Tuesday, June 16, 2015

EPA will not be able to approve Louisiana SIP as proposed for 1-hour SO2 standard

EPA has “identified a number of instances in which the State’s plan does not follow the EPA’s April 23, 2014, Guidance for 1-hour SO2 Nonattainment Area SIP Submissions and deviates from the modeling protocol approach previously agreed upon between EPA Region 6 and the Louisiana Department of Environmental Quality. Unfortunately, we do not believe we will be able to approve the SIP as proposed. The enclosure to this letter details specific issues and recommendations we have concerning the proposed attainment demonstration SIP.” 
“We appreciate your work on the proposed attainment demonstration SIP and are committed to working with you to address the issues we have identified to ensure the plan is protective of public health in St. Bernard Parish.”       

EPA's comments on Louisiana's State SIP for St Bernard Parish Sulfur Dioxide:

If the State is unable to submit a plan that EPA approves, within 18-  and 24- month milestones from non-approval, EPA must develop a FIP (Federal Implementation Plan) and apply sanctions to St Bernard Parish. Sanctions could include, limited highway funded projects and grants, and, increased emission offsets for new or modified major industry in St Bernard Parish

On April 1 2015 Louisiana submitted its State SIP for St Bernard Parish Sulfur Dioxide:

We need a State SIP with appropriate modeling and permit limits that ensures a violation cannot occur. It is not enough just to now have a promise for reduced production rates, a higher stack, and a monitor without violations. We need federally enforceable limits to protect the air we are forced to breathe. 

Basically, it seems EPA is concerned with what was excluded from the modeling used for the SIP and what was excluded from emissions data for Rain CII calcining plant.  Based on EPA's comments, LDEQ did not include:

-           all four of Rain CII’s permitted operating scenarios. “LDEQ forwarded a document that summarized Rain CII modeling of these four scenarios but it does not appear to follow the parameters previously agreed upon”  The modeling only addresses ONE of the FOUR permitted operating scenarios at Rain.

-          It does not include “Enforceable limits” to address all operating conditions at Rain CII….  It does not clearly state pounds per hour for each stack and does not ensure the limits are to be complied with on a short term rate, such as a 3-hour average.

-          It does not include All major sources within 20 km; “LDEQ should follow the previously agreed upon procedures in the modeling protocol version from late January 2015”

-          LDEQ also did not include minor sources within close proximity to the violating monitor, but EPA previously agreed to this. There is no further information on what these minor sources are or how small business maybe effected in the future.       

-          The background monitor value was not calculated correctly. “LDEQ’s use of an annual average value for 1-Hour SO2 is not acceptable."   “This is a modeling demonstration to show compliance with a one hour standard. As a result, the modeling demonstration needs to show that under worst case conditions (i.e. the most difficult hours of the year) the NAAQS will be protected. As a result, it is not appropriate to use average background conditions as proposed in the SIP.”

-          Excluded modeling receptors inside Chalmette Refinery, considering Rain’s close proximity to ExxonMobil's Chalmette Refinery, “there should be a separate  run for each of the scenarios in the attainment demonstration that evaluates a set of receptors within the Chalmette Refinery”, but that excludes emissions from the Chalmette refinery.

-          Apparently, LDEQ has permitted several EGU turbine facilities in the area that have the capability to burn fuel oil with no hours per year restriction. The largest source is Entergy's Michoud facility in New Orleans East (although New Orleans was not included in the non-attainment designation). The Michoud facility has a permit allowable of over 39,000 tons per year SO2, but no restrictions on hours per year when the power plant switches from natural gas to fuel oil.  The SIP must either include restrictions in an Administrative Order or a permit……  otherwise, this could affect the ability of the area [St Bernard] to achieve and maintain attainment..

-          The modeling protocol is undated and has significant differences from the protocol that EPA approved January 2015.

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