air management study group - wisconsin department of ... · 11/1/2018 · 2015 naaqs: 70 ppb ....

Wisconsin Department of Natural Resources

Air Management Study Group Quarterly Meeting

Madison November 30, 2017

Recruitment/Staffing Update


Gail Good Air Program Director

Andy Stewart Field Operations Director

2

Proposed Guidance and Rules


Kristin Hart Permits and Stationary Source Modeling Section Chief

David Bizot

Regional Pollutants and Mobile Sources Section Chief 3

Proposed DNR Guidance


DNR Guidance in Drafting Phase Description Target Date

None

DNR Guidance Available for Comment Date Posted Comments Due

Updates to Air Dispersion Modeling Guidelines

September 1, 2017 September 22, 2017

1-hr NO2 NAAQS Implementation September 29, 2017 October 20, 2017

Finalized DNR Guidance Location Final Date

None since last time

4

EPA Proposed Rules

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Proposed rules being considered for comment Docket Comments due

None

DNR recently submitted comments Docket Comments due

EPA’s 120-day letter regarding intended 2010 SO2 NAAQS area designations

EPA-HQ-OAR-2017-0003-0519 October 5, 2017

Draft FY 2018-2022 Environmental Protection Agency Strategic Plan

EPA-HQ-OA-2017-0533-2736 October 31, 2017

Revisions to Method 202: Dry Impinger Method for Determining Condensable Particulate Emissions From Stationary Sources

EPA-HQ-OAR-2016-0456-0023 November 7, 2017

https://www.regulations.gov/document?D=EPA-HQ-OAR-2017-0003-0519


https://www.regulations.gov/document?D=EPA-HQ-OA-2017-0533-2736

https://www.regulations.gov/document?D=EPA-HQ-OA-2017-0533-2736



Guidance Module Survey



Amanda Jutrzonka

Public Information Specialist 6

Guidance Module Survey Survey Results

• Respondents - 478 • About 85% of respondents have either never used the module

or use it once or twice a year • 75% of those who never use the module did not know it existed • Respondents that do use the module find it very or fairly useful • Most want both Google-type search capabilities as well as

advanced search options • Respondents search for a variety of documents:

• Most common – air emissions inventory • Next most common – permitting guidance and policy


7

Guidance Module Survey General Take-Aways

• Most users want a Google-type search that does a search of entire documents

• MANY externals are not even aware of what the guidance module is, how to access it, or how it could benefit them

• Access to program guidance is important and should be preserved

Next Steps • User improvements • Technical upgrades • Increase awareness to the availability of the service


8

NO2 Guidance



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1-hr NO2 Guidance

Draft guidance for permit writers: Methods for making an air quality assessment for the 1-hr NO2 ambient air quality standard • Draft was placed on the Program Guidance website for 21 days • Eight formal comments received:

• Environmental consulting firms • Engine manufacturer • Utility • Trade association • Minnesota PCA • Fond du Lac Band of Chippewa

• EPA provided feedback, but decided not to make formal comments


10

1-hr NO2 Guidance

Comment Summary • Limitations of AERMOD to predict concentrations from small

variably emitting sources of NOx • Use of monitoring data • Consistency with neighboring states • Consideration of intermittent sources • Methods for deciding when modeling should be used • Potential impact to major sources undergoing PSD review when

small nearby sources have not been modeled • Use of a weight of evidence approach


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1-hr NO2 Guidance

Expected effects of 1-hr NO2 Guidance • Predictability for permit applicants • No changes to PSD major NSR reviews Next Steps • DNR drafts response to comments and final guidance • DNR meets with stakeholders, if requested • Guidance finalized – Target January 2018 • DNR continues ambient monitoring of NO2 as required by EPA


12

Member Updates


13

2018 Meeting Dates and Priority Topics


Amanda Jutrzonka Public Information Specialist

14

2018 Meeting Dates

• Proposed meeting dates • Thursday, February 15, 2018 • Thursday, May 24, 2018 • Thursday, August 16, 2018 • Thursday, November 1, 2018


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Priority Topics

2017 Priority Topics • Permitting

• 50% Registration Operation Permit (ROP) development • Permit streamlining • PM2.5 permit modeling/Significant Impact Levels (SILs)

• MATS & ICI Boiler MACT implementation • Sulfur dioxide NAAQS implementation • New Source Review Emission Reduction Credits • Implementation of the 2008 and 2015 ozone standards • Long-term planning under the new federal administration • Additional time-sensitive topics as relevant


16

Refrigerant Recovery Program


Maria Hill Compliance, Enforcement and Emissions Inventory Section Chief

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Refrigerant Recovery Program

• Processing safe transport registrations on a quarterly basis • Syncing of transporter and salvager/dismantler registrations

• Updating webpages with current coordinator and new

schedules • Outreach: direct mailings to affected customers and an article in

small business and trade association newsletters

• Working on a move of the Refrigerant Recovery Registration Database (CFC) to the Environmental Licensing & Certification System (ELC)


18

E-signature


Sheri Stach Business Support and IT Section Chief

Andy Stewart

Field Operations Director

19

E-signature

Background • E-signature finalized in Federal Register at end of August • “Digital Signature Service” developed to manage e-signature for

agency

• Programs will build a connection from program specific applications to Digital Signature Service


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E-signature

Current Project Status • Air is the first program in agency to build connection and use

service

• Initial connection being developed for e-submittal compliance documents

• Outreach and roll-out plan developed


21

E-signature


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• Outreach – External webpage – Instruction manual – Integration with existing

outreach documents – FAQs – Fact sheets – Emails/Newsletter

• Roll-Out – Pilot companies – Staff training – News release – Intra-agency

communication – IT upgrades

E-signature

Timeline • November through February 2018

• Work with program and department staff to identify issues or improvements

• Pilot group evaluation • Outreach materials created

• December 2017 – Updates to system completed

• March 2018 – System available for general use

• Post Implementation – Continue collecting feedback


23

Trends Report


Katie Praedel Air Monitoring Section Chief

Amanda Jutrzonka

Public Information Specialist 24

Trends Report

• Published on the DNR website on 11/7/17

• Additions in 2017 report

• 2008 and 2015 Ozone Standards

• 1-hour sulfur dioxide update

• Near-road NO2 monitoring update


25

Trends Report

• Success stories • Fine particle design values in WI

have decreased 30% in 14 years


26

Trends Report • Success stories

• SO2 emissions from Wisconsin sources have been reduced by 77% in the last six years

• NO2 near-road federal requirements for additional monitors were eliminated due to low concentrations recorded at established near-road monitors nationwide


27

Trends Report

• Enhancements for 2018

• Emissions inventory information

• All fine particle sites on one graph

• Multiple pollutants overview/display


28

2017 Ozone Data & 2015 Ozone NAAQS Designations


David Bizot Regional Pollutants and Mobile Sources Section Chief

Katie Praedel

Air Monitoring Section Chief 29


30

Status of the 2017 Ozone Season

2008 NAAQS: 75 ppb 2015 NAAQS: 70 ppb

Note: Data have not yet been QA’ed or certified and are subject to change. Values are only shown for monitors that exceeded their critical value at least once.

Top Four 8-Hour Average Ozone Concentrations – as of November 1, 2017

Exceeds the 2015 NAAQS critical value or standard

Exceeds the 2008 NAAQS critical value or standard

Concentrations (ppb) 2017 Critical

values Days

at/above C.V. Current 2015-2017

"design value" site 1st

high 2nd high

3rd high

4th high

2008 std

2015 std

2008 std

2015 std

Newport 74 72 71 69 77 62 0 9 73 Chiwaukee Prairie 84 80 80 79 73 58 9 43 78 Kenosha WT 81 78 77 76 84 69 0 7 73 Kewaunee 74 74 70 67 86 71 0 2 69 Manitowoc 78 77 73 71 77 62 2 13 74 Milw SER 78 73 71 67 92 77 0 1 67 Bayside 79 72 71 70 83 68 0 7 71 Grafton 81 81 78 73 87 72 0 5 71 Harrington Beach 78 77 72 71 78 63 1 13 73 Racine 83 82 81 80 84 69 0 15 74 Sheboygan Kohler Andrae 79 79 76 75 62 47 22 90 80 Sheboygan Haven 76 73 71 70 87 72 0 2 70


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Preliminary 2015-2017 Ozone Design Values

as of November 1, 2017

Data is draft/preliminary, not QA’d, and is subject to change Heavy lines delineate statistical areas


32

2015 Ozone NAAQS Designations • EPA made its initial designations for the 2015 ozone NAAQS through a final

notice signed on 11/6/2017. • EPA is taking a phased approach, designating most areas of the country as

attainment/unclassifiable while deferring action on all other areas.

• For Wisconsin, EPA designated all of Wisconsin as attainment/unclassifiable except for 16 counties (see next page).

• Counties with violating monitors, counties adjacent to counties with violating monitors, and the 8-county Milwaukee CSA.

• EPA has given no timeline for finalization of designations for the deferred

areas. The CAA requires EPA to give states at least 120 days notice prior to finalizing any designation that differs from the state recommendation.


33

EPA “Round 1” 2015 Ozone NAAQS Designations

Based on EPA’s signed final rule of 11/6/2017

Unshaded = Attainment/unclassifiable

Shaded = Deferred for later action (16 counties)

Milwaukee-Racine-Waukesha Combined Statistical Area

Permit Streamlining Update



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Permit Streamlining Update

• Scope Objective “…to improve operational efficiency and simplify the Air Pollution Permitting processes administered under chs. NR 406 and 407, Wis. Adm. Code, while remaining consistent with the Federal Clean Air Act.”

• Changes to NR 400 – Definitions

• Changes to NR 406 – Construction Permits

• Changes to NR 407 – Operation Permits

• Narrow change to NR 445.09


35

Permit Streamlining Phase I Effective December 1, 2015

• Natural Minor Exemption • Exclusion allowing certain activities prior to receiving a permit • Non-expiring non-Title V permits • Registration Permit for sources capped at 50% of major source

threshold (did not require rule change) • Exemption for restricted use engines • Engine testing allowed with higher sulfur diesel • Other clean up


36

Permit Streamlining Phase II

New exemptions under ss. NR 406.04(1) and 407.03(1) • Replace or amend solid waste incineration exemption to allow

for the incineration of confiscated drugs by law enforcement • Include exemption for external combustion units firing ultra low

sulfur diesel

Under ss. NR 406.04(2) and 407.03(2) • Allow general exemption for engines certified to meet NSPS

and RICE NESHAP

Clarifications to existing exemptions


37


Revisions to exclusion from commence construction 406.03(1e) • Delete activities that are not consistent with the federal

definition of commence construction: (a) Installation of building supports or foundations (b) Laying of underground piping or conduit (j) Paving

• Revise construction waiver language in 406.03(2)(b)2. to broaden use: c. A substantial Economic or financial hardship that may preclude the project in its entirety


38


Define “the cause or exacerbation of a violation of an ambient air quality standard” • DNR considered adding a plain definition of Cause or

Exacerbate under NR 406.02 • During final meeting workgroup, asked DNR to pursue no

further action on defining “cause or exacerbate”


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Other changes: preparation for e-docs and e-signature; clarification and cleanup; consistency • Remove references in permit chapters to submit “2 copies” • Remove requirements to “submit on paper” or for “written

notification” • Remove requirements for ink signature • Remove notes with mailing addresses • Make language consistent


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Stakeholders recommended these changes not move forward: • Administrative Construction Permit Revisions • Insignificant sources for construction permits • Like-kind replacement exemption Other paths to streamlining continue to be explored • The department is looking into structural changes to the permit

cover page and content


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Phase II Timeline

Rule must be approved by Governor no later than February 4, 2020 • Summer 2018

– Draft board order – Request for comment on draft Fiscal Estimate and Economic

Impact Analysis (FE/EIA) – Draft rule analysis

• Fall 2018 – Finalize FE/EIA, Analysis and Board Order • Late Spring 2019 – Present to NRB for adoption • January 2020 – Governor’s review/approval


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air management study group - wisconsin department of ... · 11/1/2018 · 2015 naaqs: 70 ppb ....

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