air quality regulations – what’s new? (for ethanol plants)
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Air Quality Regulations – What’s New?
(for Ethanol Plants)
Shelley SchneiderAir Quality Division Administrator
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Presentation Overview
• National Ambient Air Quality Standards Revisions– Implications
• Greenhouse Gas Regulation– Mandatory Reporting Rule– PSD and Title V Tailoring Rule
• Opportunities for More Information
Ambient Air Quality Standards
Previous Standard
Revised Standard Finalized
Lead •1.5 ug/m3, quarterly average
Lead•1.5 ug/m3, quarterly average•0.15 ug/m3, rolling 3-month average
October 2008
Nitrogen Dioxide•53 ppb, annual ave
Nitrogen Dioxide•53 ppb, annual ave•100 ppb, 1-hour
January 2010
Sulfur Dioxide•30 ppb, annual ave•140 ppb, 24-hour max
Sulfur Dioxide•75 ppb, 1-hour•30 ppb, annual ave•140 ppb, 24-hour max
June 2010
(revoked in most areas, but apply in areas not attaining)
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Ambient Air Quality Standards
Implications for Nebraska Ethanol Plants• NO2
– Sources model when permitting– April 2010 Steve Page memo
• SO2– Monitoring in Douglas County
indicates non-compliance• Non-compliance = non-attainment• Douglas County only (at this time)
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Ambient Air Quality Standards
• SO2– EPA to require modeling for
designation process• Nonattainment = monitored OR modeled
violations• Attainment = modeled AND modeled
evidence of no violations• Unclassifiable = all other areas, INITIALLY
only
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Ambient Air Quality Standards
• Proposed Revision to Ozone Standard – EPA will finalize by August 31st
• Proposed PM Standards – EPA plans to propose in February 2011– Finalize in October 2011
• Secondary NO2 and SO2 standards– Looked at together in separate rulemaking
• Modeling compliance with NAAQS expected
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Ambient Air Quality Standards
Implications for Nebraska• Ozone proposal
– Monitoring in Omaha area indicates potential issues
– NDEQ working with IDNR on plan• Voluntary measures if appropriate• Non-attainment plan if appropriate• Community Based Planning approach
Ambient Air Quality Standards
04/21/23 Free Template from www.brainybetty.com 10
Omaha Core Based Statistical Area
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GHG Mandatory Reporting Rule
• EPA implemented – Report electronically to EPA• 25,000 metric tons actual emissions
CO2equiv or more must report
• Begin reporting for CY 2010– Deadline March 31, 2011
• No 3rd Party verification required• Monitoring plan in place by April 1,
2010
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GHG Mandatory Reporting Rule
• Ethanol Facilities– Covered ONLY through combustion
emissions
– ≥ 25,000 metric tons CO2equiv actual emissions• All combustion units• Aggregate units• No exemptions for space heaters or
insignificant units (except emergency equip)
– Fermentation emissions don’t count (for now)
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GHG Tailoring Rule– “Tailors” PSD & Title V program for
GHGs– Finalized May 2010– Without Tailoring Rule, 250 and 100 tpy
threshold apply• Nebraska has ~ 100 Title V sources subject
to current program
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GHG Tailoring Rule– Does NOT mirror Reporting Rule
• Short tons, not metric • Biogenic sources (ex. fermentation) count
toward applicability
– Phases in program
– Expressed as CO2equiv
04/21/23 Free Template from www.brainybetty.com 15
04/21/23 Free Template from www.brainybetty.com 16
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GHG Tailoring RuleImplications for Nebraska• Rulemaking necessary to
appropriately manage program• EPA requiring a letter outlining state’s
plans by August 2nd
– If rule isn’t adopted, EPA will be responsible for that piece of program
– If rule is adopted, NDEQ and the appropriate local programs would be responsible
– NDEQ plans to move forward with rulemaking in Fall 2010
• Program will mirror federal program
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GHG Tailoring Rule • Implications for Nebraska
– Preliminary estimates • All /most ethanol plants will likely be major
– Due to fermentation emissions– Actual emissions
• ~ 30 to 50 minor sources may be ‘major’ for GHG emissions
– Due to fuel combustion– Based on PTE
• Increase Class I sources 30 to 50%
GHG Tailoring Rule
04/21/23From Iowa DNR 2009 Emission Inventory Report for 2008
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GHG Tailoring Rule • Iowa Data on Actual Emissions• Fermentation only (need to include
fuel too) – 121 MM gal plant
• 0.33 MMt CO2equiv (396,000 tons CO2equiv )
– 110 MM gal plant• 0.30 MMt CO2equiv (360,000 tons CO2equiv )
– 77 MM gal plant• 0.21 MMt CO2equiv (252,000 tons CO2equiv )
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Opportunity for More Information
• Air Waves E-Newsletter– Contact Tracy Thompson 402-471-4272– Tracy.thompson@nebraska.gov
• Air Program Updates– August 3rd in Grand Island– August 4th in Scottsbluff– August 10th in Norfolk– August 18th in Lincoln
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Air Program Updates• Topics to be Covered
– Engines (everything you need to know!)– Air Regulations Update – Permitting – New Permit Review Policy,
Greenhouse Gas Tailoring Rule, Modeling– Compliance – NAAQS, Chapter 34, Stack
Testing– Air Toxics & NSPS Updates– The Air DVD – Your Guide to the Nebraska
Air Quality Regulations
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Air Program Updates• Reminders and Changes
– Register through NDEQ website– $10 registration fee
• Payable 2 weeks in advance (preferred) • At the door• Cash or check only
– Morning snacks, beverages, and lunch provided • Vegetarian meals can be provided
– CDs with workshop materials
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Questions?
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