1. SUBCHAPTER19

2. SC 19 Study Where do numbers come from? Re-evaluate the basis of the numbers How would you come up with the numbers today?

3. Todays Presentation How would you come up with the numbers today? How would you come up with the numbers today? Summary of study Summary of study Recommendations Recommendations

4. How would you come up with the numbers today? Appendix C Appendix C –Use most stringent rule from EPA R6 and CenSARA states Kansas, Missouri, and New Mexico – same as Oklahoma Kansas, Missouri, and New Mexico – same as Oklahoma –Use existing information gathered from recent stack tests Reduce current algorithm by 37.5% Reduce current algorithm by 37.5%

5. How would you come up with the numbers today? Appendix G Appendix G - Adopt the most commonly used standard of nearby, similar states Okla., LA, Kan., Missouri, Iowa, Neb.

6. How would you come up with the numbers today? Appendix G Appendix G Use most stringent algorithm in EPA R6 and CenSARA states – Existing units use current Oklahoma algorithm E = 4.10P 0.67 P 30 TPH E = 4.10P 0.67 P 30 TPH E = 55P 0.11 – 40 P > 30 TPH E = 55P 0.11 – 40 P > 30 TPH – New units use : E = 3.59P 0.62 (E = 4.10P 0.67 ) P 30 TPH E = 3.59P 0.62 (E = 4.10P 0.67 ) P 30 TPH E = 17.31P 0.16 (E = 55P 0.11 – 40) P > 30 TPH E = 17.31P 0.16 (E = 55P 0.11 – 40) P > 30 TPH

7. Summary Does present rule include condensables and should it? Does present rule include condensables and should it? –Historical research determines – yes –All EPA R6 and CenSARA states rules include condensables –EPA approved original SIP on the basis of full train –NSR calculations for permitting and emission inventory require total PM –If algorithms were created today, they would be full train

8. Recommendation Options Relax the rule Relax the rule Must justify relaxation to EPA and the public Existing units meet the current rule 2007 PM 2.5 monitoring results show potential problem Recent modeling results for NSR indicate potential PM increment problem in Oklahoma

9. Recommendation Options Adopt a more stringent rule Adopt a more stringent rule –Appendix C Okla. has the most stringent rule in EPA R6 and CenSARA Okla. has the most stringent rule in EPA R6 and CenSARA Stack tests results could justify a 37.5% reduction in allowables Stack tests results could justify a 37.5% reduction in allowables –Appendix G Okla. has the most commonly used algorithm Okla. has the most commonly used algorithm Okla. could adopt more stringent rule for new units (Minnesota Rule) Okla. could adopt more stringent rule for new units (Minnesota Rule) PM 2.5 data suggest future potential problems PM 2.5 data suggest future potential problems

10. Recommendation Options Do not change the rule Do not change the rule –Okla. has the most stringent rule in EPA R6 and CenSARA for indirect fired units –Okla. has most common algorithm in R6 and CenSARA for direct fired units –Vast majority of existing units comply with current rule –Future units will be more likely to meet SC 19 than existing units

11. Recommendation Clarify that existing SC 19 algorithms include full train PM Clarify that existing SC 19 algorithms include full train PM Do not change existing rule until and unless future data identifies a PM problem that can be addressed by altering SC 19. Do not change existing rule until and unless future data identifies a PM problem that can be addressed by altering SC 19.