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Potential permitting impacts of new naaqs

Potential permitting impacts of new naaqs. A&WMA Southern Section Annual Meeting Biloxi, MS September 12, 2012 Carla Brown, P.E. MS Dept. of Environmental Quality 601-961-5235 cbrown@deq.ms.gov. NAAQS: New vs. Old.

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Potential permitting impacts of new naaqs

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  1. Potential permitting impacts of new naaqs A&WMA Southern Section Annual Meeting Biloxi, MS September 12, 2012 Carla Brown, P.E. MS Dept. of Environmental Quality 601-961-5235 cbrown@deq.ms.gov

  2. NAAQS: New vs. Old *Final Rule that established the most current standard, excluding those rules revoking previous standards.

  3. “Background” Air Quality • The background concentrations must be added to modeled concentrations to determine compliance with NAAQS. • MS Ambient Air Data: • Annual PM-2.5 (2009-2011): 9.5-11.8 ug/m3 • 24-hr PM-2.5 (2009-2011): 18-23 ug/m3 • 1-hr NO2 (2011, only one site): 32 ppb • 1-hr SO2 (2011, only one site): 29 ppb • Problem – very limited monitor data and background can result in double-counting emissions from stationary sources that are also being included as nearby sources in the model.

  4. Case Study • Roxul, a proposed mineral wool facility, was MDEQ’s first PSD processed under these significant NAAQS changes. • Proposed emissions from Roxul: • PM-10/PM-2.5 = 562/510 TPY • SO2 = 1035 TPY • NOx = 403 TPY • Modeling initially predicted… • 35 violations of 1-hr SO2 • One violation of 24-hr SO2 • 61,446 violations of 1-hr NO2

  5. Modeled 1-hr NO2 Violations

  6. Culpability Analysis • Significant NOx contributions from natural gas compressor station engines: • Trunkline Compressor Station – 5,500 TPY PTE • ANR Sardis Compressor Station – 2,900 TPY PTE • Tennessee Gas, New Albany Compressor Station – 1,900 TPY PTE • For those receptors showing violations after applying the 0.8 NO2:NOx default ratio (still 34,475 instances), the highest contribution from Roxul was determined to be less than 30% of SIL. • Per 40 CFR 51.165(b), if less than the SIL, source/project does not cause or contribute to the violation.

  7. Impacts on Applications • For PSD projects, months added to application preparation. • MDEQ has suggested submitting applications piece-meal so as not to delay the permitting process. • Time and $$$ due to refining modeling runs to meet the standards or to show no culpability should there be modeled violations.

  8. Impacts on Permitting • How does the State address modeled violations due to existing sources? • Based on decisions from the Sixth Circuit Court (1978-80), modeled violations are considered just as valid as measured violations. • Require those significant sources to perform air quality analysis? • Include limitations in SIP or enforceable operating permit? • Install monitor(s) in area of highest predicted impacts (at whose expense?)

  9. Modeled vs. Monitored • Based upon current modeling protocols, modeled concentrations will generally be much greater than monitored. • EPA acknowledged this in March 1, 2011, guidance memo regarding the 1-hr NO2 standard. • Yet EPA had planned to require state-wide modeling to demonstrate compliance with the 1-hr SO2 standard (generally due to lack of monitors for SO2).

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