How to Develop Reasonable Progress, BART, and Consultation Submissions (and what tools can help)

Transcription

1 How to Develop Reasonable Progress, BART, and Consultation Submissions (and what tools can help) Gary Kleiman NESCAUM/MANE-VU Class I States Workshop March 6, 2006

2 Technical SIP Submissions Baseline and Natural Visibility Conditions Reasonable Progress Goals Long Term Strategy (including inventory, modeling, pollution apportionment, control measures, smoke management plan, and BART) Monitoring strategy

3 Technical SIP Submissions Data Analysis for Setting Reasonable Progress Goals (Guidance requires you to identify pollutants first!) Contribution Assessment Tools for Consultations and Strategy Development Single Source Impact Assessment for BART Visibility Determinations

4 Reasonable Progress Goals

5 Uniform Progress Goals (20% Worst Visibility Days) Regional Haze Visbility (DV) DV Almost 4 DV Year Acadia Brigantine Lye Brook Moosehorn Shenandoah

6 Uniform Progress Goals (20% Best Visibility Days) Regional Haze Visbility (DV) Acadia Brigantine Lye Brook Moosehorn Shenandoah Year

7 Changes to Baseline and Natural Visibility Condition Calculations New multipliers for Organics and Sulfates (segregated by size) New humidity [f(rh) ] curves Raleigh extinction is altitude dependent Sea salt is included! (and NO 2 where measured) Matching assumptions for Natural Conditions under development Of all regions, MANE-VU will be affected least, but sea salt will still likely make a difference

8 Reasonable Progress Goals (Preamble language) If the State determines that the amount of progress identified through the analysis is reasonable based upon the statutory factors, the State should identify this amount of progress as its reasonable progress goal for the first long-term strategy, unless it determines that additional progress beyond this amount is also reasonable. If the State determines that additional progress is reasonable based on the statutory factors, the State should adopt that amount of progress as its goal for the first long-term strategy. If the State determines, based on the statutory factors, that the identified uniform rate of progress needed to reach natural conditions is not reasonable, the State must provide in its plan submission the analysis and rationale supporting this determination. The State then must provide a demonstration as part of its SIP submission showing why a less ambitious goal is reasonable, based on the statutory factors.

9 Reasonable Progress Goals (Preamble language) If the State determines that the amount of progress identified through the analysis is reasonable based upon the statutory factors, the State should identify this amount of progress as its reasonable progress 1. Consider goal uniform the first ratelong-term strategy, unless it determines that additional progress beyond this amount is also reasonable. 2. If additional progress is reasonable, the state should adopt it! If the State determines that additional progress is reasonable based 3. If uniform on the statutory progress factors, is not reasonable, the State should the state adopt should that amount justify of why progress not, then as its adopt goal what for the is first reasonable. long-term strategy. If the State determines, based on the statutory factors, that the identified uniform rate of progress needed to reach natural conditions is not reasonable, the State must provide in its plan submission the analysis and rationale supporting this determination. The State then must provide a demonstration as part of its SIP submission showing why a less ambitious goal is reasonable, based on the statutory factors.

10 What is Reasonable? EGU-1 or EGU-2 Cement Plant RACT Municipal Waste Combustor RACT Refinery RACT Consumer Products Portable Fuel Containers Reduced Sulfur Heating Oil Chip Reflash Diesel Retrofits ICI Boiler RACT Glass/Fiberglass Furnace RACT Lime Kiln RACT Asphalt plant RACT Regional Fuels (on road) Adhesives Asphalt Paving Metal Production RACT Peaking Units Autofinish Coatings POTWs Printing and Graphic Arts Residential Wood Combustion Anti-Idling CA Diesel Fuel Stage 1 Gasoline Distribution Electrification of GSE & Ports Lawn & Garden Equipment EZ Pass rebate for efficient LDV Pre-96 Catalyst Changeouts Modeling and Consultations Depend on These Decisions!

11 Lye Brook Source Regions Meteorological source region on 10% highest sulfate days. Red indicates Increased probability of contributing to high days. Meteorological source region on 10% lowest sulfate days. Red indicates Increased probability of contributing to low days.

12 Same source region?? Meteorological source region on 10% worst sulfate days at Brigantine, NJ Meteorological source region on 10% worst organic carbon days

13 What to control?? (Example: Brigantine, NJ) Sulfates and Nitrate Based Control Program 1.26 µg/m3 Mass Reduction Organic Carbon Elemental Carbon Nitrate Sulfate Control All Components In Proportion 1.46 µg/m3 Mass Reduction Baseline Conditions Median Day (8.4 µg/m 3 )

14 Alternative strategies for achieving uniform progress by 2018 Proportional reductions in sulfate and nitrate only, or (µg/m 3 ) Acadia Brigantine Lye Brook Moosehorn Shenandoah Median Day Proportional reductions in sulfate, nitrate, organic carbon and elemental carbon (µg/m 3 ) Acadia Brigantine Lye Brook Moosehorn Shenandoah Median Day

15 What to do for Reasonable Progress? Site-specific, species-specific contributions to baseline conditions Source regions associated with important factors via source apportionment studies Develop control measures which address those factors Test for reasonability

16 Consultations

17 Pollution Apportionment REMSAD with SO2 tagging CALPUFF with 2 types of Meteorology Residence time probability x emissions Emissions/distance 4 quantitative/semi-quantitative methods of apportionment

18 REMSAD SO 2 Emission Tags (Run 1, 2, 3) Black : Run 1 Red : Run 2 Blue : Run 3 11

19 Contributions by RPO 100% 80% 60% 40% 20% 0% DOSO SHEN BRIG LYBR GRGU ACAD MOOS AVG MANE-VU M-RPO VISTAS CENRAP CANADA OTHER

20 Method Comparison Brigantine Sulfate 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Primarily from outside domain REMSAD CALPUFF %UW Q/D OTHER CANADA CENRAP VISTAS MIDWEST Vermont Rhode Island Pennsylvania New York New Jersey New Hampshire Massachusetts Maryland Maine District of Columbia Delaware Connecticut

21 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% No Other Brigantine Sulfate REMSAD CALPUFF %UW Q/D OTHER CANADA CENRAP VISTAS MIDWEST Vermont Rhode Island Pennsylvania New York New Jersey New Hampsh Massachuset Maryland Maine District of Co Delaware Connecticut

22 REMSAD Tags by Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec OTHER MANE-VU M-RPO VISTAS 0.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec OTHER MANE-VU M-RPO VISTAS Acadia NP Lye Brook Wilderness

23 Shenandoah NP Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec VISTAS M-RPO MANE-VU OTHER Brigantine NWR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec VISTAS M-RPO MANE-VU OTHER REMSAD Tags by Month

24 REMSAD Tags Day-by-Day Lye Brook, VT Acadia, ME ug/m ug/m Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug CENRAP VISTAS MW-RPO MANE-VU CENRAP VISTAS MW-RPO MANE-VU Brigantine, NJ ug/m August 9-16, sites, 3 influences Aug Aug Aug Aug Aug Aug Aug Aug CENRAP VISTAS MW-RPO MANE-VU

25 Episode Analysis (Continued) See Animation

26 REMSAD tags by geographic area

27 What to do for Consultations? State-specific sulfate attribution on an annual average basis When available, future estimates of statespecific sulfate attribution Define threshold contribution? Hourly/Daily/Seasonal Analysis? Area of Influence Analysis? What will help make the case for implementing reasonable measures for Haze?

28 BART

29 BART Resource Book BART Eligible Source List (to the extent possible) BART Workgroup Recommendations All eligible sources are subject to BART Presumptive levels of control BART Technology Assessment M-V Assessment (EGU/ICI/Cement/P&P) Industry Assessments NESCAUM BART Determinations (recommendations only!)

30 BART Modeling Exemption modeling detailed, resource intensive, subject to approval Visibility Determination subject to state discretion, both with regard to how it is conducted and how it is weighted against other factors.

31 MANE-VU Goal To provide all states with multiple regionallyconsistent source specific data analysis and modeling products to use as a justification for BART controls if desired and needed! States may also choose to conduct their own modeling or require sources to conduct additional modeling.

32 Acadia 24-Hour Max Day Impact (relative to 20% worst natural and baseline conditions) Wyman St Acadia Conesville WH Sammis Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

33 Brigantine 24-Hour Max Day Impact (relative to 20% worst natural and baseline conditions) Wyman St. Conesville WH Sammis Brigantine Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

34 Lye Brook 24-Hour Max Day Impact (relative to 20% worst natural and baseline conditions) Lye Brook Wyman St Conesville WH Sammis Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

35 Shenandoah 24-Hour Max Day Impact (relative to 20% worst natural and baseline conditions) Wyman St Conesville WH Sammis Shenandoah Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

36 Acadia Annual Average Impact (relative to 20% worst natural and baseline conditions) Wyman St Acadia Conesville WH Sammis Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

37 Acadia 24-Hour Max Day Impact (relative to 20% best natural and baseline conditions) Wyman St Acadia Conesville WH Sammis Indian River Change in Visibility ( dv) relative To Natural Background - Blue Change in Visibility ( dv) relative To Baseline - Red

38 What to do for BART? Source-specific sulfate, PM attribution on an annual average and 24-hour max basis Define threshold contribution? Relative to Natural Background or Baseline? Relative to Worst Days or Best? Use extinction or DV? REMSAD tagged runs for which sources? What will be most helpful for justifying controls when needed?

39 Other Tools

40 Inventory Analysis NEI 1996 NEI 1999 NEI > 30 tons/sqmile Pennsylvania Rhode Island Vermont North Carolina Virginia West Virginia New York New Jersey New Hampshire Maryland Massachusetts Maine Connecticut Delaware District of Columbia million t/y

41 Source Apportionment

42 Monitoring Data: RAIN

43 Incremental Probability Lyebrook Sulfate Incremental Probability, 500m Start Height, Worst 5% Sulfate Worst 5%-10% Sulfate Worst 10%-15% Sulfate Worst 20% Sulfate Worst 15%-20% Sulfate

44 Rotated Coordinates Best and Worst Days Acadia Mohawk Mountain Lyebrook Highest Sulfate Sulfate= 3.19 Bext= PM =8.19 OC = 1.91 Sulfate= 5.10 Bext= PM =11.78 OC = 3.19 Sulfate= 3.92 Bext= PM =9.11 OC = 1.72 Lowest Sulfate Sulfate= 1.40 Bext= PM =4.09 OC = 1.04 Sulfate= 2.01 Bext= PM =5.35 OC =1.50 Sulfate= 1.30 Bext= PM =3.62 OC = 0.90

45 CAMNET

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