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

04/19/23 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

04/19/23 Free Template from www.brainybetty.com 15

04/19/23 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

04/19/23From 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?