PM2.5 NAAQS Implementation & Permitting in Georgia

Transcription

1 PM2.5 NAAQS Implementation & Permitting in Georgia Georgia Environmental Conference Jekyll Island, Georgia August 25, 2016 Brad James, P.E.

2 Overview Current UFP Regulation (as PM 2.5 ) PM 2.5 NAAQS SIP Implementation PM 2.5 Permit Modeling Guidance Industrial Perspective

3 Regulating PM2.5

4 Current NAAQS Pollutant Primary/ Secondary Averaging Time Value Rule Year Form Carbon Monoxide (CO) Primary 8 hours 9 ppm 1 hour 35 ppm 1971 Not to be exceeded more than once per year Lead (Pb) Both Rolling 3 mo μg/m Not to be exceeded Nitrogen Dioxide (NO 2 ) Primary 1 hour 100 ppb 2010 Both 1 year 53 ppb 1971 Annual mean 98th percensle of 1- hour daily maximum concentrasons, averaged over 3 years Ozone (O 3 ) both 8 hours ppm 2015 Annual fourth- highest daily maximum 8- hour concentrason, averaged over 3 years ParScle PolluSon (PM) Sulfur Dioxide (SO 2 ) PM 2.5 Primary 1 year 12.0 μg/m Annual mean, averaged over 3 years Secondary 1 year 15.0 μg/m Annual mean, averaged over 3 years Both 24 hours 35 μg/m th percensle, averaged over 3 years PM 10 Both 24 hours 150 μg/m From hzp://www3.epa.gov/zn/naaqs/criteria.html Primary 1 hour 75 ppb 2010 Not to be exceeded more than once per year on average over 3 years 99th percensle of 1- hour daily maximum concentrasons, averaged over 3 years Secondary 3 hours 0.5 ppm 1971 Not to be exceeded more than once per year

5 PM 2.5 Standards Through the Years Pollutant 1997 NAAQS 2006 NAAQS 2012 NAAQS PM10 24-hour 150 µg/m µg/m µg/m 3 PM10 Annual 50 µg/m 3 Revoked PM hour 65 µg/m 3 35 µg/m 3 35 µg/m 3 PM2.5 Annual 15 µg/m 3 15 µg/m 3 12 µg/m revisions promulgated January 15, 2013 Effective March 18, 2013 hzp://

6 How is it Regulated? Permitting Program Minor New Source Review (NSR) Major NSR Prevention of Significant Deterioration (PSD) attainment areas Nonattainment NSR (NNSR) nonattainment areas Reviewing today Major NSR PM 2.5 Issues

7 When Does Major NSR for PM 2.5 Apply? Install new source: PM 2.5 >100 tpy nonattainment area (NNSR) PM 2.5 >100/250 tpy attainment area (PSD) Direct PM 2.5, SO 2 (precursor), NO X (precursor) Modify existing major source: Direct PM 2.5 > 10 tpy SO 2 or NO X > 40 tpy (precursor)

8 PM 2.5 NAAQS SIP Requirements (1 of 2) July 29, 2016 EPA finalized requirements For areas currently classified as nonattainment for PM 2.5 Rules for governing attainment plans and NNSR permitting Attainment dates Guidelines for attainment designations RFP outlines Revocation of 1997 standard (replaced with 2012 standard) Environmental justice considerations Compliance and enforcement of control measures

9 PM 2.5 NAAQS SIP Requirements (2 of 2) NNSR permitting precursor pollutants: VOC, NO X, SO 2, and ammonia Must be presumptively addressed by states in SIP State does not have to adopt control requirements if precursor pollutant does not affect PM 2.5 in a nonattainment area Defines major source and major stationary source (for moderate and serious areas) Defines SERs for PM 2.5 and PM 2.5 precursors Promulgation of planning requirements (remanded in 2013 DC Court decision)

10 PM 2.5 NAAQS Implementation Schedule Regarding moderate and serious nonattainment areas Two tier classification system April 2015: moderate area designations become effective (most areas) October 2016: moderate areas SIPs due 18 months from effective date of designation December 2021: moderate areas attainment date Outmost - end of 6 th year after designation December 2025: serious areas attainment date Outmost - end of 10 th year after designation

11 PM 2.5 Promulgated Implementation Rule Possible Control Measures Stationary source controls Year round operation of seasonal NO X controls Diesel retrofits Open burning laws and enhanced enforcement Year round programs to reduce vehicle miles traveled Programs to reduce residential wood combustion and back yard barrel burning Mobile source Inspection/Maintenance programs

12 2012 Annual PM 2.5 Standard Status U.S. EPA issued final nonattainment areas January 15, 2015 Effective April 15, 2015 Three years attainment data for all areas in state Therefore, no nonattainment areas in Georgia So why should you care about PM 2.5 standard?

13 Implications of PM 2.5 NAAQS Using PM 2.5 =PM 10 emissions calculation strategies for sources with a significant fraction of coarse PM no longer advisable, especially for fugitive material handling and storage activities Condensables (CPM) must now be considered in setting emission limits and determining NSR applicability Monitored PM 2.5 concentrations in state are close to the 24-hr and annual PM 2.5 NAAQS complicating NAAQS modeling for PSD permitting For many sources, triggering PSD for PM 2.5 is no longer a viable option because modeling to show compliance will be unworkable Stay apprised of PM 2.5 PSD permitting activity in your area Your source may be considered as a regional inventory source in a PM 2.5 NAAQS modeling study without your knowledge High impacts may be attributed to your source if PM 2.5 emissions and source characterization data in the inventory is not accurate

14 When Does PM 2.5 Modeling Apply? PSD new or modified > significant levels Used for: NAAQS compliance Increment consumption Pre-application monitoring trigger Visibility impact on Class I areas Impact on nonattainment areas

15 When Does PM 2.5 Modeling Apply? Nonattainment NSR new or modified > significant levels Used for: Net air quality benefit analysis Visibility impact on Class I areas State Implementation Plan (SIP) modeling done by the State

16 Steps to Successful PSD Modeling for PM 2.5 Talk to our modeler s first find out what you need to submit Submit a complete modeling protocol before the modeling Get Georgia EPD to approve the protocol Then submit your modeling

17 What Qualitative Analysis is Required for Secondary PM 2.5? Review projected impacts Review current monitor values and placement Determine conservative estimate of conversion from SO 2 and NO 2 to PM 2.5 and consider proposed SERs from EPA EPD has required limited qualitative analysis

18 Characterize Regional PM 2.5 Background Complete for NO X and SO 2 Discuss how the new emissions impact area inventory big/small change in inventory? Will the emissions significantly impact attainment? Is the area close to nonattainment? Will the emissions significantly push the area to nonattainment?

19 Questions to Ask Before You Think About a New Permit and Before You Model Have you accurately characterized PM 2.5 emissions? Does your project have direct PM 2.5 emissions as well as precursors (SO 2 & NO x )? Are you close to a representative PM 2.5 monitor? If not, should you install one?

20 Questions to Ask Before You Think About a New Permit and Before You Model How close to the NAAQS is the representative monitor? Does your state have resources to review expected hybrid modeling or photochemical modeling studies? How will timing of your permit application be affected for secondary PM 2.5 and will it need to go to your EPA Region for review?

21 PM 2.5 Permit Modeling Guidance

22 PM 2.5 Steps Leading Up to the Current Guidance 5/16/2011: End of PM 10 surrogacy policy 12/14/2012: Revision of Annual NAAQS 1/22/2013: DC Circuit Court Ruling Vacates Significant Monitoring Concentration (SMC) Vacates and remands Significant Impact Level (SIL) 3/4/2013: Draft PM 2.5 Modeling Guidance Changes to requirements for major source NSR modeling for PM /20/2014: Guidance for PM 2.5 Permit Modeling Updates to draft guidance 8/1/2016: Draft guidance for PM 2.5 SIL

23 PM 2.5 SIL Guidance EPA accepting comments until 9/30/16 Describes how values will be used for meeting PSD requirements Technical basis on how values determined Legal support documentation

24 Clearing Air Ahead EPA states that a value of 1.3 µg/m 3 is appropriate for a 24-hr PM 2.5 SIL However, since (b)(2) still lists 1.2 µg/m 3 as the 24-hr SIL EPA recommends 1.2 µg/m 3 EPA lowered the recommended SIL for annual PM 2.5 from 0.3 µg/m 3 to 0.2 µg/m 3 However, for annual SIL EPA acknowledges this is less than the value established currently in (b)(2) States have discretionary authority to still accept a SIL value of 0.3 µg/m 3 EPA acceptance of use of a PM 2.5 SIL for PSD Increment Potential concern following EPA s May 2014 PM 2.5 guidance document (at that time EPA stated could not use a SIL for PM 2.5 increment)

25 PSD Increments (Corrected) EPA views ratio of the Class I and Class II PSD increments as the additional protection Congress intended for the Class I areas Guidance: applying the Class I and Class II increment ratio to the NAAQS SIL in creating each PM 2.5 PSD Class I increment SIL PM hr PSD Increment Class I: 0.05 µg/m 3 Class II/III: 0.2 µg/m 3 PM 2.5 annual PSD Increment Class I: 0.27 µg/m 3 Class II/III: 1.2 µg/m 3

26 General Steps in Air Quality Analysis (NSR Workshop Manual) Step 1 Model Project Step 2 If impacts < SIL, Done If impacts > SIL, Step 3 Step 3 Define Radius of Impact (ROI) Define Significant Impact Area (SIA) as ROI + 50 km ROI = 3 km

27 General Steps in Air Quality Analysis (NSR Workshop Manual) Step 4 Define Regional Sources Step 5 Model project + regional sources Step 6 Define background concentration Step 7 If cumulative impacts + background < NAAQS, Done SIA

28 PM 2.5 Guidance Summary

29 Primary PM 2.5 Assessment Methods Use AERMOD To compare with SIL* - use highest of 5-year average of maximum modeled 24-hr or annual PM 2.5 concentrations Consistent with prior guidance Final guidance included more caveats regarding use of SIL To compare with NAAQS (24-hr), new First Tier approach = design model conc. (98%) + design monitored conc. (98%) Less stringent than previous guidance, which required: highest model conc. (1 st High) + monitored design conc. (98 th %)

30 Secondary PM 2.5 Assessment Methods Qualitative Develop appropriate conceptual description of PM 2.5 using design value, speciation, meteorology, seasonality, composition, existing grid modeling Hybrid Qualitative/Quantitative Use of local/region specific offset ratios for precursor emissions Quantitative Photochemical Models or other models as modifications become more applicable, i.e., CAMx or CMAQ

31 The Future EPA working on revisions to the Guideline of Air Quality Models (40 CFR 51 Appendix W) Proposed rulemaking - July 2015 Final rulemaking expected October 2016 Revisions are expected Create new secondary PM 2.5 modeling SERs Would be greater than SO 2 and NO X rates of 40 tpy, each, used to trigger modeling Could be as much as 10 to 40 times higher than current significant rates and pollutant specific

32 An Industrial Perspective of PM 2.5

33 Industry Perspective Plant modifications New Source Review (PSD) evaluations per PM 2.5 attainment status PM 2.5 major modification threshold is 10 tpy AP-42 PM emission factors do not account for all PM 2.5 PM 2.5 fraction of Total PM factors exclude aerosols: e.g., Nitrates and Sulfates NOx / SO 2 major mods also considered major for PM 2.5 As precursors to aerosol formation. Also organics considered.

34 Industry Perspective Cement Plant Example: 2013 Kiln installation permit was NSR PM is Filterable PM and CPM - PM 2.5 Condensable Particulate (CPM) CPM tests: RM 5 back-half or RM 202 Mono-vent baghouse replaced by Stack Guaranteed outlet loadings: gr/dscf Initial modeling met SILs, no increment Highest NAAQS receptors right at fence line PM modeling passed All Fractions

35 Industry Perspective Measuring Particulate continuously is difficult NSPS and MACT Standards Particulate Matter EPA moving away from Opacity Opacity is cursory Indicator. Particle sizing and species even more vague EPA regulating PM with CEMS PM CEMS measure volume conc., but cannot assess mass rate without correlating to manual stack tests Certification of PM CEMS is difficult Diagnostic and spiked stack testing So, EPA uses PM CEMS parametrically

36 Industry Perspective CEMS, Tests NESHAP-MACT PM Standards: Power/Cement EPA now regulating particulate using a PM CPMS Continuous Parametric Monitoring System (CPMS) use uncertified PM CEMS output data correlated to compliant stack tests PM CEMS data challenged - PS 11 requires correlation tests - not sensitive to PM size fractions Not enough certified US data to establish a PM CEMS MACT Floor PM compliance monitor range established during stack tests But also difficulties establishing CPMS limits Instrument output average restriction - 30 Day Roll Avg.

37 Industry Perspective SCR/SNCR Cement and Power Plants (combustion sources) inject ammonia w/catalysts for NO X reductions. Fuel/material bound sulfur/chlorine reacts forms ammonium chlorides and sulfates PM 2.5 aerosols formed Thus, NO X control can increase PM 2.5

38 Industry Perspective Ambient Air Ambient monitors can also assess contributions from fugitive/mobile sources PM atmospheric chemistry on gases (secondary formation) is accounted for by applying lab wet chemistry methods Ideally, chemical composition could be evaluated on all measurements: stack/ambient for all PM 2.5 species Integrated real-time networks-stacks and fugitive sources combined

39 Summary Permit application requirements are going to be tricky Development of dispersion modeling scenarios demonstrating compliance may be challenging Demonstrating a representative monitor may be challenging Including secondary formation may be difficult Emission factors are still sparse CEMS and air monitoring equipment are difficult

40 Questions? Brad James, Manager of Consulting Services Trinity Consultants Atlanta Office (678) , ext. 224