"Mark Wenclawiak presented 'National Ambient Air Quality Standards Update' in October 2015."

1. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
National Ambient Air
Quality Standards Update
Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | 678.460.0324
October 27, 2015
Presented to the 2nd Annual Alabama Environmental
Conference by All4 Inc.

2. 2 Your environmental compliance is clearly our business.
Agenda
 Recent changes to U.S. EPA’s NAAQS
• October 1, 2015 – ozone (Wednesday session)
• August 21, 2015 – SO2 (including a case study)
• January 15, 2013 – PM2.5
 Implications to industrial facilities?
• Increasingly difficult to permit in attainment areas
(PSD)
• More dispersion modeling and ambient monitoring
requirements
• Plantwide applicability limit (PAL) permits

3. National Ambient Air
Quality Standards Update
SO2 NAAQS and the Data Requirements
Rule (DRR)

4. 4 Your environmental compliance is clearly our business.
 August 11, 2015 (40 CFR Part 51, Subpart BB)
 Applies to facilities that:
1. Emitted 2,000 tons per year (tpy) of actual emissions
during most recent calendar year
2. Not located in a nonattainment area
3. “Hot spots” = know your neighbors
 Applicable facilities will be required to conduct
modeling or evaluate new ambient monitor
locations
 Technical Assistance Documents (TADs)
SO2 NAAQS and the DRR

5. 5 Your environmental compliance is clearly our business.
 Agencies notify U.S. EPA regional offices on list
of SO2 sources by January 15, 2016
 Agencies specify whether each source will use
monitoring or modeling by July 1, 2016
 Air dispersion modeling protocols due by July 1,
2016; analysis due January 13, 2017
 Ambient monitoring plans are due by July 1,
2016; monitors operational by January 1, 2017
When is This Happening?

6. Air Dispersion Modeling
for SO2 DRR

7. 7 Your environmental compliance is clearly our business.
SO2 Modeling TAD
 Representative
meteorological data
for most recent 3
years
 Receptors placed only
where an ambient
monitor could actually
be located
Comparison to Regulatory Modeling
Regulatory Modeling
 Representative
meteorological data
for 5 years
 Receptors placed
anywhere deemed as
ambient air

8. 8 Your environmental compliance is clearly our business.
Traditional PSD Receptor Grid

9. 9 Your environmental compliance is clearly our business.
DRR Receptor Grid

10. 10 Your environmental compliance is clearly our business.
SO2 Modeling TAD
 Actual emission rates
from past 3 years
 Characteristics can be
varied on an hourly
basis
 Use of actual (i.e.,
current) stack heights
only
Comparison to Regulatory Modeling
Regulatory Modeling
 Potential to emit
 Can vary emissions
rates – but typically
not varied hourly (and
could result in permit
limits)
 Use of GEP, not
current stack height

11. 11 Your environmental compliance is clearly our business.
 Varied emissions data is intensive and time
consuming
 Intermittent sources (i.e., emergency
generators) only evaluated if operated enough
to contribute to 99th percentile
 Actual emissions can be an improvement over
allowable emissions
 June - December 2013: 246 monitors across the
U.S. did not collect 1-minute meteorological
data due to a lack of funding
Considerations for DRR Modeled
Emission Rates

12. 12 Your environmental compliance is clearly our business.
 Pros:
• Less costly and likely less time consuming
 Cons:
• Determining actual emissions can be challenging
• Ongoing compliance demonstrations in rule (annual
reports of emissions; recommendations for additional
modeling)
 Completed when modeling shows no receptors > 50% of
NAAQS
• Facility may not be able to demonstrate compliance
with the NAAQS
Pros and Cons of Modeling

13. Ambient Monitoring for
SO2 DRR

14. 14 Your environmental compliance is clearly our business.
 A facility may use a combination of the
following:
1. Perform dispersion modeling to identify location(s)
of maximum SO2 concentrations
• Normalized emissions rate
• Rank each receptor for concentration and number of
days when that receptor is the highest for the day for all
receptors
2. Install temporary ambient monitors at several
locations to identify the location(s) of maximum
SO2 concentrations
Steps to Determining Ambient Monitoring
Locations

15. 15 Your environmental compliance is clearly our business.
 Pros:
• More realistic view of ambient SO2 emissions
• Future compliance requirements may diminish
 Cons:
• Ambient monitoring sighting challenges (SLAMS)
• Capital costs (installation and upkeep)
• Time consuming
• Quarterly and annual reporting
• Noncompliance will mean ongoing monitoring
obligations and more stringent future air permitting
obligations
Pros and Cons of Monitoring

16. SO2 DRR Case Study

17. 17 Your environmental compliance is clearly our business.
 Chemical plant in the southeast
 Modeling not previously conducted
 CEMS data for largest SO2 emitting source, limited
emissions data for other sources
 Relatively flat terrain in rural setting
 Next door neighbor is utility power plant
Background

18. 18 Your environmental compliance is clearly our business.
 2 tasks
• Modeling-based evaluation
 Cumulative concentration of plant’s sources relative to the
NAAQS
• Monitoring-based evaluation
 Rank normalized modeling results
Project

19. 19 Your environmental compliance is clearly our business.
 Recommendations for mitigating elevated
concentrations
• Balance with future expansion plans with facility,
particularly PSD projects
 If not possible, recommend ambient monitoring
locations
 Outcome
• Modeling shows noncompliance; Appendix W options
• Expanded scope to include other criteria pollutants
and PTE rates in anticipation of future modeling needs
such as a PSD project
Compliance Approach

20. National Ambient Air
Quality Standards Update
PM2.5 NAAQS

21. 21 Your environmental compliance is clearly our business.
 2012 annual NAAQS (12 mg/m3) – Primary
 1997 annual NAAQS (15 mg/m3) – Secondary
 Final 2012 annual PM2.5 NAAQS designated on
January 15, 2015
 Updates to some areas initially designated non-
attainment to attainment made on April 7, 2015
based on 2012-2014 monitoring data.
 U.S. EPA’s “Guidance for PM2.5 Permit Modeling”
 No nonattainment areas in AL so what is the fuss?
PM2.5 NAAQS

22. 22 Your environmental compliance is clearly our business.
PM2.5 NAAQS

23. 23 Your environmental compliance is clearly our business.
 Challenges related to PSD permitting
 Your permitted sources PLUS regional sources
 PM2.5 emissions inventory data
• Often assumed to equal PM10
• Missing or incorrect exhaust parameters
• Inaccurate source locations (assignment of single
coordinate location for all emissions sources at a
facility)
PM2.5 Challenges

24. 24 Your environmental compliance is clearly our business.
 PM2.5 measurement method issues
• Overstatement of true emissions due to lack of blank
corrections in test methods (low emitting and fugitive
sources)
• Biases in condensable PM due to presence of SO2 and
NH3 – new Method 202 may not eliminate all biases
(boilers firing fossil fuels, units using NOX controls)
• Lack of validated method for measuring filterable
PM2.5 from wet sources (boilers with scrubbers)
 Ambient PM2.5 background concentrations close
to standard in and of themselves
PM2.5 Challenges

25. 25 Your environmental compliance is clearly our business.
 Understand your ambient air boundary
 Work with ADEM to develop appropriate ambient
air boundary
 Understand where your fugitive (i.e.,
roadway/pile) and low release point (i.e., process
silos/starch silos) sources are relative to your
ambient air boundary
Ambient Air Boundary

26. 26 Your environmental compliance is clearly our business.
 “Ambient air” definition [40 CFR Part 50.1(e)]
• “the portion of the atmosphere, external to buildings
to which the general public has access”
• Ambient air starts at the applicant’s property line. It
does not include the atmosphere over land owned or
controlled by the source and to which public access is
precluded by a fence or other physical barriers. If a
publicly accessible road, water body or rail line
intersects property owned by a facility; those areas
are considered ambient.
• Fence defined as 3 strands of barbed wire
Ambient Air Boundary

27. 27 Your environmental compliance is clearly our business.
 For example if a public rail line intersects the
property owned by the facility to where the
facility does not have control over access to the
rail line then the rail line is considered ambient
air. If the facility does control access to the rail
line such as in the instance of a rail spur, than the
facility can consider the air over their spur part of
their property.
Ambient Air Boundary

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Questions & Open Discussions