Air Program Basics
Clean Air Act of 1970



Established NAAQS
Set hazardous pollutant standards
Set automobile emissions standards



Carbon monoxide, hydrocarbons
New Source Performance Standards
Gave citizens right to sue people and
organizations in violation of emissions
standards
1977 Major Amendment

New Source Review (NSR) Permitting


Visibility Goals


Prevent & remedy visibility impairment in Class I
areas
Motor vehicle standards


Prevention of Significant Deterioration (PSD)
permits for major sources in attainment areas
Gasoline lead limit
Extended time to meet NAAQS
CAA: 1990 Major Amendment

Title IV Acid Rain program

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Reasonable further progress for nonattainment areas

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Cap and trade for sulfur dioxide
Differing levels of non-attainment provide flexibility
Title V Operating Permit program
Raised vehicle emission standards
Control technology for air toxics
CFC Reduction
Clean Air Rules of 2004

Clean Air Interstate Rule

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
Clean Air Mercury Rule



Cap and trade for NOx emission reductions
28 Eastern States
Standards of performance, cap and trade for
mercury reductions
Nonroad Diesel Rule
Ozone and Fine Particle Rules
National Ambient Air Quality
Standards

Set for six “criteria”
pollutants


Primary levels
protect human
health
Secondary levels
protect public
welfare and
environment
Pollutant
Primary Standard
Averaging
Time
Secondary
Standard
CO
9 ppm
(10 mg/m3)
8-hr
None
35 ppm
(40 mg/m3)
1-hr
None
Lead
1.5 µg/m3
Quarterly
Primary
NOX
0.053 ppm
(100 µg/m3)
Annual
Primary
PM10
50 µg/m3
Annual
Primary
150 µg/m3
24-hour
15 µg/m3
Annual
65 µg/m3
24-hour
Ozone
0.08 ppm
8-hour
Primary
SOx
0.03 ppm
Annual
--------
0.14 ppm
24-hr
--------
----------
3-hr
0.5 ppm (1300
µg/m3)
PM2.5
Primary
Meeting NAAQS

Non-Attainment Area: Any area that does not
meet (or contributes to air quality in a nearby
area that does not meet) the primary or
secondary standard for a pollutant



Designated via EPA rulemaking
State plans are generally due 3 years after
designations
These plans (or SIPs) must demonstrate how
control measures will attain the NAAQS by a
future date
Meeting NAAQS: History
1990 non-attainment




SO2:
PM10:
Lead:
CO:
Twin Cities, Rochester
St. Paul, Rochester
Dakota County
Twin Cities, Duluth, St. Cloud
Spring, 2002 – All areas
reach attainment
Meeting NAAQS: SIPs

CAA requires:


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SIP is a collection of the regulations a state
will use to achieve attainment



General plan to achieve the NAAQS in all areas
Specific plans for nonattainment areas
State rules/statutes and programs
Site-specific plans
When approved, SIPs and control measures
are enforceable at state and national levels

Minnesota’s is 40 CFR 52.1220
Site-Specific SIPs
Area
Pollutant
Facilities
Eagan
Lead
Gopher Resources Corporation
Rochester
PM10
RPU – Silver Lake
Rochester
SO2
RPU – Silver Lake, Associated Milk Producers, Franklin Heating Station, IBM,
Olmsted Waste to Energy, Rochester Public Utilities - Cascade Creek, St. Mary's
Hospital
Twin Cities 7-County
Area
SO2
Federal Cartridge, Hoffman Enclosures, BAE Systems Land and Armaments,
Xcel Energy - Inver Hills, Xcel Energy - Riverside, GAF Materials, NRG - Mpls
Energy Center
Rosemount/Pine Bend
SO2
Flint Hills Resources (Koch) – Pine Bend Refinery
St. Paul Park/Ashland
SO2
Marathon Ashland Petroleum
St. Paul
PM10
Aggregate Industries, Cenex Harvest States, Commercial Asphalt, Gerdau
Ameristeel, Great Western Dock and Terminal, Lafarge North America, Met
Council WWTP, St. Paul Terminals
St. Cloud
CO
N/A – Mobile source pollution
Duluth
CO
N/A – Mobile source pollution
Twin Cities Metro
CO
N/A – Mobile source pollution
SIP steps
Air Quality
Monitoring
Legal Authority
Control Strategy
Demonstration
Resources
State
Modeling data
Implementation
Plan
Emission Limiting
Rules and Regs
(SIP)
New Source Review
Enforcement
Permitting
Permitting
Voluntary and
Non-traditional
Measures
Mobile Measures
and Fuels
Taken from presentation by Tom Helms, EPA, on non-attainment/SIP
Control Strategies

LAER – Lowest Achievable Emissions Rate – Required for new
sources in nonattainment areas

BACT – Best Available Control Technology – A source-specific
emission limitation for a pollutant based on the maximum degree
of reduction and taking into account energy, environmental,
and economic impacts and other costs

MACT – Maximum Achievable Control Technology – A very high
level of pollution control technology, often used for hazardous air
pollutants or air toxics, as opposed to criteria pollutants

BART – Best Available Retrofit Technology – Retrofit technology
for sources built in 1962 – 1977; specifically being required for
sources that cause visibility impairment over a certain level

RACT – Reasonably Available Control Technology –
Recommended for existing sources in non-attainment areas
Two Approaches to Environmental
Management
Program Element
Air Quality Planning
Technology Standards
Attainment Plans
RACT, Regional controls
Offsets
LAER
Increments
BACT
Mobile Sources
Emission budgets
(conformity)
National standards for new
vehicles
Air Toxics
Residual risk
MACT
Indoor Air, Radon
---
Voluntary Measures
Criteria Pollutants
Point Sources: Existing (via SIPs)
Point Sources: New (via permits)
Non-attainment areas
Attainment areas
From: EPA Region V Air and Radiation Division, Basic Program Overview
Title V/Part 70 Permits

Title V of CAA requires operating permits for
stationary sources with PTE over a threshold
Permitting Thresholds Based on Potential to Emit (tons per year)
Pollutant
EPA Part 70 Threshold
State Permit Threshold
VOCs
100 tpy
100 tpy
CO
100 tpy
100 tpy
NOx
100 tpy
100 tpy
SO2
100 tpy
50 tpy
PM10
100 tpy
25 tpy
Combined HAPs
25 tpy
25 tpy
Individual HAPs
10 tpy each
10 tpy
Lead
10 tpy
0.5 tpy
Title V/Part 70 Permits

Includes all CAA requirements in a single,
federally enforceable document


State rules are used to issue federal permits




Minnesota combines construction and operation
permits
Minnesota permit rules approved by EPA
EPA gets a 45-day review of all permits
Unless noted, all provisions enforceable by state
and federal government
Minnesota has issued 328 Title V Permits
Other Permits

Several types of permits are used in the
air regulatory programs

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Title V permit
State individual permit
State registration permit
The type of state permit is based on



Facility emissions
If facility meets specific rules and statutes
If a general permit is available
Permits Issued
Total Facility Operating Permits Issued
Through February 2006
Individual Federal/ Individual State
398
General Permits (General Manufacturing and Nonmetallic Mineral Processing )
163
Registration
2,730
Capped
8
Total
3,299
Permit Review

All new or continuing permit applications must be
reviewed by permit staff

Permit applications are submitted through forms available
on our Web Page


Approximate Timelines



Goal to issue construction permits within 150 days of receipt
Straight-forward and non-controversial: 3-5 months for the permit to
be placed on public notice and 6-8 months for permit issuance
Subject to PSD, requires environmental review or is otherwise
complex or potentially controversial: 9-14 months for permit issuance
All individual (not general) total facility permits must be
put on public notice for 30 days
Air Modeling

Air Dispersion Modeling

Part of technical review of a proposal for a new or modified
facility that will have air emissions

Emissions are modeled through a computer simulation to
predict air quality concentrations


Elements modeled depend on the type of facility or modification,
potential to emit, actual emissions, and location
Air Emission Risk Analysis (AERA)


Done in support of permitting or environmental review
process
Evaluates potential impacts of toxic air pollutants from point
sources on human health
Emissions Inventory

Emissions Inventory is calculation of criteria
pollutant, VOC, and air toxics emissions

Point sources (Part 70, permitted)

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Required annual inventories of criteria pollutants and
VOCs,
Voluntary toxics inventory every three years
Area sources, Mobile and non-road

Emissions of criteria pollutants and toxics are calculated
on a three-year cycle
Emissions Fees

From the inventory, criteria emissions are
calculated and the facility pays fees for
chargeable pollutants (Minn. R. 7019.3000)

Chargeable Pollutants

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NOx, any VOC, PM10, SO2, lead, and any pollutant with
a national ambient air quality standard, except carbon
monoxide.
States must calculate actual emissions and fees
that are sufficient to cover the permit program
costs for Part 70 sources (40 CFR § 70.9)
Monitoring

EPA requires ambient air quality monitoring

MPCA has 77 monitors at 46 locations

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Most (32) are in the Twin Cities
Rochester, Marshall, St. Could, Detroit Lakes, Brainerd,
Duluth, Cloquet, Virginia and Ely
Data from air quality monitoring networks used to:

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Determine compliance with NAAQS
Activate emergency control procedures that prevent or
alleviate air pollution episodes
Track pollution trends
Provide research data to evaluate standards, corrective
actions, and validate dispersion models
Monitoring

Monitoring networks are used to meet the following
objectives:

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Determine the highest ambient concentrations expected to
occur Determine representative concentrations in high
population areas
Determine the impact of emissions from facilities
Determine general background concentrations
MPCA monitors:

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Criteria pollutants
Toxics
Acid rain
Mercury
Fine particle speciation
Hydrogen Sulfide
Monitoring: Criteria Pollutants
Monitoring: Criteria Pollutants
Monitoring: Criteria Pollutants
Alerts and Forecasting

Air Quality Index (AQI)


Reports daily air quality conditions
Calculated from ground-level ozone, sulfur dioxide, carbon
monoxide and fine particles (PM2.5)
Alerts: AQI Monitoring


Air Quality Index reporting in Twin Cities
since 1970s
Twin Cities only before 2003


Rochester, Duluth and St. Cloud added in 2003
2005 expansion to Brainerd, Marshall, Detroit
Lakes and Ely
Alerts: AQI Monitors
2005 AQI Days
Environmental Review

Environmental Assessment Worksheet (EAW)


Required when air emissions increase by more than 100
(soon to be 250) tpy
Preliminary assessment of a project’s environmental impact


Some facilities have mandatory environmental review:


Review ways to minimize or avoid such impacts
EGUs over 25MW, petroleum refineries, ethanol plants,
metallic mineral mining and processing, paper or pulp
processing mills, and solid waste incineration
Environmental Impact Statement (EIS)

Much more detailed than EAW

EAW may lead to an EIS
Air Program Strategic Goals



Goal 1: Meet all state and federal ambient air
quality standards.
Goal 2: Minnesota’s outdoor air quality will
meet environmental and health benchmarks
for toxic and other air pollutants
Goal 3: Take responsibility for reducing
Minnesota’s share of air pollutants having
regional, national and global impacts
Meeting Goal One
Meeting Goal One
Trends in Key Air Pollutants in Twin Cities 1979-2004
Percent of National Ambient Air Quality Standard
180
160
Carbon Monoxide
140
120
All values below 100 meet standards
100
Ozone
80
Fine Particles
60
Nitrogen Dioxide
40
Sulfur Dioxide
20
Lead
0
1979
1982
1985
1988
1991
1994
1997
2000
2003
Meeting Goal One


Objective A1b – Reduce pollutants contributing to particle
formation 30% by 2011
 SO2
 Estimated reduction 17% (2002 – 2009)
 Estimated reduction 16% (2002 – 2012)
 NOx
 Estimated reduction 24% (2002 – 2009)
 Estimated reduction 27% (2002 – 2012)
Object A1c – Reduce pollutants contributing to ozone formation
30% by 2011
 VOCs
 Estimated reduction 13% (2002 – 2009)
 Estimated reduction 15% (2002 – 2012)
 NOx
 Estimated reduction 24% (2002 – 2009)
 Estimated reduction 27% (2002 – 2012)
Meeting Goal One
Criteria pollutant emissions by Source category
(Emissions in Tons)
Pollutant
Name/Year
Point
Area
Onroad
Nonroad
Total
1999 NOx
151,395
26,393
171,628
128,246
477,661
2002 NOx
153,101
60,628
171,627
107,084
488,440
1999 SO2
127,022
6,673
6,332
13,625
153,652
2002 SO2
130,519
15,986
3,010
9,071
158,585
1999 VOC
32,360
156,333
106,585
100,989
396,267
2002 VOC
29,485
164,925
90,972
84,278
369,660
Meeting Goal Two

Reduce ambient concentration of air toxics below
health benchmarks
Benzene Trends
Meeting Goal 2

Note that formaldehyde benchmark has been under review

Many have suggested it could be set at a higher level
Formaldehyde Trends
Meeting Goal Three

Reduce visibility impairment in the Boundary
Waters and Voyageurs


Working with other states on Regional Haze plan
implementation to address this
SIP with regional haze control strategies due to
EPA December 2007
Meeting Goal Three

Reduce greenhouse gas intensity of economy
GHG Emissions/$GSP
Meeting Goal Three

Reduce mercury emissions by 70% from 1990 levels
by 2005
References
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EPA. Plain English Guide to the Clean Air Act.
http://www.epa.gov/air/oaqps/peg_caa/pegcaain.html
American Meteorological Society. History of the Clean Air Act.
http://www.ametsoc.org/sloan/cleanair/index.html
Air Quality in Minnesota, Progress and Priorities (2005 Report to the
Legislature) http://www.pca.state.mn.us/publications/reports/lraq1sy05.pdf
Presentation by Tom Helms, EPA, on non-attainment/SIP
EPA Region V Air and Radiation Division, Basic Program Overview
Air Program Basics
PowerPoint Prepared by:
Catherine Neuschler
Air Policy and Mobile Sources Unit