implications of proposed ozone standards in southeast missouri (sem) smrpc meeting, perryville, mo...
TRANSCRIPT
Implications of Proposed Ozone Standards in Southeast Missouri
(SEM)SMRPC Meeting, Perryville, MO
April 24, 2015
Joletta Golik
Overview
˃ Proposed O3 NAAQS
˃ Implication of Proposed O3 NAAQS˃ Nonattainment Permitting
Proposed Ozone NAAQS
EPA’s Proposed November 25, 2014 Rule˃ Propose to lower the primary and secondary
NAAQS to within the range of 65 to 70 ppb˃ Add an Appendix U to 40 CFR Part 50 detailing
data selection, handling, and reporting requirements for ozone NAAQS – For MDNR
˃ Revise ambient monitoring requirements for ozone monitoring
˃ Add a grandfathering provision to PSD permitting program exempting pending permits from the revised ozone NAAQS when they are fully promulgated
Proposed Revisions to Ozone NAAQS
˃ Proposed grandfathering provision for pending PSD permits˃ Timing is critical here˃ More
˃ Change the Air Quality Index so that the primary NAAQS equals 100 on the index
Proposed O3 NAAQS SEM Attainment Status
˃ Based on 2012-2014 monitoring data, counties in southeast Missouri maybe designated as nonattainment areas
˃ Nonattainment classification depends on final O3 standards Marginal Moderate
What are the Implications of an Area Being Declared Nonattainment?
Definition of Major Source˃ The definition of a “major stationary source”
changes depending on the classification of the nonattainment area – in the case of the example provided for an ozone nonattainment area 100 tpy – marginal or moderate nonattainment for
ozone 50 tpy – serious nonattainment for ozone 25 tpy – severe nonattainment for ozone 10 tpy – extreme nonattainment for ozone Classification dependent on the level of the monitored
design value of the area over the standard “major stationary source” applies to both New Source
Review (NSR) and Title V connotations
http://www.epa.gov/oaqps001/greenbk/define.html
Key Requirements
1. Lowest Achievable Emission Rate (LAER)
2. Obtain emissions offsets
3. Alternatives Analysis Sites, sizes, production
processes, and environmental control techniques
4. All major sources in state must be in compliance with all applicable emission limitations and standards
PSD NA-NSR*1. Control Device Review
(BACT)2. Air Quality Review
NAAQS analysis PSD increment analysis
4. Class I Areas5. Additional Impacts
Analysis Growth Visibility Soils, Vegetation,
Animals
* Federal NA-NSR program is presented. State NA-NSR programs are established in state SIPs and may contain major differences. It is important to review state NA-NSR program!
The Takeaways!
˃ Nonattainment Designation More stringent state regulations likely for major sources NSR/Title V Major source threshold lower in
nonattainment areas Nonattainment New Source Review permitting can be
challenging Nonattainment designations tend to impact industrial
growth in the designated nonattainment area ♦ A new source wishing to construct a facility within a nonattainment
area with a potential to emit of 80 tpy of NOX and 70 tpy of VOC would be required to undergo nonattainment NSR for NOX and VOC. Outside of this nonattainment area, the site would be a true minor source of emissions.
Implications of Proposed Ozone NAAQS
2014 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036
Attainment Year - All NAA
10/1/2037Attainment Year - Serious NAA10/1/2026
Attainment Year - Moderate NAA10/1/2023
Attainment Plans10/1/2020
Attainment Year - Marginal NAA10/1/2020
SIP Infrastructure Setup10/1/2018
EPA Finalize Area Designations10/1/2017
State and Tribe Recommendation for Area Designations10/1/2016
Final NAAQS Rule10/1/2015
Proposed Rule11/25/2014
Non Attainment New Source Review
PSD – Grandfathered or Complicated
PSD – 2008 NAAQS
Proposed Rule Timeline
PSD Review before October 2015
˃ Required when Project VOC emissions > 100 tpy
And\Or Project NOX emissions > 100 tpy
˃ Quantitative Demonstration˃ Qualitative Demonstration
PSD Review after October 2015 before October 2017 (1 of 2)
˃ PSD Grandfathering - PSD permit application “in the pipeline” &
“meeting certain criteria” would be only required to consider its impact on 2008 NAAQS
No clear “criteria” provided by EPA, instead seeking public comments on appropriate criteria for grandfathering
˃ Till then Qualitative Analysis Quantitative Analysis
PSD Review after October 2015 before October 2017 (2 of 2)
˃ Main Purpose of the Analysis To demonstrate net improvement
increase in the overall air quality in the area
Analysis of project’s potential impact on the overall air quality in the area
Comparison of project impact to screening thresholds\ de-minimis values
Non Attainment New Source Review after October 2017
˃ No Ozone Impact Analysis required˃ Must procure\make available
emission offsets for precursor emissions (VOC & NOX) to improve air quality
˃ May have to show improvement in air quality using quantitative assessment
Other Nonattainment Area Implications (1 of 2)˃ Nonattainment New Source Review (NANSR)
Permitting Applicable to new major sources or major modifications
in nonattainment areas Functionally similar to PSD permitting in some aspects.
However, more challenging requirements including but not limited to;♦ LAER♦ Emissions Offsets
Unlike PSD, NNSR is evaluated solely on a pollutant-by-pollutant basis for source classification and review of modifications♦ Major for one regulated NSR pollutant does not make a source
major for all♦ Exceeding major source threshold (MST) does not reduce threshold
for other pollutants to Significant Emission Rate (SER)http://www.epa.gov/nsr/naa.html
Other Nonattainment Area Implications (2 of 2)˃ Nonattainment New Source Review (NANSR)
Permitting LAER – Lowest Achievable Emission Rate
♦ The most stringent emission limitation contained in the implementation plan of any State for such class or category of source; or
♦ The most stringent emission limitation achieved in practice by such class or category of source.
♦ LAER is not a technology but an emission rate that can be achieved by any/all of add-on control technology, process changes or changes in raw materials or it can be a work practice
Emission Offsets♦ “Obtained” (through purchase!) from existing sources located within the
same nonattainment area region which must offset the emissions increase from the new or modified source and provided a net air quality benefit.
♦ Offsets obtained from Emission Reduction Credits (ERCs). Credits, in tpy, obtained at an offset ratio (i.e. 1.3 to 1) to provide a net air quality benefit.
http://www.epa.gov/nsr/naa.html
Lowest Achievable Emission Rate (LAER)˃ No allowance for economic analysis˃ Costs associated with installing and operating the
controls for LAER can be significant “without consideration of cost”
˃ Might require additional monitoring requirements “Continuous Emissions Monitors (CEMS)” Combustion temperature, pressure drop, etc
˃ These devices can have excessive repair and maintenance (due to excessive plugging and corrosion)
˃ Analyze and submit quarterly data quality reports˃ Increased operational cost to demonstrate
compliance
Example LAER Determinations˃ Source
http://cfpub.epa.gov/RBLC/
Source Pollutant LAER ControlHeaters/Boilers NOX Ultra Low-NOx Burner
Gas Turbine NOX Selective Catalytic ReductionPaint Spray Booth VOC Carbon Adsorber
Tanks VOC Proper design and operation of tanks (0.76 lbs/hr)
Diesel Engines NOX
Design and limiting non-emergency operations to only
100 hr/yr each.
Emission Offsets
˃ These are emission reduction credits
˃ A facility in serious NAA for O3 with a PTE of VOC for 50 tpy may be required to obtain 60 tpy of VOC emission reduction credits (60/50 = 1.2)
Nonattainment Classification
Major Source Threshold (tons/year)
Offset Ratio
Marginal 100 1.1 - 1Moderate 100 1.15 - 1
Serious 50 1.2 - 1Severe 25 1.3 - 1
Extreme 10 1.5 - 1
Emission Reduction Credits
˃ Emission reduction credits (ERCs) must be: Real Permanent Quantifiable Enforceable Surplus
˃ Emission reduction credits must have occurred within ten years of application for the proposed project
˃ From the same nonattainment areas (unless otherwise approved)
˃ Generally the same pollutant credits are valid (unless a precursor or the SIP allows for inter-pollutant offsets
Impact on Title V Permitting˃ Previous minor sources could
become major Title V sources depending on designation
˃ Title V facilities in NAA require Additional compliance assurance
and periodic monitoring Source testing, monitoring,
recordkeeping and reporting˃ Understanding applicable
emission standards, operation practices, monitoring/testing, recordkeeping and reporting requirements
˃ Develop a system for tracking and reporting compliance
Nonattainment Classification
Major Source
Threshold for NOX
(tpy)
Major Source
Threshold for VOC
(tpy)
Marginal 100 100Moderate 100 100
Serious 50 50Severe 25 25
Extreme 10 10
Impact on Title V facilities – Examples of CAM
Control Technology Pollutant Example CAM Strategy Frequency Recording
Method
Fabric Filter Baghouse PM Pressure drop
across the device Each batch Datalogger or logbook
Flare CO Visual presence of flame
Twice per shift Logbook
Carbon Adsorption System VOCs Time since last
generation Continuous Strip chart
Things To Do for Industry˃ Calculate current site wide PTE to see the impact
on any potential projects˃ Permitting Strategy
Apply for PSD permits as soon as possible Understand redesignation with regard to RACT, NSR
permitting and Title V permitting and begin to plan accordingly
˃ Reduce emissions of precursors for O3 (i.e., NOX and VOC)
˃ Understand ozone trends in your area˃ NAA Preparation – Quantitative net air quality
benefit analysis
Potential Impacts˃ Business and economic business development concerns˃ Direct and indirect costs to both public and businesses˃ More stringent and expensive control equipment
Burners, boilers and heavy engines Painting, coating and solvent uses
˃ Vehicle inspection program˃ Reduced speed limits on highways and expressways˃ May impact energy costs from power plants due to
control devices installed on their end˃ A public education campaign about ozone˃ Cost of establishing SIP˃ Cost of Transport Conformity
Things To Do for Community to Reduce O3 Emissions in Summer
˃ Keep vehicle tires properly inflated as under inflated tires increase gasoline consumption
˃ Carpooling, public transportation, bike or walk
˃ No overfilling of gasoline by stopping at first click when filling up gas tanks
˃ Not use gas-powered lawn mowers on hot, sunny days
˃ Conserve energy by turning off lights and appliances when not in use
http://blogs.mo.gov/env/2011/08/02/help-fight-ozone-this-summer/
