All other applications will develop 3-D wind fields consistent with the unique nature of near-field application of model. August 31, 2009 EPA memorandum regarding CALMET settings for LRT applications is not considered universally appropriate. Protocol necessary to discuss CALMET settings appropriate for near-field application of model.

18 What is the purpose of the IMPROVE Equation? IMPROVE does not measure visibility directly we collect particles on filters and determine average particle composition and mass. The interaction of light with particles depends on: particle composition ability to absorb water size shape The IMPROVE Equation is used to convert our filter measurements into visibility. We need to include some assumptions about other parameters (size, shape, hygroscopicity).

19 The IMPROVE Equation b ext = 2.2 f s (RH) [Small Sulfate] f L (RH) [Large Sulfate] f s (RH) [Small Nitrate] f L (RH) [Large Sulfate] [Small Organic Mass] [Large Organic Mass] + 1 [Fine Soil] f ss (RH) [Sea Salt] [Coarse Mass] + 10 [Elemental Carbon] + Rayleigh Scattering [NO 2 (ppb)]

20 The Path Forward for IMPROVE 1. Working Group develops/recommends a new IMPROVE Equation. 2. Review of the revised equation by the IMPROVE Steering Committee. Potentially peer review. 3. Review of the revised equation by a larger group of stakeholders. 4. Review of the revised equation by EPA and states for Regional Haze Rule implementation. 5. Implementation of new IMPROVE Equation. Timeframe: 2-3 years

21 Mass Extinction Coefficient 10 µg coarse mass Chiricahua 10 µg Elemental Carbon Modeled using WinHaze Important to get this conversion correct. Biggest uncertainties are assumed size distributions.