Presentation to Utility Restructuring Task Force

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Presentation to Utility Restructuring Task Force

• November 26, 2001

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ComparisonHB 2759 Bill
compared to what DEQ already does.
HB 2759 DEQ
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DEQ PermittingState Permit Program

• A state program operated under regulations
  adopted by the State Air Pollution Control Board.
• For emissions ? 250 tpy.
• ?100 tpy for certain source categories.
• Used statewide for sources less than federal
  major in size (non PSD).

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State Permit Program (contd)

• Requires a technology review for utilization of
  proven controls.
• Requires an air quality analysis to determine
  impact of emissions on health based air quality
  standards.

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State Permit Program (contd)

• Source must be designed, built, and equipped to
  operate without interferring with attainment or
  maintenance of any air quality standard.
• Conservative screening models are use i.e.
• (1) Worst case emissions
• (2) Worst case meteorology

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State Permit Program (contd)

• Results from this model always over predict the
  impact
• If you pass this test, real world impacts will
  always be less.

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Prevention of Significant Deterioration (PSD)
Permit Program

• A national program established by the Clean Air
  Act.
• Used for major sources in attainment areas.
• Requires Best Available Control Technology
  (BACT).
• Requires two air quality impact analyses
• a) PSD increment consumption.
• b) Impact on air quality standards if
  significant.

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Modeling Analysis

• EPA established national significant impact
  levels for source alone.
• If insignificant, no further analysis is needed.
• If impact is significant, you model the impact on
  the significant area for those sources within the
  significance area plus sources located 50
  kilometers beyond the significance area.

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Modeling Analysis (contd)

• Significant level for NO2 -- (annual standard is
  100 micrograms per cubic meter).
• 1. Class II areas (most of Virginia)
• 1 micrograms per cubic meter.
• 2. Class I areas (Shenandoah
• National Park and James River
• Face Wilderness area 0.1
• micrograms per cubic meter.

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Modeling Analysis (contd)

• Initial modeling is very conservative using
• a) Maximum predicted
• emissions.
• b) Worst case meteorology.
• Predicted impact will be greater than what really
  happens.
• Significant impact level (SIL) varies for Class
  II and Class I areas.
• Sources must pass both tests.

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Modeling Analysis (contd)

• While cumulative impact is not defined anywhere,
  the PSD analysis for criteria pollutants is, in
  effect, a cumulative analysis.

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Impact on Ozone

• No individual source model approved by EPA for
  predicting ozone impact.
• We do this periodically with multiple sources to
  satisfy public concern.
• It is expensive and time consuming.
• The procedure we use is as follows
• a) Photochemical model -- to predict ozone
• impact.

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Impact on Ozone (contd)

• b) Emissions Model -- to include all sources
• within the domain.
• c) Meteorological model for met data.
• d) Ozone episode July 4 - 8, 1996.
• e) Domain modeled contains 5,175 grid
  cells,
• each 12 kilometers by12 kilometers.

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Impact on Ozone (contd)

• Latest run used these eight plants
• Dominion Virginia Power Remington 249T.
• Dominion Virginia Power Ladysmith 249T.
• ODEC Louisa
  244.7T.
• Tenaska - Fluvanna County
  577T.
• Com. Chesapeake Power Station
  119T.
• White Oak - Pittsylvania County
  602T.
• Mirant - Pittsylvania County
  400T.
• Competitive Power Vent, Fluvanna
  321T. Total Emissions -- 2,761.7 Tons
  

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Maximum Ground Level Impact

• 2.3 PPB in 4 grid cells.
• 1.0 PPB or above in 30 grid cells.
• Negligible in all other cells.
• 1 PPB impact in Northern Virginia.
• Negligible impact in Richmond and Hampton Roads
  maintenance areas.
• Well below what is considered significant for
  this type of model i.e. 10 ppb

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Public Information

• DEQ web site contains a wealth of information
  about proposed sources including
• 1. General Description
• 2. Plant Name
• 3. Location
• 4. Application Status
• 5. Permit Type
• 6. Facility Type
• 7. Agency Contact

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Public Information (contd)

• Most such facilities require a public briefing
  about the facility, plus a public hearing on the
  proposed permit.
• Info on AQ impacts is provided to the public
  prior to and during these hearings.

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Cumulative Impact Analysis for Ozone

• It is expensive to do.
• To set up to do this with an outside firm would
  cost between 100,000 and 500,000.
• Putting data in takes five working days.
• If we used a different ozone episode, it would
  take 3 months.

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Cumulative Impact (contd)

• Modeling and post processing takes 10-15 work
  days.
• Cost using existing episode is about 10,000.
• Much more than that for a new episode.
• Limitations
• 1) Model not sensitive enough for evaluating a
• single source.
• 2) Typically we do model for groups of 8 - 10
• plants.

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In Summary

• DEQ will not issue a permit if a facilitys
  emissions would adversely affect health based air
  quality standards adopted by EPA (NAAQS).