Welcome

1. Welcome General Information Session:Air Permitting and Proposed Coal-Fired Power Plants

2. Before we Begin… • Registration • Handout • Presentation materials available on website • Questions • Note Cards and Microphones • Discussion Room • Breaks and Restrooms

3. Vinson Hellwig Chief Air Quality Division

4. Today’s Goals • Provide information on MDEQ Air Quality Division’s responsibilities and role in permitting coal-fired power plants • Listen to concerns and answer questions about permitting process

5. Agenda • Overview Air Quality Division • Overview of Air Permitting Process • Human Health Risk Assessment • Project Overviews • General Question Session

6. Air Quality Division Overview Jim Ostrowski MDEQ, Environmental Assistance Program 517.241.8057 ostrowskij2@michigan.gov

7. Department of Environmental Quality Air Quality Division Office of Geological Survey Environmental Science & Services Division Remediation & Redevelopment Division Land & Water Management Division Waste & Hazardous Materials Division Water Bureau

8. Air Quality Division Overview RegulatoryAuthority Clean Air Act Part 55, of the Natural Resources and Environmental Protection Act Michigan Air Pollution Control Rules

9. Air Quality Division Overview Air Quality Division Field Operations Enforcement Evaluation Permits Toxics Air Monitoring Rule Implementation Evaluate Permit Applications Conduct Inspections Determine Compliance

10. Air Quality Division Overview • What is Reviewed When Making a Permit Decision? • Conduct Technical Review of Application • Proposed Emissions • Proposed Control Technology • Impacts to Public Health & Environment Identified in Fed and state air rules

11. Air Quality Division Overview • What is NOT Reviewed When Making a Permit Decision? • Zoning Restrictions • Site Selection • Traffic Patterns (except dust) • Light • Noise • Consumer Demand/Product Need • Carbon Dioxide (CO2) Emissions

12. Air Quality Division Overview • MDEQ has the authority to regulate: • Pollutants with established National Ambient Air Quality Standard (NAAQS) • CO, NOx, SO2, PM, Lead, Ozone (VOC) • Hazardous Air Pollutants – • 187 pollutants • Toxic Air Contaminants • As defined by rule

13. Air Quality Division Overview • Michigan Climate Action Council • Created under Executive Order • Provide Inventory CO2 and other greenhouse gas (GHG) emissions • Identifying policies/strategies Michigan should adopt to reduce CO2 and other GHG emissions www.miclimatechange.us

14. Air Quality Division Overview • Permit to Install operates as contract • Contains emission and material limits, operation and design restrictions • Contains monitoring/recordkeeping, testing sampling, and reporting requirements • Allows facility to begin construction or installation • Major sources must also obtain a Renewable Operating Permit

15. Source Duties Comply with conditions Monitor emissions Maintain records Submit reports Apply for new or modified permit if certain changes are made AQD Duties Monitor stack testing Conduct inspections Review emission reports Review compliance certifications Certify monitoring systems Respond to complaints Air Quality Division Overview Air Permit

16. Air Quality Division Overview • AQD operates within strict framework of what is allowed by law • Procedures for review of permit application • Operate openly and transparently • Opportunities for public comment • Staff available for questions

17. Air Permitting Process Mary Ann Dolehanty AQD Permit Section 517.373.2098 dolehantym@michigan.gov

18. Rule 201 Permits to Install “A person shall not install, construct, reconstruct, relocate, alter, or modify any process or process equipment ... which may emit an air contaminant, unless a permit to install which authorizes such action is issued by the Department”

19. Two Types • Permit To Install (PTI) • Required Prior to the Construction of a New Source or a Modification to an Existing Source. • Renewable Operating Permit (ROP) • Required for Major Sources. Incorporates all Applicable Requirements at Facility (PTIs and State/Federal Rules) & Includes Enhanced Monitoring, Recordkeeping, & Reporting

20. Categories of Permits to Install Minor Source • Proposed emissions below defined thresholds • Examples: Auto Parts Suppliers , crematories, etc. Major Source • Large emitting sources that emit above certain defined thresholds • Example: Auto Assembly Plants & Power Plants

21. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

22. Administrative & Technical Completeness Check • What is a complete application? • Assure the application is both administratively and technically complete • All information needed to begin the review

23. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

24. Technical Review • Type, size and location of source • Emission calculations/proposed emissions • Applicable state and federal requirements

25. Technical Review (cont) • Control Technology review • BACT (Best Available Control Technology) • MACT (Maximum Achievable Control Technology) • TBACT (Best Available Control Technology for Toxics)

26. Technical Review (cont) • Ambient Impact Analysis/Modeling • Compare impacts of proposed emissions to established federal standards (NAAQS) and state health based criteria (TACs)

27. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

28. Development of Draft Permit Conditions AQD Coordination and Agreement on Draft Conditions Applicant Input on Draft Conditions Assurance that all Requirements Met

29. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

30. Public Participation Process • Required by Federal Permitting Rules for major sources • Fact Sheet with Draft Conditions • 30 Day Public Comment Period • Public Hearing • Public notice of comment period/hearing • Local newspapers, AQD website, Direct mailing • Notification of EPA, Local Government & Interested Parties

31. Public Participation Process • Enhanced Public Participation Process • Website Posting of Applications and related information • General Information Session • Public notice of comment period/hearing • Local newspapers, AQD website, direct mailing, press release, public service announcements, re-Noticing • 60 Day Public Comment Period • Site Specific Information Meetings • Multiple Public Hearing Times • Public Comment will be accepted via email

32. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

33. Permit Decision • Decision-making Process • Review of comments received • Re-evaluation of application • May Need Additional Information or Review • Response to comments document

34. Permit Decision • Three Possible Outcomes • Approval • Approval with Modifications • Denial • Notification of Final Decision • Letters to Interested Parties, EPA, & Local Government

35. Process Steps Administrative & Technical Completeness Check Technical Review Development of Draft Permit Conditions Public Participation Process Permit Decision

36. Human Health Risk Assessments for Power Plant Proposals in Michigan Robert Sills Toxicologist Specialist Michigan Dept. of Environmental Quality Air Quality Division 517-335-6973 sillsr@michigan.gov June 25, 2008

37. Toxicology and Risk Assessment • Toxicology is the study of harmful effects of exposure to substances. • Risk assessment is the estimation of potential adverse health effects from exposure to substances. This includes evaluating hazards, exposures, and potency, and characterizing the potential risk of health effects.

38. Overview of air toxics risk assessment for power plants This talk will briefly cover: • Types of air contaminants • Cancer and noncancer risks • Screening levels for inhalation exposure • Mercury and lead oral exposure • Cumulative impacts of inhalation exposure to complex mixtures

39. Air contaminants regulated • Criteria pollutants: ozone, lead, carbon monoxide, sulfur dioxide, nitrogen dioxide, particulate matter • Toxic air contaminants (“air toxics”): non-criteria pollutants, which could be harmful at some level in the air.

40. Regulatory standards and criteria to ensure public health protection • Criteria pollutants: EPA has established National Ambient Air Quality Standards which are designed to protect the public health. • Air toxics: AQD has developed screening levels that are designed to be protective of the public health.

41. AQD Screening Levels are: • Air concentrations of substances that are protective of the public health • based on the available toxicity information • protective for inhalation exposure, for all people (including sensitive groups), for a lifetime of exposure • protective for noncancer and cancer effects

42. Noncancer risk • Includes all types of harmful effects other than cancer. • Irritation, organ toxicity, reproduction and development effects, neurological effects, etc. • There is assumed to be a safe exposure level below a “threshold” for effects. • Screening levels are designed to be protective, taking into account uncertainties.

43. Cancer risk • Carcinogens are substances that have been shown in human or animal studies to increase the development of tumors. • Carcinogens include benzene, dioxins, arsenic, etc. • Carcinogens are assumed to pose some level of risk at any air concentration. • Screening levels are set at a level of protection of 1 in 1 million risk or 1 in 100,000 risk, for a lifetime of exposure.

44. How screening levels are applied in regulating air emission sources • Anticipated emission rates of air toxics are determined. • Computer modeling accounts for the emission source characteristics, emission rate, and meteorology information, to model the dispersion of air toxics. • The model estimates the impacts to the ambient air (the outdoor air that people may breathe). • The ambient air impacts cannot exceed the screening levels.

45. Deposition and oral exposure • Some air pollutants can deposit out of the air and pose concerns for oral exposure. • Mercury and lead can raise this concern more than other substances.

46. Mercury and lead concerns • Both can pose a risk of affecting neurological development in children, among other effects. • Methylmercury has a very high tendency to accumulate in fish tissue, resulting in exposure for people eating fish, and fish consumption advisories. • Lead can accumulate in soil and dust; it is already a public health problem in some areas, primarily due to the historical use of lead paint.

47. Assessment of power plant mercury emissions • For each of the proposed power plants, the local mercury deposition is modeled. • Local water bodies are the focus, because relatively more deposition impact is close to the source. • Models account for the environmental fate of mercury in the local watersheds. • 30-year accumulation in fish is estimated.

48. Assessment of power plant mercury emissions, cont’d • People are assumed to eat fish; mercury exposure and risk are estimated. • Impacts should be considered in the context of background levels, which may already be elevated.

49. Assessment of power plant lead emissions • Although lead is a criteria pollutant, not an air toxic, a detailed assessment is warranted. • Lead air emissions can deposit and accumulate in topsoil, and can affect house dust levels. • Lead air emissions are modeled for dispersion and deposition.

50. Assessment of power plant lead emissions, cont’d • Children’s total lead “background” exposure from air, soil, dust, food, and drinking water is estimated. • The facility calculated impact is added, after 30 years at the point of maximum impact. • Children’s exposure is estimated, both with and without the added impact of the facility.