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VISTAS BART Modeling: Update, Schedule, Some Decisions

VISTAS BART Modeling: Update, Schedule, Some Decisions. Presented by Sheila Holman NC DAQ VISTAS Air Directors Meeting November 15, 2005. Today …. BART Plan Schedule VISTAS BART Protocol (Almost finalized …) VISTAS Support for BART Modeling

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VISTAS BART Modeling: Update, Schedule, Some Decisions

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  1. VISTAS BART Modeling: Update, Schedule, Some Decisions Presented by Sheila Holman NC DAQ VISTAS Air Directors Meeting November 15, 2005

  2. Today … • BART Plan • Schedule • VISTAS BART Protocol (Almost finalized …) • VISTAS Support for BART Modeling • BART Exemption Modeling (How much can VISTAS do?)

  3. BART Plan • How did Air Directors want VISTAS to help? How could States collaborate on BART? • Training • Common Modeling Protocol • CALMET Fields • Exemption Modeling • Possibly Control Assessment Modeling for BART Determination

  4. VISTAS BART Schedule • Feb/Mar 2004 -- VISTAS drafts BART Protocol • April 2004 -- Issue RFP to enhance Draft Protocol & Conduct BART Modeling • May 2004 – Selected contractor for BART Modeling (Earth Tech) • Summer 2004 – Developed Issue Papers to enhance Protocol • July 2004 – CALPUFF Beginner Training • Sept 2004 – Draft Protocol out for comment after Sept 21 Mtg • October 2004 – Comment Period Ends • November 2004 – VISTAS incorporating comments; discussion of comments at Nov 1 Nashville Meeting • Nov 2004 – CALPUFF Overview Training • End of Nov 2004 – Finalize Protocol • December 2004 – Run CALPUFF forScreening & Demo (VA) • Jan/Feb 2006 – Advanced CALPUFF Training • Jan/March 2006 – Run CALPUFF for BART

  5. VISTAS BART Protocol - Purpose • Provide common modeling protocol for VISTAS States • Outline BART modeling process steps • Outline common CALPUFF configuration • Outline information required for site-specific modeling protocol • Specify VISTAS States’ expectations for products

  6. VISTAS BART Protocol - Modeling • Exemption Modeling to determine whether a BART-eligible source is “subject to BART” • Control Modeling of emissions from sources that have been found to be subject to BART to evaluate regional haze benefits of alternative control options and to document the benefits of the preferred option • Cap & Trade -- will not address modeling to demonstrate the effectiveness of an optional cap and trade program

  7. Comments on VISTAS Protocol • VISTAS BART Protocol comments under review (extensive comments received) • Comments can be viewed on VISTAS website www.vistas-sesarm.org/BART/BARTcomments.asp • EPA Q and A document provides clarification on several policy issues • Protocol discussed at Sept 21 and Nov 1 meetings • Extensive discussions with FLM and EPA • Goal is to finalize protocol by end of Nov

  8. VISTAS Support for BART Modeling • Develop General BART Modeling Protocol • Develop CALMET meteorological fields for 2001-2003 for VISTAS 12-km domain • Develop CALMET fields for 1 or more finer grid subdomains? • Decision based on number, spatial area, grid resolution, cost of subdomains and SCHEDULE; Awaiting estimate from contractor; Assuming adequate resources, recommendation is to proceed with development. • Recommendation: CALPUFF modeling at 12 km for sources with Q/d for SO2 is < or = 10

  9. Map based on 299 sources, as of Oct 14, 274 sources

  10. Is a Source Subject to BART? • How to apply EPA model plant analysis? • EPA intended to exempt sources if SO2+NOx < 500 tons and > 50 km, or < 1000 tons and >100 km. • Only guidance for PM is to use de minimus level (15 TPY) • Sources that meet SO2+NOx threshold but have PM > 15 TPY can’t be exempted without modeling • PM being tested in CMAQ • Most States have indicated they would like to use the model plant approach, if possible

  11. VISTAS Process to Determine if Source is Subject to BART If source agrees it is subject, can skip determination steps Q/d > 10? No Regional 12-km CALPUFF for 2001-2003 Max 24-hrdv > 0.5 Source not subject to BART No Yes Yes Subregional Fine-scale CALPUFF for 2001-2003 Source not subject to BART 98th % 24-hr dv > 0.5 No Yes Source subject to BART, evaluate visibility impacts of controls

  12. If a Source Subject to BART … • Use CALPUFF modeling system to determine if single source is subject to BART • Apply CALPUFF for SO2 + NOx + PM together across all eligible units and compare to 0.5 dv change from natural background • EPA clarified that natural background should be defined as 20% best days (rather than annual average) • VISTAS applying CMAQ to test impact of NH3, VOC, PM to see if contribution

  13. Is a Source Subject to BART? • VISTAS is recommending Q/d as a presumptive indicator that a source is subject to BART • If Q/d for SO2 > than 10 for 2002 actual emissions, then State presumes that source is subject to BART; no exemption modeling required • If source agrees, then proceed to evaluate impacts of control options and perform engineering analyses. • If a source disagrees, may perform either 12 km or fine grid modeling to determine if impact is <0.5 dv • If Q/d for SO2 is < or = 10 (based on 2002 actual SO2 emissions), VISTAS assistance may be available for Earth Tech run CALPUFF

  14. VISTAS BART ELIGIBLE Q/D ANALYSIS

  15. Is a Source Subject to BART? • If visibility impact > 0.5 dv, then source is subject to BART. Proceed to evaluate control options. • For 12-km initial exemption test, use highest single 24-hr average • Use 12 km test to define Class I areas for fine grid analyses • If use fine grid (4 km or less), use 98th percentile value • Use either the 8th highest day in each year or the 22nd highest day in 3 year period, whichever is more conservative

  16. Decisions Needed Today • Approval of approach to use Q/d based on 2002 actual SO2 emissions < 10 to identify sources eligible for exemption modeling (12 km CALPUFF runs) • Approval to begin work with VA sources (most critical schedule) • Approval to start with lowest Q/d sources and work through list to determine if greater Q/d consistently shows > 0.5 dv impact • Approval to design work based on each State’s regulatory needs • After initial results are completed on 12 km runs, may adjust work to include some 4 km CALPUFF work – would present recommendation to change course

  17. Decisions Needed Today • Approval needed to move forward with designing 4 km domains and development of CALMET fields based on cost estimate from contractor

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