“Impact of Ambient Air Rules for PM2.5 and Ozone” was the Hot Topic on April 22 and April 23
Colin T. McCall, Project Leader at All4, Inc., observed that 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. In fact the new NO2 ambient standard forced one plant to include SNCR which had been deemed unnecessary under the old standard.
Katherine (Kate) L. Vaccaro, Associate at Manko, Gold, Katcher & Fox LLP, discussed state-level implementation of the Federal New Source Review (NSR) requirements for PM2.5. Owners and operators of fossil fuel-fired power plants and other industrial facilities located in states, that are seeking to institute PM2.5 NSR regulations that are more stringent than the federal standards, are facing difficulties. Pennsylvania is one such state.
Tom Anderson of Midwesco showed that the new fabrics will eliminate fine particles. These fabrics have been tested by an EPA verification program (ETV). Some Asian-made membranes did not test nearly as well as those made in the U.S.
Bryan Brendle, Director of Energy & Resources Policy for the National Association of Manufacturers, indicated that there are many new regulations which in combination are making manufacturing in the U.S. more difficult and expensive. Many significant rules are likely to be passed in the next two years.
Sonja Sax, Environmental Health Scientist and Senior Associate at Gradient Corporation, presented an overview of the new proposed PM and Ozone NAAQS and said that EPA is recommending lowering both the PM and the ozone NAAQS despite considerable uncertainties associated with the underlying studies used to support these efforts. Power plants will be significantly impacted if the standards are lowered.
Lysa Modica, Senior Project Manager at AMEC, observed that there is much change under the Obama Administration. This has temporarily slowed down some rules but is likely to make them more stringent in the long term. She analyzed each under the “good, the bad, and the ugly.”
Gale F. Hoffnagle, CCM, QEP, Senior Vice President and Technical Director Air Quality Consulting Practice Manager at TRC Environmental Corporation, explained the difficulties in modeling. Photochemical modeling of PM2.5 is likely to be necessary due to the secondary particle creation of SO2 and NOx.
The Bios, Abstracts and Photos can be viewed as follows:
BIOS, PHOTOS, ABSTRACTS - APRIL 22-23, 2010.htm
The individual slides can be viewed in the PARTICULATE DECISION TREE as follows:
TOM ANDERSON – MIDWESCO FILTER RESOURCES, INC. (MFRI)
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Products |
Particulate Continuing Decision Process For: Products
PM2.5 Compliance, presented by Tom Anderson, Midwesco. Hot Topic Hour April 22, 2010.
KATHERINE VACCARO – MANKO, GOLD, KATCHER & FOX
BRYAN BRENDLE – NATIONAL ASSOCIATION OF MANUFACTURERS
COLIN MCCALL – ALL4, INC.
SONJA SAX – GRADIENT
GALE HOFFNAGLE – TRC ENVIRONMENTAL CORP.
LYSA MODICA – AMEC
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PM2.5 |
Particulate Continuing Decision Process For: PM2.5
See PM2.5 link below for presenters’ slides.
PM2.5