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1-Hour SO2 National Ambient Air Quality Standards (NAAQS) Implementation – What’s Next?
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1-Hour SO2 National Ambient Air Quality Standards (NAAQS) Implementation – What’s Next?


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John Egan of ALL4 Inc. explains the National Ambient Air Quality Standards (NAAQS) 1-Hour Standard for SO2. This presentation also includes implementation updates, experiences, impacts of permitting, …

John Egan of ALL4 Inc. explains the National Ambient Air Quality Standards (NAAQS) 1-Hour Standard for SO2. This presentation also includes implementation updates, experiences, impacts of permitting, and what we at ALL4 think is next!

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  • Originally the Council reached out to me to talk about the short term NAAQS implementation, modeling and monitoring. However, given EPA’s recent shift in how they see, or don’t see the 1-hr SO2 implementation process happening, we agreed that it was more important to focus on how the process has played out so far and what to expect next.
  • 2006 EPA revised primary PM2.5 standard.February 9, 2010 EPA revised primary NO2 standard.June 2, 2010 EPA revised primary SO2 standard.March 20, 2012 EPA took final action to retain Secondary NO2 and SO2 standards.
  • When new 1-hr standard was published and the air quality modeling was included as part of the attainment designation and demonstration process EPA acknowledged that additional guidance beyond what was included in Appendix W was needed. Draft guidance September 2011.As late as Annual EPA modeling conference in mid-March this year EPA indicated final guidance not available before end of year.Surprise came mid-April when EPA changed its mind…
  • Three stakeholder meetings are now scheduled for late May/early June. Industry group session will be June 1 in RTP. Ink to website gives contact name and phone number if interested.
  • Lets talk about what’s been happening over the past year:Some states moving forward requesting info, some actually doing modeling with data in hand.Facilities trying to compile appropriate info and considering and/or conducting “exploratory” modeling.Issues cropping up everywhere thanks to the stringency and form of the standard.
  • Look at what goes into and comes out of the modeling exercise and consider all the areas where issues can and have occurred:
  • Then there are confounding additional considerations that can add to the difficulty in modeling attainment:
  • So what happens when the results come back and the initial numbers are problematic: Emission rates – new limits, change fuels/raw materials, add controlsReconfigure exhaustsLimit access, move fence to property lines, acquire property?Work with model or consider alternative to AERMOD
  • What have we seen:
  • May not be out of the question if backed into a corner.
  • If EPA no longer requiring AQM for state 2013 SIP submittals why are we even bothering to talk about the 1-hr SO2 issues?
  • Strategy!!!!!Timing!!
  • Strategy!!!!!Timing!!
  • Transcript

    • 1. 1-Hour SO2 NAAQS Implementation – What’s Next? John P. Egan NCASI 2012 Northern Regional Meeting Portland, ME May 10, 2012
    • 2. Agenda      2 Quick NAAQS Review NAAQS Implementation Updates NAAQS Implementation Experiences NAAQS Impacts on Permitting What’s Next?
    • 3. NAAQS Background     3 “Backdrop” of the Clean Air Act States design their SIPs and implement enforce their regulations to meet the NAAQS Air quality construction permit programs are designed around NAAQS compliance • PSD: Maintaining NAAQS attainment • NNSR: Getting into NAAQS attainment NAAQS reevaluated every 5 years
    • 4. NAAQS Summary CO Ozone Pb PM10 PM2.5 NO2 SO2 4 Averaging Period Primary/Secondary 1-Hour 8-Hour 8-Hour 3-Month Rolling 24-Hour 24-Hour Annual 1-Hour Annual 1-Hour 3-Hour 24-hour Primary Primary Primary/Secondary Primary/Secondary Primary/Secondary Primary/Secondary Primary/Secondary Primary Primary/Secondary Primary Secondary Primary 40,000 10,000 75 ppb 1.5 150 65 15 N/A 100 N/A 1,300 365 40,000 10,000 Withdrawn 0.15 150 35 15 188 100 196 1,300 Revoked Annual Pollutant Historic Revised NAAQS NAAQS (µg/m3) (µg/m3) Primary/Secondary 80 Revoked
    • 5. SO2 NAAQS Implementation  5 NAAQS Implementation Schedule: • June 2011: Initial state nonattainment recommendations to U.S. EPA (most counties were “unclassifiable”) • June 2012: EPA to finalize attainment status (most states will still be “unclassifiable” or attainment) • June 2013: Maintenance SIP submittals including individual facility modeling to achieve compliance with the NAAQS • August 2017: Full NAAQS compliance in all areas
    • 6. Implementation Update    6 Draft guidance for states to evaluate designations using AERMOD air dispersion model was released on September 22, 2011 Numerous comments received on draft guidance On April 12, 2012, U.S. EPA issued a letter to all states stating that modeling demonstrations showing attainment of the standard for areas initially designated “unclassifiable” will no longer be required for the June 2013 SIP submittals
    • 7. Implementation Update   U.S. EPA now proposing “Stakeholder Outreach” in order to discuss a workable approach for implementation of the new standard including: • How best to assess compliance with standard • How to implement new approach U.S. EPA recommending that states focus 2013 SIP submittals on traditional CAA infrastructure elements 7
    • 8. Implementation Experiences   8 Air dispersion modeling scramble: • States requested data and/or modeling • States conducting modeling • Facilities reevaluating data and resources • Facilities conducting exploratory modeling Troubling results…
    • 9. Air Quality Modeling Steps 1. Emission Inventory 2. Meteorological Data (AERMET/AERSURFACE) 3. Terrain Data (AERMAP) 4. Building Downwash (BPIPPRM) 5. Run model (AERMOD) 6. Assess results 7. Strategic planning 9
    • 10. Full NAAQS Evaluation      10 Includes facility and other local facilities Modeled emission rates need to be considered as possible 1-hour permit limits Considerations for accounting for emissions during startup and shutdown Emergency unit considerations Includes background
    • 11. Assessing Modeled Results     11 Emission Rate Strategies Stack/Exhaust Strategies Facility Fence Line Strategies Modeling Strategies
    • 12. Troubling Results     12 Use of PTE emissions and AERMOD can over estimate concentrations Known issues with certain terrain and meteorological conditions Sensitivity of the model to very site-specific parameters (angle of buildings, distance to property lines, etc.) Consideration of ambient SO2 monitoring to compare to AERMOD results
    • 13. Ambient SO2 Monitoring   13 Pros: • Monitoring data could be used to discount air quality modeling results • Potentially avoid need for permit limits, pollution controls, fuel restrictions, or worse… Cons: • Collection of monitoring data above the SO2 NAAQS • Time and cost
    • 14. NAAQS Impacts on Permitting  14 Major projects that trigger PSD require demonstration of compliance with PSD increments and NAAQS: • Initial evaluation of project impacts vs. significant impact level (SIL) • Full NAAQS evaluation if SIL exceeded • Like short-term NAAQS, SILs are extremely low
    • 15. NAAQS Impacts on Permitting   15 Full NAAQS evaluation under PSD no different than under SO2 implementation Supports value of exploratory modeling for strategic planning
    • 16. What Next    16 Primary NAAQS are health-based and not likely to increase Stakeholder Outreach to still consider modeling – get involved in process Projects triggering major NSR air permitting can still require modeling
    • 17. What Next  17 Strategic planning for future growth and compliance should consider: • Exploratory dispersion modeling • Emissions reduction options • Ambient SO2 and meteorological monitoring • Alternative permitting approaches - PALs
    • 18. Questions? John Egan (610) 933-5246 x14 2393 Kimberton Road PO Box 299 Kimberton, PA 19442 All4 Inc. 18