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ENV-17-22 PM2.5 Modeling Challenges, An Unheralded Project Stopper for Large Refineries

Anna Henolson, Trinity Consultants Mark Hixson, Trinity Consultants

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $35.00

Description:

Particulate matter (PM) represents a very diverse mixture of chemicals consisting of solid particles and liquid droplets. Some particles are emitted directly from a source as “primary” emissions (e.g., soot) whereas other particles are formed in the atmosphere as “secondary emissions” from complex reactions of precursor chemicals (e.g., SO2, NOX, NH3, and VOC). Fine particles (PM2.5) exhibit more significant health effects and can remain airborne longer than coarse particles (PM10). These more significant PM2.5 health effects have driven EPA to regulate PM2.5 separately from PM10, with more stringent National Ambient Air Quality Standards (NAAQS) applied to PM2.5. In 2016 EPA finalized the latest Implementation Rule for fine particles to address State Implementation Plan requirements for areas designated as nonattainment under the 1997, 2006, and 2012 PM2.5 NAAQS. The Implementation Rule has implications for how precursor emissions are assessed from major sources in the context of control technologies and nonattainment new source review (NNSR). While fewer and more geographically isolated PM2.5 nonattainment areas exist relative to PM10 nonattainment areas, more than 50 percent of the attainment monitors in the top 10 refining states have design values within 75% of the annual PM2.5 NAAQS (at or above 9 μg/m3). The relatively small margins against the annual PM2.5 NAAQS coupled with the conservatism of EPA’s recommended single-source modeling techniques can cause significant modeling issues for existing refineries near nonattainment areas or refinery modifications in areas with elevated background concentrations. Using case studies from recent PM2.5 NAAQS State Implementation Plan (SIP) development and PM2.5 PSD air quality analyses for industrial sources, this paper illustrates the technical and regulatory challenges that can be encountered by petroleum refineries and other large industrial sources when attempting to demonstrate a facility or modification project will not cause or contribute to a violation of the PM2.5 NAAQS.

Product Details:

Product ID: ENV-17-22
Publication Year: 2017