PM2.5 Permitting Implementation in MN

1. PM2.5 Permitting Implementation in MN Steven Pak, P.E. Minnesota Pollution Control Agency AWMA-UMS PM2.5 PSD Implementation Workshop August 27, 2008

2. PSD Permitting in Minnesota Nonattainment NSR does not apply Minnesota is currently a delegated PSD State 40 CFR �52.21 applies MPCA may develop a SIP-approved program PM2.5 rule effective July 15, 2008

3. PM2.5 PSD Rule Implementation in Minnesota Condensables (Organic and Inorganic) must be included in: Emission calculations and applicability determinations BACT analyses Permit emission limits Stack testing Dispersion modeling Only SO2 and NOx are considered PM2.5 precursors

4. PM2.5 Calculations � When are they required? Total Facility Permit Applications (GI-07 and EC forms) Change/Modification Applications (CH-04 and EC forms) May also be required if: AERA/Environmental Review required Project controversial or concerns exist Project going to the Citizens Board for any reason

5. PM2.5 Emission Factors � What are the best ones to use? Emission factor means the most accurate and representative emission data available�. (Minn. R. 7005.0100) EPA: AP-42, FIRE, and PM Calculator Stack test results (if representative) Manufacturer guarantees (may not be reliable) Assume all PM/PM10 is PM2.5 Combinations of the above (e.g., PM2.5/PM10 ratios applied to stack test results) Supporting documentation for emission factors and calculations is critical!

6. PM2.5 Emission Limits � When will they be included in permits? If a PM2.5 BACT limit is established If a limit on PTE is established If required by federal or state rules Emission limit may also be included in permits: To avoid issues with modeling the NAAQS or, when finalized, the increment To reduce health risks estimated through an AERA or risk assessment

7. PM2.5 Stack Testing � When will it be required? Stack testing may be required in the following situations: To verify compliance with a BACT limit To verify compliance with a any other permit limit To establish or verify an emissions factor

8. PM2.5 Stack Testing Methods � What will MPCA accept? Method 202 or Other Test Method (OTM) 28 for condensables OTM 27 or Conditional Test Method (CTM) 39 for PM2.5 Method 5 and Method 201A assuming everything PM2.5 Other options may exist - Contact MPCA stack testing staff

9. PM2.5 PSD Modeling � When will it be required? Required if a project triggers PSD for PM2.5 (i.e., major modification or new major source) EPA hasn�t yet finalized increments, SILs & SMCs Until rule finalized, increment modeling not required Until rule finalized, MPCA will use most stringent/conservative SILs and SMCs in EPA�s proposed rule: Class I SIL: 0.04 �g/m3, annual; 0.07 �g/m3, 24-hr Class II SIL:0.3 �g/m3, annual; 1.2 �g/m3, 24-hr SMC: 2.3 �g/m3, 24-hr average

10. PM2.5 Modeling � When Else Might It Be Required? �Modeling may be required, even if PSD is not triggered, in the following situations: Environmental Review required AERA required Projects going to the Citizens Board for any reason Concerns exist with PM2.5 NAAQS and, when finalized, the increment

11. MPCA PM2.5 Contacts

12. Additional Resources MPCA NSR Web Clearinghouse http://www.pca.state.mn.us/air/permits/nsr/index.html Air Quality Listserv http://www.pca.state.mn.us/air/air-techinfo.html