Regional Haze ProgramRegional Haze ProgramRegional Haze Program

Mary Jean Fenske, MPCA

Aq-rule1-03

Twin Cities Skyline During Twin Cities Skyline During Particle Alert Particle Alert

St. Paul Skyline During St. Paul Skyline During Local Particle EpisodeLocal Particle Episode

dv= 15, VR=85 km dv=2, VR=320 km

Grand Canyon National ParkGrand Canyon National ParkGrand Canyon National Park

Fine Particles: Main Factor in HazeFine Particles: Main Factor in HazeFine Particles: Main Factor in Haze

The DriversThe Drivers● CAA §169A

“…prevention of any future, and the remedying of any existing, impairment of visibility in … Class I areas which impairment results from manmade air pollution”

● 40CFR §51 “…calls for States to establish goals and emission reduction strategies for improving visibility in all 156 mandatory Class I national parks and wilderness areas.”

National Park and Wilderness Areas Protected by Haze RuleNational Park and Wilderness National Park and Wilderness Areas Protected by Haze RuleAreas Protected by Haze Rule

Average VisibilityAverage VisibilityAverage Visibility

Average visibility expressed as deciviews, calculated from aerosol concentrations measured in the IMPROVE monitoring program.

Regional Planning OrganizationsRegional Planning OrganizationsRegional Planning Organizations

Urban v. Rural(Annual Average Fine Particle Concentrations)Urban v. RuralUrban v. Rural(Annual Average Fine Particle Concentrations)(Annual Average Fine Particle Concentrations)

4 Core Requirements of SIP4 Core Requirements of SIP

1. Calculate Baseline & Natural Visibility Conditions

2. Reasonable Progress Goals 3. BART (Best Available Retrofit

Technology)4. Long-term Strategy (includes control

measures needed to achieve goals)

0

5

10

15

20

25

1980 2000 2020 2040 2060 2080

deci

view

sFirst SIP Goal in 2018 2.1 deciview improvement

Attain natural background on worst days by 2064

No degradation on best days

Reasonable Progress Goal: BWCA

7 dv 20 dv

BWCA CameraBWCA Camera

Regional Haze Monitoring SitesRegional Haze Monitoring SitesRegional Haze Monitoring Sites

Fine mass proportions on 20% “worst” daysFine mass proportions on 20% Fine mass proportions on 20% “worst” days“worst” days

Boundary WatersBoundary WatersBoundary Waters

High Extinction Days

Orange: where air is most likely to come from on poor air quality days. Green: where air is least likely to come from on poor air quality days.

Low Extinction Days

Green: where air is most likely to come from on good air quality days. Orange: where air is least likely to come from on good air quality days.

Comparing Incremental Probability on Good and Bad Visibility DaysComparing Incremental Probability Comparing Incremental Probability on Good and Bad Visibility Dayson Good and Bad Visibility Days

Air DataAir DataAir Data

BART BasicsBART Basics

Federal regional haze rules requires emission controls or Best Available Retrofit Technology (BART) on certain facilities emitting pollutants that reduce visibility

EPA Guidelines For BART EPA Guidelines For BART DeterminationsDeterminations● MPCA asking for comment on its BART

strategy ● BART strategy follows the EPA

Guidelines● Comment period is Sept. 6 – Oct. 21● Public Information meeting on Oct. 4http://www.pca.state.mn.us/news/data/inde

x.cfm?PN=1

Steps in Implementing Steps in Implementing BARTBART1. Identify facilities that are BART-

eligible2. Determine whether facility causes

or contributes to visibility impairment in a Class I area

3. Conduct a BART determination for facilities that are subject to BART

4. Make BART limits federally enforceable, e.g. through a permit

1. Identify facilities that are 1. Identify facilities that are BARTBART--eligibleeligible

● Facilities in one of 26 categories listed● Same categories as PSD

● Facilities with emission units built between 1962 and 1977

● Sum of “limited” potential to emit from those units is greater than 250 tpy of SO2, NOx, or PM

Request for Information was sent to facilities in late July 2005

What facilities in Minnesota What facilities in Minnesota may be BARTmay be BART--eligible?eligible?● Electric Generating Units*● Taconite facilities● Paper mills● Refineries● Others

*If affected EGU covered under Clean Air Interstate Rule, state may accept CAIR as substituting for BART

MN’s Class I Areas and Nearby Facilities

2. 2. Determine whether facility Determine whether facility causes/contributes to visibility causes/contributes to visibility impairment in Class I areaimpairment in Class I area

Perform individual source exemption analysis:● Use CALPUFF or other EPA approved

model● Compare to natural background● “Cause”= impact > 1.0 deciview● “Contribute”= impact > 0.5 deciview (or

lower)

3. Conduct a BART deter3. Conduct a BART deter--minationmination for facilities subject for facilities subject to BARTto BART

Facility will conduct a BART determination used by MPCA to establish emission limits. Analysis considers:● Costs of compliance● Energy and non-air environmental impacts● Existing controls at source● Remaining useful life of plant● Visibility improvement reasonably expected

from the control technology

4. Make BART limits federally 4. Make BART limits federally enforceableenforceable

MPCA reviews BART determinations and makes emissions limitations federally enforceable through:● Title V Permit; and/or●Rule; and/or●Compliance document such as

Administrative Order

Timeline for BART ImplementationTimeline for BART ImplementationTimeline for BART Implementation

BART controls in place (5 yrs after SIP approved)<2014

MPCA submits Regional Haze SIP to EPADec. 2007

MPCA determines what additional control strategies beyond BART are needed to meet goalAugust 2007

By this date, BART-eligible facilities that are not exempt submit a BART determination

April 2006(tentative)

MPCA completes Individual Source Exemption AnalysisNov. 2005

BART Strategy Notice Published in MN State RegisterSept. 2005

MPCA sent out Request for Information (RFI) to facilities July 2005

EPA published regional haze rule amendmentsJuly 6, 2005

Staff InvolvementStaff Involvement● David Thornton – Chair, Policy

Oversight Group● Margaret McCourtney – Modeling

Wkgrp and Midwest RPO tech liaison● Gordon Andersson – Monitoring Wkgrp

and SIP development● Paul Kim – Emission Inventory Wkgrp● Mary Jean Fenske – SIP development

and BART implementation● John Seltz – Co-chair, Control Strategy

Wkgrp