Federal Requirements for PM-2.5 Emissions and Anticipated Changes - - PowerPoint PPT Presentation

New Jersey Department of Environmental Protection Air Quality Permitting Program

Ketan Bhandutia, Rule Manager December 18, 2012

Federal Requirements for PM-2.5 Emissions and Anticipated Changes to NJ Rules

1

Nine Proposals

• 1. Identify SO2 as a precursor of PM-2.5
• Federal Rule

(40 CFR 51, Appendix S.II.A.31(iii)(b) and P/28327 of 5/16/08 FR)

• SO2 is a precursor of PM-2.5
• SO2 undergo chemical reactions to form PM
• Sulfate is a significant component of the national

PM-2.5 concentrations ranging up to 40%

2

• 1. Identify SO2 as a precursor of PM-2.5

(Contd.)

• NJDEP Proposal

(N.J.A.C. 7:27-8.1, 18.1, 21.1 and 22.1)

• Regulate SO2 as a PM-2.5 precursor
• Revise definition of SO2 to state SO2 is a

precursor of PM-2.5

3

• 2. Identify NOx as a precursor of PM-2.5
• Federal Rule

(P/28328 & 28343 of 5/16/08 FR and 40 CFR 51.165(a)(1)(xxxvii)

• NOx are precursors to PM-2.5 (unless the State

demonstrates to EPA that NOx from sources in specific area are not a significant contributor to that area’s ambient PM-2.5 concentrations)

• NOx undergo chemical reactions to form PM
• NOx are significant component of national PM-2.5

concentrations ranging up to 40%

• 4

• 2. Identify NOx as a precursor of PM-2.5

(Contd.)

• NJDEP Proposal

(N.J.A.C. 7:27-8.1, 18.1, 21.1 and 22.1)

• Revise definition of NOx to regulate NOx as

PM-2.5 precursor

• NJ’s PM-2.5 monitoring data speciation shows

nitrates range approx. from 10% to 14% of the PM- 2.5 mass

• NOx is more important in urban areas and during

winter months. Also, nitrates could increase as we reduce sulfates (MANE-VU research)

5

• 3. Define PM-2.5
• Federal Rule

(40 CFR Part 51, Appendix S.II.A.31 and 5/16/08 FR P/28321 and P/28327-8)

• PM-2.5 is regulated under the definition of “Regulated

NSR pollutant”

• PM-2.5 is not defined separately
• PM-2.5 is referred as particles with an aerodynamic

diameter less than or equal to a nominal 2.5 micrometers and SO2 and NOx are precursors

6

• 3. Define PM-2.5 (Contd.)
• NJDEP Proposal

(N.J.A.C. 7:27-8.1, 18.1, and 22.1)

• “PM-2.5” means a class of air contaminants which

includes all particulate matter having an aerodynamic diameter less than or equal to a nominal 2.5 microns, including condensable particulate matter, as measured using EPA Method 201A and EPA Method 202”

• Revise the current definition of “PM-2.5” in Sub-21 for

consistency

7

• 4. Specify “Major Source” Thresholds

Federal Rule

40 CFR 51, Appendix S II.A.4(i)(a)

NJDEP Proposal

N.J.A.C. 7:27-18.2

PM-2.5 100 TPY 100 TPY SO2

(as PM-2.5 precursor)

100 TPY 100 TPY NOx

(as PM-2.5 precursor)

100 TPY 100 TPY (*)

(*):

NOx are also regulated as precursor for ozone. “Major Source” threshold for NOx as a precursor for ozone is 25 TPY under N.J.A.C. 7:27-18.2

8

• 5. Specify “Modification” Triggers

Federal Rule

40 CFR 51, Appendix S II.A.10(i) & p/28333 of 5/16/08 FR

NJDEP Proposal

N.J.A.C. 7:27-18.7

PM-2.5 10 TPY 10 TPY SO2

(as PM-2.5 precursor)

40 TPY 40 TPY NOx

(as PM-2.5 precursor)

40 TPY 40 TPY (*)

(*):

“Modification” trigger for NOx as a precursor for

• zone is 25 TPY under N.J.A.C. 7:27-18.7. When

NOx offsets are triggered for both ozone and PM- 2.5, NJ revised rules would require NOx offsets only

• nce-

whichever is more stringent.

9

• 6. Specify “Significant Impact Levels (SILs)

Federal Rule

40 CFR 51, Appendix S III.A.

NJDEP Proposal

N.J.A.C. 7:27-18.4

PM-2.5

0.3 ug/m3 (Annual) 1.2 ug/m3 (24-hour) 0.3 ug/m3 (Annual) 1.2 ug/m3 (24-hour)

SO2

(as PM-2.5 precursor)

None (*) None (*)

NOx

(as PM-2.5 precursor)

None (*) None (*)

(*):

USEPA approved models are available for direct SO2 and NOx emissions only, not for conversions

Triggers for multi-source modeling to determine Attainment/NA

10

• 7. Specify Emissions Offset Ratios

(Creditable emissions reductions to offset emission increases from a project)

Federal Rule

40 CFR 51, Appendix S IV.G and May 16, 2008Federal Register (p/28338)

(Reductions: Increase)

NJDEP Proposal

N.J.A.C. 7:27-18.5(c) (Reductions: Increase)

PM-2.5

Minimum 1:1 Minimum 1:1

SO2

(as PM-2.5 precursor)

Minimum 1:1 Minimum 1:1 (*)

NOx

(as PM-2.5 precursor)

Minimum 1:1 Minimum 1.3:1.0 (**)

11

(*):

Minimum Ratio of 1:1 for SO2 specified in current N.J.A.C. 7:27- 18.5(c) would remain unchanged (**): Minimum Ratio of 1.3:1.0 for NOx specified in current N.J.A.C. 7:27-18.5(c) would remain unchanged

• 8. Inter-pollutant offsets (New Provision)
• Federal Rule:

(40 CFR Part 51 Appendix S.IV.G.5 and 5/16/08 FR, P/28339)

• Facilities can offset emission increases of PM-2.5

and its precursors with reductions of either PM-2.5

• r its precursors

i.e. facility can increase PM-2.5 emissions by x tons in exchange for reducing SO2 emissions by y tons and/or reducing NOx by z tons

• 40:1 (SO2:PM-2.5) and 200:1 (NOx:PM-2.5) are in

the preamble. EPA did not codify these ratios. These default ratios became a subject to a reconsideration

12

• 8. Inter-pollutant offsets (New Provision)

(Contd.)

• Federal Rule:
• On 7/21/11, EPA issued a policy memo, which

prohibits use of the default ratios

• The federal rule allows inter-pollutant offsets on a

case-by-case basis or a statewide basis in a regional multi-state program. EPA memo requires technical demonstration of net air quality benefits

13

• 8. Inter-pollutant offsets (New Provision)

(Contd.)

• NJDEP Proposal

(New Provision at N.J.A.C. 7:27-18.11)

• Emission offset requirements for PM-2.5 emissions
• r emissions of precursors of PM-2.5 may be

satisfied by offsetting reduction of PM-2.5 emissions or emissions of any PM-2.5 precursor

• For such inter-pollutant offsets, applicant shall

submit a technical demonstration showing net air quality benefits

• The Department shall approve such inter-pollutant
• ffsets on case-by-case basis

14

• 9. Expanding Geographical Limit for Offsets Transfer

(Discussion Item)

• Federal Rule

(CAA Section 173(C)(1) and 40 CFR Part 51, Appendix S, IV.D)

• Offsets can be obtained from the same non-

attainment area as the facility or from another non-attainment area with an equal or higher classification

• Reductions committed to must be enforceable by

the neighboring State and or local agencies

15

• 9. Expanding Geographical Limit for Offsets Transfer

(Discussion Item)

• NJ Offset Options

(1) Encourage EPA to allow offsets from any state that contributes to New Jersey non-attainment area (Note: This option would require federal rule revision) (2) New Jersey develops MOUs with neighboring

• states. The current provisions allow offsets

transfer between New Jersey and neighboring states located in the same AQCR

16