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 (1), F.A.C.]  More stringent SO 2 standards [Rule (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 ppm8-hour LeadOctober  g/m 3 3-month NO 2 February ppb1-hour* SO 2 June 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 – 70 ppb8-hr NO 2 SecondaryJul 2010?Jul 2011??? SO 2 SecondaryJul 2010?Jul 2011??? PMJul 2010Apr  g/m 3 annual COOct 2010May 2011??  In 3 years from 2008, all NAAQS may be new!

Proposed Ozone NAAQS

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 ppm8-hourSame as Primary 2010 Re- Revision to 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).

There’s a Map for That…

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, FR – 7/11/2007 January 6, FR /19/2010 Final StandardsMarch 12, FR – 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 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

Revised NO 2 NAAQS

Sources of NO x Pollution Source: EPA Office of Air Quality Planning and Standards ( )

 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

Revised SO 2 NAAQS

 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 (

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 ppb ppb100 ppb6.6:1 Annual SO 2 30 ppb ppb 75 ppb 5:1 24-hr SO ppb ppb4.67:1 3-hr SO ppb 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 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 Boiler ,506 Aux Boiler Biomass Boiler Gas Turbine Turbine Startup , New Generator5, , Existing Generator16, ,

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

Questions?