Technical Data for the Montana Regional Haze FIP

Technical Data for the Technical Data for the Montana Regional Haze FIPMontana Regional Haze FIP

Laurel Dygowski and Doug LatimerLaurel Dygowski and Doug Latimer

TAF Meeting TAF Meeting

San Francisco, CaliforniaSan Francisco, California

October 11th and 12October 11th and 12thth, 2007, 2007

Possible Structure of the TSDPossible Structure of the TSD

Summary Section on all Class I areas based Summary Section on all Class I areas based on TSS dataon TSS data

Individual sections on all Class I areas with Individual sections on all Class I areas with detailed information on monitoring, detailed information on monitoring, attribution, etc…based on TSS dataattribution, etc…based on TSS data

Section with discussion on source attribution Section with discussion on source attribution and controllable/non-controllable sourcesand controllable/non-controllable sources

TSD con’tTSD con’t

Emission Inventory SectionEmission Inventory Section Section containing the numerical data from Section containing the numerical data from

the TSS to backup graphical representationsthe TSS to backup graphical representations

Reasonable Progress – Smoke Management, Reasonable Progress – Smoke Management, Non-BART Stationary Sources, and BARTNon-BART Stationary Sources, and BART

To address non-BART stationary sources:To address non-BART stationary sources:– Worked with State on 2002 and 2005 EIWorked with State on 2002 and 2005 EI

– Determined highest emitters of SODetermined highest emitters of SOxx and NO and NOxx

– Compiled summary permit information for each Compiled summary permit information for each source, including permit limits and current source, including permit limits and current controlscontrols

– Determine Q/d for these sourcesDetermine Q/d for these sources– ECR will be looking at cost of controls for ECR will be looking at cost of controls for

sources and providing a reportsources and providing a report


Smoke managementSmoke management– State has well developed plan and is making revisionsState has well developed plan and is making revisions– Relying on the plan and the review of the FLM’s to Relying on the plan and the review of the FLM’s to

address smoke managementaddress smoke management– Determine if there are other revisions neededDetermine if there are other revisions needed– FLM’s and other EPA offices have provided information FLM’s and other EPA offices have provided information

on burn days in MT and Idahoon burn days in MT and Idaho– Smoke from other states:Smoke from other states:

Have used the TSS to look at best/worst days in Montana and Have used the TSS to look at best/worst days in Montana and recorded burn daysrecorded burn days

Have used back trajectories to correlate the effects of these Have used back trajectories to correlate the effects of these days.days.


BART SourcesBART Sources– Relying on certified data from the sourcesRelying on certified data from the sources– Using a contractor to evaluate and research Using a contractor to evaluate and research

BART for sources based on sources’ submitted BART for sources based on sources’ submitted analysisanalysis

– Contractor has referenced additional control Contractor has referenced additional control measure documents, in addition to EPA measure documents, in addition to EPA guidance and policiesguidance and policies

Montana’s Class I AreasMontana’s Class I Areas

Technical QuestionsTechnical Questions

What is the impact of sources within the What is the impact of sources within the state to total light extinction? state to total light extinction? We use TSS. We use TSS.

What is the impact of sulfate and nitrate? What is the impact of sulfate and nitrate? We use PSAT results in combination with We use PSAT results in combination with IMPROVE data regarding SOIMPROVE data regarding SO44 and NO and NO33..

What is the impact of organic and elemental What is the impact of organic and elemental carbon? carbon? We use CMAQ and weighted We use CMAQ and weighted emission potential results from TSS.emission potential results from TSS.

Simple MathSimple Math

Deciview (dv) = 10 ln (bDeciview (dv) = 10 ln (bextext/10)/10) Change in dv = 10 ln (bChange in dv = 10 ln (bext-contolext-contol/b/bext-baseext-base)) For small ext. changes delta deciview is For small ext. changes delta deciview is

approximately 1/10th the extinction change in approximately 1/10th the extinction change in percent (1.0 dv change = 10% change in bpercent (1.0 dv change = 10% change in bextext))

Change in bChange in bextext = (fractional change of species = (fractional change of species light extinction)(fraction of total blight extinction)(fraction of total bextext contributed by species)contributed by species)

Example at Medicine LakeExample at Medicine Lake

Percentage contributions of species’, source Percentage contributions of species’, source categories’ and states’ contributions from categories’ and states’ contributions from SOSO22 emissions: emissions:

– Sulfate is 28% of total bSulfate is 28% of total bextext

– Canada is 14% of total bCanada is 14% of total bextext

– Outside domain is 7% of total bOutside domain is 7% of total bextext

– North Dakota is 3% of total bNorth Dakota is 3% of total bextext

– Montana is < 1% of total bMontana is < 1% of total bextext (< 0.1 dv) (< 0.1 dv)

Source Attribution of Sulfate at Cabinet Mountains for 20% Worst Haze Days based on CAMx PSAT (1st bar = 2002; 2nd = 2018)

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AZ CA CAN CEN CO EUS ID MEX MT ND NM NV OR OutsideDomain

PO SD UT WA WY

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lfat

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Elev. Fires

Natural Fires

Motor Vehicles

Anthro Fire

Point

Source Attribution of Medicine Lake Sulfate for 20% Worst Days Based on CAMx PSAT (First bar is for 2002 baseline; second for 2018)

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PO SD UT WA WY

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Elevated Fires

Natural Fires

Motor Vehicles

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Point

Source Attribution of Nitrate at Cabinet Mountains for 20% Worst Haze Days based on CAMx PSAT (1st bar = 2002; 2nd = 2018)

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PO SD UT WA WY

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ug

/m3)

Area

Elevated Fires

Natural Fire

Motor Vehicle

Antro Fire

Point

Source Attribution of Medicine Lake Nitrate for 20% Worst Days based on CAMx PSAT (First bar is for 2002; 2nd = 2018)

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PO SD UT WA WY

Nit

rate

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ntr

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ug

/m3)

Area

Elevated Fires

Natural Fires

Motor Vehicles

Anthro Fires

Point Sources

Impacts of Biogenic Organics is LargeImpacts of Biogenic Organics is Large

Organic AerosolOrganic Aerosol

Based on CMAQ (TSS), 90% or more of the Based on CMAQ (TSS), 90% or more of the organic aerosol in western Montana is from organic aerosol in western Montana is from biogenic sources: secondary aerosol formed biogenic sources: secondary aerosol formed from gaseous terpene emissions from trees from gaseous terpene emissions from trees and vegetation.and vegetation.

Of the remainder a big fraction of organics is Of the remainder a big fraction of organics is from fire emissions, dominated by natural.from fire emissions, dominated by natural.

Anthropogenic secondary organic aerosol Anthropogenic secondary organic aerosol contributions are very small.contributions are very small.

What Can Controls Get Us?What Can Controls Get Us?

The “30,000 foot view:” PSAT, CMAQ, and The “30,000 foot view:” PSAT, CMAQ, and WEP give us estimates of the contributions WEP give us estimates of the contributions of states and categories.of states and categories.

The view from where the “rubber meets the The view from where the “rubber meets the road:” Emissions analysis gives us road:” Emissions analysis gives us information regarding what sources should information regarding what sources should be controlled.be controlled.

Q/d factors in source-receptor geometry to Q/d factors in source-receptor geometry to give relative impact estimates.give relative impact estimates.

Cumulative SO2 Emissions in Montana

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90% of Emissions come from 13 sources

Cumulative NOx Emissions in Montana

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90% of NOx Emissions Come from 32 Sourcesx Emissions come from 32 sources

PotentialPotential Long-term Strategies Long-term Strategiesto make Reasonable Progressto make Reasonable Progress

Aggressive BART controls (beyond Aggressive BART controls (beyond minimum)minimum)

Controls on largest non-BART sourcesControls on largest non-BART sources Controls on agricultural burningControls on agricultural burning Smoke management including smoke Smoke management including smoke

minimization through biomass utilizationminimization through biomass utilization Controls on diesel vehicles (on and off road)Controls on diesel vehicles (on and off road) Construction activity controls for dustConstruction activity controls for dust

What would constitute Reasonable What would constitute Reasonable Progress to the National Goal?Progress to the National Goal?

If the National Goal is no human-caused If the National Goal is no human-caused impact in Class I areas by 2064.impact in Class I areas by 2064.

This implies 100% control in 2064.This implies 100% control in 2064. We have 5 planning periods to 2064.We have 5 planning periods to 2064. This implies that a reasonable goal would be This implies that a reasonable goal would be

to control 1/5to control 1/5thth (20%) of human-caused (20%) of human-caused emissions that cause visibility impairment in emissions that cause visibility impairment in each planning period.each planning period.

(This is a strawman for discussion.)(This is a strawman for discussion.)

Technical Data for the Montana Regional Haze FIP

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