Impact of Ambient Air Rules for PM_2.5 and Ozone - Hot Topic December 9 and 10, 2010

The individual presentations are linked as follows:

Speakers on Thursday, December 9^th.

Robert (Bob) Paine, Technical Director of AECOM Environment, discussed the effect of tighter ambient standards for PM_2.5 and ozone on permitting of new sources. Each nonattainment area and changes to the State Implementation Plan requires considerable investment by stakeholders to assure that their interests are protected when reviewing agencies are looking for emission reductions to bring these areas into modeled attainment.

Effects of More Stringent Ambient Standards for Ozone and PM2.5 on New and Existing Industrial Sources

John Kinsman, Senior Director Environment at Edison Electric Institute, indicated that the new ambient limits would create a significant burden on the utility industry. The 2011 ozone NAAQS would greatly increase nonattainment areas and would add additional monitoring and control costs. The proposed ambient particulate matter standard raises questions on both cost and attainability. The SO₂ and NO₂ ambient rules would require modeling by utilities and add a cost burden. Secondary standards would also be stringent. The Transport Rule II and III impact would be likely greatly than the present proposed rule.

Impact of Ambient Air Rules for PM2.5 and Ozone

Katherine (Kate) L. Vaccaro, Associate at Manko, Gold, Katcher & Fox LLP, an Environmental Law Firm, addressed the NAAQS for PM_2.5 and ozone, focusing on state-level implementation of the federal New Source Review (NSR) requirements for PM_2.5.  In particular, she discussed certain challenges faced by owners and operators of fossil fuel-fired power plants and other industrial facilities located in states seeking to institute PM_2.5 NSR regulations. The power production sector may be compounded by other air quality regulations being developed by EPA, including the new proposed rule to reduce Interstate Transport of Fine Particulate Matter and Ozone, which would impose stringent emission limits for NO_x and SO₂ on affected electric generating units. 

  Impact of Ambient Air Rules for PM2.5 and Ozone

Speakers on Friday, December 10^th.

Kevin Crosby, Technical Director of The Avogadro Group, LLC, described the new PM_2.5 stationary source sampling methods and discussed how the collection technique varies from the ambient sampling methodology and how these new sampling methodologies for PM_2.5 might or might not improve the results for stationary sources. The new sampling method re-defines what is considered to be PM_2.5. This will have an impact on abatement equipment selection and will be a great fit for the measurement of fine particulate sub-topic.

PM2.5 Emissions: Do the New Test Methods Improve the Results?

Sonja Sax, Environmental Health Scientist and Senior Associate at Gradient Corporation, provided an update 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. Sonja presented an update of the 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. 

Conclusions:

• About 10 percent of monitoring sites are currently out of compliance with the PM_2.5 standard and a lower standard would bring many more out of compliance. This will significantly impact power plants. It is less certain how changes to the PM₁₀ standard will impact power plants.
   
• For ozone, many monitoring sites are currently out of compliance and further reductions will bring many more out of compliance. This will have significant implications for power plants.

The Particulate Matter and Ozone NAAQS

Colin McCall, Manager of the Ambient Group of All4, Inc. Within the past two years, the U.S. EPA has promulgated/proposed a 1-hour NO₂ NAAQS, a 1-hour SO₂ NAAQS, and a revised 8-hour ozone NAAQS.  In addition, U.S. EPA has finalized new source review (NSR) regulations related to the annual and 24-hour PM_2.5 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. Facilities may also be impacted by the new NAAQS levels even in the absence of a new project.

Conclusions:

• The new 1-hour SO₂ NAAQS levels are so stringent that they will drive project feasibility and project design.
• The NAAQS will replace BACT as the most critical PSD permitting issue.
• NAAQS modeling will be required even in the absence of new projects.
• Plan early for new projects and for the SO₂ NAAQS implementation process.

National Ambient Air Quality Standard Update

The BIOS, ABSTRACTS AND PHOTOS for both days are linked below.

BIOS, PHOTOS, ABSTRACTS - DECEMBER 9-10, 2010.htm