Embed Size (px)
Citation preview
2007 U.S. EPA Regional/State/Local Dispersion
Modelers WorkshopJessica Montañez
Office of Air Quality Planning and Standards (OAQPS)New Source Review Group (NSRG)
New Source Review Program Update
Agenda
1. What is New Source Review?1. What is New Source Review?
2. Prevention of Significant Deterioration2. Prevention of Significant Deterioration
3. Nonattainment New Source Review3. Nonattainment New Source Review
4. Other NSR Rules and Guidance 4. Other NSR Rules and Guidance
What is New Source Review?
Major source thresholds used to identify whether a source is major or minor.100 or 250 tons/year for PSD, depending on the source category.100 tons/year or lower for NA NSR depending on the severity of the nonattainment.
Regulated NSR pollutants include the National Ambient Air Quality Standards (NAAQS) and some other pollutants such as sulfuric acid mist and hydrogen sulfide. In NA NSR, the regulated NSR pollutants are only the NAAQS.
Major NSRin attainmentareas (PSD)
Minor NSRin both attainment and
nonattainment areas
Major NSRin nonattainmentareas (NA NSR)
New Source Reviewa pre-construction
permitting program for new or modified stationary sources
NSR is divided into three parts:1 32
Prevention of Significant Deterioration
(PSD) Program
Refinements of Increment Modeling Procedures Proposal
• Prevention of Significant Deterioration (PSD) program protects clean air through a system of “increments.”
• Proposed rule:• Clarifies how PSD emissions increases are calculated • Incorporates some of Western States Air Resources
Council (WESTAR) recommendations • Addresses issues related to the 2004 State of North
Dakota and the U.S. EPA Memorandum of Understanding (MOU)
• Proposal:• Signed by Office of Air and Radiation (OAR) Acting
Administrator May 15, 2007• Publication scheduled for June 2007
Refinements of Increment Modeling Procedures Proposal (Continued)
Topics being considered in the proposal:how to estimate actual emissions from applicable sources that consume the PSD incrementusing actual emissions to model short-term incrementsusing an alternative time period to model baseline concentrationhow to treat subsequent air quality permits following a “variance” issued by the Class I area’s Federal Land Manager (FLM)appropriate types of meteorological data and processingappropriate years of meteorological data for modeling increment
Ambient Air
Memo about EPA’s interpretation of the definitions of:
“ambient air” and“building, structure, facility, or installation” as applied to air quality analyses in leased land scenarios under the PSD program
Source not required to model its emissions impacts at locations that are not considered to be “ambient air”EPA’s practice has been to only exempt an area from “ambient air” analyses when the source:
Owns or controls the land or property; and Precludes public access to the land or property using a fence or other effective physical barrier
Memo discusses various leased land scenarios and EPA’s interpretation for each. Scenarios:
Under the existing business relationship, two (or more) operating companies constitute a single sourceTwo (or more) companies operate separate sources on property owned by one company and leased in part to the other, and the lessor retains control over public access to the entire property and actually maintains a physical barrier around it to preclude public accessTwo (or more) companies operate separate sources on property owned by one company and leased in part to the other, and the lessor grants the lessee sole control over who may access the leased property The property owner agrees to allow a lessee to operate a business on the leased land that is open to the general public
Ambient Air (Continued)
Nonattainment New Source Review
(NA NSR) Program
Appendix S
Transitional NA NSR program for newly designated nonattainment areasFinal Rule:
Revised Sections II and IV of Appendix S to be consistent with the 2002 NSR reforms Changes related to determining when NSR would apply to a new source or a modification of an existing facility including:
Baseline emission determinationsActual-to-projected-actual methodology for emissions increasesPlantwide applicability limits (PALs)
Includes an interim interpretation of “reasonable possibility”Published March 8, 2007Effective May 7, 2007
Other New Source Review Rules
(applicable to both PSD and NA NSR) and
Guidance
Reasonable Possibility
Standard identifies when a source should do recordkeeping and reporting after undergoing a modification that does not trigger major NSRProposal:
Published March 8, 2007Included two alternative options for determining whether recordkeeping and reporting are required. Source could use:
Actual emission increasesPotential emissions increases
Comment period closed May 7, 2007Publication scheduled for September 2007
October 20, 2005: EPA proposed options to change the emissions increase test applicable to modifications at existing power plants from an annual to an hourly test
Compares maximum hourly emissions at a unit during the past 5 years (considering controls) to its post-change maximum hourly emissions. Options:1. Maximum achievable hourly emissions test2. Maximum achieved hourly emissions test3. Output-based hourly emissions test
April 25, 2007: Supplemental proposal recasts proposed alternatives
Output-based text is not an alternative but a way to measure the hourly emission rateNew option: Retain the current annual emissions increase test, apply it to situations where EGU’s hourly emissions increase
July 9, 2007: Comment period closes
Emissions Increases for Electric Generating Units (EGUs)
Implementation of NSR for PM2.5
• July 1997: PM2.5 NAAQS promulgated • January 5, 2005: PM2.5 designations established• Nov. 1, 2005: PM2.5 Implementation rule proposed• March 29, 2007: PM2.5 Implementation rule
promulgated• For NSR purposes, PM10 has been used as surrogate
• September 2007: Scheduled publication of final rule. Addresses:
• Precursors• Offset ratios• Interpollutant trading• Transition policy
PM2.5 Increments, SILs and SMCs
Separate proposal from PM2.5 Implementation RuleSignificant Impact Levels (SILs) – screening tool used to determine if a comprehensive increment analysis is neededSignificant Monitoring Concentrations (SMCs) – screening tool to determine if site-specific ambient monitoring is needed
Proposal considers three options for each:Increments:
Percent of NAAQS option, the "Equivalent Increment" approach anda variation of the second option that also considers the stringency of PM2.5 NAAQS
SILs:Percent of increments option, emissions ratio of PM10 option, and NAAQS ratio of PM10 option.
SMCs:Emissions Ratio option, NAAQS Ratio option, and Lowest Detectable Concentration option
Publication scheduled for September 2007
Equipment Replacement Provision
Replacement of process components with “like-kind” components is “routine maintenance, repair and replacement (RMRR),” and therefore excluded from major NSR requirementsRule schedule:
October 27, 2003: Rule PromulgatedDecember 24, 2003: Rule stayed by DC CourtJune 6, 2005: Reconsideration CompletedMarch 2006: Vacated by DC Court May 2006: EPA petitioned for rehearing, then deniedNovember 2006: Supreme Court denied our petition for writ of certiorariEPA currently considering next steps
Aggregation, Debottlenecking and Project Netting
September 8, 2006: EPA proposed three improvements for the NSR program:
Aggregation – how to group related projects at a single source for NSR purposesDebottlenecking – considers emission increases at units downstream and/or upstream from the changed unitProject Netting – source-wide analysis of emissions increases and decreases over a five-year period
Final Rule:Publication scheduled for Fall 2007
Fugitives Reconsideration
EPA policy has been to count fugitive emissions regardless of category when determining if a major modification has occurred2002 NSR Reform rules specifically codified counting of fugitive emissions, which prompted petition and lawsuit from Newmont Mining
Newmont argued EPA failed to comply with CAA
Proposal:Publication scheduled for July 2007
Other Rules/Guidance
Phase II OzoneProposal for reconsideration scheduled to be signed by May 2007
Tribal NSR RulesComment period closed March 20, 2007Final rule publication scheduled for Spring 2008
Flexible Permits Proposal currently under OMB reviewPublication scheduled for June 2007
Power Plant Review Team (PPRT)
Headquarters review of draft comments on proposed power plant permits to ensure national consistencyRegional Offices (ROs) typically have 30 calendar days to submit comments on proposed construction permits
By Day 21, Air Program Manager (APM) should forward by e-mail their draft comments to the NSR group leader (Racqueline Shelton) and carbon copy Raj Rao and Dave SvendsgaardPPRT will review and assign a Lead Staff Reviewer (LSR). Comments will be forwarded to Office of General Counsel (OGC) for their review tooBy Day 28, the LSR will obtain OAR approval and provide officialfeedback to the ROBy Day 30, the PPRT will share their policy decisions related to a specific permit with all ROs through a database, monthly meetings with APMs and the Coal Best Available Control Technology (BACT) workgroup
PPRT (continued)
Recent PPRT reviews related to modeling:Deseret Bonanza in Utah – EPA Region 8 is PSD Permit AuthorityDesert Rock in Arizona – EPA Region 9 is PSD Permit AuthorityBig Brown Steam Electric Station in Texas –EPA Region 6 is PSD Permit Authority
Contacts
Jessica MontañezPhone: 919-541-3407
Dave Svendsgaard919-541-2380
Questions?
NSR Reform
Promulgated December 31, 2002. Included:Plantwide applicability limits (PALs) on air emissionsSource owners who have units that have state of the art control (known as Clean Units) to make changes to their unit without revising their permits as long as the permitted emissions are not exceeded and permitting conditions are maintainedSource owners to install certain environmentally beneficial pollution control projects (known as PCPs) without a prior permit revisionReasonable Possibility recordkeeping and reporting requirementsA 10-year baseline period look-back capActual-to-future-actual applicability test
June 2006 – D.C. Circuit Court of Appeals:Vacated the method of calculating emissions for Clean Units and the PCPs exemption Remanded the issue of recordkeeping
Modeling Analyses Required Today
Ambient Air Quality (Each PSD pollutant, Class II)Compare previously determined project sig. impact concentrations to monitoring de minimis impact levels (if
monitoring data appropriate) . Perform pre-construction air quality monitoring if above do not exempt pollutant.
Additional Impacts (Class II)Growth, visibility, soil and vegetation analysis
Class I Area (Each PSD pollutant)1. Significant Impact Assessment – modeling of the project’s emissions at FLM provided Class I area
receptors. 2. Class I Increment – cumulative modeling at FLM provided receptors. 3. AQRV’s – modeling of project’s emissions at FLM receptors for comparison to FLM target/threshold values.
Increment (Each PSD applicant with SIA, Class II)Refined cumulative modeling (project + existing increment affecting sources) within SIA to determine cumulative
impacts.
NAAQS (Each PSD applicant with SIA, Class II)Refined cumulative modeling (project + existing sources) within the SIA to determine cumulative impacts.
Significant Impact (Each PSD pollutant, Class II)Screening modeling to determine the project’s significant impact area (SIA). Done by each PSD applicant in Class II
areas.
