How NAAQS Revisions
Can Affect Your Facility
Michael Ballenger, P.E.
and Russell Bailey
Central District’s Power Generation Conference
July 29, 2010
trinityconsultants.com
Presentation Outline

Background –





What are NAAQS?
How are they
established / revised?
Expected Timeline - More Revisions
How do NAAQS revisions affect me?
General Case Study
Background - NAAQS


6 criteria pollutants used as AQ indicators
Maximum ambient concentration levels
Adverse effects on human health or public welfare
can occur above these levels
 Florida SIP adopts NAAQS [Rule 62-204.800(1), F.A.C.]

 More

stringent SO2 standards [Rule 62-204.240(1), F.A.C.]
Areas where air concentrations exceed
NAAQS designated as “nonattainment”
Background – NAAQS Revisions

CAA §109(d)(1): EPA must reevaluate NAAQS on 5-year basis

Standards not based on cost!


Whitman v. American Trucking
Recent re-evaluations led to the following:
Revised
NAAQS
Date Finalized
Primary
Standard
Averaging
Time
March 2008
0.075 ppm
8-hour
Lead
October 2008
0.15 mg/m3
3-month
NO2
February 2010
100 ppb
1-hour*
SO2
June 2010
75 ppb
1-hour*
Ozone

* New averaging periods
NAAQS Revisions in Progress

The following are currently proposed or
being planned by EPA:
NAAQS
Proposal
Date
Final Rule
Expected
Standard
Averaging
Time
Ozone – Round 3!
Jan 2010
Aug 2010
60 – 70 ppb
8-hr
NO2 Secondary
Jul 2010?
Jul 2011?
?
?
SO2 Secondary
Jul 2010?
Jul 2011?
?
?
PM
Jul 2010
Apr 2011
12-14 mg/m3
annual
CO
Oct 2010
May 2011
?
?

In 3 years from 2008, all NAAQS may be new!
Proposed Ozone NAAQS
Current Proposed Ozone Updates



EPA notified D.C. Circuit that they would reconsider 2008 Ozone NAAQS
Proposed new standards on Jan. 6, 2010
NA Counties 515 to 650 (322 currently)
Ozone
NAAQS
Primary
Standard
Averaging
Time
2008
Revision
0.075 ppm
8-hour
2010 ReRevision
0.060 to
0.070 ppm
8-hour

Secondary
Standard
Averaging
Time
Same as Primary
7 to 15 ppmhours
W126*
W126 is a “cumulative peak-weighted index” to identify the 3 consecutive
months during the ozone season with the highest index value (averaged
over 3 years).
There’s a Map for That…
More 3G Coverage…

3rd Generation of the 8-hour Ozone NAAQS
to

And these maps are just monitors showing NA – do
not include Core-Based Statistical Areas (CBSAs)!
Expedited Timeline
Timeline
2008 Ozone Standard
Revised 2010 Ozone
Standard*
Standard Proposed
June 20, 2007
72 FR 37818 – 7/11/2007
January 6, 2010
75 FR 2938 - 1/19/2010
Final Standards
March 12, 2008
73 FR 16436 – 3/27/2008
August 31, 2010
March 12, 2009
January 7, 2011
Final NA Area
Designations
March 12, 2010
(proposed 3/12/2011)
July 2011
(effective by 8/31/2011)
NA SIPs Due
March 12, 2013
December 2013
2013 to 2030
2014 to 2031
States Recommend
NA Areas
Attainment Dates
* Schedule for Primary Std., possible schedule for Secondary Std.
How Will Ozone Revisions
Affect My Facility?

2008 Standard replaced


Nonattainment designations may
be coming even to rural areas


Permitting continues under 0.08 ppm
until new designations final
Permitting impacts
Reductions, new permits


Not just new sources and modifications
May pull in existing sources
Potential Obligations to Existing
Permitted Sources in NA Areas

Lower VOC/NOX Title V thresholds


RACT requirements



Re-evaluate if facility is still minor
What units are subject?
Permitting requirements
Areas of influence

Will other counties not included in nonattainment
designation be considered area of influence?
Potential Obligations to New or
Modified Sources in NA Areas

Lower VOC/NOX NSR threshold(s)


Fugitive emissions


Small changes may now result in major NSR
Aggregation for minor changes?
Costs




Emission reduction credits (ERCs)
LAER
Alternatives Analysis
Compliance issues with other sister sites
Revised NO2 NAAQS
Sources of NOx Pollution
Source: EPA Office of Air Quality Planning and Standards
(http://www.epa.gov/air/nitrogenoxides/actions.html )
Revisions to NO2 NAAQS


Annual Average Standard = 53 ppb (100 µg/m3)
Final revisions published in FR on 2/9/2010 (effective
4/12/10)



Changes to NO2 Air Quality Monitoring Network




New 1-Hour Standard = 100 ppb hourly expressed as 3-yr average
of 98th percentile of annual distribution of max daily1-hour avg
No changes to the annual standard or secondary standard
(secondary standard currently under review)
Peak, short-term concentrations primarily near major roadways in
urban areas
Highest concentrations of NO2 that occur over wider areas
Concentrations impacting susceptible and vulnerable groups
EPA requiring all NO2 monitors to begin operating no later
than January 1, 2013
1-Hour NO2 Standard
Implementation







April 12, 2010 – Final standard effective
January 2011 – States submit designation
recommendations to EPA
January 2012 – EPA designates most areas
“unclassifiable” (because near-road monitors not in
place)
January 2013 – New near-road monitors in place
January 2015 – Next NO2 NAAQS review
January 2017/2018 – Non-attainment redesignations
January 2022/23 – Attainment date
Revised SO2 NAAQS
Revisions to SO2 NAAQS

Final rule published June 2, 2010







1-Hour Standard = 75 ppb on a 3-year average of 99th percentile
concentration
Effective Date August 23, 2010
EPA anticipates that new 1-hour standard would prevent
concentrations from exceeding current 24-hour standard
(140 ppb) and current annual standard (30 ppb) healthbased standards
New standard to reduce exposure to high, short-term
concentrations of SO2 deemed to be greatest health risk in
recent health studies
EPA revoked both annual and 24-hour current primary SO2
standards and replace with 1-hour standard
No change to secondary standard (under separate review)
New near source monitoring required by 2013
Sources of SO2 Pollution
Source: EPA Office of Air Quality Planning and Standards
(http://www.epa.gov/air/sulfurdioxide/pdfs/SO2proposalbriefing.pdf)
Revised SO2 NAAQS Monitoring


Current network not primarily configured to monitor high
concentration sources
EPA proposing two categories of required monitors




Monitors required in certain CBSAs based on
combination of population and SO2 emissions
Additional monitors may be required by the Regional
Administrator based on the state’s contribution to
national SO2 emissions – specific locations to be
determined by states and the Regional Administrator
Adjusted network will have a minimum of 163 sites
nationwide that are to be operational by 1/1/2013 (from
348 initially proposed)
EPA plans to utilize refined modeling results, as part of
the attainment designation process
1-Hour SO2 Standard
Implementation





August 23, 2010 –Final standard effective
June 2011 – States submit designation
recommendations to EPA
June 2012 – Final Area Designations
June 2013 – Attainment Demonstration SIPs due
August 2017 – Attainment date
Comparing Old v. New (1 of 2)

Without considering different forms of the
revised standards, comparing the revised
standards using SCREEN conversion factors
between averaging periods…
Previous Std
SCREEN
Convert
Equivalent
1-hr Std
Revised
1-hr Std
Ratio
100 ppb
6.6:1
Annual NO2
53 ppb
12.5
663 ppb
Annual SO2
30 ppb
12.5
375 ppb
24-hr SO2
140 ppb
2.5
350 ppb
3-hr SO2
500 ppb
1.11
555 ppb
5:1
75 ppb
4.67:1
7.4:1
Comparing Old v. New (2 of 2)


Short-term emission rates > long-term
New form of standards


Average of 98th / 99th percentile of max daily 1-hr values
Different approach to models


NO2/NOX ratios and PVMRM
New AERMOD or massive post-processing


H8H, H4H are close
Max monitored value for background


Background > standard even in attainment area?
E.g., 2007 H1H NO2 in Broward County = 155 ppb
Impacts to My Facility?

New PSD Permitting





A nearby facility undergoes PSD Permitting


BACT may not be enough (“BACT-Plus”)
Ancillary equip. emissions control / taller stack
Short-term vs. annual modeled emission rates
Startup/shutdown modeled emission rates
Existing sources included in NAAQS inventory
Attainment Demonstrations by DEP

SO2 determinations may be based on refined
modeling – how will your facility be represented?
Case Study: NO2 and SO2 Impacts
Emission Unit
Type
Controls
Stack
NO2
SO2
600 MW
USCPC
SCR,
Scrubber
400’
0.07
lb/MMBtu
0.12
lb/MMBtu
100
MMBtu/hr
None
80’
0.1
lb/MMBtu
0.052
lb/MMBtu
Biomass Boiler
100 MW
BFB
SNCR,
SDA
200’
0.11
lb/MMBtu
0.01
lb/MMBtu
Gas Turbine
F Class
CCCT
SCR, DLN
Burners
150’
2.0 ppmvd
2 lb/hr
Turbine Startup
“
“
“
200 lb/hr
1.85 lb/hr
New Generator
300 kW
Tier 2,
ULSD
15’
6.4
g/kW-hr
15 ppm S
in fuel
Existing
Generator
300 kW
Diesel
15’
4.41
lb/MMBtu
500 ppm S
in fuel
Coal Boiler
No. 6 Oil Aux
Boiler
Simple SCREEN Results (1 of 2)


Individual emission unit impacts only
Downwash included for typical building size
EU
NO2
(mg/m3)
SO2
(mg/m3)
NO2 Cavity
(mg/m3)
SO2 Cavity
(mg/m3)
Coal Boiler
82.4
141.2
878.6
1,506
Aux Boiler
8.2
4.3
-
-
Biomass Boiler
68.1
6.2
903.4
82.1
Gas Turbine
8.3
1.0
189.7
22.7
Turbine Startup
99.9
0.9
2,272
21.0
New Generator
5,614
5.7
10,222
10.4
Existing Generator
16,444
185.4
29,945
337.5
Simple SCREEN Results (2 of 2)

Assume cavity on-site, add background


Orange County: NO2=0.058 ppm, SO2=0.02 ppm
1-hr NO2 std: 100 ppb; 1-hr SO2 std: 75 ppb
EU
NO2
(ppb)
Under 1-hr
Std?
SO2
(ppb)
Under 1-hr
Std?
Coal Boiler
102
No
69
Yes
Aux Boiler
62
Yes
21
Yes
Biomass Boiler
94
Yes
22
Yes
Gas Turbine
62
Yes
20
Yes
Turbine Startup
111
No
20
Yes
New Generator
3,044
No
22
Yes
Existing Generator
8,804
No
85
No
Questions?