Impact of Ambient Air Rules for PM2.5 and Ozone is Hot Topic on April 22 and
April 23
On October 8, 2009, the Environmental Protection Agency (EPA) issued final area
designations for the 24-hour national air quality standards for fine particulate
matter (PM2.5) designating 31 areas as “nonattainment areas.” In December 2009,
the new 24-hour fine particle PM2.5 National Ambient Air Quality Standards (NAAQS)
of 35µg/m3 became effective. States with “nonattainment areas” are required to
submit SIP’s to attain compliance by April 2013 with compliance achieved by
2015. All states must also address how they will prevent “significant
deterioration” in “attainment areas”. In addition, the grace period during which
condensable PM2.5 did not need to be addressed under NSR regulations ends in
January 2011. PM2.5 will present the power plant operators with a number of
unique challenges different from those faced with NOx and SO2 including
measurement and quantification of PM2.5.
On January 6, 2010, EPA proposed to strengthen the national ambient air quality
standard (NAAQS) for ground-level ozone by setting the 8-hour “primary” ozone
standard to a level within the range of 0.060-0.070 parts per million (ppm).
Ozone is formed by the reaction in the atmosphere of volatile organic compounds
(“VOCs”) and oxides of nitrogen (“NOx”). The EPA plans to designate ozone
“nonattainment areas” by July of 2011 and require states to submit SIP’s to
achieve compliance by December 2013. While ozone is not emitted by coal-fired
power plants, control of ozone pollution can be accomplished by controlling the
emissions of VOCs and NOx. VOCs are generally not emitted from power plants.
However, the combustion of coal and other fossil fuels is a major source of NOx.
Although coal-fired power plants are not the only source of NOx or PM2.5
emissions, they are a major source and are seen as perhaps the easiest source to
control. They will, therefore, most certainly face regulations requiring greater
reductions of PM2.5 particulates as well as the ozone precursors NOx and SO2. It
could be assumed that the MACT standard soon to be issued by EPA or even the new
Clean Air Act Amendments expected to be enacted by congress this year, would
adequately address these ambient air issues. But will MACT or the reductions in
emissions mandated by the CAAA of 2010 be enough in “nonattainment” areas and
will it address the fact that much of the ozone and fine particulate can
originate from a source far from the “nonattainment area”?
The following speakers will provide an update on these regulations, address the
problems that will be faced by operators of coal-fired power plants as a result
of the NAAQS for PM2.5 and ozone and suggest possible solutions or strategies
and courses of action for utilities to consider short of plant closure.
The presenters on Thursday, April 22, 2010 are:
Colin T. McCall, Project Leader at All4, Inc - Within the past two (2) years,
the U.S. EPA has promulgated/proposed a 1-hour NO2 National Ambient Air Quality
Standard (NAAQS), a 1-hour SO2 NAAQS, and a revised 8-hour ozone NAAQS. In
addition, the U.S. EPA has proposed new source review (NSR) regulations related
to the annual and 24-hour PM2.5 NAAQS. These new health-based NAAQS are
extremely stringent and will make it increasingly difficult to obtain approval
for new facilities or for existing facility expansion and modernization
projects. Now more than ever, the NAAQS and the associated air dispersion
modeling requirements in both attainment and nonattainment areas will dictate
the viability of new projects and the way that new projects are designed. This
presentation will focus on the new NAAQS and their impacts on power plants,
including recommendations on the strategic approaches that can be used to
address the new NAAQS levels.
Katherine (Kate) L. Vaccaro, Associate at Manko, Gold, Katcher & Fox LLP, an
Environmental Law Firm will discuss state-level implementation of the Federal
New Source Review requirements for PM2.5. In particular, she will present the
challenges faced by owners and operators of fossil fuel-fired power plants and
other industrial facilities located in states seeking to institute PM2.5 NSR
regulations that are more stringent than the federal standards and evaluate both
practical and economic feasibility considerations.
Tom Anderson, Midwesco
Bryan Brendle, Director of Energy & Resources Policy for the National
Association of Manufacturers’
The presenters on Friday, April 23, 2010 are:
Sonja Sax, Environmental Health Scientist and Senior Associate at Gradient
Corporation will present an overview of the new proposed PM and Ozone NAAQS. The
National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) are
currently undergoing regulatory review and the ozone NAAQS are being
reconsidered. The U.S. EPA is recommending lowering both the PM and the ozone
NAAQS despite considerable uncertainties associated with the underlying studies
used to support these efforts. Ms. Sax will present a brief history of the NAAQS
for PM and ozone, an overview of the current review process and uncertainties in
the supporting evidence, and the possible implications of lower PM and ozone
standards for point sources such as coal fired power plants.
Lysa Modica, Senior Project Manager at AMEC
Mr. Gale F. Hoffnagle, CCM, QEP, Senior Vice President and Technical Director,
Air Quality Consulting Practice Manager at TRC Environmental Corporation will
discuss the question “What is the Power Plant impact on PM2.5 and ozone
non-attainment?” There are many questions about the modeling of such impacts.
What model to use? What assumptions to make? How should we interpret the
results? The experiences of several permitting efforts in which modeling was
required for PM2.5 and ozone will help shed some light on these questions.
To register for the "Hot Topic Hour" on April 22 and April 23, 2010 at 10 a.m.
CDT (Chicago time), click on: http://www.mcilvainecompany.com/brochures/FGDnetoppbroch/Default1.htm
Bob McIlvaine
President
847 784 0012 ext 112
rmcilvaine@mcilvainecompany.com
www.mcilvainecompany.com