U.S. EPA Draft Guidance on PM2.5 Permit Modeling: Summarizing the 116-page Document
By: Liz Hendrick, Senior Scientist
On March 4, 2013, U.S. Environmental Protection Agency (EPA) released Draft Guidance for PM2.5 Permit Modeling for consideration, review, and comment. There is also an accompanying question and answer document available for review.
The guidance document reflects the EPA’s preliminary recommendations for how a stationary source seeking a Prevention of Significant Deterioration (PSD) permit may demonstrate that it will not cause or contribute to a violation of the National Ambient Air Quality Standards (NAAQS) and PSD increments for PM2.5, as required by the Clean Air Act. The document incorporates the modeling procedures and recommendations from the March 23, 2010 guidance memorandum and further clarifies for procedures for adequately addressing primary and secondarily formed fine PM2.5 in a NAAQS compliance demonstration under the PSD program.
In summary, this is still guidance, but it will ultimately have an effect on all PSD projects, even those applicants that have already submitted a PSD application but have not received a permit yet. It will have no effect on existing PSD permits.
The PM2.5 Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC) were revoked on January 22, 2013, so all sources will now be required to submit preconstruction monitoring data. One may be able to rely on data from existing monitoring sites in most cases and not have to conduct private monitoring.
EPA will be accepting comments on this draft guidance through April 17, 2013. For more information, please visit the U.S. EPA’s Web page on Permit Modeling Guidance and note that the U.S. EPA will be holding a webinar on next Wednesday March 13, 2013 from 2:30-4 pm EST. Register for the webinar at: https://www1.gotomeeting.com/register/897731257.
Does Combined Heat and Power Make Sense for your Facility?
By: AJ Jablonowski, Principal
Combined heat and power (CHP, sometimes called cogeneration) is the simultaneous production of electricity and heat from a single fuel source, such as natural gas or biomass. The most cost-effective applications are typically in facilities with year-round thermal energy needs such as industry, hotels, hospitals, colleges, schools, nursing homes, and multi-unit apartments.
What Are the Benefits of CHP?
- Efficiency: A CHP system can be 80 – 85% efficient overall, compared to 35 – 40% efficiency of electricity delivered from a central power plant.
- Reliability: CHP can provide electricity and thermal energy to a site regardless of what might occur on the power grid, decreasing the impact of a power outage. For example, parts of the New York University, Princeton University, and Fairfield University campuses that were served by their respective CHP systems remained almost entirely operational after Hurricane Sandy.
- Economic: Facilities can reduce their heating and electric bills using a CHP system. There are also financial incentives available to help fund the cost of a CHP project. President Obama signed an Executive Order to facilitate investments in industrial energy efficiency including CHP systems. The Database of State Incentives for Renewables & Efficiency lists incentives available by state. Massachusetts’ incentives range from utility sharing of feasibility study costs and rebates for installed capital costs to annual Alternative Energy Credits (AEC) payments.
- Environmental: The increased efficiency of CHP leads to a reduction of greenhouse gas emissions. This can help facilities meet sustainability goals, and may require consideration under the Massachusetts Environmental Policy Act (MEPA).
How Can Epsilon Help?
Epsilon can provide the following to a facility looking to install a CHP system:
- Experienced Professional Engineers and Certified Consulting Meteorologists, who have a broad knowledge of the energy industry with experience navigating changing environmental requirements as well as experience with alternative fuels including biomass.
- Permitting expertise, including over a dozen CHP/cogeneration studies, permits or installations, and more than 20 greenhouse gas analyses under the MEPA Greenhouse Gas Policy.
- A comprehensive approach, where we routinely advise clients through all phases of a project working with project engineers and planners through design considerations, agency and public contact, permitting, startup and compliance demonstration.
What Are the Next Steps?
Contact Epsilon for more information or assistance at (978) 897-7100 or firstname.lastname@example.org. We can work with your staff or third party engineering firm to help see if it makes sense for your facility.
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