Presentation on theme: "How NAAQS Revisions Can Affect Your Facility trinityconsultants.com Michael Ballenger, P.E. and Russell Bailey Central District’s Power Generation Conference."— Presentation transcript:
How NAAQS Revisions Can Affect Your Facility trinityconsultants.com Michael Ballenger, P.E. and Russell Bailey Central District’s Power Generation Conference July 29, 2010
Presentation Outline Expected Timeline - More Revisions How do NAAQS revisions affect me? General Case Study Background – What are NAAQS? How are they established / revised?
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 SO 2 standards [Rule 62-204.240(1), F.A.C.] Areas where air concentrations exceed NAAQS designated as “nonattainment”
Background – NAAQS Revisions * New averaging periods Revised NAAQS Date FinalizedPrimary Standard Averaging Time OzoneMarch 20080.075 ppm8-hour LeadOctober 2008 0.15 g/m 3 3-month NO 2 February 2010100 ppb1-hour* SO 2 June 201075 ppb1-hour* CAA §109(d)(1): EPA must re- evaluate NAAQS on 5-year basis Standards not based on cost! Whitman v. American Trucking Recent re-evaluations led to the following:
NAAQS Revisions in Progress The following are currently proposed or being planned by EPA: NAAQSProposal Date Final RuleExpected Standard Averaging Time Ozone – Round 3!Jan 2010Aug 201060 – 70 ppb8-hr NO 2 SecondaryJul 2010?Jul 2011??? SO 2 SecondaryJul 2010?Jul 2011??? PMJul 2010Apr 2011 12-14 g/m 3 annual COOct 2010May 2011?? In 3 years from 2008, all NAAQS may be new!
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) Ozone NAAQS Primary Standard Averaging Time Secondary Standard Averaging Time 2008 Revision 0.075 ppm8-hourSame as Primary 2010 Re- Revision 0.060 to 0.070 ppm 8-hour7 to 15 ppm- hours W126* 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).
More 3G Coverage… 3 rd Generation of the 8-hour Ozone NAAQS to And these maps are just monitors showing NA – do not include Core-Based Statistical Areas (CBSAs)!
Expedited Timeline Timeline2008 Ozone StandardRevised 2010 Ozone Standard* Standard ProposedJune 20, 2007 72 FR 37818 – 7/11/2007 January 6, 2010 75 FR 2938 - 1/19/2010 Final StandardsMarch 12, 2008 73 FR 16436 – 3/27/2008 August 31, 2010 States Recommend NA Areas March 12, 2009January 7, 2011 Final NA Area Designations March 12, 2010 (proposed 3/12/2011) July 2011 (effective by 8/31/2011) NA SIPs DueMarch 12, 2013December 2013 Attainment Dates2013 to 20302014 to 2031 * Schedule for Primary Std., possible schedule for Secondary Std.
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
Potential Obligations to Existing Permitted Sources in NA Areas Lower VOC/NO X 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?
Potential Obligations to New or Modified Sources in NA Areas Lower VOC/NO X 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
Sources of NO x Pollution Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/nitrogenoxides/actions.html )http://www.epa.gov/air/nitrogenoxides/actions.html
Annual Average Standard = 53 ppb (100 µg/m 3 ) 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 98 th 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 NO 2 Air Quality Monitoring Network Peak, short-term concentrations primarily near major roadways in urban areas Highest concentrations of NO 2 that occur over wider areas Concentrations impacting susceptible and vulnerable groups EPA requiring all NO 2 monitors to begin operating no later than January 1, 2013 Revisions to NO 2 NAAQS
1-Hour NO 2 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 NO 2 NAAQS review January 2017/2018 – Non-attainment redesignations January 2022/23 – Attainment date
Final rule published June 2, 2010 1-Hour Standard = 75 ppb on a 3-year average of 99 th percentile concentration Effective Date August 23, 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 SO 2 deemed to be greatest health risk in recent health studies EPA revoked both annual and 24-hour current primary SO 2 standards and replace with 1-hour standard No change to secondary standard (under separate review) New near source monitoring required by 2013 Revisions to SO 2 NAAQS
Sources of SO 2 Pollution Source: EPA Office of Air Quality Planning and Standards (http://www.epa.gov/air/sulfurdioxide/pdfs/SO2proposalbriefing.pdf)
Revised SO 2 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 SO 2 emissions Additional monitors may be required by the Regional Administrator based on the state’s contribution to national SO 2 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
1-Hour SO 2 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
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… Previous StdSCREEN Convert Equivalent 1-hr Std Revised 1-hr Std Ratio Annual NO 2 53 ppb12.5663 ppb100 ppb6.6:1 Annual SO 2 30 ppb12.5375 ppb 75 ppb 5:1 24-hr SO 2 140 ppb2.5350 ppb4.67:1 3-hr SO 2 500 ppb1.11555 ppb7.4:1
Comparing Old v. New (2 of 2) Short-term emission rates > long-term New form of standards Average of 98 th / 99 th percentile of max daily 1-hr values Different approach to models NO 2 /NO X 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
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 SO 2 determinations may be based on refined modeling – how will your facility be represented?
Case Study: NO 2 and SO 2 Impacts Emission UnitTypeControlsStackNO 2 SO 2 Coal Boiler600 MW USCPC SCR, Scrubber 400’0.07 lb/MMBtu 0.12 lb/MMBtu No. 6 Oil Aux Boiler 100 MMBtu/hr None80’0.1 lb/MMBtu 0.052 lb/MMBtu Biomass Boiler100 MW BFB SNCR, SDA 200’0.11 lb/MMBtu 0.01 lb/MMBtu Gas TurbineF Class CCCT SCR, DLN Burners 150’2.0 ppmvd2 lb/hr Turbine Startup“““200 lb/hr1.85 lb/hr New Generator300 kWTier 2, ULSD 15’6.4 g/kW-hr 15 ppm S in fuel Existing Generator 300 kWDiesel15’4.41 lb/MMBtu 500 ppm S in fuel
Simple SCREEN Results (1 of 2) Individual emission unit impacts only Downwash included for typical building size EUNO 2 ( g/m 3 ) SO 2 ( g/m 3 ) NO 2 Cavity ( g/m 3 ) SO 2 Cavity ( g/m 3 ) Coal Boiler82.4141.2878.61,506 Aux Boiler8.24.3-- Biomass Boiler68.16.2903.482.1 Gas Turbine8.31.0189.722.7 Turbine Startup99.90.92,27221.0 New Generator5,6145.710,22210.4 Existing Generator16,444185.429,945337.5
Simple SCREEN Results (2 of 2) Assume cavity on-site, add background Orange County: NO 2 =0.058 ppm, SO 2 =0.02 ppm 1-hr NO 2 std: 100 ppb; 1-hr SO 2 std: 75 ppb EUNO 2 (ppb) Under 1-hr Std? SO 2 (ppb) Under 1-hr Std? Coal Boiler102No69Yes Aux Boiler62Yes21Yes Biomass Boiler94Yes22Yes Gas Turbine62Yes20Yes Turbine Startup111No20Yes New Generator3,044No22Yes Existing Generator8,804No85No