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www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Inter-Precursor Trading (IPT) Guidance
ALL4 Houston|281.937.7553 |all4inc.com30th Annual Environmental, Health & Safety Seminar
Galveston, Texas | June 5, 2017
Texas Chemical Council (TCC), Association of Chemical Industry of Texas (ACIT), Louisiana Chemical Association (LCA), Louisiana Chemical Industry Alliance (LCIA)
2 Your environmental compliance is clearly our business.
Click to edit Master title style Background IPT Guidance Ozone Formation and Tier 1 Approach Approach for Area Specific IPT Ratio Approach for case-by-case IPT Ratio Comparison with TCEQ’s IP/IB Guidance Case Study
3 Your environmental compliance is clearly our business.
Click to edit Master title style“the offset requirement for emissions of ozone
precursors NOX and VOC to be satisfied by offsetting reduction in emissions of either of those precursors…”
Federal Regulatory Drivers• 40 CFR 51, Subpart I, Section 51.165 (a)(11)(i) Permit
Requirements &• 40 CFR 51, Appendix S, Emission Offset Interpretative Ruling
State Regulatory Drivers• Texas – Title 30 Texas Administrative Code (TAC) §101.302(a)
and §101.372(a)• Louisiana – Title 33 Louisiana Administrative Code (LAC), Part III
§504.F (AQ354)
Background – Why?
4 Your environmental compliance is clearly our business.
Click to edit Master title styleBackground – Ozone Formationsunlight
VOC + NOX O3 (and other products)
No sunlight no ozone productionNo NOx no ozone productionNo VOC no ozone production
5 Your environmental compliance is clearly our business.
Click to edit Master title style VOC Limited – When hydroxide (OH) radicals
production is less than the rate of production of NOX,Ozone production is VOC limited.
NOX Limited – When rate of OH production is greaterthan the rate of production of NOX, indicating NOX inshort supply, Ozone production is NOX limited.
NOX Disbenefits – NOX emissions can lead to not onlyformation but sometime destruction of ozone, slowsthe ozone formation rate. NOX disbenefits isphenomenon where NOX emissions reductions canlead to ozone increases instead of decreases.
Background – Ozone Formation
6 Your environmental compliance is clearly our business.
Click to edit Master title style On October 04, 2016, U.S. EPA published draft
guidance document - “Technical Guidance forDemonstration of Inter-precursor Trading (IPT) forOzone in the Nonattainment New Source ReviewProgram”
Technical guidance for both air agencies and permitapplicants
Approach to establish an area specific ozone IPT ratio• Screening Approach• Refined Approach
Approach to establish a case-specific ozone IPT ratio• Tier 2 Refined Photochemical Modeling Approach
IPT Guidance
7 Your environmental compliance is clearly our business.
Click to edit Master title style Screening Approach
• Analysis of existing technically credible data Emissions inventory data Ambient monitoring data Meteorological data for area
• Establish Ozone Formation NOX limited area or VOC limited area
• If NOX Limited Offset ratio of 1:1 for NOX credits No VOC credit allowed
IPT Guidance – Area Specific IPT Ratio
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8 Your environmental compliance is clearly our business.
Click to edit Master title style Refined Approach
• Use of new or existing NOX and VOC single-source impactson downwind ozone assessment to estimate IPT ratio Existing relevant technical information such as air quality
modeling data for hypothetical industrial source can be used Depending on the size of the original study, this can be only
developed for a sub-area The use of pre-existing credible information for this purpose will
be done by air agencies in consultation with EPA• Comparability analysis
Includes average and peak temperatures, humidity, terrain, ruralor urban nature, nearby regional sources, and ambientconcentration profiles
• EPA’s MERP Guidance can be used
IPT Guidance – Area Specific IPT Ratio
9 Your environmental compliance is clearly our business.
Click to edit Master title style Permit applicant may choose to NOT rely on the air
agency’s default ozone IPT ratio Case Specific IPT ratio allows permit applicant to
develop robust IPT ratio applicable to the projectspecific circumstances
Case Specific Approach• Consult with agencies and prepare protocol• Conduct photochemical gird modeling for post-project
emissions increases and credit sources and compareimpacts
• Submit modeling report and modeling files• Get approval from State air agency and EPA
IPT Guidance – Case Specific IPT Ratio
10 Your environmental compliance is clearly our business.
Click to edit Master title stylePhotochemical Models
Photochemical models are numerical models that simulate the emission, chemical transformation, transport, and deposition of gases and aerosols
Gases and Aerosols
Emissions
Chemical TransformationTransport
Deposition
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Click to edit Master title stylePhotochemical Models
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Click to edit Master title styleCAMx – Photochemical Grid Model
Figure from: CAMx User’s Guide Version 6.0, Environ, May 2013: Pg. 7.
13 Your environmental compliance is clearly our business.
Click to edit Master title style Identify the location of the project source (VOC
increases) and relevant credit source (NOX decreases) Model the project source and credit source(s) using
appropriate model (CAMx) to develop modeledOzone impacts from precursors
Compare the modeled results• All modeled impacts in grid cells within nonattainment
area with elevated ozone prediction• Use NAAQS relevant averaging period – daily maximum 8-
hr average• Discard the negative impacts (i.e. project impact > credit)• Hourly ozone impacts summed over all grid cells in the
area• Impacts from VOC and NOX compared to daily IPT ratios
IPT Guidance – Case Specific IPT Ratio
14 Your environmental compliance is clearly our business.
Click to edit Master title style Calculate IPT Ratio are calculated as the product
of the “relative change in emissions” and the“relative change in the modeled ambient O3 levelsdue to precursors• NOX emissions increases offset by VOC credits
Ratio of 𝑁𝑁𝑁𝑁𝑁𝑁:𝑉𝑉𝑁𝑁𝑉𝑉 = 𝑁𝑁𝑁𝑁𝑁𝑁 𝑡𝑡𝑡𝑡𝑡𝑡𝑉𝑉𝑁𝑁𝑉𝑉 (𝑡𝑡𝑡𝑡𝑡𝑡)
∗ 𝑁𝑁𝑂 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 𝑁𝑁𝑁𝑁𝑁𝑁 𝑡𝑡𝑡𝑡𝑝𝑝𝑁𝑁𝑂 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 𝑉𝑉𝑁𝑁𝑉𝑉 𝑡𝑡𝑡𝑡𝑝𝑝
• VOC emission increases offset by NOX credits
Ratio of 𝑉𝑉𝑁𝑁𝑉𝑉:𝑁𝑁𝑁𝑁𝑁𝑁 = 𝑉𝑉𝑁𝑁𝑉𝑉 𝑡𝑡𝑡𝑡𝑡𝑡𝑁𝑁𝑁𝑁𝑁𝑁 (𝑡𝑡𝑡𝑡𝑡𝑡)
∗ 𝑁𝑁𝑂 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 𝑉𝑉𝑁𝑁𝑉𝑉 𝑡𝑡𝑡𝑡𝑝𝑝𝑁𝑁𝑂 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 𝑁𝑁𝑁𝑁𝑁𝑁 𝑡𝑡𝑡𝑡𝑝𝑝
IPT Guidance – Case Specific IPT Ratio
15 Your environmental compliance is clearly our business.
Click to edit Master title styleEPA’s IPT Guidance
IPT guidance is optional andincludes Tier 1 & 2 approaches
IPT is guidance is case-by-caseand subject to agency approvals
IPT ratio calculation may requiremultiple modeling runs fordifferent scenarios
Credit source(s) modeled atcredit source location
Analysis of the entire basin andall grid cells in the domain isrequired
Maximum daily day-by-dayimpact evaluation is required
IPT vs Inter-pollutant (IP)TCEQ’s IP Guidance
IP guidance is mandatory forpermit applicants
IP guidance provides a detailedprocedure for modeling
IP ratio calculation is morestraightforward and depends onthe impact
Credit(s) modeled within 1 kmcircle from the project sourcelocation
Analysis of only grid cells withhigh ozone impact is required
Analysis of ozone monitorswithin the nonattainment area isrequired
16 Your environmental compliance is clearly our business.
Click to edit Master title style Hypothetical Industrial Facility located in the
Houston-Galveston-Brazoria (HGB) area Typical industrial facility with petrochemical/refinery
source profile• Industrial boilers• Engines• Catalytic cracking units• Tank farm• Polymerization and Alkylation Units etc.
Project – VOC emissions increase of ~ 145 tpy Credit – NOX emissions credits
• Option 1 – Control existing boilers• Option 2 – Utilize existing ERC
Case Study - Project
17 Your environmental compliance is clearly our business.
Click to edit Master title styleEPA’s IPT Guidance
Option 1• IPT Ratio
VOC:NOX = 1:1 Actual ratio 1:0.55
Option 2• IPT Ratio
VOC:NOX = 1:3.47
Case Study - ResultsTCEQ’s IP Guidance
Option 1• Overall Air Quality
VOC:NOX = 1:1 Actual ratio 1:0.28
• Design Value AnalysisVOC: NOX = 1:**
Option 2• Same as above
18 Your environmental compliance is clearly our business.
Click to edit Master title styleOption 2 – Credit source
at Project LocationOption 1 – Credit source
at Project Location
Case Study - Results
Monitor 3
Monitor 2
O3 Titration
Monitor 1
Project
O3 Formation
Credit
O3 Titration
Monitor 1
Source
O3 Formation
Monitor 2
Monitor 3
Credit
19 Your environmental compliance is clearly our business.
Click to edit Master title style IPT Guidance provides technical guidance to establish area
specific as well as case-by-case specific IPT ratio Depending on the project situation, the IPT ratio can vary
significantly – different atmospheric conditions can influenceprecursor potential of ozone formation
EPA’s IPT and TCEQ’s IP Guidance document difference inseveral aspects
Differences in the guidance can impact project timeline andoutcome
Be aware of unique situations like NOX Disbenefits If you have an upcoming project
• Plan ahead and understand your facility profile Understand the VOC speciation Understand the Credit sources
• Complete some fatal flaw analysis• Engage agency earlier in the process (if possible)
Conclusions
Q&A and Discussion
Thank You !!!