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1-Hour NO2 NAAQS Air Quality Modeling
1. 1-Hour NO2 NAAQS Air
Quality Modeling
Dan Dix
All4 Inc.
NCASI 2011 Northern Regional
Wausau, WI
May 19, 2011
2. NO2 NAAQS
Old Nitrogen Dioxide (NO2) NAAQS
• Annual: 100 µg/m3 (53 ppb) (Maximum
Annual Concentration)
New NO2 NAAQS
• 1-Hour NAAQS: 188 µg/m3 (100 ppb) (3-Year
Average of the 98th Percentile of Daily
Maximum 1-hour Concentrations
Annual NAAQS Still in Place
Annual PSD Increment Still in Place
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3. NO2 Air Quality Modeling Requirements
AERMOD
188 µg/m3 (100 ppb): 5-Year Average of
the 98th Percentile of Daily Maximum 1-
hour Concentrations with National
Weather Service (NWS) Data
188 µg/m3 (100 ppb): 98th Percentile of
Daily Maximum 1-hour Concentrations
with 1-year of Onsite Data
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4. PSD Air Quality Modeling Approach
Model Project-Related Emissions for
comparison to:
Significant Impact Levels (SILs)
Annual - 1.0 g/m3 (Maximum Annual
Concentration)
1-hour – 7.5 g/m3 (interim) (Maximum
Average Annual Concentration)
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5. PSD Air Quality Modeling Approach
If Project-Related Emissions are Greater
than SIL, Multi-Source NAAQS analysis
required
All Facility-Wide NO2 Emission Rates Must be
Modeled at their Potential-to-Emit Emission
Rate
All Local Sources within 50km + Significant
Impact Area (SIA)
Background Concentrations
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6. PSD Air Quality Modeling Approach
Treatment of Intermittent Emission Units
Emergency Generators
Intermittent Emission Scenarios
(Startup/Shutdown)
US. EPA Released in Latest Guidance
Memorandum
Form of the Standard Does Not Warrant
Assuming Continuous Operation for Intermittent
Emissions (Case-by-Case Basis)
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7. Other Accepted NO2 AQM Techniques
Tiering Approach for NO2 provided in
Latest Guidance Memorandum
Tier I – Assume Full Conversion of NOX to
NO2 (1 g/m3 = 1 g/m3)
Tier II – Use 0.8 as Default Ambient Ratio
(1 g/m3 = 0.8 g/m3)
Tier III – Plume Volume Molar Ratio Method
(PVMRM) or Ozone Limiting Method (OLM)
Will Become More Important to Collect
NO2/NOX In-stack Ratios from CEMS
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8. Other Accepted NO2 AQM Techniques
Tiering Approach for Including Background
Concentrations provided in Latest
Guidance Memorandum
Tier I – Add the Highest Hourly Background
Concentration to Modeling Concentration
Tier II – Multi-Year Average of Background
Data by season and hour-of-day
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9. What Does All This Mean?
Much more difficult to meet new standards
Will need to consider shutting down sources or
controlling source.
New guidance adds some flexibility for
assessing NO to NO2 chemistry
New guidance adds some flexibility for
incorporating background concentrations
New guidance on intermittent sources is very
important and benificial
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10. Recommendations
If at all possible get below the SIL for PSD
project
Complete exploratory NAAQS modeling to
determine current impacts for long range
planning at facilities (“What if” Scenarios)
Watch out for
Low wind speeds
Distance to “property line”
Impacts greater than plume can travel
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11. Questions?
Dan Dix
ddix@all4inc.com
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 19442
610.933.5246 x18
www.all4inc.com
www.enviroreview.com
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Hinweis der Redaktion
Difficult to get below 1-hour SIL
SIA = The distance from the facility of the farthest receptor greater than SIL.Background concentrations must be added to the modeled concentration from a representative ambient monitor to account for natural levels of background NO2 concentrations
March 1, 2011 Memorandum “Additional Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour NO2 NAAQS – Keep In Mind – Form of the standard is the multi-year average of the 98th percentile of the annual distribution of daily maximum 1-hour values)Consider number of days operating.Consider what other units are operating when this unit operates.Emergency Generators Test Runs (Exercising) May want to consider running during the day during better meteorological dispersion conditions
March 1, 2011 Memorandum “Additional Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour NO2 NAAQSNAAQS is NO2 – Emissions Calculated as NOX which is converted to NO2 in the atmosphere in the presence of background Ozone (O3).New Version of AERMOD set up to handle hour-of-day and seasonal ozone values.A lower NO2 in-stack ration means that there is more NO competing for Ozone to convert to NO2.
Tier I – Highest hourly background concentration from representative monitor from the 3 most recent years of available data.Tier II – 3rd highest value for seasons and hour-of-day and 8th highest value for hour-of-day only. (Last 3 years of available data)Temporal Pairing will not be accepted except on rare cases for isolated sources.New Version of AERMOD set up to handle adding in background concentrations as outline in guidance document.
Emergency Generators – unfavorable dispersioncharacteristics. (low stack height with the possibility of being affected by building downwash
AERMOD may not be the best option for predicting 1-hour impacts.