Results you can rely on
Wisconsin Manufacturers &
Commerce: Federal Air Regulations
Update
Gale F. Hoffnagle, CCM, QEP
Air Quality Consulting Practice Leader
TRC Companies, Inc.
The New NAAQS
• EPA has promulgated a plethora of new NAAQS
– Ozone (2008) (2013?) 8 Hour Average
– PM2.5 (2006)
Reduced 24 Hour Average
(2013)
Reduced Annual Average
– Sulfur Dioxide (2010)
1 Hour Average
– Nitrogen Dioxide (2010) 1 Hour Average
– Lead (2008)
Quarterly Average
These combined make existing and new sources subject to
tremendous pressure on emissions.
Results you can rely on
2
1
2008 Ozone NAAQS
• Current ozone marginal Non-Attainment for Ozone
• Kenosha and Sheboygan
• Met 1997 NAAQS
3
Results you can rely on
Non-attainment Schedule
•
•
•
•
Results you can rely on
Final NAAQS
`
Final Designations
Attainment SIPs Due
Attainment Date:
2008
2012
2015
2015
4
2
Designations Expected for
2013 Ozone NAAQS
2012
2013
Results you can rely on
5
PM2.5 2006 NAAQS
• Non-Attainment for Milwaukee, Racine and Waukesha
Results you can rely on
6
3
PM2.5 2012 NAAQS
• 2010-2012 Design Values
Results you can rely on
7
PM2.5 2012 NAAQS
Non-attainment Schedule
• Final Rule December 2012
• State NAA Designation Recommendation to EPA
December 2013
• Final EPA Designations December 2014
• Attainment Demonstration SIPs Due 2016
• Attainment Date 2020
Results you can rely on
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4
NO2 NAAQS
• New NAAQS is 188 µg/m3(or 100ppb) but for a 1 hour
average. Depending upon the meteorology of the site
this results in a 6.6 times lower threshold to meet. It
therefore will be substantially harder to meet.
• EPA has provided Guidance that you combine the 98%
background from monitored data with the 98%
modeled result, making compliance much harder. This
is equivalent to a 99.995% chance that the observed
will be less than the predicted.
Results you can rely on
9
NO2 NAAQS
• Focus of NAAQS is people living adjacent to roadways
• States are supposed to add monitoring to areas near
roadways (Interstate Highways)
• Chances of violations near roadways very high
• Non-attainment near such monitors could ensnare
nearby industrial sources
• Monitoring near industrial facilities advisable to
establish compliance and, if necessary, actual
background concentrations.
Results you can rely on
10
5
NO2 NAAQS Other Modeling
Issues
• What is the NO2/NOx ratio exiting the stack
• Interim Significant Impact Limit (SIL) of 4 ppb (7.53
µg/m3)
• No increments, monitoring limits (monitoring may be
required), etc.
• EPA has changed lowest wind speed allowable in
model and doubles the worst case concentrations
• EPA changed model to calculate downwash for GEP
stacks
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Results you can rely on
NO2 NAAQS “Guidance”
• Guidance: June 28, 2010, June 29, 2010 and March 1,
2011
– Issue of what is Nitrogen Dioxide (NO2) and subject
to the NAAQS and what is Nitrous Oxide (NO) and
not subject to the NAAQS
– Memo describes a three Tier approach
 Tier 1: Assume it is all NO2
 Tier 2: Assume that NO2/NOx ratio is .80
 Tier 3: Use 1979 Ozone Limiting Method or PVMRM as
detailed screening technique. Calculates that NOx is
converted to NO2 based on the concentration of ozone.
Methods already in AERMOD not acceptable. Assume
50% of what exits stack is NO2.
 Tier 3 requires case-by-case determinations (database)
Results you can rely on
12
6
HOURLY NO2/NOx Ratio
Results you can rely on
13
SO2 NAAQS
• New primary NAAQS of 196 µg/m3 (75 ppb) as a 1
Hour average results in a 7.7 times more restrictive
standard. New standard is 99% over three years.
• EPA has provided Guidance that you combine the 98%
background from monitored data with the 98%
modeled result, making compliance much harder. This
is equivalent to a 99.995% chance that the observed
will be less than the predicted.
• Focus of attainment demonstrations to be on
modeling, which is a continuation of past policy with
enhanced use.
Results you can rely on
14
7
SO2 NAAQS
• DRAFT Guidance issued for comment in July
– Methods to model compliance
– Methods to measure compliance
– Final Guidance not issued
– EPA not approving monitoring protocols until
guidance final.
• Will States do more SO2 monitoring?
• Interim SIL: 3 ppb (7.84 µg/m3)
Results you can rely on
15
SO2 NAAQS Designation
Process
• Oneida County
Results you can rely on
16
8
Oneida Non-Attainment Sources
• Wausau Paper Mills, LLC
• Red Arrow Foods
• Packaging Corp. of America
•
•
•
•
3128 TPY
4.5 TPY
4641 TPY
Final NAAQS
Final Designations
Attainment Demonstration SIPs Due
Attainment Date
June 2010
July 2013
2015
2018
Results you can rely on
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EPA Working Group Results
• For NO2 (no background added):
– Steel Mill
3.2
times NAAQS
– Ethanol Plant
12.9 times NAAQS
– Natural Gas Turbine
4
times NAAQS
– Coal Power Plant
2.4
times NAAQS
– Refinery
1.9
times NAAQS
– Fuel Oil Turbine
4.8
times NAAQS
– Asphalt Plant
4.7
times NAAQS
– Natural gas Compressor
16.7 times NAAQS
– Biomass facility, Landfill gas turbine passed
Results you can rely on
18
9
EPA Working Group Results
• For SO2 (no background added):
– Ethanol Plant
2.9 times NAAQS
– Pulp and Paper
4.7 times NAAQS
– Coal Power Plant
4.6 times NAAQS
– Fuel Oil Turbine
1.3 times NAAQS
– Flare
1.7 times NAAQS
– Refinery
1.4 times NAAQS
– Asphalt Plant
19.3 times NAAQS
– Cement kiln and landfill gas passed!
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Results you can rely on
Usual Practices
 Increase stacks or plume rise
 Stratify multiple stacks
 Include other control regulations that must be met
 Buy and fence more land
 Keep impacts below the SIL
 Evaluate meteorological data representativeness
 Evaluate ambient data representativeness
 Propose to use EMVAP (variable emissions)
 Change building design
 Urban version of model
Results you can rely on
20
10
Best Practices NAAQS
Example of Detailed Monitoring Data Analysis
Day
(yyyymmd
d)
20130322
20130211
20130202
20130316
20130223
20130117
20130208
20130213
20130212
20130119
Max Daily
1-hour
Conc
(ppb)
99.4
44.4
42.7
36.1
30.2
29.0
27.5
26.9
26.4
25.4
Count of
valid hourly
values for
this day
24
21
23
24
23
24
23
23
23
24
Rank
1
2
3
4
5
6
7
8
9
10
Results you can rely on
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Evaluations for PM2.5
• Problem is meeting annual average NAAQS
• Must know what your PM2.5 direct emissions are
• Must have monitoring data close by to establish
background and your contributions to that monitor
• Must identify other sources and their impacts
• May be required to perform modeling for the chemical
formation of particles in the air after emission due to
sulfur oxides, nitrogen oxides and possibly organic
vapors and ammonia emissions (secondary formation).
• Take advantage of the draft guidance to use the 8th
highest value in 5 years when evaluating 24 hour
average.
Results you can rely on
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11
Modeling for PM2.5 Secondary Formation
CASE
PM2.5
NOx &SO2
Direct
Secondary
<40 TPY
None
None
>10 TPY
<40 TPY
AERMOD
None
• 3
>10 TPY
>40 TPY
AERMOD
Chemistry
• 4
<10 TPY
>40 TPY
None
Chemistry
Emissions
Emissions
• 1
<10 TPY
• 2
• Chemistry means either a Qualitative, Hybrid, or full quantitative
photochemical grid modeling.
Results you can rely on
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Chemical Modeling for PM2.5
• Requires application of “academic” atmospheric
chemistry grid models (CAMx or CMAQ). Draft
Guidance issued March 25, 2013.
• New version of CALPUFF with updated chemistry is
not approved by EPA.
• Modeling is expensive and time consuming especially
when dealing with huge data files.
Results you can rely on
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12
Ozone
Results you can rely on
25
PM2.5
Results you can rely on
26
13
SO2
Results you can rely on
27
The Beat Goes On
• EPA proposed but withdrew secondary standards for
SOx and NOx to protect against acid rain.
Environmentalists suing to reinstate proposal.
• EPA proposed and then withdrew secondary standards
for visibility in urban areas (reduce PM2.5 even more),
Environmentalists suing to reinstate proposal.
• EPA requires SO2 monitors to report 5 minute average
data in anticipation of a 5 minute average NAAQS.
• Act says to review and revise as necessary NAAQS
every 5 years. Environmentalists sue to ensure that
EPA does.
Results you can rely on
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