Ambient Air Quality Rules will be Tough to Meet - Hot Topic Hour on Thursday, February 13, 2014

New modeling and monitoring procedures, some of which are only in draft but are being imposed on permit seekers, are creating major problems in moving new projects forward. Four experts weighed in on the impact of existing and proposed NAAQS standards.

Brian Stormwind, Manager Air Quality Engineering & Studies at AECOM, offered advice on “Dealing with Implementation of the 1-hour SO₂ NAAQS: Challenges and Options.”  The stringency and nature of the 1-hour SO₂ NAAQS is expected to significantly impact industrial clients for attainment designations that are overdue for most areas. EPA's strategy seems to focus on the largest SO₂ sources (at least one thousand tons/year), while environmental groups have already submitted modeling with purported NAAQS violations due to selected sources to the EPA and state agencies for consideration in the current designation process. The Sierra Club has also sued EPA over the delays in the designations and may force EPA to speed up this process in a settlement agreement. A soon-to-be-released “Data Requirements Rule” will be very important in this regard.   Brian came to the following conclusions:

• Most areas are deferred for SO₂ attainment.
• EPA is considering either modeling or monitoring approach for Priority Areas, but will Sierra Club accelerate this process?
• Modeling options should be explored first, and then optimum strategy can be developed.
• Sources in Priority Areas should consider strategic modeling analyses soon to provide maximum flexibility for choices.

Richard Hamel, Senior Project Manager Air Quality and Climate Change (AQCC) Practice at Environmental Resources Management (ERM), indicated the challenge with  “Dark Skies Ahead: The Challenges of Modeling the New NAAQS for Fossil-Fuel Power Plants.”  The new 1-hour SO₂ and NO₂ probabilistic NAAQS, as well as the newly tightened annual PM_2.5 standard and the already stringent 24-hour PM_2.5 standard, have brought to the table a whole new set of challenges in showing compliance compared to the older, deterministic NAAQS. Richard made the following important observations:

• The new NAAQS present unprecedented challenges to existing and new fossil fuel-fired power plants.
• Using a worst-case approach to modeling against probabilistic standards yields overly-conservative results.
• Most existing facilities have not modeled the new standards, leading to questions regarding compliance status.
• Most modeling refinements require case-by-case approval, increasing exposure to legal challenges.
• The status of future regulations increases uncertainty about the path to compliance.

Gale F. Hoffnagle, CCM, QEP, Senior Vice President and Technical Director Air Quality Consulting Practice Leader at TRC Environmental Corporation, enumerated problems related to obtaining permits under the new NAAQS.  The changes to the NAAQS and the way they are being implemented result in very expensive permit applications. The fact that almost every permit is being challenged is leading to substantially longer permitting times and greater uncertainty. The burden is severe enough to limit development of new plants. There was a discussion as to what could be done to overcome this obstacle. The answer is that it will have to be done on a case-by- case basis

Mack McGuffey, Partner at Troutman Sanders LLP, conveyed the impact and status of the NAAQS. EPA is required to update its national ambient air quality standards (NAAQS) every five years, but never in the history of the Clean Air Act has the Agency issued so many NAAQS revisions so quickly. A newly strengthened standard can seem like changing the rules of the game in the middle of a play to a facility seeking to construct a new boiler or turbine or modify its existing equipment, even before the newly revised standard has been fully implemented. Many of the standards are also subject to litigation, which can further complicate the picture. Due to the complex procedure involved in implementing NAAQS revisions, major emitting facility owners and operators should keep a close watch on the progress of EPA's recent and promised revisions, particularly those for fine particulate matter (PM_2.5), ozone and sulfur dioxide (SO₂), to avoid unwelcome surprises in the form of unexpected permitting and emission control requirements.

While many areas presently meet the current requirement of 84 ppb for ground level ozone, very few areas will be in attainment with the proposed 60-70 ppb.

Over 20 utility personnel signed up for the webinar. Utilities represented included:

Associated Electric Cooperative, Inc.

Entergy

Exelon

Great River Energy

LG&E and KU Energy

Minnesota Power

Mississippi Power

Montana-Dakota Utilities

Nebraska Public Power

South Mississippi Electric Power Assn.

Southern Company Services

TECO

Tri-State G&T

Xcel Energy

The entire February 13 recording can be heard at: Impact of Ambient Air Quality Rules on Fossil-Fueled Boilers and Gas Turbines    100 minutes
You will need to enter your name and email address after clicking link to view recording. 
 

Bios, Photos and Abstracts are as follows:  BIOS, PHOTOS, ABSTRACTS - FEBRUARY 13, 2014.htm

The individual presentations are as follows:

• Impact of Ambient Air Quality Rules on Fossil-fueled Boilers and Gas Turbines Webinar - Hot Topic Hour February 13, 2014  (Webinar Recording dated: 2/13/2014)

• Dark Skies Ahead: Modeling the New NAAQS by Richard Hamel, Environmental Resources Management - Hot Topic Hour February 13, 2014  (Presentation dated: 2/13/2014)
• National Ambient Air Quality Standards (NAAQS) by Mack McGuffey, Troutman Sanders - Hot Topic Hour February 13, 2014  (Presentation dated: 2/13/2014)
• Understanding Today's CAA Permitting Programs: Air Quality Modeling Update by Gale Hoffnagle, TRC Environmental - Hot Topic Hour February 13, 2014  (Presentation dated: 2/13/2014)
• Dealing with Implementation of the 1-Hour SO2 NAAQS: Challenges and Options by Brian Stormwind, AECOM - Hot Topic Hour February 13, 2014  (Presentation dated: 2/13/2014)