EPA Ambient Air Monitor Values Reports

Find summary reports for ambient air monitoring stations here:

Monitor Values Report AirData US EPA

Thermal & Catalytic Oxidation

Good description of thermal and catalytic oxidation technologies.

Article

VOC/NOx Screening for Ozone Standards

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The Scheffe memo has been used as a screening method to demonstrate compliance with ozone standards based on a facility's VOC and NOx PTEs. The first link below is a poor-quality scanned version of the memo with "draft" stamped on several pages. The second link is from a Nevada web site; it's cleaner and doesn't have the draft markings, but it cautions that it's a recreation of the original and they don't guarantee its accuracy.

Scanned original (marked "draft")

Cleaned version on Nevada web site

Here's a table and chart based on the Scheffe method that was used for permitting a previous incarnation of the Montana Advanced Biofuels project (stored in project folder ACT203382).
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Caterpillar Presentation - NESHAP Z4 & NSPS J4

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This is a presentation that Jeff picked up attending an Air Quality Technology Transfer meeting in Wyoming recently. It's from Caterpillar and describes requirements of the various tiers in the NESHAP ZZZZ and NSPS JJJJ subparts.
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Biomass Wars

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Here are two well-done web sites with opposite views on the benefits of using biomass for heat and power.

Partnership for Policy Integrity (OFPI)

National Alliance of Forestry Owners
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State & Local Modeling Guidelines

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Minnesota PCA. 10/2004.
MPCA modeling page. See especially modeling protocol forms and spreadsheet. (Page contains link to above guidance, but link didn't work when access attempted 8/11.)

San Joaquin Valley. Lots of useful guidance and data, especially regarding NOx modeling.

Iowa DNR. Lots of good stuff including:

• 20D "Screening Threshold Method for PSD Modeling; North Carolina Air Quality Section." Screening method for selecting nearby sources to include in a cumulative impacts analysis.
• Source Characterization Guidance and Tools. These include spreadsheets for calculating flare parameters and building volume source parameters. Documents provide guidelines on modeling haul roads, storage piles, storage tanks, truck and rail loadouts, and other specific types of sources.
• They also include guidance on the ambient ratio method for modeling annual average NO2 NAAQS compliance. But it hasn't been updated with any new information for modling 1-hour average compliance.
• They have a PSD modeling protocol template, but it's only a couple of pages and isn't nearly as extensive as we would need.
• VISCREEN tool.
• A spreadsheet that calculates shortest distance from a Class I area.

North Carolina DENR, Division of Air Quality. Includes quarry modeling and air toxics modeling guidance. PSD modeling guidance provides the 20D rule for selecting nearby sources outside of the SIA.

Texas Commission on Enironmental Quality (TCEQ). As of today (8/19/11), modeling guidelines not posted but in work. Includes draft checklist and e-mail discussion group.

Arizona DEQ modeling guidance. This page links to a 2004 guidance document and includes a March 2011 update memo. The memo mostly adds AERMOD as the prefered short-range model and clarifies air toxics modeling requirements. The page also includes links to some EPA resources such as the RBLC, the applicability determination index, and two policy databases.

Bay Area Air Quality Management District (BAAQMD). June 2007. Mostly outlines requirements; not much by way of practical guidance.

New Mexico Environment Department Dispersion Modeling and Emissions Inventory Section. Extensive guidance, updated April 2010. Noticed it says the following about modeling wind erosion from piles: "Wind erosion of storage piles should not be modeled, as it says in AP42 not to use the equations for wind erosion in a steady state model." Site includes links to other resources.

South Carolina Dept. of Health and Environmental Control. 2001

Michigan DEQ. Last revised September 2009.

Ohio EPA. 2003. Q&A format. Not a lot here.

Haul Road Emissions Modeling. Last updated June 2004. According to this presentation at the May 2010 Modeler's Workshop in Portland, OR, the Haul Road Work Group is working to update its recommendations with a report due out early 2011. (This EPA R5 presentation says a report should be issued by fall 2011. I found nothing on the internet as of 11/7/11.)

Albuquerque Modeling Guidance. Includes road dust emissions guidelines, including this introductory discussion:

"Careful examination of AP-42 for both Paved and Unpaved Roads shows the science of haul road modeling is dubious in nature. Furthermore, the WRAP Fugitive Dust handbook published  November  2004  shows  paving  of  haul  roads  and  keeping  those  roads  clean results in nearly 100  percent control of PM10 emissions. Modeling of paved haul roads will not be required if the applicant is willing to implement reasonably available control measures as specified below or if the applicant implements a department approved best management practices plan."

NEPA Significance

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Full article. Excerpt:

"According to the NEPA Regulations adopted by the President’s Council on Environmental Quality (CEQ) (40 CFR 1500-1508), the term significantly is based on the twin criteria of context and intensity (40 CFR 1508.27).

"Context means the affected environment in which a proposed action would occur; it can be local, regional, national, or all three, depending upon the circumstances."

"Intensity means the degree to which the proposed action would involve one or more of the following 10 factors:
• Adverse effects associated with “beneficial projects”;
• effects on public health or safety;
• unique characteristics of the geographic area (e.g., historic resources, park lands, prime farmland, wetlands, wild and scenic rivers, ecologically critical areas);
• degree of controversy;
• degree of highly uncertain effects or unique or unknown risks;
• precedent-setting effects;
• cumulative effects;
• adverse effects on scientific, cultural, or historical resources;
• adverse effects on endangered or threatened species or designated critical habitat (pursuant to the Endangered Species Act); and
• violations of federal, state, or local environmental law."
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NAAQS Statutory Requirements

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From 42 U.S.C. §7409 (Chapter 85, Subchapter I, Part A; CAA §109)


(b) Protection of public health and welfare 
 

(1) National primary ambient air quality standards, prescribed under subsection (a) of this section shall be ambient air quality standards the attainment and maintenance of which in the judgment of the Administrator, based on such criteria and allowing an adequate margin of safety, are requisite to protect the public health. Such primary standards may be revised in the same manner as promulgated. 

 

(2) Any national secondary ambient air quality standard prescribed under subsection (a) of this section shall specify a level of air quality the attainment and maintenance of which in the judgment of the Administrator, based on such criteria, is requisite to protect the public welfare from any known or anticipated adverse effects associated with the presence of such air pollutant in the ambient air. Such secondary standards may be revised in the same manner as promulgated. 

40 CFR 50.2 says:

(b) National primary ambient air quality standards define levels of air quality which the Administrator judges are necessary, with an adequate margin of safety, to protect the public health. National secondary ambient air quality standards define levels of air quality which the Administrator judges necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. Such standards are subject to revision, and additional primary and secondary standards may be promulgated as the Administrator deems necessary to protect the public health and welfare. 


I expected to see language about protecting sensitive populations but didn't. The only place that language is used (that I found during this quick investigation) is at 42 U.S.C. §7408(f)(1)(C) under the heading "Information regarding processes, procedures, and methods to reduce or control pollutants in transportation; reduction of mobile source related pollutants; reduction of impact on public health."It requires "information on other measures which may be employed to reduce the impact on public health or protect the health of sensitive or susceptible individuals or groups."
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FAA Regulations Regarding Tall Stacks

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This regulation describes when and how one needs to consult with the FAA before building a tall structure that could potentially interfere with flight patterns. (14 CFR 77.9)

This study addresses potential safety risks due to thermal and visible exhaust plumes interfering with aircraft. They conclude the risk is very small.
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Montana SIP Approval (Partial)

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EPA is partially approving and partially disapproving State Implementation Plan (SIP) revisions submitted by the State of Montana on August 26, 1999, May 28, 2003, March 9, 2004, October 25, 2005, and October 16, 2006. The revisions contain new, amended, and repealed rules in Subchapter 7 (Permit, Construction, and Operation of Air Contaminant Sources) that pertain to the issuance of Montana air quality permits, in addition to other minor administrative changes to other subchapters of the Administrative Rules of Montana (ARM).

See FR notice here.
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BACT Analysis Resources

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Lake Michigan Air Directors Consortium (LADCO) white papers on control technologies. Appears to be industry-specific technology reviews, from around 2005-2006, in support of SIP preparation for ozone, PM2.5, and regional haze.

Report describing above white papers: background, methodology, program description, etc.

LADCO BART reports. Also appears to be 2005-2006 vintage.

LADCO workshop presentations. See especially the March 24-25, 2010 presentations.

Several control technology presentations from a May 2011 Mid-Atlantic Regional Air Management Assn. (MARAMA) workshop on Advances in Air Pollution Control Technologies.
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Modeling Presentations from 2011 R/S/L Modelers Workshop

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Here's a link to the main page that contains links to the individual presentations.

One thing I found interesting, and potentially useful, was a San Joaquin Valley APCD web page with expanded NO2 modeling guidance and data. For example, they've collected and reported NO2/NOx ratios from a variety of source types. The range of values is surprisingly large.

(Note: Joe attended the single day of this conference that was opened to the public.)
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Montana Forms -- Public Notice and Certification Page

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Here are the individual public notification page and certification pages extracted from the Montana DEQ stationary source permit application forms 6/2011.
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Coal Combustion Residue (CCR) Regulation Status Update

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These outlines were made available as part of an audio presentation through Law Seminars that Grant and I participated in. A few highlights of the presentation:

• It is fairly certain that EPA will not issue a final rule this year. There is speculation that a final rule won't be released before next year's elections and EPA is considering requesting further public input.
• The House Energy and Commerce Committee is currently considering a bill that would short circuit EPA's efforts, prohibit any rule listing CCR as hazardous waste, and allow states to regulate the material. Here's a recent news article about the bill. 
• There is a great deal of pressure for legislative intervention because the power and CCR industries don't feel a hazardous designation would be at all workable, because the pervasive and apparently unending uncertainty is causing significant problems with planning for current and future disposition of CCR, and because the utilities are faced with an onslaught of new environmental regulations that could result in requirements for large capital expenditures.
• One of the presenters noted that those pushing for hazardous regulation are largely environmental groups opposed to coal-fired power and industries that compete with CCR for its various beneficial uses. On the other hand -- according to him -- there is overwhelming opposition to a hazardous waste determination.
• It was noted that the technical disposal requirements between the two options (RCRA Subtitle C, hazardous, or D, nonhazardous) are slight. The main reason EPA favors the Subtitle C option is that they would be responsible for enforcement rather than the states--not the case for the Subtitle D option and current regulation.

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NDDH O&G Air Permitting Guidance

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North Dakota Department of Health (NDDH) May 2011 final oil and gas permitting and compliance guidance including emission inventory spreadsheets that all operators must use:

• Memo
• Guidance document
• Emissions calculation spreadsheet

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Clean Air Act NEPA Exclusion

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Federal actions with respect to the Clean Air Act are exempt from NEPA review based on this statute:

US Code Title 15‚ CHAPTER 16C (Energy Supply and Environmental Coordination)
§793. Protection of public health and environment
...
(c) Major Federal actions significantly affecting the quality of the human environment
(1) No action taken under the Clean Air Act [42 U.S.C. 7401 et seq.] shall be deemed a major Federal action significantly affecting the quality of the human environment within the meaning of the National Environmental Policy Act of 1969 [42 U.S.C. 4321 et seq.].

Reference provided to Kevin from Dana Allen, NEPA coordinator at EPA R8, 303-312-6870)
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Indian Country Minor and Non-Attainment NSR

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June 13, 2011 - EPA finalized a Federal Implementation Plan (FIP) to ensure that Clean Air Act permitting requirements are applied consistently to facilities in Indian country.

Find the final rule and fact sheet here.

Update 7/21/11---

EPA distributed this PowerPoint presentation they plan to follow for a 8/2/11 webinar on the new rule. I briefly reviewed it and observed the following:

• BACT is required.

• The timeline for a synthetic minor permit is 60 days for a completeness determination plus one year to issue the permit.
• Timeline for a true minor source seeking a general permit: 45 day completeness review; permit "90 days after date coverage request is submitted."
• General permits "not allowed for synthetic minor sources."
• Leaves a lot of discretion regarding modeling demonstrations. They plan to develop guidelines.
• 18 months to commence construction.
• 30-day appeal period; permit stayed upon appeal.
• Pollutant-specific deminimis emission levels.
• Existing synthetic minor sources (minor relying on the Transition Policy) must submit an application by 8/30/2012.

• Violations enforceable by EPA in Federal court.

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Modeling Fugitive Particulate from Surface Coal Mines

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The 1990 Clean Air Act Amendments included Section 234, inserted by then-Wyoming Senator Alan Simpson, requiring EPA to "analyze the accuracy" of modeling analyses designed to predict impacts to short-term particulate NAAQS from surface coal mine fugitive emissions. The section also requires EPA to "make revisions as may be necessary to eliminate any significant over-prediction of air quality effect of fugitive particulate emissions from such sources." It provides that, until EPA complies, "the State may use alternative empirical based modeling approaches pursuant to guidelines issued by the Administrator." In May 2011, McVehil-Monnett Associates released this draft white paper assessing EPA's compliance with the requirement (which included a 3-year deadline) and the current state of fugitive particulate modeling.

This statement in a 1996 memo from EPA to Senator Simpson appears to be the final word on the matter:

"Since the model still appears to overpredict the impacts of surface coal mines, the Agency does not plan to use it for regulatory applications involving these sources. As a consequence, the regulatory procedures currently in place will remain in effect. These procedures are contained in the January 24, 1994 Memorandum of Agreement (MOA) between EPA Region VIII and the State (copy enclosed) and were summarized in the Federal Register on September 12, 1995 (60 FR 47290). The MOA allows the State to conduct monitoring in lieu of short term modeling for assessing coal mining-related impacts in the Powder River Basin. We believe that these procedures provide adequate protection for the environment and are also acceptable to the stakeholders. At this time, we and the various stakeholders believe that the interim procedures work well, and therefore we do not currently plan any further analyses. If in the future EPA is able to correct the model’s tendency to overpredict as described above, it may, of course, review these regulatory procedures."

The author also points out that the Wyoming Supreme Court issued a ruling in March of this year stating, in part, that EPA still has not remedied the situation addressed by the Simpson amendment.

Wyoming has a specific Memorandum of Agreement with EPA regarding modeling (or not) of surface coal mine fugitive PM. Their agreement relies heavily on an approved monitoring network and valid data and on requiring Best Available Work Practices (BAWPs). They also had to work through PSD increment issues, although it appears that the rather creative fixes no longer apply and any further work to address the issue is at a standstill.
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Annotated Appendix W Modeling Guideline

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I've started annotating, bookmarking, and linking this copy of the current Guideline on Air Quality Models (Appendix W, 2005). I used Foxit, which has some very nice annotation features. I think you can view the mark-ups and notes and use the bookmarks and links when reading with Adobe, but you may want to download Foxit (the basic version is free) if you're going to be adding to the annotations--which I would highly encourage if you're studying the document for something in particular.

(Unfortunately, clicking the link here or where the document is stored in the Bison SharePoint site only opens the document within the browser. This seems to provide limited Foxit annotation functionality. You may have to download a copy of the document, save the revised version to your computer with the same name, and re-upload to SharePoint--overwriting the existing version.)
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North Dakota Modeling Policy for Compressor Engines & Glycol Dehy Units

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Clarifies "when dispersion modeling is required for be submitted for facilities which include compressor engine(s) and/or glycol dehydration unit(s) as the primary source(s) of emissions." Applies to criteria and air toxics emissions. Also provides "procedure to follow when "further review" of emissions is required..."

May 16, 2011 NDDH Memo
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Anemometer Height Data

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WebMet has anemometer hight information, but it's not always current.

This NRCS site includes a spreadsheet with anemometer height for weather stations throughout the country. I don't know how frequently it's updated, however. The author of the NRCS wind rose site pointed me here for weather station data collections. The NWS station history files (zipped and unzipped) seem to be the appropriate sources for anemometer height histories, but the links don't work. This is the ftp site where the files are supposed to reside, but they don't. Some of the other posted files may have relevent information, but I've not found the right one or ones yet.

I was looking specifically for the current anemometer height at the Great Falls Airport. I ended up calling the NWS office in Great Falls. They said it's an ASOS station and all of them (or most all?) use 10 m towers. The person I talked to was unaware of any published information with current NWS station anemometer heights.
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Modeling Inputs & Procedures Spreadsheet

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Please use this spreadsheet to capture all pertinent information regarding a model's inputs, file names, data sources, assumptions, etc. The spreadsheet is intended to act as a checklist of items to consider while conducting the analysis and a record to facilitate second-party review and report preparation. It also includes some template tables for reporting results in a format that can be pasted into a report. As you're using the spreadsheet, and as we receive responses to submitted models from regulatory agencies, please consider how we might improve on it or develp a more effective and/or efficient tool to accomplish the same objectives.
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Health Risk Assessments

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Here's a spreadsheet with a partial listing of screening threshold values from Montana's incinerator rule at ARM 17.8.770(1)(c). (Please replace it if you create or come across a more complete accounting.)

This is a description of a screening level human health risk assessment conducted by Indiana Department of Environmental Management (IDEM) for a lime plant permit for Synergy Management (CRC205638). This write-up (along with a table of results not included here) was presented in Appendix A of the draft Technical Support Document accompanying a draft permit (T181-26877-00050) for public review. It's relatively straightforward and addresses calculation of and thresholds for chronic cancer and non-cancer risks. This is the spreadsheet that corresponds to this particular analysis.

This EPA web site includes a document, "Table 1," that lists chronic exposure thresholds for individual HAPs. I presume the IDEM analyses above uses these values, but I've only confirmed that for two HAPs; they may have relied on other sources for some thresholds. The web site also includes accute exposure thresholds in "Table 2," but I haven't seen those used. This site describes the sources of the threshold exposure values.

For a different approach to evaluating health risk from exposure to air pollutants, see Minnesota's Air Emissions Risk Analysis web site. They have a very well-developed process, including a downloadable spreadsheet that calculates pollutant concentrations without modeling and calculates risk factors. For an example of a Minnesota risk analysis, see Steve Ackerlund's Human Health Risk chapter in the Essar Steel SEIS on this Minnesota DNR web site.

EPA's Human Health Risk Assessment Protocol (HHRAP, links here) appears to be at least one of the foundational guidelines for conducting these analyses. Minnesota's AERA guideline document includes it as a reference. Chapter 7 of the HHRAP describes how to calculate cancer risk from Unit Risk Factors and non-cancer "hazard quotients" from Reference Concentrations (RfC). Chapter 7 also teases that it might provide target values, but it just says target values are "set by the permitting authority."
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Proposed Utility MACT

The proposal was published yesterday in the federal register. This EPA site contains a link to the FR proposal.

Here's an article critical of the proposal. It points out that EPA formerly found that only mercury emissions posed a risk that warranted review under Section 112, but the proposal addresses several other toxics. It also talks about the cumulative effect of several proposed rules set to hit coal-fired utilities around 2015.

This article includes a good concise history and explanation of Section 112 of the CAA in general and of the Utility MACT in specific.

This site contains two presumably less biased evaluations of the proposal from the bipartisan policy center.

While this article is not directly related to the proposed MACT, it does provide some very interesting perspective about the prospects of renewable energy sources filling the void as we drive conventional sources out of business. The main thesis is that we don't just need to replace coal/nuclear/natural gas, we need to replace them with sources that are able "to provide just the right amount of controllable power at any specified time to match demand at all times." It also talks about the falicy of being able to regulate ourselves into prosperity ( Henry Hazlitt’s Broken Window fallacy) and about the problem of just using more energy as we improve efficiency (Jevon’s Paradox).

NESHAP Subpart ZZZZ (RICE) Applicability Tool

Click on this blog title to open EPA's tool for determining applicability and applicable requirements for a specific engine. The Regulation Navigation (Reg Nav) tool is a TurboTax-like software program that guides the user through a set of questions and provides a web link to regulatory text that applies to a particular engine. The information entered into the tool is not saved and cannot be accessed by EPA.
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EPA Officially Announces AerScreen Preferred Screening Model

AerScreen EPA Memo

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October 2010 Biomass Modeling Report from RTP

This is a useful report that, among other things, provides data for in-stack ratios of NO/NO2 from wood combustion. Diane Lorenzen provided it to MDEQ to support assumptions she made in the UM boiler modeling.

Biomass Modeling Report
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BACT Resources

Clean Air Technology Center
Lots of fact sheets for various control technologies. Includes typical control efficiency ranges and very rough cost estimates.

Environmental Technology Verification Program, Air Pollution Control Technology Center
Generally more current than the CATC, but far fewer resoucrces.

Historical Chemical Engineering Plant Cost Indices
CEPCI for 1950 through 2006

Equipment cost scaling factors
Includes X^0.6 rule for scaling known price of equipment at size A to unknown price of similar equipment at size B.

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Nuclear Energy Pro and Con

Two interesting articles from the Chemical Engineering magazine evaluating nuclear energy--one for and one against. Especially interesting now that we've seen demonstrated some of the risks.

Nuclear Energy: A Vital Component of Our Energy Future

Nuclear Renaissance: A Flawed Proposition

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Libby, Columbia Falls PM10 and PM2.5 SIPs

PM10 SIP: CF and Libby

PM2.5 SIP: Libby
Final EPA acceptance published 3/17/2011

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Proposed Utility MACT

Link to EPA site with proposed rule, fact sheets, and presentation (click on title).

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Updated NO2/SO2 1-hr modeling guidance

EPA released additional guidance for modeling 1-hour NO2 NAAQS compliance 3/1/2011. It updates OLM and PVMRM policy, addresses significant contribution analyses using the SILs, and discusses how to perform cumulative analyses including the option of incorporating temporally-varying background concentrations.

It also "[r]ecommends that compliance demonstrations for the 1-hour NO2 NAAQS address emission scenarios that can logically be assumed to be relatively continuous or which occur frequently enough to contribute significantly to the annual distribution of daily maximum 1-hour concentrations based on existing modeling guidelines, which provide sufficient discretion for reviewing authorities to not include intermittent emissions from emergency generators or startup/shutdown operations from compliance demonstrations for the 1-hour NO2 standard under appropriate circumstances."

3/1/2011 Policy Memo

See this blog post for access to previous memos.

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See this article for a helpful discussion of the state of SO2 and NO2 1-hr NAAQS modeling guidance, including April updates to AERMOD and AERMET. It also talks about recent EPA guidance to states for 1-hr SO2 NAAQS attainment designation.
(added 5/20/2011, KMM)
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Boilers NESHAPs, Final 2/21/2011

UPDATE: On May 18, EPA suspended for reconsideration the major source boiler MACT (Subpart D5) and the CISWI Rule. No date was given for completion of the review.) (KMM 6/27/11) 

Go to this EPA web site for a compilation of actions related to the boiler MACTs and the CISWI rule.


Finalized NESHAP for:

• Area Source Industrial, Commercial, and Institutional Boilers (JJJJJJ)
• Major  Source Industrial, Commercial, and Institutional Boilers and Process Heaters (DDDDD)

Also finalized NSPS for Commercial/Industrial Solid Waste Incinerator Units (Subpart CCCC; Subpart DDDD provides emissions guidelines and compliance times for CISWI units).

Here's an article analyzing the rules and related issues.

Here are some applicability and requirements flow charts that Joe and Rebecca (and ??) prepared (click on links to pull up each chart):

• Biomass
• Coal
• Oil

See 5/5/2010 post for background on proposed rule.

(title is link to EPA site with rules and fact sheets)

FLIR Camera Gas Detecting Capability Detemination

Here is a website to determine if our FLIR camera can detect a specific gas:

NIST Chemical Name Search

1) Type in the name of the gas

2) Keep "SI units" button checked

3) Check the "IR spectrum" box under "other data"

4) Press "search" button

You will then be directed to another page with all the information regarding your selected gas. Scroll down to "IR Spectrum" and you will fine a bullet with "gas" next to it (linked text). Click on it. It will direct you to another page with a chart on it. The chart will be "transmittance vs. infrared spectrum". The bottom of the chart will have three dropdowns. Change "Reverse X" to "Normal X" and "cm-1" to "um (micro meter)".

This shows the transmittance signature of a particular gas. Our camera detects medium wavelength gases (between 3 and 5 micro meters). If the signature has a trough within that wavelenght range, the camera will pick it up. Anything above or below this range will not be detected. The camera detects "enes" (e.g., benzene), "anes" (e.g., methane) and "ones" (e.g., methyl ethyl ketone). It also does others that aren't yet FLIR lab verified.

Revised FLAG Document

Document, published October 2010:
Federal Land Managers’ Air Quality Related Values Work Group (FLAG)Phase I Report—Revised (2010)

Trinity summary article:
Trinity Consultants - New FLAG Guidance for Class I Area Modeling

Source Classification Codes (SCC) tool

Here's a nice tool for finding SCCs. It's hosted by the North Carolina Dept. of Environmental and Natural Resources and seems to be easier to use than WebFIRE.

PDS Net Emissions Increase

Joe Lierow asserted that, for particular unit for which utilization would increase due to a a physical or operational change at another unit and where the particular unit would not experience a physical or operational change, you calculate the net emissions increase using past actual and future actual emissions (assuming the 2002 NSR Reform rules do not apply).

I first found this from a policy memo referenced in the Advanced NSR Workshop Volume I book [Sept. 2010; pg. 179; Part 305 - NET EMISSIONS INCREASE--40 CFR 52.21(b)(3); Section 5 - Other Calculations (for modification to existing units); Actual to potential (presumptive approach under 1980 rule)]:

Question 3:

Is the approach of comparing new, allowable emissions to old, actual emissions still appropriate for determining PSD applicability?

Response:

Under the PSD regulations, whether a physical change or change in the method of operation at a source will result in a "net emissions increase" requires a comparison of the "actual emissions" of the source before and after the change. For an existing emissions unit at a source, "actual emissions" before the change equal the average rate in tons per year at which the unit actually emitted the pollutant during the 2-year period (or more representative period) which precedes the change [see 40 CFR 52.21(b)(21)(ii)]. Where the change will affect the normal operations of an existing emissions unit (as in the case of a change which could result in increased use of the unit), "actual emissions" after the change must be assumed to be equal to "potential to emit." [emphasis added] The PSD regulations are quite clear regarding such circumstances [40 CFR 52.21(b)(21)(iv)]:

For any emissions unit that has not yet begun normal operations on the particular date, actual emissions shall equal the potential to emit of the unit on that date.

Where "allowable emissions" are the same as or less than the "potential to emit" for an emissions unit, "allowable emissions" may be used to define the "actual emissions" of that unit after the change. Consequently, for determining PSD applicability, the comparison of prior "actual" versus new "potential" emissions (or "allowable" where appropriate) is the correct methodology to use.

The comparison of prior "actual" to future "potential" emissions is made on a unit-by-unit basis for all emissions units at the source that will be affected by the change. It is done for the emissions unit(s) undergoing the physical change or change in the method of operation and also for any other units at which normal operations could be affected by the change at the source. [emphasis added] This, for example, includes a review for possible emissions increases at process-related emissions units due to a physical change which removed a bottleneck at only one of the units.

1998 EPA Memorandum, pg 3 (4.42.pdf)

But then I found further in the book a section specifically on increased utilization [pg. 194; Section 7]. It references a few policy documents that support Joe's contention. Here's one of the quotes from a relevant policy document:

"...emissions increases should be calculated as the worst case increases that could occur at those existing units [presumably this means the units experiencing a utilization increase] if the new or modified units were to operate at their maximum permitted capacity."

Bakken Breakout 2011

Stories about Bakken Field oil production. (Blog title is the link.) Bison ad on page 25.

Recommendations for Modeling PM2.5

NACAA PM2.5 Modeling Methodology Recommendations

ICE Notification Requirements - NESHAP ZZZZ Modifications 10/2010

Here's a quick analysis of notification, reporting,and recordkeeping requirements in the 8/2010 revision to NESHAP Subpart ZZZZ for RICE (FR 51570 ff.). Rebecca passed along an e-mail reminder from WDEQ that some existing engines require initial notifications to the state and EPA by February 16, 2011. The message also noted that the effective date for applicable requirements is October 19, 2013.

63.6645(a)(2) requires notifications for all existing stationary RICE located at an area source of HAP emissions and existing major source RICE less than 500 HP (site rating), but (a)(5) exempts the following:
-- <100 hp
-- emergency RICE,
-- RICE not subject to any numerical emission standards.

According to Table 2d, these are the only area source SI engines that are subject to numerical emission standards (and so would require notifications):
-- non-emergency; non-black start; 4SRB/LB; >500 HP

According to Table 2c, these are the only major source SI engines that are subject to numerical emission standards (and so would require notifications):
-- non-emergency; non-black start; 4SRB/LB or 2SLB or any engine firing landfill or digester gas; >500 HP

Note that required notifications for CI engines should already have been submitted.

Here are some pertinent sections of the rule revision FR notice (with my highlights and notes).


SUMMARY: EPA is promulgating national emission standards for hazardous air pollutants for existing stationary spark ignition reciprocating internal combustion engines that either are located at area sources of hazardous air pollutant emissions or that have a site rating of less than or equal to 500 brake horsepower and are located at major sources of hazardous air pollutant emissions.

DATES: This final rule is effective on October 19, 2010.

F. What are the reporting and recordkeeping requirements?

The following sections describe the reporting and recordkeeping requirements that are required under this final rule.

Owners and operators of existing stationary emergency SI RICE that do not meet the requirements for nonemergency engines (meaning emergency engines?) are required to keep records of their hours of operation. Owners and operators of existing stationary emergency SI RICE must install a non-resettable hour meter on their engines to record the hours of operation of the engine.

Owners and operators of existing stationary SI RICE located at major sources that are subject to work practices and existing stationary SI RICE located at area sources that are subject to management practices are required to keep records that show that the work or management practices that are required are being met. These records must include, at a minimum: Oil and filter change dates and corresponding engine hours of operation (determined using hour meter, fuel consumption data, or other appropriate methods); inspection and replacement dates for spark plugs, hoses, and belts; and records of other emission-related repairs and maintenance performed.

In terms of reporting requirements, owners and operators of existing nonemergency stationary SI RICE greater than or equal to 100 HP and less than or equal to 500 HP located at major sources of HAP and existing nonemergency 4SLB and 4SRB stationary RICE greater than 500 HP located at area sources of HAP that operate more than 24 hours per calendar year must submit the notifications required in Table 8 of 40 CFR part 63, subpart ZZZZ, which lists the NESHAP General Provisions applicable to this rule. (40 CFR part 63, subpart A) These notifications include an initial notification, notification of performance test, and a notification of compliance for each stationary RICE which must comply with the specified emission limitations. Owners and operators of existing stationary nonemergency SI RICE greater than or equal to 100 HP and less than or equal to 500 HP located at major sources of HAP and existing stationary 4SLB and 4SRB nonemergency SI RICE greater than 500 HP located at area sources of HAP that operate more than 24 hours per calendar year must submit semiannual compliance reports.

Must submit all general rqmnts notifications--including initial notification--and semiannual compliance reports:
** SI, 100 ≤ hp ≤ 500, nonemergency, major source
** 4SLB/RB, ≤500 Hp, nonemergency, area source, operates >24 hr/yr

REVISED NOTIFICATION REGULATORY TEXT

63.6590(b)(3)

(3) The following stationary RICE do not have to meet the requirements of this subpart and of subpart A of this part, including initial notification requirements:

(i) Existing spark ignition 2 stroke lean burn (2SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(ii) Existing spark ignition 4 stroke lean burn (4SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(iii) Existing emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(iv) Existing limited use stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions;

(v) Existing stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions that combusts landfill gas or digester gas equivalent to 10 percent or more of the gross heat input on an annual basis;

(vi) Existing residential emergency stationary RICE located at an area source of HAP emissions;

(vii) Existing commercial emergency stationary RICE located at an area source of HAP emissions; or

(viii) Existing institutional emergency stationary RICE located at an area source of HAP emissions.

Oil and Gas Enviornmental Implications -- R8 EPA 2008 Report

EPA's view of air, water, and solid waste impacts from the industry and discussions of federal, state, and regional efforts to reduce impacts. Billed as a working draft.

An Assessment of the Environmental Implications of Oil and Gas Production: A Regional Case Study