Improving Visibility at Class I Areas Regional Haze SIP Requirements

Transcription

1 Improving Visibility at Class I Areas Regional Haze SIP Requirements Susan S.G. Wierman, MARAMA MARAMA Permits Managers Workshop Wilmington, DE February 7, 2006

2 Objectives of presentation What s regional haze? What causes it? How does the BART requirement complement other efforts to improve visibility 2

3 Topics 1. What is regional haze 2. What s required 3

4 The Clean Air Act Sets a National Goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from man-made air pollution. (CAA Sec. 169) 4

5 The Goal applies to Class I Areas Large National Parks and Wilderness Areas and International Parks 156 areas defined pursuant to the Clean Air Act Amendments of

6 10 Class I Areas in MARAMA 6

7 Haze is caused by particles Particles in the atmosphere scatter or absorb light and impair visibility Natural visibility in the eastern US is about 80 miles on the worst days to over 150 miles under the best conditions 7

8 Light absorption by fine particles Light scattering by fine particles Clear line of sight in absence of fine particles 8

9 Particles = SO 4 + OC + EC + NO 3 + NH 3 + crustal matter (soil dust, sea salt) 9

10 Haze pollution is mostly sulfate b Crustal 5% b Elem C 4% Acadia National Park, 1997 b Elem C 6% b Org C 13% b Crustal 16% Nitrate 7% b g C % b Sulfate 70% 20% Worst Visibility (1997) b Nitrate 7% 20% Best Visibility (1997) 10

11 Haze affects broad regions Regional haze is caused by the combined effects of many sources in a broad region Combustion (SO 2 & NO x ), including power plants, boilers, furnaces, vehicles, etc. Evaporation of organics from plants, vehicles, other VOC sources Fires, wood smoke Incineration Mining, pulp mills, other industrial sources 11

12 One view of sulfate source regions 12

13 Visibility is often worse in summer Brigantine Wilderness Area, NJ Days 4 Days Extinction (Mm -1 ) Sulfate Nitrate Org Carbon Crustal Elem Carbon Summer Winter 13

14 Sulfate is much higher on the 20% of days with the worst visibility compared to the 20% Best Days (1997 data) 232 Mm -1 / 51 Mm -1 Dolly Sods/Otter Creek Sulfate OC 193 Mm -1 / 45 Mm -1 Shenandoah Nitrate Crustal EC 235 Mm -1 / 64 Mm -1 James River Face Rayleigh 14

15 In general Summertime haze results largely from the regional transport/production of sulfate Wintertime haze results from the regional transport/production of sulfate + local sulfate + local organics + local nitrate Worst twenty percent days are mostly summer, but include several winter days as well 15

16 Visibility is related to nearly every other air pollution issue Reducing regional haze in Class I areas will help reduce air pollution elsewhere Haze and PM2.5 pollution will benefit from the same controls Reducing SO2 will reduce acid rain Reducing NOx will reduce ozone pollution and acid rain Reducing haze will benefit airports, cities too 16

17 The acid rain program showed us: Reducing SO 2 emissions will reduce sulfate and improve visibility 17

18 Figure 14. Differences in 4-year Mean Total Sulfur Deposition and Annual SO2 Emissions between and Differences in Total Sulfur Deposition (kg/ha) Differences in State Level Sulfur Dioxide Emissions (thousand short tons) 0 to to to to to to

19 Second Topic 1. What is regional haze 2. What s required 19

20 Regional Haze Program States must develop an implementation plan if sources have emissions which may reasonably be anticipated to cause or contribute to any impairment of visibility in any Class I area. Federal Class 1 Areas in MARAMA 20

21 Consultation is Required States/Tribes must consult with Federal Land Managers before adopting SIPs States with Class I Areas must consult with states/tribes whose sources affect those areas before adopting goals All states/tribes affecting area must also consult on long-term strategy 21

22 22

23 Four Core Requirements of EPA s 1999 Regional Haze Rule 1. Calculate baseline & natural visibility conditions 2. Set reasonable goals for visibility improvement 3. Control grandfathered sources (BART) 4. Adopt additional control measures needed to achieve reasonable progress 23

24 1a. Baseline Visibility Conditions Class I State SIP Section (d)(2)(i) of 40 CFR Baseline visibility is where we are now Baseline Period is Average impairment for 20% most and 20% least impaired days annually 24

25 1b. Natural Visibility Conditions Class I State SIP Section (d)(2)(iii-iv) of 40 CFR Natural visibility is where we want to be visibility conditions in absence of human-caused air pollution Intended to be long-term (5 yr) average best & worst visibility with contemporary land use Based on available scientific analysis and relative humidity considerations 25

26 2a. Reasonable Progress Goals Class I State Section (d)(1) of 40 CFR Ultimate goal is to reach natural visibility conditions by 2064 (Presumptive Goal) First visibility milestone is 2018 Visibility improvement required for worst 20% of days No degradation in visibility for least impaired days 26

27 2b. Reasonable Progress Goals Class I State SIP Class I State must consider: Costs of compliance Time needed for compliance Energy & non-air quality environmental impacts of compliance Remaining useful life of any potentially affected sources Must consult with FLMs & states affecting the Class I area SIP must demonstrate how these factors were considered in selecting goals. 27

28 Preliminary Uniform Progress Goals (20% Worst Visibility Days) Visual Range (mi) Acadia Brigantine Lye Brook Moosehorn Shenandoah Year 28

29 Preliminary Uniform Progress Goals (20% Worst Visibility Days) Regional Haze Visbility (DV) Acadia Brigantine Lye Brook Moosehorn Shenandoah Year 29

30 3a. BART CAA Section 169 A (b)(2)(a) Major stationary sources built in previous 15 years which contribute to visibility impairment must be controlled by best available retrofit technology (BART) as determined by the state. Section (e) of 40 CFR

31 3b. BART EPA rules requires states to: List all BART-eligible sources PTE 250 t/y, PSD categories, 8/7/62 8/7/77 Determine which sources contribute to visibility impairment those require BART Determine BART for each source Justify sources that are exempt May examine/establish a trading program 31

32 4a. Long Term Strategy Requirement all state SIPs Section (d)(3) of 40 CFR Must include Enforceable emissions limits Compliance schedules Other measures necessary to achieve reasonable progress goals at every Class I area affected BART will be one part of the long term strategy 32

33 4b. Long Term Strategy Factors Section (d)(3)(v) of 40 CFR At minimum, the state must consider Ongoing air pollution control programs Measures to mitigate construction impacts Emissions limits & schedules to achieve goals Source retirement & replacement schedules Smoke management techniques Enforceability Anticipated net effect on visibility due to changes during the period 33

34 4c. Long Term Strategy Section (d)(3)(i-iii) & (i)(2) of 40 CFR States must consult with each other and FLMs State must document basis for its share of reductions Strategy must achieve reductions agreed to through RPO process 34

35 Additional SIP Elements Monitoring sufficient to asses progress Inventory of emissions contributing to visibility impairment Consultation on Long Term Strategy Address all comments by FLMS Continuing consultation process 35

36 Key MANE-VU Decisions Create MANE-VU and begin analysis Estimate Natural Background Visibility Determine BART, Review Reasonable Progress Goals States Submit SIPs Approve Timeline for SIP/TIP development Contribution Assessment and discuss alternative strategies Approve Long-term Strategy 5-year progress review 36

37 BART Timeline BART requirements must be included in SIP (December 2007) BART sources must implement BART by 5 years after EPA approves SIP Progress Reports on SIP implementation due every 5 years SIP updates every 10 years 37

38 Objectives of presentation What s regional haze? What causes it? How does the BART requirement complement other efforts to improve visibility 38

39 Regional haze is visibility impairment caused by the cumulative effect of a large number of emission sources over a broad area Haze is caused by particles, which scatter or absorb light 39

40 The Clean Air Act Sets a National Goal Remedy existing visibility impairment in Class I areas due to human activities Prevent future visibility impairment in Class I areas 40

41 Best Available Retrofit Technology Required specifically by the Clean Air Act Also part of the overall strategy to make reasonable progress in improving visibility in Class I areas Applies to major sources contributing to haze that were built in the 15 year period before the enactment of the Clean Air Act Amendments of 1977 (i.e., pre-psd) 41