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WESTAR 2003 Fall Technical Conference on

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N. Cheyenne Indian Res. ( MT) = 172 km. Permit Review Period = April 2001 September 2002 ... located 24 km south of Northern Cheyenne Indian Reservation ' ... – PowerPoint PPT presentation

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Title: WESTAR 2003 Fall Technical Conference on


1
WESTAR 2003 Fall Technical Conference on PSD
Increment Tracking Cumulative Effects
Modeling Seattle, Washington
Conducting Class I Area Increment Analyses Ken
Rairigh, P.E. State of Wyoming Department of
Environmental Quality - Air Quality Division
September 16, 2003
2
Requirements for Conducting a Class I Area
Increment Analysis in the PSD Rule
  • No specific requirements provided in PSD Rule for
    conducting increment analyses for New Source
    Review
  • PSD Rule states
  • An analysis of the predicted impact of emissions
    from the facility is required
  • for all pollutants which are emitted in
    significant amounts.
  • Such analysis shall identify and quantify the
    impact on the air quality in the area
  • of all emissions not included in the baseline
    concentrations including,
  • but not limited to, those emissions resulting
    from the instant application
  • and all other permits issued in the area.
  • The purpose of this analysis is to determine the
    total deterioration of air quality
  • from the baseline concentrations.

3
EPA Guidance on Conducting a Class I Area Analyses
  • Guideline on Air Quality Models (Revised 2003)
  • New Source Review Workbook (EPA, 1990)

If proposed major source or major modification
located lt 100 kilometers from a Class I area
- Increment Analysis
- Analysis of Air Quality Related Values (AQRVs)
4
Notifying the FLM of the Proposed Modification or
Proposed New Source
  • If proposed major source or major modification
    located lt 100 kilometers from a Class I area

March 19, 1979 memorandum from EPA Regional
offices Provide notice to the Federal Land
Manager of any proposed PSD sources that would
locate within 100 kilometers of a Class I area.
5
Notifying the FLM of the Proposed Modification or
Proposed New Source
  • Not clearly defined when proposed PSD source
    located gt 100 kilometers from Class I area

PSD Rule states, the Administrator shall provide
written notification to all Federal Class I Area
Federal Land Managers of such proposed new major
emitting facility or major modification whose
emissions may affect the Federal Class I Area or
affect visibility in such Area.
6
How to Determine If Proposed PSD Source May
Affect a Class I Area ?
  • Use Class I Significant Impact Levels (SILs)
  • Brought into Proposed Rules in 1996
  • No prescribed distance criteria for using SILs
  • lt 100 km from Class I area use Class I SILs
    for any PSD source
  • gt 100 km Rely on Class I SILs for large PSD
    sources

- Modeled impact gt Class I SILs gt Cumulative
analysis
  • No prescribed distance for constructing the
    emissions inventory
  • for cumulative Class I increment analysis

7
Proposed Class I SILs
  • Two Sets of Proposed Class I SILs (EPA FLM)
  • Pollutant Ave Period EPA FLM
  • SO2 3-hour 1.0 0.48
  • 24-hour 0.2 0.07
  • Annual 0.1 0.03
  • PM10 24-hour 0.3 0.27
  • Annual 0.2 0.08
  • NOx Annual 0.1 0.03
  • EPA Class I SILs are calculated as 4 of the PSD
    Class I increments

FLMs have typically deferred to EPA Class I
SILs Apply to Increment Consumption, not AQRVs
8
Constructing the Cumulative Class I Increment
Emissions Inventory
  • Based on the lack of guidance, State of Wyoming
    DEQ developed some concepts

Start with Class II increment source inventory
(50 km) Includes major and minor sources
Add 50 kilometers onto Class II increment
source EI (100 km) Does not include sources
near Class I areas if distance
from source to Class I area gt 100 km
9
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11
What About Sources Located Near the Class I Area ?
  • Alternative approaches under consideration by
    WDEQ to better define increment inventory
  • Calculate distance (radius) from proposed major
    source or major modification to Class I Area(s)
    and include additional major sources

1. Circle centered on location of PSD source
2. Circle centered on Class I Area(s)
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14
Issues Associated With Acquiring Emissions
Inventories for Cumulative Analyses
  • Difficult to acquire baseline source/emissions
    data

Model actual or allowable emission rates ?
Short-term emissions data not available
Defer to allowable emissions on a
short-term basis
Acquiring emissions data from multiple states
Need a regional database that states can access
AIRS is gone, NEI is successor
NEI format is widely used in regional scale
analyses
15
Model Selection for Class I Area Analyses
  • Distances lt 50 km

ISC, AERMOD, CTDMPLUS, CALPUFF
  • Approved models under Appendix A of the
  • Guideline on Air Quality Models

( AERMOD expected to be added to Appendix A)
September 8, 2003 Notice in Federal
Register
16
Model Selection for Class I Area Analyses
  • Distances gt 50 km

CALPUFF, CMAQ, UAM-V, CAM-X
CALPUFF is the least resource intensive
Established guidance from EPA and FLMs
already being implemented for CALPUFF by some
states (IWAQM Phase II Report)
CALPUFF has been recommended by EPA for
assessing PSD increment consumption - April
15, 2003 Revisions to Guideline on Air Quality
Models
17
CMAQ, UAM-V, CAM-X
  • Photochemical grid models are very resource
    intensive

Model run times may preclude the use of more
than one year of meteorological data
Much better treatment of chemistry than
CALPUFF
Could use at larger distances than CALPUFF
18
IWAQM Phase II Prescribed Methodologies for
CALPUFF
  • CALPUFF Lite methodology

Simplistic, single station met data
Intended as a screening-level option for
CALPUFF
Typically limited to single source analyses
CALPUFF refined methodology
More complex, 3-D wind field, prognostic data)
Required for cumulative source increment
analyses
Requires a lot more resources and time to
QA/QC meteorological inputs than CALPUFF
Lite analysis
19
Case Study Conducting Class I Analyses The
WYGEN 2 Experience
  • WYGEN 2 - Proposed Coal-Fired 500 MW Power Plant
  • Located in Campbell County, WY
  • Nearest Class I Areas to proposed WYGEN 2
    location
  • Wind Cave NP (SD) 168 km
  • Badlands NP (SD) 213 km
  • N. Cheyenne Indian Res. (MT) 172 km
  • Permit Review Period gt April 2001 September
    2002

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22
Class I Modeling Protocol
  • April 25, 2001 May 24, 2001
  • WDEQ required applicant to submit a Class I
    modeling protocol to WDEQ and FLM

  Follow-up meeting to be held after the FLM
(NPS) reviews Class I modeling protocol
Class I area modeling protocol submitted to
WDEQ and the National Park Service (NPS)
Conference call with NSR applicant, DEQ, and
FLM (NPS)
23
Class I Modeling Protocol Contd.
  • Proposed CALPUFF Lite for screening level
    analysis and also CALPUFF refined analyses, if
    required

Compare impacts from new source to proposed
Class I SILs
Class I protocol did not specifically commit
to or identify additional analyses if
source's impact was greater than Class I SILs
(OUR BAD !!)
The NPS did not comment on the Class I
modeling protocol
24
Initial Proposed Emission Rates Used in Class I
Area Significance Analysis
  • SO2
  • Annual emission rate 3,381 TPY
  • Short-term rates for boiler 0.15 lb/MMBtu
    (30-day average)
  • 0.17 lb/MMBtu (2-hour average)
  • NOx
  • Annual emission rate 2,028 TPY (0.09 lb/MMBtu)
  • PM10
  • Annual emission rate 421 TPY (0.018 lb/MMBtu)

25
CALPUFF Screening Level Analysis
  • Predicted PM10 and NOx impacts from the proposed
    new source were at least 1-2 orders of magnitude
    below the proposed Class I SILs for these two
    pollutants
  • WDEQ did not require applicant to conduct
  • cumulative Class I NOx and PM10 increment
  • consumption analyses

26
CALPUFF Screening Level Analysis
  • July 2001 November 2001

Permit application received
Modeled SO2 impact from the proposed new
source greater than 3-hour 24-hour Class I
SILs
WDEQ required the applicant to conduct a
cumulative SO2 Class I increment consumption
analysis for three (3) designated Class I areas
Cumulative analyses required going to refined
CALPUFF analysis (IWAQM Phase II)
27
CALPUFF Refined Increment Analysis
  • November 2001 March 2002

CALMET wind field and SO2 emissions inventory
provided to applicant by WDEQ
Cumulative source emissions inventory based on
SO2 sources located within 100 km of the
proposed WYGEN 2 site
Applicant submits cumulative PSD Class I
increment consumption analysis for SO2
SO2 emission rates based on WDEQs BACT
determination
28
BACT Emission Rates Used in CALPUFF Refined
Increment Analyses
  • SO2
  • Annual emission rate 2,254 TPY
  • Short-term rates for boiler 0.10 lb/MMBtu
    (30-day average)
  • 0.15 lb/MMBtu (3-hour average)
  • NOx
  • Annual emission rate 1,578 TPY (0.07 lb/MMBtu)
  • PM10
  • Annual emission rate 270 TPY (0.012 lb/MMBtu)

29
Permit Out to Public Notice
  • May 2, 2002 - Permit analysis out on public
    notice
  • May 9, 2002 - FLM requested CALMET CALPUFF
    files
  • First time we have heard from FLM in a year
  • FLM had concerns that no upper air stations were
    used in CALMET simulation
  • May 31, 2002 - Comments received from EPA, FLM,
    and Environmental Defense organization

Now, All He Breaks Loose !!
30
Comments From EPA
  • Inclusion of additional major sources in Class I
    increment consumption analyses

Colstrip power plant (MT) Ben French power
plant (SD) South Dakota cement plant (SD)
Include baseline facilities near the proposed
WYGEN 2 site if there have been emission
increases since the minor source baseline date
was triggered
31
Comments From FLM
  • FLM did not receive a technical report describing
    Class I increment analysis and assumptions used

FLM claims application is incomplete
Based on lack of cumulative AQRV analyses
Concerns regarding the impacts of emissions to
visibility and other AQRVs at Wind Cave and
Badlands National Parks
No formal adverse impact determination to
AQRVs
32
Comments From Environmental Defense
  • WDEQ unlawfully relied upon significant impact
    levels (SILs) for Class I areas to exempt WYGEN 2
    from a cumulative modeling analysis for the NO2
    and PM10 increments at the nearby Class I areas
  • WDEQ did not require the applicant to conduct
  • cumulative visibility and AQRV analyses
  • Remember what the PSD Rule requires

An analysis of the impairment to visibility,
that would occur as a result of the facility or
modification
33
WDEQ Ran Additional Analyses To Evaluate Impact
From Colstrip
  • Colstrip power plant (Unit 3 Unit 4) included
    in Class I increment analysis

Unit 1 Unit 2 are pre-baseline sources
Not included in Class I increment analysis
Ben French power plant and South Dakota cement
plant were also pre-baseline sources and were not
included in our analyses
34
Cumulative Class I Increment Analysis Results
  • Badlands National Park Class I Increments
  • HSH 3-hr 1.8 mg/m3 3-hr 25 mg/m3
  • HSH 24-hr 0.5 mg/m3 24-hr 5 mg/m3
  • Wind Cave National Park
  • HSH 3-hr 2.1 mg/m3
  • HSH 24-hr 0.7 mg/m3
  • Northern Cheyenne Indian Reservation
  • HSH 3-hr 27.3 mg/m3 gt Single modeled
    exceedance
  • HSH 24-hr 3.5 mg/m3
  • Colstrip power plant (MT) contribution 99.9

35
Use Class I SILs To Demonstrate Insignificant
Impact From WYGEN 2
Modeled exceedance was due to Colstrip power
plant located 24 km south of Northern Cheyenne
Indian Reservation
Near-field impact CALPUFF may not be the
right tool
WDEQ compared new sources contribution to
Class I SIL
Contribution from WYGEN2 at NCIR was 0.07
mg/m3 (7 of Class I SO2 3-hr SIL)
Proposed new source does not significantly
impact the location of the modeled exceedance
36
Final Decision
  • September 26, 2002

WDEQ demonstrated that the proposed source
does not exceed the Class I increments, or
contribute significantly to any existing Class
I increment exceedances
WDEQ issued final decision to approve NSR
permit for WYGEN 2 after having reviewed all
comments received
NPS has appealed WDEQ's final issuance of
permit
NPS appeal based on visibility impacts, not
increment issues
37
FLM Involvement in the Permit Review Process
  • WDEQ involved FLM in the application review
    process as required by the PSD Rule

Early involvement with FLM
Consultant sent Class I modeling protocol to
FLM and requested approval
Submitted permit application to FLM within 30
days of receipt
Submitted permit analysis review, permit
conditions, and proposed decision on public
notice
38
FLM Responsibility in the Permit Review Process
  • FLMs are part of the PSD review process

WDEQ expects the FLM to review permit
application in a timely fashion
WDEQ expects some kind of response from FLM
if a protocol has been submitted to FLM
FLM needs to understand and work within our
review process and required time lines as well
39
Changes in FLM Notification Based on this
Experience
  • Improve on communications with FLM

Upon determining completeness of
application - Notify FLM that application is
complete - Submit all information to FLM that
has been received since initial permit
application
40
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41
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