How NAAQS Revisions Can Affect Your Facility

1. How NAAQS Revisions Can Affect Your Facility Michael Ballenger, P.E. and Russell Bailey Central District’s Power Generation Conference July 29, 2010 trinityconsultants.com

2. Presentation Outline • Background – • What are NAAQS? • How are they established / revised? • Expected Timeline - More Revisions • How do NAAQS revisions affect me? • General Case Study

3. Background - NAAQS • 6 criteria pollutants used as AQ indicators • Maximum ambient concentration levels • Adverse effects on human health or public welfare can occur above these levels • Florida SIP adopts NAAQS [Rule 62-204.800(1), F.A.C.] • More stringent SO2 standards [Rule 62-204.240(1), F.A.C.] • Areas where air concentrations exceed NAAQS designated as “nonattainment”

4. Background – NAAQS Revisions • CAA §109(d)(1): EPA must re-evaluate NAAQS on 5-year basis • Standards not based on cost! • Whitman v. American Trucking • * New averaging periods • Recent re-evaluations led to the following:

5. NAAQS Revisions in Progress • The following are currently proposed or being planned by EPA: • In 3 years from 2008, all NAAQS may be new!

6. Proposed Ozone NAAQS

7. Current Proposed Ozone Updates • EPA notified D.C. Circuit that they would re-consider 2008 Ozone NAAQS • Proposed new standards on Jan. 6, 2010 • NA Counties 515 to 650 (322 currently) • W126 is a “cumulative peak-weighted index” to identify the 3 consecutive months during the ozone season with the highest index value (averaged over 3 years).

8. There’s a Map for That…

9. More 3G Coverage… • 3rd Generation of the 8-hour Ozone NAAQS to • And these maps are just monitors showing NA – do not include Core-Based Statistical Areas (CBSAs)!

10. Expedited Timeline * Schedule for Primary Std., possible schedule for Secondary Std.

11. How Will Ozone Revisions Affect My Facility? • 2008 Standard replaced • Permitting continues under 0.08 ppm until new designations final • Nonattainment designations may be coming even to rural areas • Permitting impacts • Reductions, new permits • Not just new sources and modifications • May pull in existing sources

12. Potential Obligations to Existing Permitted Sources in NA Areas • Lower VOC/NOX Title V thresholds • Re-evaluate if facility is still minor • RACT requirements • What units are subject? • Permitting requirements • Areas of influence • Will other counties not included in nonattainment designation be considered area of influence?

13. Potential Obligations to New or Modified Sources in NA Areas • Lower VOC/NOX NSR threshold(s) • Small changes may now result in major NSR • Fugitive emissions • Aggregation for minor changes? • Costs • Emission reduction credits (ERCs) • LAER • Alternatives Analysis • Compliance issues with other sister sites

14. Revised NO2 NAAQS

15. Sources of NOx Pollution Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/nitrogenoxides/actions.html )

16. Revisions to NO2 NAAQS • Annual Average Standard = 53 ppb (100 µg/m3) • Final revisions published in FR on 2/9/2010 (effective 4/12/10) • New 1-Hour Standard = 100 ppb hourly expressed as 3-yr average of 98th percentile of annual distribution of max daily1-hour avg • No changes to the annual standard or secondary standard (secondary standard currently under review) • Changes to NO2 Air Quality Monitoring Network • Peak, short-term concentrations primarily near major roadways in urban areas • Highest concentrations of NO2 that occur over wider areas • Concentrations impacting susceptible and vulnerable groups • EPA requiring all NO2 monitors to begin operating no later than January 1, 2013

17. 1-Hour NO2 Standard Implementation • April 12, 2010 – Final standard effective • January 2011 – States submit designation recommendations to EPA • January 2012 – EPA designates most areas “unclassifiable” (because near-road monitors not in place) • January 2013 – New near-road monitors in place • January 2015 – Next NO2 NAAQS review • January 2017/2018 – Non-attainment redesignations • January 2022/23 – Attainment date

18. Revised SO2 NAAQS

19. Revisions to SO2 NAAQS • Final rule published June 2, 2010 • 1-Hour Standard = 75 ppb on a 3-year average of 99th percentile concentration • EffectiveDateAugust23,2010 • EPA anticipates that new 1-hour standard would prevent concentrations from exceeding current 24-hour standard (140 ppb) and current annual standard (30 ppb) health-based standards • New standard to reduce exposure to high, short-term concentrations of SO2 deemed to be greatest health risk in recent health studies • EPA revoked both annual and 24-hour current primary SO2 standards and replace with 1-hour standard • No change to secondary standard (under separate review) • New near source monitoring required by 2013

20. Sources of SO2 Pollution Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/sulfurdioxide/pdfs/SO2proposalbriefing.pdf)

21. Revised SO2 NAAQS Monitoring • Current network not primarily configured to monitor high concentration sources • EPA proposing two categories of required monitors • Monitors required in certain CBSAs based on combination of population and SO2 emissions • Additional monitors may be required by the Regional Administrator based on the state’s contribution to national SO2 emissions – specific locations to be determined by states and the Regional Administrator • Adjusted network will have a minimum of 163 sites nationwide that are to be operational by 1/1/2013 (from 348 initially proposed) • EPA plans to utilize refined modeling results, as part of the attainment designation process

22. 1-Hour SO2 Standard Implementation • August 23, 2010 –Final standard effective • June 2011 – States submit designation recommendations to EPA • June 2012 – Final Area Designations • June 2013 – Attainment Demonstration SIPs due • August 2017 – Attainment date

23. Comparing Old v. New (1 of 2) • Without considering different forms of the revised standards, comparing the revised standards using SCREEN conversion factors between averaging periods…

24. Comparing Old v. New (2 of 2) • Short-term emission rates > long-term • New form of standards • Average of 98th / 99th percentile of max daily 1-hr values • Different approach to models • NO2/NOX ratios and PVMRM • New AERMOD or massive post-processing • H8H, H4H are close • Max monitored value for background • Background > standard even in attainment area? • E.g., 2007 H1H NO2 in Broward County = 155 ppb

25. Impacts to My Facility? • New PSD Permitting • BACT may not be enough (“BACT-Plus”) • Ancillary equip. emissions control / taller stack • Short-term vs. annual modeled emission rates • Startup/shutdown modeled emission rates • A nearby facility undergoes PSD Permitting • Existing sources included in NAAQS inventory • Attainment Demonstrations by DEP • SO2 determinations may be based on refined modeling – how will your facility be represented?

26. Case Study: NO2 and SO2 Impacts

27. Simple SCREEN Results (1 of 2) • Individual emission unit impacts only • Downwash included for typical building size

28. Simple SCREEN Results (2 of 2) • Assume cavity on-site, add background • Orange County: NO2=0.058 ppm, SO2=0.02 ppm • 1-hr NO2 std: 100 ppb; 1-hr SO2 std: 75 ppb

29. Questions?