Presentations on Permits & Compliance made in Track A at EUEC 2015, San Diego, CA.

A6.1 Compliance Determinations for Coal-Fired EGUs that are Subject to BART

Carl Weilert, Principal Consultant, CVW Consultants, LLC
EPA’s Regional Haze (RH) Rule requires the installation of best available retrofit technology (BART)
on emission sources in 26 source categories that began operation between 1962 and 1977 if those
sources are found to cause or contribute to visibility impairment in any federal Class I area. RH state
implementation plans (SIPs) were required to identify all units that are “subject to BART” based on
the results of visibility impairment modeling. EPA has completed its review of all RH SIPs and has
issued its determination of the adequacy of the state plans. In some cases, EPA has issued federal
implementation plans (FIPs) to cover deficiencies in the SIPs. Each SIP or FIP identifies, for all units
that are subject to BART, the specific emission control and/or emission limit that constitutes BART for
emissions of SO2, NOx and PM. States affected by the Cross State Air Pollution Rule (CSAPR) were
allowed to substitute the emissions trading program requirements of that rule for BART requirements
with regard to SO2 and/or NOx emissions (but not PM emissions) from EGUs. Most CSAPR-affected
states opted to do so. Western states, which are not covered by CSAPR, generally included full BART
determinations for all EGUs that are subject to BART in their RH SIPs. This paper presents an analysis of
the final BART determinations for all coal-fired EGUs that are subject to BART and presents an analysis of
the emission rates and control technologies that were established as BART.

synapse-logoA6.2 EPA’s AVERT: Avoiding Emissions From the Electric Sector Through Efficiency & Renewable Energy
Jeremy Fisher, Sr. Scientist, Synapse Energy Economics; Robyn DeYoung, EPA State & Local Climate & Energy Program
Historically, states have been reticent to use energy efficiency (EE) & renewable energy (RE) as
mechanisms to reduce criteria or other pollutants to meet EPA regulations; measuring reductions due
to EE/RE was prohibitively complex or expensive. EPA commissioned Synapse to develop an openaccess
tool designed to allow states & other stakeholders to rapidly calculate, on an hourly basis,
locational emissions benefits of EE/RE programs. AVERT, the Avoided Emissions & Generation Tool, has
undergone rigorous peer review & beta testing in five states. AVERT is a statistical behavioral model
built on publicly available operational data. It identifies which generators are likely to reduce emissions
of CO2, SO2, & NOx due to EE/RE. The tool is designed to allow states to use EE/RE initiatives in State
Implementation Plans (SIPs). AVERT & similar tools will allow stakeholders to assess the efficacy of using
EE to meet CO2 reduction goals.

hmhA6.3 Air Quality Compliance Management for Small & Mid-Size Rural Utilities
Erik Haas, Principal, HMH Consulting LLC
This presentation provides a summary of the potential challenges small and mid-sized rural utilities face
in complying with local, state and federal air pollution regulations. The presentation also describes
possible options to avoid or obtain variances for federal rules for rural utilities. Specific cases to be
discussed will include: Balancing compliance with 40CFR60 (NSPS) and Part 63 (NESHAP) for diesel and
gas fired engines, utility boilers, gas turbines municipal and oily waste incinerators; Use of Environmental
Compliance Management Systems (EMS) that meet ISO 14001 standards but are greatly reduced
in scope and are suitable for small utilities; Potential pitfalls when using federal construction grants
for clean-coal and green energy projects; Special considerations for utilities that are not part of the
Federal Aid Highway System (FAHS); Special Best Available Control Technologies (BACT) considerations
for rural utilities; Use of alternative emission monitoring methods, data acquisition, record storage and
reporting systems for small and mid-sized utilities; Electric transmission line losses and electric generation
efficiency questions for cold regional climates.

360factors-logoA6.4 A Look at EPA’s Proposed New Ozone Standards

Jon Greene, Air Quality Engineer, 360factors; Ed Sattar
EPA’s Proposal and Basis: The EPA proposed a lower 8 hour ozone standard in November 2014. They
are proposing to lower it from the current 75 ppb to a number between 65 and 70 ppb and are
accepting public comments on lowering it further to 60 ppb. EPA reports that its basis for the lower
standard is the reduction of premature death, acute bronchitis, asthma-related ER visits, asthma
attacks, and missed work and school days. Review of EPA’s Report: EPA published a 575 page report
in support of its proposed reduction. We review the report’s findings, scientific basis, results of modeling
the proposed reduction in ozone. What are the report’s findings? What scientific studies did the report
use? What did EPA’s model predict? Review of Scientific Literature: We review some real world
data that EPA did not consider in its report. Ozone Chemistry; Hospital records of asthma admissions;
What is the national trend in asthma diagnoses, and What is the national trend in ozone? Real World
Considerations and Problems Implementing the New Standard: Ozone: an outdoor pollutant: People:
an indoor creature: Epidemiology studies: Costs of Implementing the Standard: Big Bend National Park
may be redesignated to Nonattainment.

zephyrA6.5 The Pursuit of Representative PM2.5 Emission Factors for Gas-Fired Combustion Units
Louis Corio, Senior Air Quality Scientist, Zephyr Environmental Corporation
The more restrictive PM2.5 NAAQS and EPA’s May 2014 guidance for conducting PSD permit modeling
analyses for PM2.5 emissions are necessitating a more accurate representation of emissions for permit
applicants, especially for projects involving natural gas-fired combustion units. Data collected under
test method research programs demonstrate that PM2.5 measurements using EPA reference methods
are not representative of the actual, lower emissions from natural gas combustion. Despite this
information, AP-42 PM2.5 emission factors for combustion turbines and boilers, developed using the EPA
reference methods, remain unchanged. However, EPA has recognized concerns with the reference
method for condensable PM – Method 202, issuing interim guidance in April 2014 for processing Method
202-based measurements that may yield lower emission factors for some sources. With available
supporting technical information from PM2.5 measurement research studies, alternate reference
method-based emission factors that better represent actual PM2.5 emissions are being developed by
permit applicants and approved for use by regulatory agencies. This presentation discusses successful
uses of such alternate PM emission factors by the regulated community, and analyzes the potential
benefit of emission factor adjustment based on EPA’s recent interim guidance for processing Method
202 measurements.

A7.1 EPA 301 Study on Visible Emissions from large stacks
Allison Dolan, Visible Emission Consultant, Sustainable Skys
The presentation will explain the EPA’s 301 Alternative Method Evaluation methodology & the data
required to achieve a Broadly Applicable Alternative Method designation. The presentation will detail
the studies performed to compare the Digital Opacity Compliance System with EPA Method 9 to
determine the equivalence of the Methods in a large stack environment as well as fugitive & non-point
source environments. The presentation will explain the field procedures & data quality required for an
EPA 301 study & the comparison evaluation. The presentation will conclude with a case study of the
use of the EPA 301 Method for determining the applicability of EPA Alternative Method 082 for large
diameter stack emissions.

all4_logoA7.2 The Evolution of Greenhouse Gas Permitting
Jennifer Flannery, Project Manager, All4 Inc.
In April 2007, the U.S. Supreme Court ruled that greenhouse gases (GHGs) were “air pollutants” under
the Clean Air Act (CAA) and must be regulated by U.S. EPA if GHGs could be reasonably anticipated
to endanger public health and welfare1. In response to the Court’s ruling, U.S. EPA issued its final
Endangerment Finding in December 2009 concluding that six classes of GHGs did, in fact, endanger
public health and welfare by causing global climate change, triggering a requirement to issue GHG
regulations under the CAA. This began the evolution of GHG permitting. This presentation will walk you
through the history of GHG permitting and highlight the legal challenges that have had major effects
on the permitting of GHGs, including the June 23, 2014 Utility Air Regulatory Group vs. U.S. EPA Supreme
Court decision2. Recent case studies will provide insight into the effects these challenges have as
industry struggles with trying to prepare GHG Best Available Control Technology (BACT) determinations.
The presentation will also provide insight into complying with the proposed New Source Performance
Standards (NSPS) for new power plants under CAA Section 111(b) and the Clean Power Plan to regulate
existing power plants under CAA Section 111(d).

Black_Veatch_LogoA7.3 Project Risks In Determining Startup Emissions Limits For Air Permits
Mark Bleckinger, AQC Section Lead, Black & Veatch; Jason Zoller
Startup emissions limits are becoming a standard part of new air permits for combined cycle power
plants due to recent court rulings and policy changes. Preliminary emissions data estimated by
combustion turbine OEMS is typically used by permitting consultants to develop the emissions limits
used in the permit application. Due to the many variables involved and transient nature of a startup,
accurately predicting startup emissions is difficult. Standard EPA approved test methods for the
measurement of emissions during a transient conditions do not exist. The accuracy of using CEMS
equipment during transient conditions is unknown. Due to these factors and depending on how
the project is executed, the OEMs and EPC contractors may not be willing to provide commercial
guarantees for startup emissions which could impact the financing of the project. This paper presents
these issues and offers some strategies to mitigate the risk of setting permit requirements that cannot
be met during project development, project execution, or during operation of the plant after project

cpp_logo_BLUEA7.4 Implications of Accurate Source Characterization On Permitting for the 1-hour NAAQS
Ron Petersen, Vice President, CPP, Inc.
The 2013 EPA Draft SO2 NAAQS Designations Modeling TAD states that an accurate characterization
of the modeled facility is critical. The document also says that that if the building information is not
accurate, downwash will not be accurately accounted for in AERMOD. This paper will discuss two
generic facilities, one with a 31 m high long narrow solid building and a single stack that is 1.5 times
the building height. The second facility has two 50 m high porous structures located near a single
stack of the same height. Accurate building information was assembled and input into BPIP. The BPIP
AERMOD input file was analyzed and the following problems were found: 1) building widths and/or
lengths outside the range of AERMOD theory; and 2) the porous structures were assumed to be solid.
In spite of inputting accurate site information, BPIP generated building dimensions for AERMOD input
will not result in accurate predictions. An EPA “Source Characterization” study was conducted where
“Equivalent Building Dimensions” were defined that more accurately model the dispersion for these
two sites. AERMOD was then run using the original BPIP determined inputs and the refined inputs based
on a more accurate “Source Characterization.” With refined BPIP inputs, the max 1-hr concentration
decreased by factors of 2 to 3.5 Due to the stringent nature of the 1-hr NAAQS, clearly a more
accurate source characterization should be high on the list of refined modeling options.

A7.5 At the Intersection of Modeling, Permitting, & Compliance – The NO2/NOx In-Stack Ratio
Shirley Rivera, Principal Consultant, Resource Catalysts
This presentation provides perspectives for the project developer and the air agency regarding the
identification and selection of the NO2/NOx In-Stack Ratios (ISRs). The Federal EPA recognizes this is
important and has been in the process of collecting information for a publicly available database;
however, this database is still evolving. Choosing a representative ISR can mean the difference
between operational flexibility, constrained operations, and/or more timely permit processing. But
unlike emission benchmarks established for BACT requirements, there are not yet ISR benchmarks.
Since the implementation of the more stringent federal 1-hour NO2 NAAQS ambient air quality standard
established in 2010, there has been increased awareness about the relevance of the NO2/NOx ISR.
Hosted by EPA on its SCRAM website, ISRs are being compiled. That said, the ISR has typically been
perceived as an air quality modeler?s concern. However, the justification of the ISR also is meaningful
for those in the permitting and emissions testing roles. Projects subject not only to major source
permitting but also minor source permitting may require NO2 air quality modeling. Furthermore, as part
of operating permits, some air agencies may require compliance demonstration of the NO2 fraction of
the NOx emissions not only for normal operations but also for startup operations. This presentation will
include examples of projects that have undergone permitting and required to justify ISRs.

aecomA7.6 Fast Starts vs. Modeled Compliance: A Feasibility Study for New Power Generation
Sara Head, Vice President, AECOM
This presentation will provide the results of a feasibility study that assessed the viability of up to 1,000
megawatts of new power generation at a site in Southern California. The study looked at two scenarios,
one with combined-cycle generation and the other with use of simple-cycle peakers only. Other
ancillary equipment, such as a boiler, cooling tower, emergency generators and a fire water pump,
was included. The availability of sufficient meteorological and air quality data was evaluated, and a
new modeling data set was assembled. Turbine performance data were obtained from the potential
turbine manufacturer in order to have the latest information on emissions and stack parameters at this
site. The emissions were modeled in order to determine whether or not compliance with both National
and California Ambient Air Quality Standards could be demonstrated. The modeling for demonstrating
compliance with NO2 AAQS used ozone limiting method as a refinement. The faster starts that are
needed to serve the grid ramp rates but which cause NO2 1-hour ambient standards compliance
issues during the startup hour were assessed. Data on NO2/NOx in stack ratios was compiled from
various air district, EPA and manufacturer’s data. A health risk assessment (HRA) with the potential air
toxics emissions was also performed. Other issues, such as an assessment of potential future regulatory
changes and the availability/cost of offsets, were also assessed.

eeiA8.1 The Final MATS Rule: Last Call for Compliance
Michael Rossler, Manager, Environmental Programs, EEI
The final MATS rule for coal- & oil-based EGUs was published February 16, 2012. Affected sources had
three years to comply—by April 16, 2015, which is in two months. Some companies have gotten a oneyear
extension, some companies may need an additional year. To date, this rule is unprecedented
in its scope & has created numerous challenges for the electric utility sector. After numerous legal
challenges—which are still not over—and resolution on only few issues requested for reconsideration,
companies are moving forward with compliance. Where does MATS compliance fit in with the big
picture of other environmental rules, recently promulgated & imminent?

SLR-logoA8.2 Summary of Compliance for MATS Options
Eri Ottersburg, Senior Engineer, SLR International; Bruce Macdonald
MATS contains many options for compliance including which pollutants to use and how to demonstrate
compliance. Also available is designation as a low-emitter. Making sure the EGU is on schedule can
be tricky with all the other compliance, monitoring, and testing requirements already on the calendar
especially if you are starting or restarting a new unit. The compliance clock starts as soon as an EGU
sells power, will all the systems be ready in time to demonstrate compliance with MATS? I will outline
a compliance schedule and summarize the demonstration requirements, continuing compliance
requirements, and reporting requirements for various MATS options.

TrinityLogoA8.3 MATS Emissions Averaging – Restrictions and Implementation
Russell Bailey, Principal Consultant, Trinity Consultants
Many utilities are using emissions averaging to allow more flexibility in meeting MATS, and, for the most
part, using emissions averaging is straightforward, with good flexibility to use stack test, CEMS data,
or both. However, an emissions unit operating under an emissions averaging plan is not unlimited
in operation, due to §63.10009(d), which requires that the emissions rate achieved during the initial
performance test must not exceed the emissions level that was being achieved 180 days after April 16,
2015 or in some cases earlier, or alternatively an analogous restriction on control technology efficiency.
This presentation reviews in detail what §63.10009(d) means and how it impacts your units operating
under an emissions averaging plan.

CongressA8.4 EPA’s Power Plant Carbon Standards: A View from Capitol Hill
James McCarthy, Specialist in Environmental Policy, Congressional Research Service
Congressional reaction to EPA’s power plant carbon standards — both the New Source Performance
Standards & the requirements for existing power plants — has been sharply divided. The House, since
2011, has voted repeatedly to strip EPA of regulatory authority over greenhouse gas emissions or to
set conditions on the use of that authority that would prevent the agency from moving forward with
the proposed standards. The Senate, with its more cumbersome procedures, has rejected the Housepassed
measures, or simply refrained from considering them. In 2015, a new Congress with newly
elected majorities can be expected to consider such legislation again. This presentation will discuss
the new Congress’s options as EPA moves to finalize the power plant carbon rules.

ch2mA8.5 The Effects of Changing Permitting Regulations
Don Caniparoli, Air Quality Scientist, CH2M HILL; Tim Burke & Dave Weiss, US Borax
This presentation will describe the effects of PSD delegation and the GHG Supreme Court Decision
on an on-going co-generation permitting project. Rio Tinto Minerals U. S. Borax (U.S. Borax) operates
a co-generation facility to provide power and steam for the borate plant in Borax, California. The
existing co-generation facility needed to be replaced and two new natural gas-fired turbines with heat
recovery steam generators (HRSG) were proposed. Initial permit applications included a Prevention of
Significant Deterioration (PSD) application to US EPA Region IX for PM2.5 and Greenhouse Gases (GHGs)
and a New Source Review (NSR) application to Eastern Kern Air Pollution Control District (EKAPCD).
Additionally, the new co-generation facility was required to meet California Environmental Quality Act
of 1970 (CEQA) requirements for criteria and GHG pollutant impacts. During the permitting process, PSD
authority was delegated to EKAPCD and the GHG PSD requirements changed based upon the June,
2014 Supreme Court ruling. Continuing the permitting process with changing regulations and regulatory
authority resulted in application updates, application withdrawals, application resubmissions and ongoing
dialogues with regulatory agencies. Ultimately, US Borax expects to receive an NSR construction
permit and a PSD permit amendment for the new co-generation unit without any changes to the basic
project design.