The New NAAQS EPA has promulgated a plethora of new NAAQS Ozone - - PDF document

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The New NAAQS EPA has promulgated a plethora of new NAAQS Ozone - - PDF document

Jun 03, 2023 264 likes •408 views

Results you can rely on Wisconsin Manufacturers & Commerce: Federal Air Regulations Update Gale F. Hoffnagle, CCM, QEP Air Quality Consulting Practice Leader TRC Companies, Inc. The New NAAQS EPA has promulgated a plethora of new

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Results you can rely on

Wisconsin Manufacturers & Commerce: Federal Air Regulations Update

Gale F. Hoffnagle, CCM, QEP Air Quality Consulting Practice Leader TRC Companies, Inc.

Results you can rely on

The New NAAQS

  • EPA has promulgated a plethora of new NAAQS

– Ozone (2008) (2013?) 8 Hour Average – PM2.5 (2006) Reduced 24 Hour Average (2013) Reduced Annual Average – Sulfur Dioxide (2010) 1 Hour Average – Nitrogen Dioxide (2010) 1 Hour Average – Lead (2008) Quarterly Average These combined make existing and new sources subject to tremendous pressure on emissions.

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Results you can rely on

2008 Ozone NAAQS

  • Current ozone marginal Non-Attainment for Ozone
  • Kenosha and Sheboygan
  • Met 1997 NAAQS

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Results you can rely on

Non-attainment Schedule

  • Final NAAQS

` 2008

  • Final Designations

2012

  • Attainment SIPs Due

2015

  • Attainment Date:

2015

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Results you can rely on

Designations Expected for 2013 Ozone NAAQS

2012 2013

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Results you can rely on

PM2.5 2006 NAAQS

  • Non-Attainment for Milwaukee, Racine and Waukesha

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Results you can rely on

PM2.5 2012 NAAQS

  • 2010-2012 Design Values

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Results you can rely on

PM2.5 2012 NAAQS

Non-attainment Schedule

  • Final Rule December 2012
  • State NAA Designation Recommendation to EPA

December 2013

  • Final EPA Designations December 2014
  • Attainment Demonstration SIPs Due

2016

  • Attainment Date 2020

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Results you can rely on

NO2 NAAQS

  • New NAAQS is 188 µg/m3(or 100ppb) but for a 1 hour
  • average. Depending upon the meteorology of the site

this results in a 6.6 times lower threshold to meet. It therefore will be substantially harder to meet.

  • EPA has provided Guidance that you combine the 98%

background from monitored data with the 98% modeled result, making compliance much harder. This is equivalent to a 99.995% chance that the observed will be less than the predicted.

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Results you can rely on

NO2 NAAQS

  • Focus of NAAQS is people living adjacent to roadways
  • States are supposed to add monitoring to areas near

roadways (Interstate Highways)

  • Chances of violations near roadways very high
  • Non-attainment near such monitors could ensnare

nearby industrial sources

  • Monitoring near industrial facilities advisable to

establish compliance and, if necessary, actual background concentrations.

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Results you can rely on

NO2 NAAQS Other Modeling Issues

  • What is the NO2/NOx ratio exiting the stack
  • Interim Significant Impact Limit (SIL) of 4 ppb (7.53

µg/m3)

  • No increments, monitoring limits (monitoring may be

required), etc.

  • EPA has changed lowest wind speed allowable in

model and doubles the worst case concentrations

  • EPA changed model to calculate downwash for GEP

stacks

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Results you can rely on

NO2 NAAQS “Guidance”

  • Guidance: June 28, 2010, June 29, 2010 and March 1,

2011 – Issue of what is Nitrogen Dioxide (NO2) and subject to the NAAQS and what is Nitrous Oxide (NO) and not subject to the NAAQS – Memo describes a three Tier approach

  • Tier 1: Assume it is all NO2
  • Tier 2: Assume that NO2/NOx ratio is .80
  • Tier 3: Use 1979 Ozone Limiting Method or PVMRM as

detailed screening technique. Calculates that NOx is converted to NO2 based on the concentration of ozone. Methods already in AERMOD not acceptable. Assume 50% of what exits stack is NO2.

  • Tier 3 requires case-by-case determinations (database)

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Results you can rely on

HOURLY NO2/NOx Ratio

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Results you can rely on

SO2 NAAQS

  • New primary NAAQS of 196 µg/m3 (75 ppb) as a 1

Hour average results in a 7.7 times more restrictive

  • standard. New standard is 99% over three years.
  • EPA has provided Guidance that you combine the 98%

background from monitored data with the 98% modeled result, making compliance much harder. This is equivalent to a 99.995% chance that the observed will be less than the predicted.

  • Focus of attainment demonstrations to be on

modeling, which is a continuation of past policy with enhanced use.

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Results you can rely on

SO2 NAAQS

  • DRAFT Guidance issued for comment in July

– Methods to model compliance – Methods to measure compliance – Final Guidance not issued – EPA not approving monitoring protocols until guidance final.

  • Will States do more SO2 monitoring?
  • Interim SIL: 3 ppb (7.84 µg/m3)

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Results you can rely on

SO2 NAAQS Designation Process

  • Oneida County

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Results you can rely on

Oneida Non-Attainment Sources

  • Wausau Paper Mills, LLC

3128 TPY

  • Red Arrow Foods

4.5 TPY

  • Packaging Corp. of America

4641 TPY

  • Final NAAQS

June 2010

  • Final Designations

July 2013

  • Attainment Demonstration SIPs Due

2015

  • Attainment Date

2018

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Results you can rely on

EPA Working Group Results

  • For NO2 (no background added):

– Steel Mill 3.2 times NAAQS – Ethanol Plant 12.9 times NAAQS – Natural Gas Turbine 4 times NAAQS – Coal Power Plant 2.4 times NAAQS – Refinery 1.9 times NAAQS – Fuel Oil Turbine 4.8 times NAAQS – Asphalt Plant 4.7 times NAAQS – Natural gas Compressor 16.7 times NAAQS – Biomass facility, Landfill gas turbine passed

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Results you can rely on

EPA Working Group Results

  • For SO2 (no background added):

– Ethanol Plant 2.9 times NAAQS – Pulp and Paper 4.7 times NAAQS – Coal Power Plant 4.6 times NAAQS – Fuel Oil Turbine 1.3 times NAAQS – Flare 1.7 times NAAQS – Refinery 1.4 times NAAQS – Asphalt Plant 19.3 times NAAQS – Cement kiln and landfill gas passed!

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Results you can rely on

Usual Practices

  • Increase stacks or plume rise
  • Stratify multiple stacks
  • Include other control regulations that must be met
  • Buy and fence more land
  • Keep impacts below the SIL
  • Evaluate meteorological data representativeness
  • Evaluate ambient data representativeness
  • Propose to use EMVAP (variable emissions)
  • Change building design
  • Urban version of model

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Results you can rely on

Best Practices NAAQS

Day (yyyymmd d) Max Daily 1-hour Conc (ppb) Count of valid hourly values for this day Rank 20130322 99.4 24 1 20130211 44.4 21 2 20130202 42.7 23 3 20130316 36.1 24 4 20130223 30.2 23 5 20130117 29.0 24 6 20130208 27.5 23 7 20130213 26.9 23 8 20130212 26.4 23 9 20130119 25.4 24 10

Example of Detailed Monitoring Data Analysis

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Results you can rely on

Evaluations for PM2.5

  • Problem is meeting annual average NAAQS
  • Must know what your PM2.5 direct emissions are
  • Must have monitoring data close by to establish

background and your contributions to that monitor

  • Must identify other sources and their impacts
  • May be required to perform modeling for the chemical

formation of particles in the air after emission due to sulfur oxides, nitrogen oxides and possibly organic vapors and ammonia emissions (secondary formation).

  • Take advantage of the draft guidance to use the 8th

highest value in 5 years when evaluating 24 hour average.

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Results you can rely on

Modeling for PM2.5 Secondary Formation

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CASE PM2.5 NOx &SO2 Direct Secondary

Emissions Emissions

  • 1

<10 TPY <40 TPY None None

  • 2

>10 TPY <40 TPY AERMOD None

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>10 TPY >40 TPY AERMOD Chemistry

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<10 TPY >40 TPY None Chemistry

  • Chemistry means either a Qualitative, Hybrid, or full quantitative

photochemical grid modeling.

Results you can rely on

Chemical Modeling for PM2.5

  • Requires application of “academic” atmospheric

chemistry grid models (CAMx or CMAQ). Draft Guidance issued March 25, 2013.

  • New version of CALPUFF with updated chemistry is

not approved by EPA.

  • Modeling is expensive and time consuming especially

when dealing with huge data files.

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Results you can rely on

Ozone

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Results you can rely on

PM2.5

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Results you can rely on

SO2

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Results you can rely on

The Beat Goes On

  • EPA proposed but withdrew secondary standards for

SOx and NOx to protect against acid rain. Environmentalists suing to reinstate proposal.

  • EPA proposed and then withdrew secondary standards

for visibility in urban areas (reduce PM2.5 even more), Environmentalists suing to reinstate proposal.

  • EPA requires SO2 monitors to report 5 minute average

data in anticipation of a 5 minute average NAAQS.

  • Act says to review and revise as necessary NAAQS

every 5 years. Environmentalists sue to ensure that EPA does.

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