Biographical Information George J. Schewe, CCM, QEP, Principal - - PDF document

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Biographical Information George J. Schewe, CCM, QEP, Principal - - PDF document

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Workshop F Air Permitting Impact of Modeling Emission Rates for Precursors (MERPS) on Permitting of PM 2.5 , Nox & VOC Sources Tuesday, March 27, 2018 9:45 a.m. to 11 a.m . Biographical Information George J. Schewe, CCM, QEP, Principal

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Workshop F

Air Permitting … Impact of Modeling Emission Rates for Precursors (MERPS) on Permitting

  • f PM2.5, Nox & VOC Sources

Tuesday, March 27, 2018 9:45 a.m. to 11 a.m.

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Biographical Information

George J. Schewe, CCM, QEP, Principal Consulting Meteorologist, Trinity Consultants 1717 Dixie Hwy, Suite 900, Covington, Kentucky 41011 859-341-8100 x109 gschewe@trinityconsultants.com

  • Mr. Schewe is a Certified Consulting Meteorologist as well as a Qualified Environmental

Professional who has over 40 years of dispersion modeling and air quality management experience in Kentucky, Indiana, and Ohio. He has prepared permit applications, interfaced with state agencies, prepared overall air quality impact assessments as well as regulatory review requirements, prepared additional impacts analyses, and modeled both criteria and toxic chemical releases to assess potential air impacts. He has contributed to a wide variety of environmental assessment studies including Prevention of Significant Deterioration, non- attainment area net emission modeling, state and federal air toxics analyses and risk assessments, RACT and BACT assessments, and State Implementation Plan (SIP) preparation. He has used modeling approaches for emergency as well as routine releases of air

  • contaminants. He has prepared modeling studies covering plantwide point-source emissions as

well as plantwide fugitives from roadways, materials handling, waste and scrap areas or other process related fugitive emissions. While with the U.S. EPA, he performed dispersion modeling in support of emission standards development and helped develop and improve industrial source dispersion models. He has conducted numerous workshops, seminars, and technical classes over the past 25 years for the U.S. EPA - Air Pollution Training Institute, Ohio EPA, and the Dayton Regional Air Pollution Control (RAPCA). Christopher Beekman, PhD, Specialist III, Ohio EPA PO Box 1049, Columbus, OH 43216-1049 614-644-3597 christopher.beekman@epa.ohio.gov

  • Dr. Beekman is a 1999 graduate of Muskingum University with a B.S. in Chemistry and

Environmental Science, and a 2009 graduate of The Ohio State University with a Ph.D. in Environmental Science. He started his career well outside of the environmental field in 1999, working as a chemist in a research lab focused on the development of novel cancer treatments incorporating known cancer-fighting pharmaceuticals with nano-engineered silica particles. His doctorate research focused on open path spectroscopy of the atmosphere, atmospheric chemistry, and the combination of air dispersion models with state-of-the-art solar radiative transfer models. Chris joined the Ohio EPA in 2012. His responsibilities include air quality modeling, the Mercury and Air Toxics Standards, and Ohio’s electric generating utility inventory. He works in the State Implementation Plan section of the Division of Air Pollution Control. Chris is Ohio EPA’s main contact for the electric generating utilities in Ohio. He also serves as the primary contact for the NOx Budget Trading Program, Cross State Air Pollution Rule, and the Mercury and Air Toxics Standards. Chris has been with the Ohio EPA for six years.

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Biographical Information

Robert Hocks, Senior EHS Professional - Midwest Duke Energy, 139 East Fourth St, EM740, Cincinnati, OH 45202 513-287-3235 Cell: 937-925-0166 robert.hocks@duke-energy.com Robert is a corporate environmental engineer for Duke Energy. He manages various environmental and sustainability projects and programs across the enterprise, most recently focused on Midwest Gas Operations in the Cincinnati and Nashville metro areas. Previously, he has been involved with National Emissions Standards for Hazardous Air Pollutants (NESHAP – MACT) implementation, Acid Rain monitoring programs, New Source Review (NSR) project determinations, evaluation of greenhouse gases emissions and reports, and waste management programs, all leading to compliance and cost reduction. Robert shares responsibility for EPA compliance in air, water and solid waste media at Duke gas operations, projects and gas facilities in the Midwest. He has worked in the environmental field for over 25 years, including employment at corporate, manufacturing/industrial facilities, power generation plants and in consulting. Robert holds a master’s degree in environmental science and engineering from the University of Cincinnati and bachelor’s degree in atmospheric science from the University of Missouri. He holds professional certifications as a Professional Engineer (PE) in Ohio and broadcast meteorologist from the American Meteorological Society (AMS). Robert has been an active A&WMA member in the East Central Section since starting his environmental career and is currently Vice Chair in the Southwest Ohio Chapter. He has presented papers, presentations and participated in voluntary efforts in support of the A&WMA. Brian M. Otten, Consultant, Trinity Consultants 1717 Dixie Hwy, Suite 900, Covington, Kentucky 41011 botten@trinityconsultants.com Brian M. Otten, Consultant, is currently employed with Trinity Consultants residing in the Covington, KY office location. He has worked with numerous industrial clients in Kentucky, the Greater Cincinnati Area, and supports other Trinity offices in providing service to industrial clients across the U.S. He is proficient in dispersion modeling and has used many of the options in AERMOD as well as other models like the BLP Model for characterizing coke ovens and rooftop vents for aluminum smelters. Prior experience includes air dispersion modeling, air quality permitting, and emission characterization for electric power generation, the mineral products industry, oil & gas refining, and various other manufacturing facilities. He also assists clients in regulatory reporting (e.g toxic release emission inventory (TRI) and annual compliance certification), facility-wide emission inventories, and regulatory applicability determinations. Brian as a degree in Environmental Engineering from Purdue University.

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Workshop F - Air Permitting … Impact of Modeling Emission Rates for Precursors (MERPS)

  • n Permitting of PM2.5, NOx & VOC Sources

March 27, 2018 9:45 – 11:00 AM Cincinnati Convention Center

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Presenters

George Schewe Trinity Covington Brian Otten Trinity Covington Robert Hocks Duke Cincinnati Chris Beekman OEPA Columbus

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Agenda for Workshop F

˃ George – overview of MERPS ˃ Chris – MERPs, PS

D in Ohio

˃ Discussion break ˃ Brian Otten – Example applications of

MERPs

˃ Robert Hocks – MERPs at Duke ˃ Roundtable discussion of MERPS

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Outline

˃ S

chewe – MERPs, basis, current guidance

˃ Cordes – tiered approach, Kentucky’s

guidance

˃ Otten – example applications

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S

  • what are MERPs?

George S chewe Trinity Consultants

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Introduction - Definition

MERP = Modeled Emission Rates for Precursors

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So What is a Precursor?

˃ S

  • me pollutants are “ primary” meaning

they are directly emitted by sources to the atmosphere

˃ S

  • me pollutants are “ secondary” meaning

they are not emitted directly but form in the atmosphere either chemically or mechanically

˃ “ Precursors” are primary pollutants that

convert to secondary pollutants

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Sources of Air Pollution

PM2.5, PM10

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Precursors of Interest

˃ S

O2 converts to sulfates – a particulate

˃ NO2 converts to nitrates – a particulate

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

˃ NO2 involved in the ozone generation

process

˃ VOCs involved in the ozone generation

process

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How are Precursors Used?

˃ If the emissions from a new or modified source

represent a level of increased precursor emissions that are not expected to contribute to significant levels of ozone or PM2.5 then no further analysis required

˃ These levels of precursor emissions are called

the De Minimis Levels below which no modeling

  • r detailed qualitative assessment is needed
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So Let’s Talk About What MERPs Apply to

˃ Particulates – especially PM2.5 ˃ Ozone – O3 ˃ What’s the big deal? ˃ Why look at these pollutants?

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PM2.5 –A Breakdown

˃

PM2.5 = Particulate Matter < 2.5 µm

“ Primary” PM2.5 emissions

Directly emitted as PM2.5

Includes filterable and condensable

“ S econdary” PM2.5 emissions

♦ NOX + S

O2 emitted as precursors

♦ React atmospherically to form particulate

Source: Particulate Matter Science for Policy Makers – A NARSTO Assessment, 2003.

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Contributions to Ambient PM2.5 Samples

From: The Particle Pollution Report ‐ https://www.epa.gov/sites/production/files/2017‐ 11/documents/pp_report_2003.pdf

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Ozone - Well its not all bad!

˃ Good ozone - S

tratospheric Ozone –

S hields the Earth’s surface from the S un's UV Light

https://uag‐earthsci.blogspot.com/2017/11/day‐038‐giftionary‐ozone‐layer.html

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Ozone - Well some is bad

˃ Ground Level Ozone – a NAAQS

because at certain concentrations in the air, it is unhealthy

˃ Not emitted directly into the atmosphere –

it is generated from combinations of:

˃ Oxygen ˃ Nitrogen compounds (precursor) ˃ Volatile organic compounds (precursor)

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Health Effects

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The Whole O3 Process in the Lower Atmosphere

http://wbrc.typepad.com/.a/6a0133f1918702970b016766b9cc96970b‐pi

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What Guidance Do We Have? EPA Guidance on Single Source Analysis

˃

05/ 2014: Guidance for PM2.5 Permit Modeling

˃

12/ 2016:

 Final Appendix W  Draft MERPs Guidance  S

ingle S

  • urce O3 and

PM2.5 Modeling Guidance

˃

08/ 2017: Clarification Memo

  • n PGM for NAAQS

& Regional Haze

˃

EP A Desires Final MERPs Guidance Issued in Mid-2018

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Section 5 of Final Appendix W:

Models for O3 & Secondary PM2.5

˃ Background

 S

ierra Club petition was the key driver

 Former Appendix W provided little to no

guidance about assessing single source secondary impacts for Ozone and PM2.5

˃ No preferred model or technique yet

 Goal was to offer flexibility

˃ Recommends two-tiered approach with

detailed guidance documents

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Appendix W, MERPs, and PSD

Christopher P. Beekman Ohio EPA Division of Air Pollution Control

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Revised Appendix W

  • Appendix W to 40 CFR Part 51
  • Proposed 7/14/2015, finalized 1/17/2017
  • Opens possibility of full CTM* assessments

–PSD projects only –Expected to be limited to small number –Provides very loose guidance on alternatives

*Chemical transport model/photochemical model

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Single‐Source Photochemical Modeling

  • Appendix W solidifies that some sources may require

photochemical modeling for secondary PM2.5 and O3

  • Prior to this, applicants could utilize existing data to conduct

semi‐quantitative analyses of formation under loose guidance

  • U.S. EPA contemplates a 2‐Tier approach to PM2.5 and O3

formation analyses

  • OEPA has repeatedly stated that single‐source photochemical

modeling is not appropriate

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2‐Tier Approach

Use Technically Credible Existing Information to Demonstrate Secondary Impacts are Insignificant Photochemical Transport Modeling Tremendous jump in complexity, resources needed, and expertise

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Tier 1: Existing Technical Info

  • Appendix W is “hazy” on the topic
  • U.S. EPA more forthcoming face‐to‐face: old

methods still viable

  • Goal: demonstrate project’s primary +

secondary impacts do not exceed NAAQS or increment

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Tier 1: Existing Technical Info The Old Way

  • Regional inventory and monitor analysis

–Demonstrate that project is small relative to regional inventory –Demonstrate additional safety margin at monitor(s)

  • Relationships between emissions and impacts

–Past CTM results (LADCO Round 4) –X increase in VOC  Y increase in O3

  • Reduced‐form models as Tier 1b?
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MERPs as a Tier 1 Tool

  • Modeled Emissions Rates for Precursors
  • U.S. EPA work product based on

photochemical modeling (Draft Guidance)

  • MERPs describe a level of precursor emissions

that are not expected to cause a significant change in secondary O3 or PM2.5

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When to Assess Formation: Now

Guidance for PM2.5 Permit Modeling, May 20, 2014

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When to Assess Formation: Future

Based on 02/28/2018 R5 modeling call regarding pending guidance

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Acceptable Demonstrations

  • Discussion of regional inventory, in context of

historical monitor data and the project

  • Establish relationships between emissions and

impacts based on recent photochemical modeling

  • Demonstrate a margin of safety at monitor(s)
  • Be conservative, consider background and modeled

impacts

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Acceptable Demonstrations

  • Use the MERPs as additional support!

_______________________________________ Modeling of pollutant off‐set ratios:

–Not as widely accepted –OEPA’s less preferred approach –Do not pull directly from NAACA report –More acceptable if area/region specific

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Pending Guidance

  • It is doubtful new guidance will make MERPs

the go‐to

  • Ohio EPA is exploring developing state‐specific

MERPs

–Lengthy process, public input for all stages

  • The guidance will cover Ozone, PM2.5, MERPs,

AERMOD alpha and beta options, and potentially AERSURFACE

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Conclusions

  • Appendix W requires accounting of secondary

formation

  • Possibility of photochemical modeling
  • MERPs are one possible assessment tool
  • MERPs currently provide strong support to secondary

analysis

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Conclusions

  • Secondary Formation  Primary Consideration
  • Use monitor data in the analysis
  • Early engagement is crucial

–Protocol should discuss the technical approach

  • The goal is to demonstrate that project will not cause

issues, not to avoid CTM

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MERP Application Examples Brian Otten Trinity Consultants

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MERPs Examples

˃ S

mall source –Tier 1 Conservative Approach

˃ Large source –Tier 1 Conservative Approach

followed by Tier 1 Refined Approach

˃ Cumulative Impact Analysis ˃ If we fail, what else can we do?

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Most Conservative MERPs by Region

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  • 150 tpy S

O2

  • 100 tpy NOx
  • Neg. VOC

.

. . .

  • MERPs Tier 1 Example: Small Source

Modeled Direct PM2.5 Concentration

24‐hour Annual 0.3 µg/m3 0.1 µg/m3

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0.3

  • 1.2
  • 150

238 100 1,693 0.94 PM2.5 Daily:

  • Result < 1
  • Need Agency approval
  • Additional info?

0.1

  • 0.2
  • 150

839 100 5,496 0.70 PM2.5 Annual:

MERPs Tier 1 Example: Small Source

948 100 126 0.79 1 8 O3:

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MERPs Example: 1,000 MW NGCC

0.3

  • 1.2
  • 42.1

238 240.5 1,693 0.57 PM2.5 Daily: 0.12

  • 0.20
  • 42.1

839 240.5 5,496 0.69 PM2.5 Annual: 101.4 948 240.5 126 2.01 8 O3:

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Factors for MERP Selection

MERP Value Emissions Stack Height Location

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Representative MERP Selection

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Large Source Example

˃ Outline similarity to EP

A ’s hypothetical source: similar source characteristics and

emission rates of precursors that are located in similar atmospheric environments

 Proximity  Terrain & Landuse  Climate  Regional sources of pollutants  Ambient concentrations

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Precursor Area Emissions (tpy) Height Source FIPS State County Max Impact (ppb)

MERP Value NOx EUS

500

H

12 39157

Ohio Tuscarawas

1.35 370

NOx EUS

500

L

12 39157

Ohio Tuscarawas

1.36 368

NOx EUS

1000

H

12 39157

Ohio Tuscarawas

2.44 410

NOx EUS

3000

H

12 39157

Ohio Tuscarawas

4.99 601

VOC EUS

500

H

12 39157

Ohio Tuscarawas

0.17 2,941

VOC EUS

500

L

12 39157

Ohio Tuscarawas

0.18 2,778

VOC EUS

1000

H

12 39157

Ohio Tuscarawas

0.37 2,703

VOC EUS

3000

H

12 39157

Ohio Tuscarawas

1.15 2,609

˃ If the first-pass test fails, Draft Guidance has options ˃ Demonstrate equivalence to modeled source ˃ 4 hypothetical sources located in North Carolina

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MERPs Example: 1,000 MW NGCC

0.3

  • 1.2
  • 42.1

238 240.5 1,693 0.57 PM2.5 Daily: 0.12

  • 0.20
  • 42.1

839 240.5 5,496 0.69 PM2.5 Annual: 101.4 , 240.5

  • 0.68 8

O3:

What if MERPs were already the most representative available?

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MERPs Example: 1,000 MW NGCC

0.3

  • 1.2
  • 42.1

238 240.5 1,693 0.57 PM2.5 Daily: 0.12

  • 0.20
  • 42.1

839 240.5 5,496 0.69 PM2.5 Annual: 101.4 948 240.5 126 2.01 8 O3:

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˃ Ozone

∗

˃ PM2.5

. . ∗ . .

MERPs Example: Cumulative Analysis

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Background Selection

NKU Ozone Monitor 2014-2016 DV 70 ppb

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˃ Ozone

70 101.4 948 240.5 126 ∗ 1.0 71.5 70

MERPs Example: Cumulative Analysis

˃ Ozone

∗

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MERPs – What if facility fails?

˃ Additional values may be determined by states ˃ S

ignificant work to be done to generate MERP thresholds, if not using EP A examples (photochemical modeling)

˃ Range of values by regions within a state and

even stack height

˃ Cumulative Analysis ˃ Alternative Quantitative and Qualitative

Analyses

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S ummary of MERP Applications for Duke Energy S tations Robert J. Hocks, PE Duke Energy

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MERPs –Application to Duke

˃ MERPS

= Modeled Emission Rates for Precursors

˃ Tier I Demonstration for S

econdary Pollutants

 Technically creditable relationships developed

between precursor emissions and ambient impacts based on air quality models

 Emission rate of precursor resulting in an exceedance

  • f S

ignificant Impact Level (S IL) for ambient PM2.5 /

  • Ozone. Note S

ILs will not be finalized until mid-2018.

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MERPs –Application to Duke

˃ Power Plants produce significant PM2.5 precursors as

condensable particulate matter, nitrates and sulfates

Condensable atmospheric formation related to S O2 and NOx gaseous emissions rates

˃ Power Plants also emit significant Ozone (O3) precursors:

NOx and VOC gaseous emissions

˃ MERPs developed/ refined based on modeling analysis ˃ EP

A MERP Analysis utilized Air Quality modeling platform e.g., CAMx, S MOKE emissions data and WRF Meteorology data – EP A performed simulations analysis over Cont. US

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MERPs –Application to Duke

˃ Ambient PM2.5 increases noted with both NOx increases

and with ambient NH4 (ammonia) concentrations

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MERPs –Application to Duke

˃ Eastern US

Power S tation modification:

 EGU–

Electric Generating Unit modification

 MERPs Tier I: ~500, 1000, 3000 tpy hypothetical

increases of NOx, S O2 and VOC.

 Hypothetical stack parameter used 90m

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MERPs –Application to Duke

˃ Eastern US

domain was used in this example

˃ S

tate applied worst- case MERP analysis.

˃ Note nearby station

located in Ashe Co., North Carolina

˃ We then applied EUS

station specific values

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MERPs –Application to Duke

˃ Carolina S

team S tation, NC – 2017 Modification - Natural Gas firing capability added on two EGUs – Unit 5 (up to 40% ) and 6 (up to 100% )

PM2.5 primary < 10 tpy, S econdary PM2.5 S O2/ NOx < 40 tpy

Ozone precursors analysis conducted: Proj ect NOx: 17.6 tpy increase insignificant, VOC: 124 tpy increase was significant

˃ S

tate assumed linear relationship between modeled VOC emissions and predicted ozone concentration impacts from Eastern U.S . modeling

Proj ect VOC emissions conservatively expected to increase 8-hour ozone concentrations by, at most, 0.1 ppb

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MERPs –Application to Duke

˃ Therefore, based on available photochemical modeling for

the proj ect area, the state determined VOC emissions expected to have negligible impacts on ozone such that further refined modeling analysis was not required.

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MERPs –Application to Duke

˃ Carolina Modification: NOx = 17.6 tpy, VOC = 124 tpy ˃ S

pecifically, if considering both NOx/ VOC contributions at nearest EP A-modeled station in Eastern US , Ashe County, North Carolina:

O3: 124 16,667 17.6

  • 100 7.3% 8
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Summary & What’s Next?

˃ EP

A photochemical modeling (PGM) of very large sources resulted in small impacts

˃ Despite emphasis on PGM in guidance,

EP A is giving alternatives to avoid

˃ Multiple ways to avoid PGM even if MERPs

exceeded

˃ Final S

IL guidance at OMB; expected mid- 2018; final MERP guidance after

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Questions?

George J. S chewe, CCM, QEP gschewe@ trinityconsultants.com Ben Cordes ben.cordes@ ky.gov Brian M. Otten botten@ trinityconsultants.com