Tennessee Air Quality Issues Presented to: Tennessee Mining Association Department of Environment and Conservation.

Tennessee Air Quality Issues

Presented to: Tennessee Mining Association

Department of Environment and Conservation

We Have Moved!

TDEC’s central office personnel have moved to a new location.

Our new address is TN Department of Environment and

ConservationDivision of Air Pollution ControlWilliam R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 15th Floor Nashville, TN 37243

The Commissioner is on the 2nd floor.

Presentation Outline

The NAAQS Criteria Pollutant Process Ozone PM2.5

Sulfur Dioxide

Greenhouse Gases (GHG)

History of the Clean Air Act (CAA)

The Air Pollution Control Act of 1955 The Clean Air Act of 1963 Air Quality Act of 1967 Clean Air Act of 1970 Clean Air Act Amendments of 1977 Clean Air Act Amendments of 1990

The NAAQS Process

EPA has set national ambient air quality standards for each of the criteria pollutants to be met in all states of the nation.

Periodically, EPA revises these standards, usually making them more restrictive, to reflect the latest science about exposures to the pollutant.

The NAAQS Process - Continued

A nonattainment designation means: The air in the area may not always be

healthy to breathe.

Emission and procedural requirements on sources of air pollution in the nonattaining area will need to be made more stringent than those in attaining areas of the state.

Tennessee filed a petition for reconsideration regarding the Shelby County designation of nonattainment. Local governments in Anderson, Blount and Knox Counties filed their own petition for reconsideration. EPA denied the petitions.

Tennessee 2008 Ozone NAAQS Nonattainment Areas

A New 2014 Ozone NAAQS?

EPA has announced that it will be reviewing the latest scientific data, particularly the recommendations of CASAC, and finalizing a new, proposed ozone NAAQS in December 2014. The new NAAQS is very likely to be more restrictive.

PM2.5

Overall, PM2.5 levels in Tennessee have been improving.

There are two PM2.5 NAAQS: Annual, set at 15 µg/m3 → new 12 µg/m3

standard Daily, set at 35 µg/m3

PM2.5 is primarily composed of sulfates, organic compounds and ammonia

On January 15, 2013, EPA promulgated a new Annual Standard set at 12 µg/m3 and retained the current 35 µg/m3 daily standard. This new rule became effective March 18, 2013. Designations are scheduled to occur in spring 2015.

1997 Annual and 2006 Daily PM2.5 Nonattainment Areas

SO2 Nonattainment Designation Recommendation for Tennessee

EPA promulgated a new NAAQS for Sulfur dioxide (SO2) on June 10, 2010.

Tennessee currently has one non-attainment area for the 1 hour SO2 ambient standard.

EPA will make designations in stages. This graphic represents the 1st stage that is based upon existing monitoring data. The next stages will be based upon a combination of new monitoring data and/or modeling data. Notable SO2 emission sources are later shown to illustrate areas of the state that will be the subject of further analysis.

Tennessee 2010 SO2 NAAQS Nonattainment Areas

Department of Environment and Conservation

Sulfur Dioxide – Modeled Nonattainment Area Recommendations

The story is yet to be written

Challenging standard with a model that does not necessarily reflect accurate predictions in terrain areas.

Tennessee views climate change discussions as a global and national issue. Its stance on Greenhouse Gases is to comply with federal law & regulations.

Greenhouse Gases are being inventoried under the federal requirement to track trends.

Greenhouse Gases (GHGs)

Greenhouse Gases

On June 23, 2014, the U.S. Supreme Court ruled that the Environmental Protection Agency stepped outside its bounds by changing the greenhouse-gas emissions threshold in the Clean Air Act. The court also said the EPA cannot require greenhouse-gas permits for certain industries. The ruling partially reverses a 2012 federal appeals court decision; however, the court found the EPA can still regulate greenhouse-gas emissions from industries that are already required to get permits for other emissions.

Greenhouse Gases

What does this mean for Tennessee? Only sources that are PSD major for

another pollutant and greenhouse gases will be required to undergo PSD BACT review for GHGs.

Sources previously considered Title 5 major only for greenhouse gases are no longer required to obtain a Title V permit.

What the GHG Tailoring Rule Is By rule/policy, PSD and Title V

permitting programs under the Clean Air Act apply to major sources and modifications of “regulated NSR pollutants.” Greenhouse gases (GHG) have never

before been “regulated” and thus have not been covered by these programs.

Many concerns were raised about how EPA would administer these programs if GHG became “regulated.”

What the Tailoring Rule Isn’t

The tailoring rule does not dictate limits on emissions of greenhouse gases Emission limits will be set as part of the

PSD permitting process (Best Available Control Technology)

Greenhouse Gases

On June 18, 2014 EPA issued proposed standards of performance for carbon emissions from existing power plants.

Also on June 18, 2014, EPA issued proposed standards of performance for carbon emissions from reconstructed and modified power plants.

TDEC/APC is preparing comments to submit to EPA about this controversial proposed action under the authority of 111(d) of the CAA.

EPA is proposing guidelines to be used by the states to develop a plan under 111(d). EPA is proposing a goal – a CO2 emission rate in lbs/MWh - for each state. Under 111(d), this rate would represent BSER – the Best System of Emission Reduction.

Carbon Pollution Emission Guidelines

EPA would have you believe that the proposed rule with its 4 building blocks provides the states flexibility to tailor their responses to the rule to their own specific energy profiles, needs, and policies. This is not the case.

Carbon Pollution Emission Guidelines

Building Block I:For Building Block I, EPA applies an average heat rate improvement of 6% across all coal-fired EGUs in the state. For Tennessee, this reduces the state goal from the 2012 rate of 2,244 lbs / MWh to 2,110 lbs/ MWh.

Carbon Pollution Emission Guidelines

Building Block I:TDEC has concerns about the reasonableness of EPA’s methodology for this building block, the accuracy of data used (or lack of thereof) to make assumptions across a portfolio of coal-fired units at the national level, as well as the feasibility of implementing heat rate improvements (HRI) at the proposed levels across all coal units in Tennessee.

Carbon Pollution Emission Guidelines

Building Block II:EPA focused on reducing emissions amongst affected EGUs by shifting demand from higher-emitting EGUs to lower-emitting EGUs. Specifically, EPA proposed to reduce emissions from affected EGUs by shifting demand away from coal-fired EGUs, while ramping up generation across all existing and under-construction NGCC EGUs in states. This shifting of demand from one EGU to another is known as “re-dispatching.”

Carbon Pollution Emission Guidelines

Building Block II:Re-dispatch of generation from higher-emitting facilities to lower-emitting facilities may be a strategy to reduce emissions. However, any technically feasible dispatching scenario is entirely dependent on the system’s ability to adequately, reliably, and affordably manage supply and demand constraints.

Carbon Pollution Emission Guidelines

Building Block III:EPA’s building block 3 methodology proposes to reduce mass emissions through the use of an expanded amount of less carbon-intensive generating capacity. Unlike the measures included in building blocks 1 and 2, carbon emission reductions in this building block are assumed to occur across all affected EGUs.

Carbon Pollution Emission Guidelines

Building Block III:The low- and zero-carbon emitting generation technologies EPA’s analysis considered for inclusion in this building block are existing and under-construction nuclear facilities; new, upgraded, and existing conventional hydroelectric capacity; urban and rural utility-scale solar photovoltaic (PV), concentrated solar power (CSP); onshore wind; conventional geothermal; select existing biopower capacity types; offshore wind; and distributed renewable energy generation technologies.

Carbon Pollution Emission Guidelines

Building Block III:EPA included nuclear generating capacity in this building block under the assumption that it can replace generation at fossil fuel-fired EGUs, thereby reducing CO2 emissions. EPA concludes that increasing nuclear capacity above the amount of nuclear capacity that “would otherwise be available to operate” is a technically viable approach, citing low variable operating costs of nuclear

Carbon Pollution Emission Guidelines

Building Block III:Building block 3’s nuclear methodology yields inequitable results between states and across regions of the country, with a particularly substantial impact upon states in the Southeast. Georgia, South Carolina and Tennessee are the only three states where nuclear construction is currently occurring in the United States. The proposal’s distinction between states with nuclear and those without nuclear is arbitrary and punishes states in the Southeast for forward-thinking investments in large-scale, zero-emitting technology.

Carbon Pollution Emission Guidelines

Building Block IV:

Energy Efficiency – outside the fence line for regulatory agencies under the Clean Air Act

Carbon Pollution Emission Guidelines

Electronic Document Submittal

The Department has begun accepting documents electronically, but not confidential information.

Send non-confidential documents to [email protected]

You can copy your permit writer, but be sure to send it to the above email so it is logged in as officially received.

PDF signatures are acceptable, no hard copy necessary.

Information to EFOs

Each APC Environmental Field Office also has an official email address.

Chattanooga: [email protected] Columbia: [email protected] Cookeville: [email protected] Jackson: [email protected] Johnson City: [email protected] Knoxville: [email protected] Nashville: [email protected]

Questions?