TRC Senior VP, Technical Director and Air Quality Practice Leader, Gale Hoffnagle delivered this presentation as part of a webinar series called Masterminding Air Act Compliance. The presetnation addressed Clean Air Act regulations, timeframes for compliance and tips for success.

1. Understanding Today’s Clean Air Act Challenges
November 8, 2012

2. The New NAAQS
 New Short-term NAAQS
- Sulfur Dioxide (2010) 1 Hour Average (3,24 and Annual)
- Nitrogen Dioxide (2010) 1 Hour Average (Annual only)
 Other New NAAQS
Ozone (2008) Reduced 8 Hour Average
Lead (2008) Reduced Quarterly Average (1/10)
PM2.5 (2006) Reduced 24 Hour Average (1/2)
Carbon Monoxide No change
These combined make existing and new sources subject to
tremendous pressure on emissions.
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3. NO2 NAAQS
 New NAAQS is 188 µg/m3(or 100ppb) but for a 1 hour
average. Depending upon the meteorology of the site this
results in a 6.6 times lower threshold to meet. It therefore
will be substantially harder to meet. Annual standard
remains.
 Compliance is determined by the 98% of the days over 3
years, i. e. each day with a concentration over 188 µg/m3
counts as an exceedance day. The eighth exceedance day is a
violation for that year. The 24th exceedance day in 3 years is
non-attainment.
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4. NO2 NAAQS Schedule
 Primary emphasis of 1 Hour NAAQS is roadways
(50-500 meters) which are currently unmonitored
 Requires State monitoring plans by July 1, 2011
 Requires deployment of new monitors by July 1, 2013
 Includes requirement for met data.
 Non attainment designations by January 2012 based on
2008-2010 data and then another round when the roadway
monitoring is in.
 State Implementation Plans due 18 months after designation
(July 2013) and attainment required in 5 years (January 2017)
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5. NO2 NAAQS the Real Trouble
 States have virtually no control over
automotive emissions, thus point sources
near roadways could be in for control.
No implementation guidance yet issued.
 The real danger, not even discussed in the
Final rule or the Regulatory Impact Analysis
is the application of the 1 Hour NAAQS to
point sources.
 This will have a tremendous effect on all
types of industrial sources, new and existing.
The effect on distributed generation and
emergency generators in urban areas could
be huge and the effect on the oil and gas
industry could be monumental.
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6. NO2 NAAQS hints for compliance
 Have on hand testing that demonstrates
the NO2/NOx ratio of your stack emissions. NAAQS is for NO2
only.
 Perform “preliminary modeling” to determine potential for
compliance with the NAAQS, whether isolated source or in
industrial area.
 Based on results of modeling, determine whether ambient
monitoring is necessary
to demonstrate actual background concentrations or that the
model is over predicting actual concentrations.
 EPA’s own modeling showed that 90%
of sources will not meet NAAQS
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7. SO2 NAAQS
 New primary NAAQS of 196 µg/m3 (75 ppb) as a 1 Hour
average results in a 7.7 times more restrictive standard. New
standard is 99% over three years.
 This NAAQS is the 99% of the days with at least 1 hour above
the level of the NAAQS, i.e. 4th highest value over three years.
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8. SO2 NAAQS Schedule
 Focus of attainment demonstrations was to be on modeling,
which was said to be a continuation of past policy use.
 Any new monitors by December 2012, with 3 years of data
by 2015.
 State attainment decisions by June 2011, EPA attainment
decisions by June 2012. This is delayed!!
 Attainment by June 2017.
2011 2017
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9. SO2 NAAQS hints for compliance
 Perform “preliminary modeling” to determine potential for
compliance with the NAAQS, whether isolated source or in
industrial area.
 Based on results of modeling, determine whether ambient
monitoring is necessary to demonstrate actual background
concentrations or that the model is over predicting actual
concentrations.
 EPA’s own modeling showed that 90% of sources will not
meet NAAQS
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10. PM2.5 NAAQS
 Old NAAQS was 65 µg/m3 on a 24 hour basis
(98%) and 15 µg/m3 on an annual average
basis.
 New NAAQS is 35 µg/m3 on a 24 hour basis.
The annual was retained at 15 µg/m3 but the
EPA has proposed to lower to 11-13 µg/m3.
 Modeling assumes that the SOx and NOx
emissions are converted to particles through
combining with ammonia in the atmosphere
thereby becoming sulfates and nitrates.
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11. PM2.5 NAAQS (cont)
 EPA recently promulgated PSD increments for PM2.5
– Class II areas
 Annual average 4 ug/m3 (1/4th)
 24 Hour average 9 ug/m3 (1/4th)
– Class I areas (National Parks , etc)
 Annual average 1 ug.m3
 24 Hour average 2 ug/m3
– Significance limits (Class II and Class I)
 Annual Average 0.3 and 0.06 ug/m3
 24 Hour Average 1.2 and 0.07 ug/m3
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12. PM2.5 NAAQS hints for compliance
 Have stack teats to understand exact nature of particulate
emissions (filterable, condensable, etc)
 Perform “preliminary modeling” to determine potential for
compliance with the NAAQS, whether isolated source or in
industrial area.
 Based on results of modeling, determine whether ambient
monitoring is necessary to demonstrate actual background
concentrations or that the model is over predicting actual
concentrations.
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13. Future (election delayed) NAAQS Changes
 On June 14, 2012 EPA proposed to lower the annual average
PM2.5 NAAQS again to 11-13 µg/m3
 Proposed to set a Secondary NAAQS to improve visibility in
urban areas
 Gave Advanced Notice of Proposed Rulemaking to revise
Ozone NAAQS to 50-60 ppb
 Lead NAAQS proposal by February 2014
 NO2 NAAQS proposal by August 2015
 SO2 NAAQS proposal by February 2016
 CO NAAQS proposal by July 2016.
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14. The CSAPR/CAIR Delemma
 EPA wants to impose a regional approach to ozone and
PM2.5 compliance in the eastern US.
 Court has stymied approaches of two administrations.
 Trading under State plans can still go forward but
foundation for those plans is subject to change.
 No resolution is expected in the near future.
ozone
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15. BART
 There are many legal challenges to EPA BART
determinations (SCR for all!).
 EPA’s reliance on CSPAR for BART in the east is now moot
and may force modeling analysis for eastern sources.
 EPA’s reliance on insignificant changes in Deciviews as
determined by models was also struck down by the court
and a basis for challenges.
 Understand your BART modeling analysis.
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16. MATS
 EPA (due to political pressure) is reconsidering new
source limits.
 EPA is not reconsidering existing source limits.
 Compliance by April 2015
 States are handing out 1 year extensions.
 Utilities must act now to build case
for additional “reliability extensions”
which EPA expects to be rare.
 No FERC policy yet.
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17. RICE MACT
 Insure that diesel engines meet the MACT requirement
of less than 23 ppm CO.
 Compliance deadline May 2013. Are you ready?
 One year extensions.
 Oxidation catalyst manufacturers will run out of capacity
soon and many installation require more engineering than
the manufacturers provide.
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18. NSPS for Electric Utilities
 EPA proposed 1000 tons CO2e/MW
which means combined cycle with
HRSG’s or sequestration.
 Expect finalization after election.
 Current applicants, of course, must
comply with the proposal.
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19. Summary
 Know your emissions of SO2, NO2, PM2.5, and HAPs
 Do preliminary modeling, so that you know the situation
for compliance.
 Decide whether ambient monitoring will help determine
the accuracy of compliance.
 Follow the implementation schedules and regulations in
your State. The NAAQS will not change but the
implementation may change.
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20. Gale F. Hoffnagle, CCM, QEP
P: xxx.xxx.xxxx | E: GHoffnagle@trcsolutions.com
www.trcsolutions.com