Implementation of the New Source Review NSR Program for PM2'5 An Industry Perspective

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Implementation of the New Source Review (NSR)
Program for PM2.5An Industry Perspective
Greg Archer Environmental Administrator Great
River Energy August 27, 2008
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Four Questions

• What PM2.5 emission rates should be used when
  permitting a new source or modifying an existing
  source?
• What are NSR BACT implications of various PM2.5
  methodologies?
• What are modeling implications of various PM2.5
  methodologies?
• Are there future compliance and enforcement
  issues associated with the various PM2.5
  methodologies in Minnesota?

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Question 1 - Preamble Quote

• In response to significant comments on the
  variability of tests methods available for
  measuring condensable emissions, we have adopted
  this transition period approach (until 2011) to
  allow us to assess the capabilities of the test
  methods and possibly revise them to improve
  performance.

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1 - What PM2.5 emission rates should be used
when permitting a new source?

• PM10 as surrogate
• Engineering estimates
• AP42
• Ch.1 assumes linear relationship of PM2.5 to
  sulfur
• Method 202 condensable particulate test
• Sulfate and acid gas artifacts, which can
  overstate PM2.5
• EPA Draft OTM 27 and 28
• EPA and EPRI effort to improve Method 202
  interference
• Questions remain on accuracy at elevated SO2
  emission rates?

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Question 2 - Preamble Quote

• this final action does not require regulation
  of SO2 and NOx as precursors of PM2.5 under PSD
  until the SIP development period ends. However,
  for delegated PSD states, SO2 and NOx are
  regulated as precursors from the effective date
  of this rule.

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2 - What are NSR BACT implications of various
PM2.5 methodologies?

• BACT analysis based on AP42 and Method 202
  emission rates
• They may overstate emission rates tripping 10 tpy
  SER and requiring PM2.5 BACT installation.
• SO2 and NOx BACT requirements are also triggered
  as precursors, in Minnesota.
• Future testing with OTM 28, or other more
  improved condensable particulate methodology, may
  disprove initial BACT determination.
• BACT limits cannot be rescinded.
• Revised BACT analysis may be problematic.

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Question 3 - Preamble Quote

• .the degree to which these individual
  precursors contribute to PM2.5 formation in a
  given location is complex and variable. There
  are competing chemical reactions taking place in
  the atmosphere, and meteorological conditions
  play a significant role in the size and
  characteristics of particle formation.

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3 - What are modeling implications of various
PM2.5 methodologies?

• Accuracy of existing emission inventories that
  may be based on Method 202 and AP42
• SIP attainment demonstrations based on existing
  emission inventories
• Increment modeling that trips SILs more easily
  resulting in need for more refined modeling
• Model accuracy with secondary particulate
  formation

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Question 4 - Preamble Quote

• The EPA acknowledges the legitimate concerns
  raised by commenters concerning potential
  exposure to retroactive enforcement and has
  established rules to address this issue. The EPA
  will not revisit applicability determinations
  made in good faith prior to the end of the
  transition period insofar as the quantity of
  condensable PM emissions are concerned, unless
  the applicable implementation plan clearly
  requires consideration of condensable PM.

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MPCA PM2.5 Implementation Plan

• The MPCA will continue to include condensable
  particulate matter, both organic and inorganic,
  when evaluating PM2.5 and PM10 for PSD
  applicability and emission limits.

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4 - Are there future compliance and enforcement
issues associated with the various PM2.5
methodologies?

• Questionable BACT determinations in the interim
  period that are based on AP42 or Method 202
• Permit limits based on AP42 or Method 202 values
• Revising permit limits once updated test method
  has been approved. Assuming it addresses
  artifact interference, PM2.5 emissions should
  logically decline.
• However, be warned - mixing logic and
  environmental requirements can be problematic!

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John Seitz, 1997 Interim Implementation of New
Source Review Requirements for PM2.5

• Of specific concern is the lack of necessary
  tools to calculate emissions
• of PM2.5 and related precursors and project
  ambient air quality impacts so
• that sources and permitting authorities can
  adequately meet the NSR
• requirements for PM2.5. Any comprehensive system
  for regulating
• PM2.5 must take into account not only the fine
  particles emitted directly by
• stationary sources but also the various
  precursors, emitted by certain
• sources, which result in secondarily-formed fine
  particles through
• chemical reactions in the atmosphere. Recent
  studies suggest that
• secondary particulate matter may account for over
  half of total ambient
• PM2.5 nationwide. Emissions factors for the fine
  particles emitted directly
• by stationary sources, and for some important
  precursors (e.g., ammonia),
• are largely unavailable at the present time.

Is this quote still relevant today?
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Thank You!!