September 12, 2003 - SW Colorado PSD Increment Study

Southwest Colorado Nitrogen Dioxide (NO2)

Prevention of Significant Deterioration (PSD)Increment Study

PHASE I

http://apcd.state.co.us/permits/psdinc/

Colorado Department of Public Health & EnvironmentAir Pollution Control DivisionTechnical Services Program

September 12, 2003

September 12, 2003 - SW Colorado PSD Increment Study

Why was this periodic increment study done?

• Federal rules require states to periodically review the adequacy of their PSD plans to prevent significant deterioration of air quality (i.e., to prevent increment violations).

• Federal Land Managers expressed concern about the Class I NO2 increment at Mesa Verde.

• Colorado had concerns about growth from minor sources in the study area.

September 12, 2003 - SW Colorado PSD Increment Study

Project Phases

• For convenience, this study was divided into two phases:– Phase I : quantified increment consumption over a

broad area and identified areas with apparent increment violations.

– Phase II: studied ‘hot spots’ found in the phase I study

• A phased approach was helpful because we didn’t have to spend lots of time trying to resolve every apparent violation found in the phase I study. It kept the process moving.

September 12, 2003 - SW Colorado PSD Increment Study

Models

• Model selection was done in late 1998; modeling was performed in 1999.

• Emissions Models: EPA’s MOBILE5 and Non-Road Emission Factor models

• Meteorological Models: 1990 MM4, CALMET

• Air Quality Models: CALPUFF, ISCST3

September 12, 2003 - SW Colorado PSD Increment Study

Modeling Domain

September 12, 2003 - SW Colorado PSD Increment Study

Inventory

• Area, Mobile, and Point inventories were developed.

• Point sources were identified as increment consuming, baseline, or retired baseline.

• For area, mobile, and baseline sources, changes in actual emissions since the minor source baseline date were estimated.

September 12, 2003 - SW Colorado PSD Increment Study

Estimating changes in actual emissions since the minor source baseline date can be

problematic (a moving target)

September 12, 2003 - SW Colorado PSD Increment Study

General Model Application

• Although the domain included New Mexico, we limited receptors to Colorado for several reasons.

• CALPUFF receptors were used for Class I areas regardless of the distance from source to receptor.

• ISCST3 was used for Class II areas.

September 12, 2003 - SW Colorado PSD Increment Study

CALPUFF Model Application

• AREA sources were used in CALPUFF for only those few grid cells with significant increment consuming emissions. This was necessary so the model wouldn’t run forever.

• We wanted to use CALPUFF for both the Class I and Class II receptors, but the CALPUFF model run time (with only the Class I receptors) was about 15 days of CPU time; thus, we could not finish the project on schedule if we modeled the Class II receptors with CALPUFF.

September 12, 2003 - SW Colorado PSD Increment Study

ISCST3 Model Application

• The inventory had over 700 increment consuming point sources with numerous meteorological towers.

• For permitting, we typically select met data for the source under review, but when 700 sources are ‘under review,’ met selection is problematic.

• Many ISCST3 model runs were done with different met sets. Results were interpreted based on the ‘most representative’ met data for a given ‘hot spot.’

September 12, 2003 - SW Colorado PSD Increment Study

Baseline and Increment Consuming NOx Stationary Sources in Modeling Domain

Class I

Class I

Mesa Verde and Weminuche are federal Class I areas where the annual nitrogen dioxide (NO2) PSD increment is 2.5 micrograms per cubic meter (g/m3). All other areas are Class II areas where the NO2 PSD increment is 25 g/m3.

September 12, 2003 - SW Colorado PSD Increment Study

Change in Mobile/Area

GriddedInventory

September 12, 2003 - SW Colorado PSD Increment Study

Highway Non-Road Area Point TotalChange between 1989 and Present

-40 -46 250 28,700 28,864

Note: A negative sign indicates increment expanding emissions.

Nitrogen Dioxide PSD Increment Consuming/Expanding Emissions in Study Area

(tons per year)

Most Increment ConsumingEmissions in the Study Area

are from Point Sources

September 12, 2003 - SW Colorado PSD Increment Study

September 12, 2003 - SW Colorado PSD Increment Study

September 12, 2003 - SW Colorado PSD Increment Study

September 12, 2003 - SW Colorado PSD Increment Study

September 12, 2003 - SW Colorado PSD Increment Study

September 12, 2003 - SW Colorado PSD Increment Study

Results

• No Class I increment violations found.

• No ‘regional’ Class II violations found.

• Apparent NO2 increment violations due to complex terrain and building downwash were found in the vicinity of a large compressor station.

September 12, 2003 - SW Colorado PSD Increment Study

Public and Peer Review

• We consulted with source operators throughout the project, particularly for sources that appeared to have problems.

• We requested comments on the draft report from various stakeholders (U.S. EPA, New Mexico, Southern Ute Indian Tribe, Source Operators, Environmental groups).

September 12, 2003 - SW Colorado PSD Increment Study

Limitations and Problems

• The report had a large section on study limitations.

• A few of the important limitations included:– NOx chemistry treatment– meteorological models– lack of observations– inventory, inventory, inventory, inventory, inventory…

September 12, 2003 - SW Colorado PSD Increment Study

Closing Thought…• If you do a periodic study, consider restricting

receptors to a single ‘baseline area’ to avoid confusion. Why?– Sources located outside the ‘baseline area’ can contribute to

increment consumption regardless of the ‘minor source baseline date’ in the area where they are located.

– Why? According to EPA, only the ‘minor source baseline date’ applicable to the ‘baseline area’ under review is relevant.

– For more, see April 5, 1999 memo from Bill Harnett (U.S. EPA)