SO 2 Ambient Air Quality Standards and Modeling Options. Chris White Department Manager, Permitting and Compliance

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1 SO 2 Modeling Options Chris White Department Manager, Permitting and

2 Presentation Topics Proposed 1-Hour SO 2 Data Requirements Rule 1-Hour SO 2 Non-Attainment Area SIP Guidance Options for Facilities Page 2

3 1-Hour SO 2 Data Requirements Rule This proposed rule contains requirements for air agencies to characterize SO 2 emissions for the 1-hr SO 2 NAAQS in areas with insufficient monitoring Data will be used for NAA designations in 2017 and 2020 Focus would be on areas with large SO 2 sources By January 15, 2016, states will need to identify large sources to be characterized submit a modeling protocol Page 3

4 1-Hour SO 2 Data Requirements Rule The proposal includes 3 options for emissions thresholds for sources to be included in this characterization: Option 1 - sources >1000 tons of SO 2 in metro areas with population >1MM; and sources >2000 tons everywhere else. Option 2 - sources >2000 tons of SO 2 in metro areas; and sources >5000 tons everywhere else. Option 3 sources >3000 tons of SO 2 in metro areas; and sources >10,000 tons everywhere else. EPA prefers Option 1 but has requested comments on the other two options Page 4

5 1-Hour SO 2 Data Requirements Rule Site Name City State 2011 SO2 (tons) Wisconsin Rapids Fiber and Energy Mill WISCONSIN RAPIDS WI 1948 ESCANABA PAPER COMPANY ESCANABA MI 2196 WAUSAU PAPER MILLS, LLC RHINELANDER WI 2422 Domtar A. W. LLC-Nekoosa NEKOOSA WI 4731 PACKAGING CORPORATION OF AMERICA TOMAHAWK WI 4777 Biron Mill WISCONSIN RAPIDS WI 6140 THILMANY LLC KAUKAUNA WI 7695 Georgia-Pacific Consumer Products LP GREEN BAY WI P. H. Glatfelter Company Chillicothe OH Page 5

6 1-Hour SO 2 Data Requirements Rule Agencies can use monitoring or modeling Modeling is likely to be primary tool due to cost of monitoring USEPA will allow use of actual emission data in modeling analysis Agencies can work with sources to establish enforceable limits to avoid NAA designation based on modeling Page 6

7 1-Hour SO 2 Non-Attainment Area SIP Guidance USEPA Released Guidance Memo for 1-hour SO 2 Non- Attainment Area (NAA SIP Development) on April 23 rd, 2014 Guidance in not enforceable, so negotiation regarding schedules and content can be expected Upper Midwest NAA of Concern City of Rhinelander, Crescent Town, Newbold Town, Pine Lake Town, and Pelican Town, Wisconsin Page 7

8 1-Hour SO 2 Non-Attainment Area SIP Guidance Key Points in the Guidance SIP submittal must include an attainment demonstration based on a modeling analysis of the non-attainment area The modeling analysis will utilize proposed enforceable emission limits for sources Entire non-attainment area should be included in modeling for attainment determination Sources outside the non-attainment area should be included Emission limits may be based on an averaging period greater than 1-hr, up to 30 days USEPA suggest using a ratio method that can be quite restrictive EPRI has developed an Emission Variability Processor (EMVAP) EMVAP is a processor that randomly samples emissions from an annual emissions distribution and applies them into AERMOD Page 8

9 1-Hour SO 2 Non-Attainment Area SIP Guidance Key Dates in the Guidance Initial designation of NAA (October 2013) 18 months after initial designation all elements of the nonattainment area SIPs are to be submitted (April 2015) One year before attainment date sources are expected to comply with RACM/RACT requirements (January 2017) 5 years after initial designation Achieve Attainment (October 2018) Page 9

10 What does this mean to Industry? If : your facility is a large source of SO 2 or If your facility is near a large source of SO 2. Your facility will be part of the 1-hr SO 2 attainment analysis Attainment issues identified during the analysis will need to be addressed Page 10

11 Options for Industry Complete initial modeling using allowable emission rates and model defaults Refine modeling Develop hourly emission data from fuel use, steam generation, or other auditable data sources Need three years of data due to NAAQS basis Evaluate use of non-guidance low wind speed options Refine emission profile Include future reductions required by other regulations Page 11

12 Options for Industry Refine Meteorological data Install site specific met station Will need agency concurrence on location and design of station Will need one year of data Complete site specific monitoring Use passive monitors to help site selection Collect sufficient data to justify selection Will need agency concurrence on location and design of station Will need three years of data, but monitoring will delay NAA determination Page 12

13 Strategy for Industry Comment on proposed data requirements rule Be specific Provide examples supporting comment Follow/participate in SIP development process Understand your impacts before the Agency starts their analysis Use information as a planning tool Pay attention to third party analyses/reports Page 13

14 Conclusions Early action provides more flexibility Taking control of process provides greater control of costs and timeline Comment on rules Know the answer Engage agency staff when appropriate Page 14

15 Thank You