experience of the forest products industry in obtaining air quality permits for new and modified sources

A detailed study of the air quality permitting process for 65 different forest products industry projects requiring preconstruction permit approvals from EPA, state, and local air pollution control agencies was conducted. The projects included a wide array of sources including kraft recovery furnaces, lime kilns, fossil fuel and wood residue fired boilers, solid wood products manufacturing facilities, paper coaters, and printing presses. Information concerning the time involved in the permitting process, costs associated with obtaining the permits, use of air quality models and ambient monitoring data, emission control technology determinations, problem areas encountered during the permitting process, perceived benefits and drawbacks of the permitting process, and the effect of permitting requirements on project planning was obtained.

The results indicate that certain permitting requirements such as Best Available Control Technology (BACT) determinations, dispersion modeling results, and use of ambient air quality monitoring data seldom influence the emission limitations ultimately imposed in the final approved permit, with 87% of the final emission limits equivalent to the applicable New Source Performance Standard (NSPS). The 65 permitting case histories also show that obtaining permits for projects subject to Prevention of Significant Deterioration (PSD) requirements takes approximately twice as long and costs twice as much as obtaining permits for projects not subject to PSD requirements.     

PSD and Nonattainment Regulation: Implications of a Settlement Agreement

The EPA recently issued an internal memorandum and a settlement agreement in the case of Chemical Manufacturers Association et al. vs. EPA. The agreement reflects potential changes to the PSD regulations and the Emissions Offset Interpretive Ruling for nonattainment areas. The information presented in this paper is a summary of the significant aspects of the agreement, as it will affect future industrial sources. This paper also discusses other recent changes to the PSD and nonattainment regulations.

The changes to the regulations provide for significant relaxation of some aspects of PSD and the nonattainment regulations. The most significant aspect is the proposed change in the method of tabulating net increases of emissions due to source modifications. The change would allow offset credit for decreases in emissions due to shutdown of equipment based on the potential emission rate rather than the actual.     

EPA’s Clean Air Act Operating Permit Rules

Title V of the Clean Air Act requires tens of thousands of air pollution sources to obtain an operating permit incorporating all applicable requirements under the Act. EPA recently promulgated its controversial Title V regulations, which establish the minimum elements for state permit programs.

The new permit system is among the most important changes made by the 1990 Clean Air Act Amendments, and will significantly alter the way companies comply with air pollution requirements. Previously, the Act only required certain sources to obtain a new source review permit before constructing or modifying the facility (although many states established operating permit systems on their own). Now, all states must adopt operating permit programs consistent with the minimum federal requirements, and submit them to EPA by November 1993. Even though EPA has established minimum requirements, these programs are likely to vary widely from state to state.     

A Regulatory Analysis

The information presented in this paper is directed to those individuals interested in future air quality control programs aimed at areas that are attaining one or more air quality ambient standards. Section 116 of the Clean Air Act, as amended, requires the Environmental Protection Agency to promulgate regulations for the prevention of significant deterioration (PSD) of air quality in order to protect the nation's clean air resources from hydrocarbons, carbon monoxide, ozone, nitrogen oxides, and lead (Set II pollutants). This program will affect industry siting in many areas of the country, particularly in the rural, undeveloped areas. Among the many alternatives currently being considered by EPA to meet the PSD Set II goals are emission management systems, marketable emission permits, air quality increments, emission fees, and control of transportation related sources. The final regulation may be a combination of several options or may present several alternatives from which a State would choose its specific program.     

Theoretical study of the impact of particulate matter gravitational settling on ambient coarse particulate matter monitoring for agricultural emissions

The particle size distributions (PSDs) of particulate matter (PM) in the downwind plume from simulated sources of a cotton gin were analyzed to determine the impact of PM settling on PM monitoring. The PSD of PM in a plume varies as a function of gravitational settling. Gravitational settling has a greater impact on the downwind PSD from sources with PSDs having larger mass median diameters (MMDs). The change in PSD is a function of the source PSD of emitted PM, wind speed, and downwind distance. Both MMD and geometric standard deviation (GSD) in the downwind plume decrease with an increase in downwind distance and source MMD. The larger the source MMD, the greater the change in the downwind MMD and GSD. Also, the greater the distance from the source to the sampler, the greater the change in the downwind MMD and GSD. Variations of the PSD in the downwind plume significantly impact PM10 sampling errors associated with the U.S. Environmental Protection Agency (EPA) PM10 samplers. For the emission sources with MMD > 10 microm, the PM10 oversampling rate increases with an increase in downwind distance caused by the decrease of GSD of the PSD in the downwind plume. Gravitational settling of particles does not help reduce the oversampling problems associated with the EPA PM10 sampler. Furthermore, oversampling rates decrease with an increase of the wind speed.     

The New Clean Air Act Operating Permit Program: EPA’s Proposed Regulations

The 1990 Clean Air Act Amendments added a new Title V to the Act which establishes an operating permit program for numerous sources of air pollution. Certain sources are currently required to obtain a construction or “new source review” permit; the 1990 Amendments will require many more sources to apply for a permit which will give them permission to operate. CAA Title V was modeled on the National Pollutant Discharge Elimination System (NPDES) permit provisions of the Clean Water Act, but there are important differences between the two statutes.

Although many states already have their own operating permit programs, by late 1993 every state must establish a program that meets the requirements of Title V and EPA’s implementing regulations. EPA recently proposed these regulations, and by the statutory deadline of November 15, 1991 hopes to issue final regulations establishing the minimum elements of state operating permit programs. These regulations will significantly affect implementation of air pollution measures for years to come because a Title V operating permit will have to assure compliance with all applicable CAA requirements. In addition, permitted sources will be required to pay fees to cover the costs of the permit program.     

"Fuel Cleaning" and Materials Separation at Waste-to-Energy Plants

Separation of materials from municipal waste streams is not recycling. Successful recycling is demand-pulled rather than supply-driven; it depends on local markets that reuse separated materials. For this reason EPA's Office of Solid Waste has opposed national mandates for materials separation which do not address associated markets. But a recent Air Act decision could reverse that stance, potentially mandating high levels of materials separation for every new waste-to-energy (WTE) facility.

The decision holds that Best Available Control Technology (BACT) requires PSD permit applicants to consider separating "feasible" levels, of each "readily-ascertainable" waste component that contributes to air emissions when incinerated, despite their installation of advanced emissions controls or the lack of any evidence that emission concentrations would be further reduced by such "fuel cleaning." Because total emissions of any facility may always be reduced by requiring it to consume less fuel—or burn gas rather than oil, or use conservation rather than combust at all—the decision could radicalize New Source Review, transforming preconstruction permits from a process meant to assure specific emissions controls to one in which air agencies deny the existence of emitting sources. The decision could also delay preconstruction permits; force downsizing of disposal facilities EPA concedes to be necessary; accelerate landfill closures; inject air permit writers into solid waste management determinations; and make local waste infrastructure more difficult to finance. It demonstrates the slippery slopes created by attempts to convert single-medium statutes into multi-media programs under the banner of "pollution prevention."     

Sensitivity of two dispersion models (AERMOD and ISCST3) to input parameters for a rural ground-level area source

As of December 2006, the American Meteorological Society/U.S. Environmental Protection Agency (EPA) Regulatory Model with Plume Rise Model Enhancements (AERMOD-PRIME; hereafter AERMOD) replaced the Industrial Source Complex Short Term Version 3 (ISCST3) as the EPA-preferred regulatory model. The change from ISCST3 to AERMOD will affect Prevention of Significant Deterioration (PSD) increment consumption as well as permit compliance in states where regulatory agencies limit property line concentrations using modeling analysis. Because of differences in model formulation and the treatment of terrain features, one cannot predict a priori whether ISCST3 or AERMOD will predict higher or lower pollutant concentrations downwind of a source. The objectives of this paper were to determine the sensitivity of AERMOD to various inputs and compare the highest downwind concentrations from a ground-level area source (GLAS) predicted by AERMOD to those predicted by ISCST3. Concentrations predicted using ISCST3 were sensitive to changes in wind speed, temperature, solar radiation (as it affects stability class), and mixing heights below 160 m. Surface roughness also affected downwind concentrations predicted by ISCST3. AERMOD was sensitive to changes in albedo, surface roughness, wind speed, temperature, and cloud cover. Bowen ratio did not affect the results from AERMOD. These results demonstrate AERMOD's sensitivity to small changes in wind speed and surface roughness. When AERMOD is used to determine property line concentrations, small changes in these variables may affect the distance within which concentration limits are exceeded by several hundred meters.     

Federal Regulations for New Source Performance Standards

Section 111 of the Clean Air Act Amendments of 1970 authorizes the U.S. Environmental Protection Agency (EPA) to impose emission standards (NSPS) on those stationary sources that are determined to be significant contributors to air pollution and that consequently endanger the public health or welfare. In five years EPA promulgated 19 final and 1 proposed NSPS for stationary sources. Section 112 of the Act authorizes EPA to promulgate national emission standards for hazardous air pollutants (NESHAPS). EPA promulgated three final and 1 proposed regulation under Section 112. In addition, EPA promulgated NSPS for three "designated" pollutants from specific sources under Section Hid. EPA’s use of Section 111 and 112 authority provides for a quick response emission control program compared to the relatively slow process of establishing additional ambient air quality standards and having the states adopt implementation plans (Section 109). Three court cases, argued in the U.S. Court of Appeals for the District of Columbia, established basic guidelines for future promulgation of NSPS although certain legal actions are still pending. Proposed amendments to the Clean Air Act would further broaden and strengthen EPA’s direct regulatory authority.     

Clean Air and Energy: Reform of the PSD Provisions of the Clean Air Act

Air pollution regulation in the United States has come under repeated attack over the years for a number of reasons. Early in the past decade, prevention of significant deterioration (PSD) legislation, which protects currently clean areas, came into conflict with domestic energy production goals. This paper presents an applied analysis of present and alternative regulations for achievement of PSD air quality goals. A model of the Four Corners region of the Southwest is developed, and several policy alternatives tested in terms of economic efficiency and ability to achieve air quality goals. Alternatives examined include emission fees, marketable emission permits, and technological standards.     

A short-term diffusive sampler for nitrogen dioxide monitoring in epidemiology.

An automated timed exposure diffusive sampler (TEDS) for sampling nitrogen dioxide (NO2) was developed for use in epidemiological studies. The TEDS sequentially exposes four passive sampling devices (PSD) by microprocessor controlled valves while a pump and air flow guide prevent sampler "starvation." Two TEDS units and two portable, real-time NO2 monitors were tested for accuracy, precision, sensitivity, and linearity of response. The accuracy of the TEDS was within 10 percent of the calibrated NO2 values, and precision was within 10 percent of the means of the measured values. The TEDS sensitivity was 20 to 30 ppb-hour for NO2. Co-location of the TEDS with a chemiluminescent NOx monitor (EPA reference method) showed similar responses to ambient NO2 (R2 = 0.9991). TEDS allows better time resolution than traditional diffusive samplers (i.e., Palmes tube) while sharing their ability to sample a variety of gases.     

Waste Analysis Plan Review Advisor: An Intelligent Database to Assist RCRA Permit Reviewers

The Waste Analysis Plan Review Advisor (WAPRA) system assists in the review of the Waste Analysis Plan Section of RCRA Part B facility permit applications. Specifically, this program automates two functions of the waste analysis plan review. First, the system checks all wastes which will be processed in the same treatment or disposal unit to identify possible chemical interactions which might pose a health threat to unit operators or degrade the performance of the waste processing unit. Second, sampling methods are analyzed and judged for appropriateness based on guidelines in EPA Reference SW-846. WAPRA is best classified as an intelligent database. It contains the expertise of a chemist in a menu-driven user-friendly interface.     

Mercury Measurement and Its Control: What We Know,Have Learned,and Need to Further Investigate

ABSTRACT

Based on the available evidence of health effects, the U.S. Environmental Protection Agency (EPA) has been evaluating the need to regulate mercury releases to the environment. In response to the congressional mandates in The 1990 Clean Air Act Amendments (CAAA), the EPA has issued the Mercury Study Report and the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units Report. In spite of the enormous effort represented by these reports, as well as the efforts of both the U.S. Department of Energy (DOE) and the Electric Power Research Institute (EPRI), in conducting the field measurement programs that form the basis for these reports, a definitive answer on the need for mercury regulation has not been found. However, the EPA, as well as other regulatory agencies and health researchers, have suggested a "plausible link" between anthropogenic sources emitting mercury and the methylation, bioaccumulation in the food chain, and adverse health effects in humans and wildlife.     

A Short-Term Diffusive Sampler for Nitrogen Dioxide Monitoring in Epidemiology

An automated timed exposure diffusive sampler (TEDS) for sampling nitrogen dioxide (NO₂) was developed for use in epidemiological studies. The TEDS sequentially exposes four passive sampling devices (PSD) by microprocessor controlled valves while a pump and air flow guide prevent sampler "starvation." Two TEDS units and two portable, real-time NO₂ monitors were tested for accuracy, precision, sensitivity, and linearity of response. The accuracy of the TEDS was within 10 percent of the calibrated NO₂ values, and precision was within 10 percent of the means of the measured values. The TEDS sensitivity was 20 to 30 ppb-hour for NO₂. Co-location of the TEDS with a chemiluminescent NOX monitor (EPA reference method) showed similar responses to ambient NO₂ (R2 = 0.9991). TEDS allows better time resolution than traditional diffusive samplers (i.e., Palmes tube) while sharing their ability to sample a variety of gases.     

Comparison of six particle size distribution models on the goodness-of-fit to particulate matter sampled from animal buildings

Lognormal distribution is often used as a default model for regression analysis of particle size distribution (PSD) data; however, its goodness-of-fit to particle matter (PM) sampled from animal buildings and its comparison to other PSD models have not been well examined. This study aimed to evaluate and to compare the goodness-of-fit of six PSD models to total suspended particulate matter (TSP) samples collected from 15 animal buildings. Four particle size analyzers were used for PSD measurement. The models' goodness-of-fit was evaluated based on adjusted R2, Akaike's information criterion (AIC), and mean squared error (MSE) values. Results showed that the models' approximation of measured PSDs differed with particle size analyzer. The lognormal distribution model offered overall good approximations to measured PSD data, but was inferior to the gamma and Weibull distribution models when applied to PSD data derived from the Horiba and Malvern analyzers. Single-variable models including the exponential, Khrgian-Mazin, and Chen's empirical models provided relatively poor approximations and, thus, were not recommended for future investigations. A further examination on model-predicted PSD parameters revealed that even the best-fit model of the six could significantly misestimate mean diameter median diameter; and variance. However, compared with other models, the best-fit model still offered the relatively best estimates of mean and median diameters, whereas the best predicted variances were given by the gamma distribution model.     

Mercury Measurement and Its Control: What We Know,Have Learned,and Need to Further Investigate

ABSTRACT

Based on the available evidence of health effects, the U.S. Environmental Protection Agency (EPA) has been evaluating the need to regulate mercury releases to the environment. In response to the congressional mandates in The 1990 Clean Air Act Amendments (CAAA), the EPA has issued the Mercury Study Report and the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units Report. In spite of the enormous effort represented by these reports, as well as the efforts of both the U.S. Department of Energy (DOE) and the Electric Power Research Institute (EPRI), in conducting the field measurement programs that form the basis for these reports, a definitive answer on the need for mercury regulation has not been found. However, the EPA, as well as other regulatory agencies and health researchers, have suggested a “plausible link” between anthropogenic sources emitting mercury and the methylation, bioaccumulation in the food chain, and adverse health effects in humans and wildlife.

Policy-makers have recognized that regulations must be based on good science and that a number of issues still remain. These issues can generally be grouped into four main categories: emissions inventory, control technology, fate of releases, and health effects. This paper will discuss recent, ongoing, and planned studies to address the remaining issues regarding the presence of mercury in the environment, with an emphasis on those studies that are directly related to the DOE/Federal Energy Technology Center’s (FETC) programmatic effort.     

Source identifications of airborne fine particles using positive matrix factorization and U.S. Environmental Protection Agency positive matrix factorization

The widely used source apportionment model, positive matrix factorization (PMF2), has been applied to various air pollution data. Recently, U.S. Environmental Protection Agency (EPA) developed EPA positive matrix factorization (PMF), a version of PMF that will be freely distributed by EPA. The objectives of this study were to conduct source apportionment studies for particulate matter less than 2.5 microm in aerodynamic diameter (PM(2.5)) speciation data using PMF2 and EPA PMF (version 1.1) and to compare identified sources between the two models. In the present study, ambient PM(2.5) compositional datasets of 24-hr integrated samples collected at EPA Speciation Trends Network monitoring sites in Chicago, IL, and Portland, OR, were analyzed. Both PMF2 and EPA PMF extracted eight sources for the Chicago data and 10 sources for the Portland data. The model-resolved source profiles were similar between two models for both datasets. However, in several sources, the average contributions did not agree well and the time series contributions were not highly correlated. The differences between PMF2 and EPA PMF solutions were caused by the different least-square algorithm and the different nonnegativity constraints. Most of the average source contributions resolved by both models were within 5-95% uncertainty provided by EPA PMF, indicating that the sources resolved by both models were reproducible.     

Evaluation of the SO2 and NOX offset ratio method to account for secondary PM2.5 formation

The U.S. Environmental Protection Agency (EPA), state and local agencies have focused their efforts in assessing secondary fine particulate matter (aerodynamic diameter ≤2.5 µm; PM_2.5) formation in prevention of significant deterioration (PSD) air dispersion modeling. The National Association of Clean Air Agencies (NACAA) developed a method to account for secondary PM_2.5 formation by using sulfur dioxide (SO₂) and nitrogen oxides (NO_x) offset ratios. These ratios are used to estimate the secondary formation of sulfate and nitrate PM_2.5. These ratios were first introduced by the EPA for nonattainment areas in the Implementation of the New Source Review (NSR) Program for Particulate Matter Less than 2.5 Micrometers (PM_2.5), 73 FR 28321, to offset emission increases of direct PM_2.5 emissions with reductions of PM_2.5 precursors and vice versa. Some regulatory agencies such as the Minnesota Pollution Control Agency (MPCA) have developed area-specific offset ratios for SO₂ and NO_x based on Comprehensive Air Quality Model with Extensions (CAMx) evaluations for air dispersion modeling analyses. The current study evaluates the effect on American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) predicted concentrations from the use of EPA and MPCA developed ratios. The study assesses the effect of these ratios on an electric generating utility (EGU), taconite mine, food processing plant, and a pulp and paper mill. The inputs used for these four scenarios are based on common stack parameters and emissions based on available data. The effect of background concentrations also evaluates these scenarios by presenting results based on uniform annual PM_2.5 background values. This evaluation study helps assess the viability of the offset ratio method developed by NACAA in estimating primary and secondary PM_2.5 concentrations. An alternative Tier 2 approach to combine modeled and monitored concentrations is also presented.

Implications:

On January 4, 2012, the EPA committed to engage in rulemaking to evaluate updates to the Guideline on Air Quality Models (Appendix W of 40 CFR 51) and, as appropriate, incorporate new analytical techniques or models for secondary PM_2.5. As a result, the National Association of Clean Air Agencies (NACAA) developed a screening method involving offset ratios to account for secondary PM_2.5 formation. The use of this method is promising to evaluate total (direct and indirect) PM_2.5 impacts for permitting purposes. Therefore, the evaluation of this method is important to determine its viability for widespread use.     

Legislating risk: the USA struggles to reform its policies for the assessment and management of risk

This paper focuses on recent efforts in the United States to improve the federal government's approach to regulating risk, with particular emphasis on legislation introduced in the Congress of the United States that was designed to reform and standardize risk assessment and risk management practices at the United States Environmental Protection Agency (EPA) and other federal agencies with responsibility for health, safety, and environmental regulation. After reviewing the key provisions of the legislation and the potential impact of those provisions on EPA's risk-related activities, the paper suggests certain fundamental principles that should guide the debate on reform of policies and procedures associated with risk.     

Accurate Chemical Analysis of MTBE in Environmental Media

The new millennium ushers in changes for refiners of automobile gasoline in the United States, as well as for the state and federal regulators who establish guidelines for gasoline formulation and environmental regulation governing the fate of gasoline-related chemicals in the nation's air, soil and groundwater. One current issue in the gasoline formulation debate centers on the comparison of the proven benefits of the addition of chemical oxygenates—especially methyltert -butyl ether (MTBE)—to gasoline (to improve tailpipe emission quality) against the presumed environmental problems caused by the presence of oxygenates in ground- and surface waters due to fugitive releases of gasoline. Credible debate on this subject presumes that current and past environmental monitoring data for MTBE in environmental samples is accurate and precise. Experience suggests that this assumption is not correct, in part because certain analytical methodologies—particularly older methods supported by the U.S. Environmental Protection Agency—can fall short of reasonable data quality goals for measurement of MTBE. This Technical Note summarizes the standard EPA methods available to site investigators who need to measure MTBE in environmental media, the limitations and advantages of these measurement techniques, and recommendations for improving these standard EPA methods to yield the highest quality MTBE environmental residue data.