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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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."

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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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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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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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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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."

Updated FLAG Document

Click on title to go to a National Park Service page with a link to the October 2010 updated FLAG document.

Tailoring Rule Guidance, November 2010

GHG PSD and Title V Guidance

Regarding biogenic emissions sources, EPA indicates that it's still unsure of how to account for them and plans to issue further guidance next year. It's interesting how they think May of 2011 is "well before the start of the second phase of PSD implementation pursuant to the Tailoring Rule"; heck, that could give someone one or two whole months to respond! Here's a relevant section from the document:

“…numerous stakeholders requested that EPA exclude, either partially or wholly, emissions of GHG from bioenergy and other biogenic sources for the purposes of the BACT analysis and the PSD program based on the view that the biomass used to produce bioenergy feedstocks can also be a carbon sink and therefore management of that biomass can play a role in reducing GHGs. EPA plans to provide further guidance on the [sic] how to consider the unique GHG attributes of biomass as fuel.

“Even before EPA takes further action, however, permitting authorities may consider, when carrying out their BACT analyses for GHG, the environmental, energy and economic benefits that may accrue from the use of certain types of biomass and other biogenic sources (e.g., biogas from landfills) for energy generation, consistent with existing air quality standards. In particular, a variety of federal and state policies have recognized that some types of biomass can be part of a national strategy to reduce dependence on fossil fuels and to reduce emissions of GHGs. Federal and state policies, along with a number of state and regional efforts, are currently under way to foster the expansion of renewable resources and promote biomass as a way of addressing climate change and enhancing forest-management. EPA believes that it is appropriate for permitting authorities to account for both existing federal and state policies and their underlying objectives in evaluating the environmental, energy and economic benefits of biomass fuel. Based on these considerations, permitting authorities might determine that, with respect to the biomass component of a facility’s fuel stream, certain types of biomass by themselves are BACT for GHGs. To assist permitting authorities further in considering these factors, as well as to provide a measure of national consistency and certainty, EPA intends to issue guidance in January 2011 that will provide a suggested framework for undertaking an analysis of the environmental, energy and economic benefits of biomass in Step 4 of the top-down BACT process, that, as a result, may enable permitting authorities to simplify and streamline BACT determinations with respect to certain types of biomass.

“… Finally, EPA also plans to determine by May 2011, well before the start of the second phase of PSD implementation pursuant to the Tailoring Rule, whether the issuance of a supplemental rule is appropriate to address whether the Clean Air Act would allow the Agency and permitting authorities or permitted sources, when determining the applicability of PSD permitting requirements to sources of biogenic emissions, to quantify carbon emissions from bioenergy or biogenic sources by applying separate accounting rules for different types of feedstocks that reflect the net impact of their carbon emissions.” pages 9 & 10

Regarding BACT:
Refers to technical “white papers” that provide industry-sector-specific GHG BACT guidance, but it doesn’t say where to find these documents. (page 21)

The guidance explicitly requires consideration of alternate processes that may have better energy efficiency. They offer an example of comparing a supercritical and subcritical coal fired boiler (page 22). The guidance presents a detailed analysis of this issue starting on page 27.
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SO2 Modeling Guidance

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Although this guidance offers a "first tier" approach of using the "overall highest hourly background SO2 concentration from a representative monitor" (emphasis added), it goes on to seemingly stress the appropriateness of applying professional judgment when characterizing background by modeling nearby sources and by using monitoring data. It even goes so far as to suggest that you don't necessarily have to follow the modeling guidance in the 1980 Draft NSR Workshop Manual.

EPA SO2 Modeling Policy Memo, August 2010

I noticed, too, that Appendix W seems to encourage efforts to avoid double counting through use of modeling and monitored data. This link accesses a copy of the current version of Appendix W:

EPA SCRAM site with link to Appendix W

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Montana Legislature: Publications and Reports - Environmental Quality Council

Several possibly useful publications from the Montana Environmental Quality Council. Note especially the 2010 "Permitting in Montana" document and the 2008 "Montana Index of Environmental Permits" documents. The first includes a nice graphic of permitting steps and timelines for air quality. The second is a 261 page description of all the permits that may apply to a large variety of projects.

Montana Legislature: Publications and Reports - Environmental Quality Council

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MDEQ Confidential Business Information Policy

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MDEQ Confidential Business Information Policy

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Flare Guidance (Modeling, Emissions, etc)

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Flare Modeling Guidance from NDDH

Iowa DNR guidance and spreadsheet tool -- links on this page

Texas Natural Resources Conservation Commission


(updated post 8/19/2011, KMM)
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Part 71 Minor Source Transition Policy

2/11/2010 e-mail from EPA R8 to Marathon Oil Company regarding implementation of the "Part 71 50% PTE Transition Policy." Link to the policy memo is included at the end of the post.

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Mr. Blanco,

EPA Region 8 received your letters dated February 10, 2009, announcing Marathon Oil's intention of utilizing the Part 71 50% PTE Transition Policy. Three facilities were identified in your submittals:

--Wolding 14-24H Oil & Gas Production Facility operating on the Fort Berthold Reservation

--Jay Sandstrom 34-31H Oil & Gas Production Facility operating on the Fort Berthold Reservation

--AH 34-23H Oil and Gas Production Facility operating on the Fort Berthold Reservation.

The purpose of the Transition Policy is allow those sources not otherwise subject to Part 71 permitting whose PTE is less than 50% of the trigger level for Part 71 (100 tpy) to avoid part 71 permitting until such time that a minor pre-construction permitting program is promulgated for sources operating in Indian Country.

This policy does not apply to avoiding pre-construction PSD permitting or NESHAP standards. It only applies to avoiding the Part 71 operating permit program for those sources who are not subject to any other CAA requirements and whose actual emissions for the previous year are less than or equal to 50 tpy. Please note that Part 71 is triggered upon start-up and an application is due with in one year of the start-up date.

Examples of ways that facilities can otherwise trigger Part 71 as defined in 71.3 and in the transition policy memo you attached to each of your letters, includes:

-- Any major source. Major source as defined in Part 71 includes major PSD and NESHAP sources.

-- Any source (including minor sources) subject to NSPS (part 60) requirements promulgated after July 21, 1992 unless the NSPS specifically exempts minor sources from Part 71 permitting.

-- Any source (including minor sources)subject to NESHAP (part 61 and 63 ) requirements promulgated after July 21, 1992 unless the NESHAP specifically exempts minor sources from Part 71 permitting.

-- Any Acid Rain source

You have identified each of these facilities as having potential uncontrolled VOC emissions of 106.82, 102.94 and 135.65 tons per year each, respectively; and actual VOC emissions of 25.18, 25.18, and 35.97
tpy, respectively. In addition, your submittal states that these facilities are not otherwise subject to Part 71.

Based on the information you provided, it appears these facilities are eligible for the Part 71 permitting exemption under the Part 71 50% PTE Transition Policy.

Please be aware that upon promulgation of the Federal Minor New Source Review Permitting program for sources located in Indian Country, the 50% PTE Policy will no longer be in effect. All facilities that utilized
this policy will be required to submit a minor NSR application to the EPA to make the actual emissions legally enforceable.

If you have any questions, please feel free to call or email me.

Kathy

***********************************************************
Kathleen Paser
Region 8 Air Program
303-312-6526
***********************************************************
US EPA Region 8
1595 Wynkoop Street
M/C 8P-AR
Denver, Colorado 80202
***********************************************************

Link to 1999 Transition Policy Memo

Minor Sources in Indian Country - EPA Policy

March 7, 1999 policy memo.

"This memorandum discusses EPA’s transition policy concerning potential to emit (PTE) limits for stationary air pollution sources located in Indian country. Under this policy, EPA would treat a source as nonmajor for the purposes of the Federal Operating Permits Program (part 71) if its actual emissions area nd remain below 50 percent of the PTE thresholds for major source status, for every consecutive 12-month period (beginning with the 12 months immediately preceding the date of this memorandum) and it maintains adequate records to demonstrate that its actual emissions are kept below these levels."

EPA - Policy and Guidance Record - Potential to Emit (PTE) Transition Policy for Part 71 Implementation in Indian Country

Critique of carbon markets

"December 2009 saw world leaders come together in Copenhagen to try to agree on a post-Kyoto deal to save the planet from global warming. But the attempts to hammer out a new deal met with an apparent failure. But was it a failure? Many commentators would argue that the apparent failure can be seen as a welcome breathing space to question the underlying mechanisms that are supposed to help us fight climate change. In this way, Upsetting the Offset is a very timely book, as it critically engages with the political economy of carbon markets, which have emerged as the dominant instrument to mitigate climate change."

Upsetting the Offset

Science vs. Policy - opposing view

"The problem is not that reason fails. The problem is that politics fails to be reasonable. Blaming reason for the failure of politics is about as backwards as you can get something."

Daniel Sarewitz is Wrong

Science vs. Politics - Slate editorial

"A dangerous idea has taken hold in modern politics, and the sooner it is discredited, the better. The idea is that political disagreements can be resolved by science."

"When people hold strongly conflicting values, interests, and beliefs, there is not much that science can do to compel action. Indeed, more research and more facts often make a conflict worse by providing support to competing sides in the debate, and by distracting decision-makers and the public from the underlying, political disagreement. In such cases each side will claim to have the scientific high ground."

Science won't tell us what to do about climate change, but it can make the controversy worse. - By Daniel Sarewitz - Slate Magazine