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

New Jersey Department of Environmental Protection Air Quality Permitting Program Federal Requirements for PM-2.5 Emissions and Anticipated Changes to NJ Rules Nine Proposals Ketan Bhandutia, Rule Manager December 18, 2012 1

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 NJDEP Proposal Federal Rule 40 CFR 51, Appendix S II.A.4(i)(a) 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 NJDEP Proposal Federal Rule 40 CFR 51, Appendix S II.A.10(i) N.J.A.C. 7:27-18.7 & p/28333 of 5/16/08 FR 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 (*): ozone 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 9 once- whichever is more stringent.

6. Specify “Significant Impact Levels (SILs) Triggers for multi-source modeling to determine Attainment/NA NJDEP Proposal Federal Rule 40 CFR 51, Appendix S III.A. N.J.A.C. 7:27-18.4 PM-2.5 0.3 ug/m 3 (Annual) 0.3 ug/m 3 (Annual) 1.2 ug/m 3 (24-hour) 1.2 ug/m 3 (24-hour) SO2 None (*) None (*) (as PM-2.5 precursor) NOx None (*) None (*) (as PM-2.5 precursor) USEPA approved models are available for direct SO2 (*): and NOx emissions only, not for conversions 10

7. Specify Emissions Offset Ratios (Creditable emissions reductions to offset emission increases from a project) Federal Rule NJDEP Proposal 40 CFR 51, Appendix S IV.G N.J.A.C. 7:27-18.5(c) and May 16, 2008Federal Register (p/28338) (Reductions: Increase) (Reductions: Increase) PM-2.5 Minimum 1:1 Minimum 1:1 SO2 Minimum 1:1 Minimum 1:1 (*) (as PM-2.5 precursor) NOx Minimum 1:1 Minimum 1.3:1.0 (**) (as PM-2.5 precursor) 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 11

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 or 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 or 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 offsets 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