Particulate Matter and NSR Permitting in Maryland and Delaware

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1 Particulate Matter and NSR Permitting in Maryland and Delaware Gerallyn Duke EPA Region 3 March 28, /2/2012 1

2 Today s Discussion What is PM/PM10/PM2.5? How is it measured? What does the PM2.5 NSR Rule require/allow? What do NSR PM2.5 rules mean to you? Surrogate Policy Applicability determinations and PM2.5 What if LAER or BACT is triggered due to PM2.5? What PM rules are not covered by NSR rules? 4/2/2012 2

3 Particulate Matter (PM) TSP original indicator of PM NAAQS PM -1 st regulated under NSPS in Method 5 for filterable PM PM10 replaced TSP as NAAQS indicator in Method 201A for filterable, and, in 1991, Method 202 for CPM PM2.5 new indicator of NAAQS in Represents fine fraction and PM10 was retained as indicator of course fraction 4/2/2012 3

4 Particulate Matter and SIPs The first PM2.5 nonattainment areas were designated in 2005 Until 2005, most SIPs only addressed filterable PM (the old TSP standard) because there had not previously been many designated PM or PM10 nonattainment areas Improved methods 201A (filterable) and 202 (CPM) in 2010 March 16, 2012 Proposed CPM Fix Rule: Particulate matter emissions under 111 (NSPS and SIP) are determined consistent w/ respective test method, i.e., usually filterable only. For PM emissions for which no NSPS applies, states have discretion wrt CPM. 4/2/2012 4

5 What s in PM2.5? CPM + Filterable 4/2/2012 5

6 Condensable Emissions CPM exit the stack in the vapor phase, but quickly condense into a solid or liquid at ambient temperatures. CPM exists almost entirely within the PM 2.5 range, and accounts for anywhere from 40% to 80% of direct PM emissions. CPM is generally only considered for PM2.5 and PM10, not PM (TSP). Each state must interpret their own nonnsr PM SIP rules re CPM. 4/2/2012 6

7 Methods New method 202 to measure CPM New Method 201A* to measure filterable PM2.5 Old and still valid methods for filterable PM (also may be used with 202 as appropriate to determine total PM10/PM2.5) include: Method 5 (Part 60; PM, no particle sizing) Method 17 (Pt 60; PM where temp in stack does not affect PM) Method 201 (Pt 51; PM10) * There are exceptions to when this method may be used such as when stacks have moisture-entrained droplets and narrow stacks 7

8 Revised Test Method 202 for CPM Used in conjunction with Method 201A or equivalent method, which first removes filterable particulates Revised method 202 fixed the previous problems associated with artifacts and bias of results 4/2/2012 8

9 NEW Method 201A for Filterable PM10 & PM2.5 Method 201A (1990) Method 201A (2010)

10 May 16, 2008: Final EPA NSR Rules for PM2.5 New major source thresholds Precursors New SERs Interpollutant trading Transition period for PM2.5 Surrogate Policy NSR SIPs were due in 2011 Minor NSR affected as well 4/2/

11 PM2.5 Major Source Thresholds NNSR: 100 tpy PSD: 250/100 tpy Not a whole lot of new sources based on direct PM2.5, but precursors can cause some SO2 sources in PM2.5 nonattainment areas to become major Note if your source is located in a PM2.5 nonattainment area and state this in the fact sheet/technical memo There are separate nonattainment maps for PM2.5 annual and 24-hour PM2.5 NAAQS 4/2/

12 PM2.5 Precursors SO2 NOxunless demonstrated otherwise VOCs optional Ammonia optional 4/2/

13 Significant Emissions Rates for PM2.5 and Precursors direct PM2.5:10 tpy SO2: 40 tpy NOx: 40 tpy 4/2/

14 Applicability Determinations and Precursors If a modification at a major PM2.5 NNSR source results only in an increase + net increase of 45 tpy SO2, is NNSR triggered? If a source is only major for SO2 in a PM2.5 nonattainment area but the increase + net increase is only 18 tpy PM2.5, is NNSR triggered? 4/2/

15 More Questions... If a source is a major PSD source due to NOx but a modification results in an increase + net increase of only 11 tpy of PM2.5, is PSD triggered? Can PM2.5 offsets from a nonattainment area for the 24-hour standard be traded with a nonattainment area for the annual standard? A new source will trigger NNSR for PM2.5 but there are no PM2.5 offsets available. What can they do? 4/2/

16 NNSR Inter-pollutant Offset Trading Allowed on a regional or statewide basis Can trade: direct PM2.5 to precursor emissions increases one precursor to another precursor, and precursor emissions to direct PM2.5 emissions EPA trading ratios have been abandoned States may develop their own inter-pollutant trading ratios, if their SIP demonstrates that the ratios are appropriate for the specific State or Region Region III approved the one PM2.5 IP trade in the country; none have been done since EPA ratios were abandoned 4/2/

17 PM2.5 Surrogate Policy Early problems with implementing PM2.5 NAAQS Lack of tools to calculate PM2.5 Lack PM2.5 monitors Lack of adequate modeling techniques to predict impact 1997 PM10 Surrogate Policy issued However, there was no clear guidance on how to use the Surrogate Policy Courts subsequently ruled PM10 can be an arbitrary indicator of PM2.5 EPA has stated in petitions that PM10 must be shown to be a reasonable proxy for PM2.5, or has a strong statistical relationship to PM2.5 TODAY THE POLICY IS NO LONGER IN EFFECT 4/2/

18 More PM2.5 Developments October 20, 2010: Final Rule for Air Quality Analysis promulgated. Increment became effective December 20, Optional SILs and SMCs for PM2.5. December 21, 2010: Final Rule for Air Quality Analysis promulgated (effective January 1, 2011) finalized the methods for measurement of filterable and condensable PM. After January 1, 2011, states are required to consider inclusion of CPM emissions in new or revised BACT, LAER, RACT and minor NSR emissions limits that they establish. States have discretion re when to revise existing facility emissions limits or operating permits to consider CPM. 4/2/

19 So when can PM10 be considered a conservative indicator of PM2.5 in an applicability determination? Rarely! When all PM10 (including CPM) is considered PM2.5 to determine if a source is major Step 1 (the increase) ONLY Consider operations and fuel wrt PM2.5 Consider efficiency and effectiveness of controls wrt PM2.5 This matters not only in determining PTE/PAE but also for BAE 4/2/

20 Examples of How PM2.5 and PM10 Emissions Differ If you are running a process heater fuel-rich, proportionally more PM2.5 are emitted than a leaner system. How do operations change over time? What do you need to monitor to make sure PM2.5 emissions are controlled? If a contemporaneous decrease involved installation of a baghouse, PM10 may have been reduced but not PM2.5 unless they used a Gore membrane or ceramic filter in the baghouse If the project at hand involves installation of DSI, the particulate increase would be primarily PM10 and not PM2.5 If proposed BACT for an EGU is an ESP, it may need to be a wet - not dry ---ESP to control PM2.5 4/2/

21 What about NSR decisions made in the past that relied on the Surrogate Policy or only filterable PM? Past applicability determinations need not be revisited; However, future determinations, including netting, must consider CPM 4/2/

22 What needs to be in the NSR permit from here forward where PM2.5 is involved? BACT and LAER must reflect control performance for PM2.5 Testing must include appropriate methods Monitoring must consider how unit processes affect PM2.5 CPM + filterable 4/2/

23 What about Title V Permits? Do not impose new requirements; The form of PM will rely on the underlying requirement, e.g. a SIP limit, NSPS, MACT or a limit in previously issued preconstruction permit. Make sure your permit does not have vague permit limit(s) has test methods that relate to the limit and the pollutant (PM, PM10 or PM2.5) emission limits has clear monitoring Do you know whether/how your state rules address CPM? 4/2/

24 Status of PSD and NNSR Rules & SIPs - Maryland PSD NNSR MD passed its PM2.5 rules on May 16, 2011, ending the PM10 Surrogate Policy and establishing SO2 and NOx as precursors. MD is a SIP-Approved State: Because PSD regulations are IBR d in MD but not automatically, a SIP revision is required. MD s SIP implementing the PM2.5 PSD Rules is undergoing EPA review MD has not yet passed its PM2.5 rules; Appendix S applies so only SO2 is a precursor at this time PM10 Surrogate Policy ended 7/15/2008 MD has not submitted their SIP implementing the PM2.5 Rules 4/2/

25 Status of PSD and NNSR Rules & SIPs - Delaware PSD NNSR DE passed its PM2.5 rules on, ending the PM10 Surrogate Policy and establishing SO2 and NOx as precursors.??? DE is a SIP-Approved State DE s SIP implementing the PM2.5 PSD rules has not been received at EPA DE passed its PM2.5 rules on DE is no longer relying on Appendix S: SO2 and NOx are precursors PM10 Surrogate Policy ended 7/15/08 Where is Delaware s SIP? 4/2/

26 Take-Away -PM2.5 is its own regulated NSR pollutant - There are two forms of PM2.5 NAAQS (24-hour & annual) so 2 PM2.5 nonattainment maps -New PM2.5 NSR rules created new applicable requirements for permits - New methods developed to address unique characteristics of PM2.5 -PM10 Surrogate Policy has ended -These changes affect how applicability determinations are done in both PSD and NNSR, potential controls for particulate matter, and monitoring 26

Development of PM2.5. James Boylan and Byeong-Uk Kim. May 2, Chicago, IL

Development of PM2.5. James Boylan and Byeong-Uk Kim. May 2, Chicago, IL Development of PM2.5 Interpollutant Trading Ratios James Boylan and Byeong-Uk Kim Georgia EPD Air Protection Branch 2012 EPA R/S/L Modelers' Workshop 2012 EPA R/S/L Modelers Workshop May 2, 2012 - Chicago,