www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
National Ambient Air
Quality Standards Update
Mark Wenc...
2 Your environmental compliance is clearly our business.
Agenda
 Recent changes to U.S. EPA’s NAAQS
• October 1, 2015 – o...
National Ambient Air
Quality Standards Update
SO2 NAAQS and the Data Requirements
Rule (DRR)
4 Your environmental compliance is clearly our business.
 August 11, 2015 (40 CFR Part 51, Subpart BB)
 Applies to facil...
5 Your environmental compliance is clearly our business.
 Agencies notify U.S. EPA regional offices on list
of SO2 source...
Air Dispersion Modeling
for SO2 DRR
7 Your environmental compliance is clearly our business.
SO2 Modeling TAD
 Representative
meteorological data
for most re...
8 Your environmental compliance is clearly our business.
Traditional PSD Receptor Grid
9 Your environmental compliance is clearly our business.
DRR Receptor Grid
10 Your environmental compliance is clearly our business.
SO2 Modeling TAD
 Actual emission rates
from past 3 years
 Cha...
11 Your environmental compliance is clearly our business.
 Varied emissions data is intensive and time
consuming
 Interm...
12 Your environmental compliance is clearly our business.
 Pros:
• Less costly and likely less time consuming
 Cons:
• D...
Ambient Monitoring for
SO2 DRR
14 Your environmental compliance is clearly our business.
 A facility may use a combination of the
following:
1. Perform ...
15 Your environmental compliance is clearly our business.
 Pros:
• More realistic view of ambient SO2 emissions
• Future ...
SO2 DRR Case Study
17 Your environmental compliance is clearly our business.
 Chemical plant in the southeast
 Modeling not previously cond...
18 Your environmental compliance is clearly our business.
 2 tasks
• Modeling-based evaluation
 Cumulative concentration...
19 Your environmental compliance is clearly our business.
 Recommendations for mitigating elevated
concentrations
• Balan...
National Ambient Air
Quality Standards Update
PM2.5 NAAQS
21 Your environmental compliance is clearly our business.
 2012 annual NAAQS (12 mg/m3) – Primary
 1997 annual NAAQS (15...
22 Your environmental compliance is clearly our business.
PM2.5 NAAQS
23 Your environmental compliance is clearly our business.
 Challenges related to PSD permitting
 Your permitted sources ...
24 Your environmental compliance is clearly our business.
 PM2.5 measurement method issues
• Overstatement of true emissi...
25 Your environmental compliance is clearly our business.
 Understand your ambient air boundary
 Work with ADEM to devel...
26 Your environmental compliance is clearly our business.
 “Ambient air” definition [40 CFR Part 50.1(e)]
• “the portion ...
27 Your environmental compliance is clearly our business.
 For example if a public rail line intersects the
property owne...
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions & Open Discussions
of 28

Naaqs oct 15

"Mark Wenclawiak presented 'National Ambient Air Quality Standards Update' in October 2015."
Published on: Mar 3, 2016
Published in: Environment      
Source: www.slideshare.net


Transcripts - Naaqs oct 15

  • 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
  • 28. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC Questions & Open Discussions

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