IN THE MATTER OF :
STATIONARY RECIPROCATING
INTERNAL COMBUSTION
ENGINES AND TURBINES:
AMENDMENTS TO 35 ILL
.
ADM
. CODE SECTION 201 .146,
AND PARTS 211 AND 217
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PLEASE TAKE NOTICE that I have today filed with the Office of the Pollution Control
Board the attached
TESTIMONY OF ROBERT KALEEL, YOGINDER MAHAJAN, SCOTT
LEOPOLD, AND MICHAEL KOERBER
of the Illinois Environmental Protection Agency a
copy of which is herewith served upon you
.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
NOTICE
RECEIVED
CLERK'S
OFFICE
MAY 1
1 2007
Pollution
STATE OFControl
ILLINOIS
Board
By:
Rachel L . Doctors
Assistant Counsel
Division of Legal Counsel
DATED: May 10, 2007
P.O . Box 19276
Springfield, Illinois 62794-9276
217/782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
:
)
STATIONARY RECIPROCATING
)
INTERNAL COMBUSTION
)
ENGINES AND TURBINES
:
)
AMENDMENTS TO
35 ILL.
)
ADM. CODE SECTION
201.146,
)
AND PARTS 211 AND 217
)
TESTIMONY OF ROBERT KALEEL
My name is Robert Kaleel
. I am the Manager of the Air Quality Planning Section,
Division of Air Pollution Control, Bureau of Air at the Illinois Environmental Protection Agency
("Illinois EPA"), Springfield, Illinois
. I have a Bachelor of Science degree in meteorology from
Northern Illinois University
. I have worked at the Illinois EPA for more than twenty-six years,
and have been in my present position since 2004
. Prior to that, I was the Manager of the Air
Quality Modeling Unit in the Air Quality Planning Section, a position that I held for more than
fifteen years
. I have also worked as a private consultant as a specialist in air quality modeling
.
As Manager of the Air Quality Planning Section, my responsibilities include oversight of staff
that provides technical support for regulatory initiatives needed to address air quality issues in
Illinois, including the regulatory proposal before the Board at this hearing
. The Air Quality
Planning Section also provides technical support to the Bureau of Air's permitting and
enforcement functions, and is responsible for maintaining the Bureau's emission inventory
system, including Annual Emission Reports
. I have been closely involved with the development
R07-18
(Rulemaking - Air)
RECEIVED
CLERK'S
OFFICE
MAY 1
1 2007
Pollution
STATE OF
Control
ILLINOISBoard
of Illinois' State Implementation Plans to address the PM 2,5 and ozone nonattainment areas in
Illinois.
The purpose of my testimony is to explain the purpose of this proposal, and to describe
the components of the proposed rule . Included in this proposal are amendments to 35 Ill . Adm .
Code Parts 201, 211 and 217 . Adoption of the proposed rules will reduce emissions of nitrogen
oxides ("NOx") from stationary reciprocating internal combustion engines and turbines
.
This proposal is intended to satisfy Illinois' obligations under the United States Environmental
Protection Agency's ("USEPA") NO, State Implementation Plan
("SIP") Call Phase II. The
proposal is also intended to address, in part, Illinois' obligation to meet certain requirements
under the federal Clean Air Act ("CAA"), specifically the requirements for reasonable further
progress ("RFP"), reasonably available control technology ("RACT") for these source
categories, and attainment demonstrations for the 8-hour ozone and PM 2 5
National Ambient Air
Quality Standards ("NAAQS").
On July 18, 1997, USEPA promulgated revised primary and secondary ozone NAAQS
that increased the averaging period for the ozone standard from 1-hour to 8-hour and lowered the
concentration for violations from 0 .12 to 0 .08 parts per million ("ppm") .
It has long been
recognized that volatile organic compounds ("VOC")
and NO, are the primary precursors
responsible for the formation of ground level ozone . Illinois has two areas (greater Chicago and
Metro East/St
. Louis), consisting of 12 counties or partial counties, that were designated as
nonattainment areas for the 8-hour ozone standard. The designations were effective on June 15,
2004. The two areas in Illinois are classified as moderate nonattainment areas
. Moderate
nonattainment areas are required to submit attainment demonstrations by June 15, 2007,
addressing how the State will achieve the 8-hour ozone standard by the attainment date of June
Page 2
15, 2009, which is six years from the effective date of the nonattainment designations
.
On July 18, 1997, USEPA also added a new 24-hour and a new annual NAAQS for fine
particles, using as the indicator particles with aerodynamic diameters smaller than a nominal 2
.5
micrometers, termed PM2.5.
USEPA has determined that, in addition to direct particulate matter,
that NON
, S02
,
VOCs, and ammonia are precursors to the formation of PM
2.5. States are required
to address NO R,
sulfur dioxide ("SO 2 "),
and direct emissions of PM 2 5 in their attainment plans
.
USEPA has designated two areas in Illinois (greater Chicago and Metro East/St
. Louis),
consisting of 12 counties or partial counties within Illinois, as not attaining the PM
2.5
standard.
The designations became effective on April 5, 2005
. The attainment demonstration is due April
5, 2008, and the attainment date for most areas is April 5, 2010
. States maybe granted up to a
five-year extension of the attainment date with a demonstration showing that it is impractical for
the state to attain within five years and that the state is making generally linear progress toward
attainment.
As part of Illinois' effort to develop a comprehensive attainment strategy for ozone and
PM2 5,
Illinois EPA plans to propose reasonable and cost effective NO, control on all major
source sectors statewide, because NO, is a primary precursor to both ozone and particulate
matter
. This statewide approach to NO, control is consistent with the rulemaking now pending
with the Board addressing the requirements for the Clean Air Interstate Rule
("CAIR"),
which
addresses NO, emissions from utility boilers
. However, based upon USEPA's modeling,
reductions from CAIR are not sufficient to insure attainment in Illinois of the ozone and PM2 .5
NAAQS .
The Illinois EPA has been working with its counterparts in nearby states to develop
attainment demonstrations for both of its nonattainment areas
. In the Lake Michigan region, the
Page 3
modeling demonstrations are being performed under the direction of the Lake Michigan Air
Directors Consortium ("LADCO")
. For the Metro-East/St
. Louis area, the Illinois EPA has been
working with the State of Missouri . The LADCO modeling, while it is not yet complete, has also
shown that the reductions from the implementation of CAIR are not enough for Illinois' two
nonattainment areas to reach attainment of the PM 2 .5 NAAQS, and may not be sufficient to allow
the Chicago nonattainment area to reach attainment of the 8-hour ozone NAAQS . LADCO's
modeling does show, however, that controlling NO, emissions on a regional, and not just a local
basis, results in improved ozone and PM2 , 5 air quality . LADCO has prepared a summary of
recent modeling that describes the role of NO, emissions in causing ozone, PM 2 5 and regional
haze problems in the Midwest and has identified a number of candidate control measures . Mike
Koerber, Executive Director of LADCO, will provide testimony to the Board as part of this
rulemaking describing the summary document.
Control of engines and turbines, as well as other sources of NO R, is an important and
necessary part of Illinois' attainment strategy for ozone and PM 2.5 . Hence, the Illinois EPA has
proposed in this rulemaking that NO, emission reductions be required at the same level as that
required by the NO, Call Phase II for turbines and engines that are not subject to Phase II . In
addition, the Illinois EPA is planning on proposing that NO, RACT emission controls be
implemented statewide on other major stationary source categories
. These NO, reductions are
needed for PM 2,5 and possibly ozone attainment, which are regional pollutants affected not just
by NO, emissions within a local (nonattainment) area, but emissions from upwind areas as well
.
Illinois EPA is also developing and will propose SO 2 RACT level of emissions control statewide .
For all these reasons, the statewide approach to NO, control is appropriate
.
The geographic region subject to "Subpart Q : Stationary Reciprocating Internal
Page
4
Combustion Engines and Turbines" is the entire State of Illinois
. Emissions of NO, from
stationary internal combustion engines are not currently regulated in the State of Illinois . The
proposed regulations are expected to affect existing and new units . There are 28 existing engines
that were identified by the NO, SIP Call that will be subject to this rule. The Illinois EPA
estimates that there are more than 1,300 stationary engines, and more than 200 turbines,
currently operating in the state . The estimated reduction of NOx emissions from the 28 engines
identified by the NO, SIP Call is 5,422 tons per ozone season . The proposed regulations will,
when fully implemented, reduce NO, emissions statewide by approximately 7,540 tons per
ozone control season . The NOx SIP Call does not require any emission reductions on an annual
basis . The proposed regulations will, when fully implemented, reduce NO, emissions statewide
by approximately 17,869 tons annually . This equates to a 65 percent NO, reduction annually,
and a 55 percent NOx
emission reduction in the ozone season, from this source category
.
The Illinois EPA's staff has determined that affected engines and turbines can meet the
requirements of proposed Subpart Q through a combination of control techniques such that
compliance is both technically feasible and economically reasonable . Based on USEPA's
Alternative Control Techniques ("ACT")
document there are a number of control options
available which achieve the control levels proposed in this rulemaking in the range of unit sizes
affected
. In addition, the Illinois EPA's staff found that the levels proposed in this rule were
consistent with rules promulgated in other states . The Illinois EPA considers the control
requirements of this proposal to be technically feasible and economically reasonable
.
The proposal being considered today is the result of an extensive stakeholder process
.
Throughout the development of the rule, the Illinois EPA has sought and received comments
from interested parties
. The Illinois EPA held three general meetings (August 25, 2005, October
Page 5
5, 2005, and November 14, 2005) to which owners and operators of affected units and
environmental groups were invited
. At least three additional meetings were held at the request of
particular groups or companies affected by this proposal
. The Illinois EPA's proposal was
amended several times in response to comments provided by stakeholders
. It is my
understanding that the areas in which the parties have reached agreement are the applicability
levels for engines and turbines, the control levels for engines and turbines, use of an emissions
averaging plan as a method of compliance, the exemptions, the frequency of testing, treatment of
low usage units, the compliance dates, and the use of NO, allowances to address unexpected
noncompliance issues
. The areas where the parties did not reached agreement include the
statewide applicability of the rule . However, the Illinois EPA is proceeding with the proposal
because the overall benefit of the rule outweighs the detriment of further delay
. The Illinois EPA
has presented and discussed with the stakeholders the need for statewide reductions of NO x
emissions from sources located in both attainment and nonattainment areas in order to achieve
the 8-hour ozone and PMz5 NAAQS .
The Illinois EPA is proposing a new Subpart Q
: Stationary Reciprocating Internal
Combustion Engines and Turbines to Part 217
. The rule is intended to apply to stationary
reciprocating internal combustion engines rated 500 brakehorsepower and above, and turbines
rated 3.5 MW and above
. Illinois EPA is proposing separate concentration limits for different
types of engines and turbines, and based on the kind of fuel used
.
The Illinois EPA recognizes that many of the engines and turbines in use in Illinois
operate only intermittently and may not be cost-effective to control
. To reduce compliance costs,
the proposal provides a number of exemptions and compliance options
. Proposed exemptions
are offered for emergency and standby units, units used for research or performance verification,
Page 6
units that are used primarily to control gas from landfills, units used for agricultural purposes,
and portable units . The Illinois EPA is also proposing special requirements for low usage units
where the potential to emit ("PTE") from all engines and turbines at a source is below 100 ton
per year of NO, emissions
. Low usage units may also be exempt from the requirements to meet
the emission limits if the aggregate usage of the units is below specified thresholds .
The proposal includes alternate compliance options which provide companies with
flexibility in reducing their compliance costs . The proposal allows owners and operators the
option to comply with an emissions averaging plan in lieu of meeting the specified concentration
limit for each affected unit . Unit located in Illinois that commenced operation before January 1,
2002, and are owned by the same company or parent company, can in most cases be included in
an averaging plan . An averaging plan must insure that the total mass of actual NO, emissions
from all affected units included in the emissions averaging plan must be less than the total mass
of allowable NO, emissions for the same units
. The proposal contains specific formulas for
making the calculations needed to demonstrate compliance . This option will allow owners to
control units that are most cost effective to control, and reduce or avoid control costs for units
that are more expensive to control .
Another compliance option proposed in the rule allows owners and operators to use NO,
SIP Call allowances to meet the compliance requirements if they meet certain criteria
. This
option is intended to provide flexibility to owners and operators when noncompliance is due to
unforeseen circumstances
. An owner or operator can use this option up to two times in any five-
year rolling period
. The correct type of NO, allowances must be used, that is, annual allowances
must be used for exceedances of an annual limit and ozone season allowances must be used for
exceedances of a seasonal limit . This option is included in the proposal at the suggestion of
Page 7
stakeholders and will again provide increased operating flexibility and will reduce compliance
costs .
The Illinois EPA is proposing four different compliance dates
. Engines subject to the
NO, SIP Call, as listed in Appendix G, must comply by May 1, 2007 . Emission units that are
located in either of the 8-hour ozone or PM2
.5 nonattainment areas comply by January 1, 2009 .
For units located outside of the two nonattainment areas, later compliance dates are proposed
because of concerns expressed by stakeholders about the availability of equipment and
contractors needed to install the controls
. Accordingly, the Illinois EPA is proposing that the
larger engines and turbines, engines rated at 1,500 bhp or more, or turbines rated at five MW or
more, that are located outside of the two nonattainment areas comply by January 1, 2011, and
that the smaller engines and turbines located outside of the two nonattainment areas comply by
January 1, 2012
. Again, this extended compliance schedule was added at the request of
stakeholders who believed that there would be insufficient contractors to install the necessary
equipment if the Illinois EPA's initial compliance schedule was implemented .
The Illinois EPA's proposal provides a flexible approach for meeting the requirements
for testing and monitoring
. In general, affected units must conduct a compliance test by the
applicable compliance date . Engines listed in Appendix G, for example, must be tested by May
1, 2007
. Affected units that operate intermittently do not need to be tested until after they have
operated at least 876 hours in a year
. Units that operate less than 876 hours per calendar year can
be tested at the owner's or operator's choosing any time within the first five years after the
applicable compliance date .
Units listed in Appendix G and units included in an emissions averaging plan must
subsequently be tested once every five years
. In years in which a compliance test is not
Page 8
performed, the proposal requires that an inexpensive portable NOx monitor be used annually to
verify continued compliance
. For units that operate less than 876 hours per calendar year
monitoring is required only once every five years .
Page 9
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
PROPOSED STATIONARY
)
RECIPROCATING INTERNAL
)
COMBUSTION ENGINES AND
)
TURBINES : AMENDMENTS TO 35 ILL .
)
ADM. CODE SECTION 201.146,
)
AND PARTS 211 AND 217
)
TESTIMONY OF YOGINDER MAHAJAN
Good Morning. My name is Yoginder Mahajan . I am employed as an
Environmental Protection Engineer in the Air Quality Planning Section in the Bureau of
Air of the Illinois Environmental Protection Agency (Illinois EPA) . I have been
employed in this capacity since March 1992 . Prior to my employment with the Illinois
EPA I worked for various metal fabrication industries for nine (9) years . My educational
background includes a Bachelor of Engineering Degree in Mechanical Engineering from
Bhopal University at Bhopal, India .
As part of my regular duties in the Air Quality Planning Section, I have been
involved with preparing emission estimates for various source categories used in the
development of the 1990 ozone season weekday emissions inventories
; evaluating control
technologies applicable to volatile organic material (VOM) emissions sources utilized in
the preparation of the Rate-of-Progress plans for the Chicago and St . Louis ozone
nonattainment areas; and assisting in the development of regulations for the control of
VOM emissions from source categories included in the Rate-of-Progress plans
.
Regarding the proposal before you today, I have been involved in the development of the
regulations to control nitrogen oxides (NOx) from stationary reciprocating internal
R07-18
RECEIVED
CLERK'S OFFICE
(Rulemaking -3y)
1 12007
Pollution
STATE OFControl
ILLINOISBoard
1
combustion engines (RICE) and turbines . I provided the list of affected sources for the
proposal and technical feasibility of NOx controls for the Technical Support Document
(TSD) for the proposal .
RICE and turbines are used throughout the United States to drive compressors,
pumps, electric generators and other equipment . In Illinois, a prominent use of large
engines is to drive natural gas pipeline compressors . Emissions of NOx are the result of
combustion of fuel at high temperatures and pressures in the RICE and turbines, which
cause the nitrogen and oxygen in the air that sustains the combustion to unite and form
the various oxides of nitrogen that constitute NOx .
Today's proposal is to control NOx emissions from sources that have a potential
to emit 100 tons or more per year of NOx aggregated from all the affected units at the
source . The proposed regulation applies to RICE of 500 brake horse power (bhp)
capacities and above, and to stationary turbines of capacities equal to or greater than 3
.5
megawatt (MW) .
As part of evaluation of the control of NOx from RICE and turbines, the Illinois
EPA identified several sources of guidance . The United States Environmental Protection
Agency
(U.S
. EPA) published two Alternative Control Techniques (ACT) documents -
NOx Emissions from Stationary Reciprocating Internal Combustion engines,
and
NOx
Emissions from Stationary Gas Turbines . Also, U.S
. EPA published Regulatory Impact
Analysis for the NOx SIP Call, and Stationary Reciprocating Internal Combustion
Engines Technical Support documents for the NOx SIP Call . Controlling Nitrogen
Oxides Under the Clean Air Act : A Menu of Option
document was published by State
and Territorial Air Pollution Program Administrators/Association of Local Air Pollution
2
Control Official . These documents contain detailed information on description of sources
of NOx emissions, various techniques of controlling NOx and the costs of various
controls . The Illinois EPA relied upon the information contained in these documents for
the costs and economic impacts for this proposal .
For reciprocating engines and turbines both combustion controls and post-
combustion catalytic reduction have been developed
. For reciprocating engines, air/fuel
ratio adjustments, low emission combustion, and prestratified charge all function by
modifying the combustion zone air/fuel ratio, thus influencing oxygen availability and
peak flame temperature . Ignition timing retard lowers the peak flame temperature by
delaying the onset of combustion . For turbines water/steam injection and dry low NOx
combustors are the combustion control techniques to control NOx emissions . Selective
catalytic reduction and non-selective catalytic reduction are the two post-combustion
control strategies that destroy NOx once it has been formed for reciprocating internal
combustion engines and turbines .
After reviewing the U .S . EPA's guidance documents, the Illinois EPA determined
that there are cost effective NOx control techniques available to reduce NOx emissions
from RICE and turbines . Lean bum spark-ignited RICE may install low emission
combustion (LEC), rich bum spark-ignited RICE may use non-selective catalytic
reduction, and compression ignited diesel RICE may use electronic injection techniques
to cost-effectively comply with this proposal
. For turbines, water/steam injection for
oil/gas-fired turbines, and low NOx combustors for gas-fired turbines are available to
cost-effectively comply with the proposal.
3
Illinois EPA's inventory contains 1,200 RICE engines greater than 1,500 bhp
capacities and 205 non-EGU turbines greater than 3 .5 MW capacities. Also, the Illinois
EPA estimated that there are 175 RICE engines greater than 500 bhp but less than 1,500 bhp
capacities
. Out of 1,200 RICE engines, 202 RICE engines will be impacted by this
proposal
. Twenty-eight RICE engines, out of 202 RICE engines that are greater than 1,500
bhp capacities, are impacted by the NOx SIP Call Phase II requirements
. This proposal will
impact 36 turbines out of 205 turbines and estimated 44 engines out of 175 estimated
engines of less than 1,500 bhp capacities .
The proposed regulations will reduce NOx emissions by 5,422 tons per ozone
season in 2007 ozone control season and satisfy the U .S. EPA's NOx SIP Call Phase 11
requirements for RICE engines . When fully implemented, the statewide NOx emissions
from RICE engines will be reduced by approximately 17,082 tons per year (including 2,670
tons from RICE less than 1,500 bhp) and 7,206 tons per ozone control season (including
1,113 tons from RICE less than 1,500 bhp) at a cost effectiveness of $496 to $2,436 per ton
of NOx (in 2004 dollars) depending on the type and size of the engine . Emissions from gas
turbines will be reduced by approximately 787 tons per year and 334 tons per ozone season
at a cost effectiveness of $712 to $2,189 per ton of NOx (in 2004 dollars) depending on the
type and size of the turbine .
4
IN THE MATTER OF :
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATIONARY RECIPROCATING
INTERNAL COMBUSTION
ENGINES AND TURBINES :
AMENDMENTS TO 35 ILL .
ADM. CODE SECTION 201
.146,
AND PARTS 211 AND 217
TESTIMONY OF SCOTT LEOPOLD
My name is Scott Leopold . I work in the Air Quality Planning Section, Division of Air
Pollution Control, Bureau of Air at the Illinois Environmental Protection Agency (Illinois EPA)
.
I have a Bachelor of Science degree in meteorology from Northern Illinois University and a
Master's Degree in Geography, emphasis Meteorology, also from Northern Illinois University
. I
have worked at the Illinois EPA for more than eighteen years
. Prior to that, I was a Research
Meteorologist with the US Army at the Atmospheric Sciences Laboratory, White Sands Missile
Range, New Mexico
. As an air quality modeler, my responsibilities include photochemical
modeling, including the modeling that will be contained in Illinois' attainment demonstrations
for ozone and PM2.5 for both the Chicago and Metro-East nonattainment areas
.
The purpose of my testimony is to summarize the results of a sensitivity modeling
analysis that I performed to show the air quality benefit from reducing NOx emissions on a
regional basis
. My testimony is based on the information provided to the Board by the Illinois
EPA in the "Technical Support Document" (TSD) which accompanied the regulatory proposal
.
It is important to note that a sensitivity analysis does not show the effect of a particular strategy
.
Rather, a sensitivity analysis is used to show how the model responds to an across-the-board
change in emissions, in this case a 30% reduction of NOx emissions from all sources
.
R07-18
RECEIVED
CLERK'S OFFICE
(Rulemaking - Air)
MAY 1
1 2007
STATE OF ILLINOIS
Pollution Control Board
I
The Illinois EPA performed the sensitivity modeling analysis to determine the extent to
which NOx emission reductions would result in ozone and PM2 .5 air quality improvements in
Illinois and downwind states . This modeling used the 2009 base case developed by the Lake
Michigan Air Directors Consortium (LADCO) as the starting point to determine the sensitivity
of predicted ozone and PM2.5 concentrations to an assumed 30% reduction of NOx emissions
within the modeling domain . As I mentioned before, the modeled 30% NOx emission reduction
level is arbitrary and does not represent the reductions expected from a particular control
strategy . LADCO's 2009 "base case" scenario reflects expected emissions due to economic and
demographic growth by 2009 and also implementation of control measures that are "on-the-
books" (OTB) . "On-the-books" controls are those measures that have already been promulgated
and will be implemented by 2009, including such measures as Reformulated Gasoline, Illinois'
Vehicle Inspection and Maintenance program, etc
. All other model inputs were developed by
LADCO .
Modeling results for PM2.5 are shown in Figure 2-3 of the TSD for each of four quarters :
January - March; April - June
; July -
September ; and October - December. The results are
depicted graphically as difference plots, showing the difference between the 2009 "base case"
and the 30% NOx reduction scenario . The results indicate that a 30% NOx reduction, if
achieved domain-wide from all NOx sources, will improve PM 2.5 concentrations regionally by
0.5 ug/m3
to 1
.8 ug/m3
. Improvements are shown for all four calendar quarters . The greatest
benefits (spatially) are predicted to occur in the fourth quarter (October through December), and
the smallest benefits (spatially) are predicted to occur in the first quarter (January through
March)
. Improvements are also shown for all four quarters in Illinois, with predicted PM2
.5
reductions in the range of 0.5 ug/m3 to 1.5 ug/m3 . The NAAQS for PM2.5 is 15 ug/m3 on an
2
annual basis, and the current 2004-2006 annual design value for Chicago is 15 .6 ug/m3, so a
reduction of NOx emissions of the magnitude modeled here would certainly help the area
achieve attainment .
Photochemical modeling for ozone was performed in a similar manner comparing the
2009 LADCO "base case" to the 30% NOx reduction scenario . For ozone, only the summertime
period of June, July, and August was modeled
. The results are again depicted as difference plots,
which show the difference in 8-hour ozone concentrations between the two scenarios . Figure 2-4
of the TSD shows the 8-hour ozone concentration differences for two days in the June 2002
regional ozone episode
. Results are shown for two selected days from the three month period
modeled. These days are considered representative of the results during periods of elevated
ozone concentrations in the region . The results indicated that widespread improvements in 8-
hour ozone concentrations are predicted to occur from the assumed 30% NOx emission reduction
from all NOx sources in the modeling domain . Ozone improvements in Illinois range from 2 .5
parts per billion (ppb) to about 10 ppb . The NAAQS for ozone is 0 .08 parts per million, or 84
ppb. Illinois currently attains the 8-hour ozone standard at all monitoring locations, but
downwind locations in Wisconsin and Michigan do not
. The highest 8-hour ozone monitored
design value in the Lake Michigan region for 2004-2006 is 88 ppb in Holland, Michigan
.
Again, a reduction of NOx emissions of the magnitude modeled here would help the region
achieve attainment.
The sensitivity analysis I described demonstrates that regional NOx emission reductions
will improve ozone and PM2, 5 air quality in Illinois .
3
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
R07-18
MAY 1
1 2007
(Rulemaking
- Air)
Pollution
STATE OFControl
ILLINOIS
Board
IN THE MATTER OF :
)
STATIONARY RECIPROCATING
INTERNAL COMBUSTION
ENGINES AND TURBINES
:
AMENDMENTS TO 35 ILL .
ADM. CODE SECTION 201
.146,
AND PARTS 211 AND 217
TESTIMONY OF MICHAEL KOERBER, DIRECTOR
LAKE MICHIGAN AIR DIRECTORS CONSORTIUM
I have been the Executive Director for the Lake Michigan Air Directors Consortium
(LADCO) for ten years and have worked there for 16
. I have a Bachelor of Science degree in
Environmental Engineering from the University of Illinois at Chicago, and a Master of Science
degree in Meteorology from the Pennsylvania State University
. As Executive Director for
LADCO, my responsibilities include preparing documentation and reporting on LADCO's
technical work
. This documentation consists of reports and memoranda, journal articles,
presentations at public meetings, and general newsletters
. I have also managed the identification
and evaluation of emissions control strategies to address
:
•
1-hour ozone nonattainment in the Lake Michigan region, in conjunction with the
four Lake Michigan States, as part of the Lake Michigan Ozone Study (LMOS),
•
ozone transport problems in the eastern half of the
U.S.,
in conjunction with over
30 states, as part of the Ozone Transport Assessment Group (OTAG),
•
visibility impairment in Class I areas across the country, in conjunction other
states and tribes, as part of the Regional Planning Organization (RPO) process,
and
•
8-hour ozone nonattainment, PM2
.5 nonattainment, and visibility impairment
throughout the upper Midwest, in conjunction with five Midwest States
.
Previously, I worked as the Regional Meteorologist at USEPA, Region V
. In that
capacity, I was responsible for reviewing, overseeing, and conducting air quality studies, for new
source permits, state implementation plans, and other purposes
.
The Consortium was established in 1989 by the States of Illinois, Indiana, Michigan, and
Wisconsin to address regional air quality problems
. Initially, LADCO's focus was ozone
nonattainment around Lake Michigan
. In 2000, the State of Ohio joined LADCO, and LADCO
began to work on other air pollution problems
. LADCO is currently helping these five
Midwestern states develop implementation plans for ozone, particle matter, and regional haze
.
The purpose of my testimony is to summarize the results of air quality analyses for NOx
emissions performed by LADCO
. NOx emissions are a precursor to ozone and PM2
.5/haze
(particulate nitrate) concentrations
. The testimony will review NOx emissions in the upper
Midwest (including, Illinois), and the effect of NOx emissions on ozone, PM2
.5, and regional
haze levels
. In particular, information will be presented which shows that reductions in NOx
emissions will help attain the current 8-hour ozone and annual PM2
.5 standards, and will help
meet the reasonable progress goals for haze .
My presentation today will review NOx emissions in the 5-state LADCO region, and the
results of air quality modeling for ozone, PM2 .5, and regional haze
.
NOx emissions come from mobile and stationary point sources
. On-road and off-road
mobile sources make up about 60% of NOx emissions in the region
. Stationary point sources
(both electrical generating units (EGUs) and non-EGUs) make up about 35% of NOx emissions
in the region, with non-EGUs contributing about 15%
. NOx emissions are projected to decrease
from our base years (2002 and 2005) to future planning years (2009, 2012, and 2015) due to
existing ("on the books") control programs .
Special modeling analyses were performed to provide information on the contribution
from source regions and source sectors . For ozone, the modeling results show that mobile and
stationary point source NOx emissions are important contributors to ozone concentrations in
urban areas. Also, nearby emissions have the highest impacts (e.g., the Chicago nonattainment
area contributes about 35% to monitoring sites in and downwind of Chicago) .
PM2.5 is comprised of several chemical species, including sulfates, nitrates, and organic
and elemental carbon. NOx emissions contribute to the formation of nitrates . For PM2 .5, the
modeling shows that mobile and stationary point source NOx emissions are important
contributors to nitrate concentrations in urban areas . Also, nearby emissions have the highest
impacts (e.g.,
the Chicago nonattainment area contributes about 40% to monitoring sites in
Chicago) . Additional modeling (i.e.,
sensitivity analyses) confirms the effectiveness of
reductions in NOx emissions (i .e., a 10% cut in regional NOx emissions produces air quality
benefits for PM2 .5 and ozone).
For regional haze, the modeling shows that mobile and stationary point source NOx
emissions are important contributors to nitrate concentrations in federal Class I areas . Unlike
urban air quality, which is heavily impacted by nearby emissions, we see that air quality in rural
areas, such as these federal Class I areas, is impacted by many upwind states (e.g., in the Seney
Wilderness Area, Illinois, Indiana, Michigan, Wisconsin, and several western states are all
important contributor) .
In conclusion, LADCO's emissions inventories and modeling analyses show that :
•
Mobile sources are a major source of NOx emissions (about 60%) and are the
important contributors to ozone, PM2.5, and regional haze concentrations .
Mobile source NOx emissions are expected to decrease in the future due to
existing federal control programs . Examination by LADCO's contractors of
additional possible control programs for mobile sources indicates relatively small
reductions and uncertain effectiveness .
•
Stationary point sources are also a major source of NOx emissions (about 35%),
and are also important contributors to ozone, PM2.5,
and regional haze
concentrations
. EGU point source NOx emissions have and will continue to
decrease in the future due to existing control programs
. Examination by
LADCO's contractors indicates that additional NOx emission reductions from
EGUs and non-EGUs are possible
(e.g.,
application of known control
technologies) .
I shall now review and discuss the slides in my presentation
.
Assessment of
Regional NOx Emissions
in the Upper Midwest
Michael Koerber
Lake Michigan Air Directors Consortium
May 21, 2007
Overview
•
Background
•
Summary of Regional NOx Emissions
•
Effect of NOx Emissions on Ozone, PM2
.5 ,
and Regional Haze
•
Summary
"One Atmosphere"
Somivolatile
Compounds
Semrvolatils and
Gaseous
Compounds
Ozone
JNH31
OH
( O
r ltIS0 4 ---W
0,HO.,0
Inorganic
Sulfate
Organic Particles
Ammonium
Nitrate
Ammonium
Sulfates
Chemical Deposition
Cite
: Particulate Matter Science for Policy Makers, NARSTO, February 2003
Regional NOx Emissions (TPD)
2002
2005
2009
2012
2015
o Area
•
On-road
•
Nonroad
p Non-EGU
•
EGU
Regional NOx Emissions
-
2009
IL
IL
IN
IN
MI
MI
OH
OH
WI
WI
o Area
•
On-road
•
Nonroad
•
Non-EGU
•
EGU
o Area
•
On-road
•
Nonroad
•
Non-EGU
•
EGU
NOx Emissions
: Summary
•
Emissions expected to decrease over time
due to "on the books" controls
•
Mobile sources make-up largest source
sector (60%)
•
Point sources make-up next largest source
sector (35%)
•
Non-EGU point sources contribute 15%
Air Quality Modeling
Model : CAMx
Domain/Grid : Eastern U
.S .
(36 km), Midwest (12 km)
Year : 2002 (full year)
- PM/haze, 36 km
2001, 2002, 2003
(summer)
-03,12
km
0
N
0
7
CD
Ozone Source Apportionment
so
45
40
35
30
25
20
15
11
5
Ozone Results
: Chicago, IL
0
IL - Cook
: (17031)0321) K2012R4SIa APCA nopig
Biog
ECU nonEGU
off mar onroad
Sector
area
BC
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
III _Chi NA
Ind_Chi NA
Wis _NA
Detroit NA
Cleoe_NA
Kentucky
WestVirginia
Missouri
VISTAS
MANE-VU
CEN WRAP
IA_MN
Canada
BC
IL - Cook
: (1703170321) K2072R4Sh APCA nopig
sector
Biog -
ECU
nonEGU
area -
..road
BC
off mar
Ozone Results
: Kenosha, WI
WI -
Kenosha :
(550590019'!) K2012R4SBAPCA_nopig
Biog
conhib
NOX -
VOC
BC - TOP52 yea
EGU nonECU
off mar
Sector
onroad
area
BC
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
Dl_Chi _NA
Ind_Chi_NA
Wm_NA
Detroit NA
Clove NA
Kentucky
WestMrginia
Missouri
VISTAS
MANE-VU
CEDIVY MW
IA_MN
Canada
BC
WI - Kenosha : (550590019J K2012R4Sk
APCA nopig
sector
Biog -
ECU - nonEGU
off mar
area -
onroad
BC
0
D
2J
30
Percent
40
50
60
50
45
Ozone Results
: St
. Louis, MO
15
ID
MO -
St.Charles : (2918310021) K20I2R4S1a_APCA nopig
5
0
Biog
EGU nonEGU off mar onroad
Sector
BC
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
Ill_Chi NA
Ind_Chi NA
Wis_NA
Detroi[_NA
Clew _NA
Kentucky
WestVi ginia
Missouri
VISTAS
MANE-VU
CENRAP WRAP
IA
_MN
Canada
BC
MO -
St.Charles :
(291831102' K2012R4SJa-APCA
nopig
sector
-
Big -
EGU
nonBGU
off mar
area -
onroad
BC
50
L ,
N
2
a
avg r-
12
~
Al
len Park
= 11.9 ug1M -,
t ~
('
avg PM2.6 = 14.7 uglm3
2004 PM2
.5 Average Composition
-Bondville _,
avg PM2.5 = 10.3 uglm3--
N
avg PM2Indianapolis-.5= 15.ug1m38'
---
St. LOUIS
avg PM2.5
= 16.1 _uglm3
0
iiD--J-220
3
440Klometers
1
Dearborn
avg PM2.5 = 19.0 uglm3
}-
-~&~
TikhonC'`
`
i ~Loral n-
avg PM25
.
= 172
. uglm3
_
vg PM25
. = 128
. uglm3
I
/
i
~- - Soil
Cincinnati -
Elemental Carbo
avg PM2.5 ;14
.9 uglm3
-Ls
r
Orange
avg PM2.5 = 17.5
ug/m3
i r
Organic Mass
AmmSulfate
AmmNitrate
Northbr ook
Note:!OM
= 1 .8'09 blank
6brreded at STN sites '~
-using average blank value
over samplingperiod
PM2.5 Source Apportionment
7
6
1
0
PM
2
.5
Results
: Chicago, IL
IL -
Cook : (170311052) K20I2R4SIa
Avg Cmc = 15.3 ug/m3
504 NH4
N03 POC EC FPRM ASOA BSOA TOP30
Species
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
III Chi_NA
Ind_Chi_NA
Detroit_NA
Clew _NA
Kentucky
Pennsylvania
Missouri
VISTAS
MANE-VU
CENRAP WRAP
Iowa
Minnesota
Canada
BC
0
a
UN
IL - Cook :
(170311052) K2012R4SIa
contrib
S04
NH4 -
N03 - POC -
EC
- FPRM -
13C
123
Concentration (ug/m3)
Avg Core = 15.4 ug/m3
sector
ECU - nonEGU -
nh3
- off_ mar
onroad -
area -
BC - ASOA
13SOA
TOP30
PM2.5 Results
: Granite City, IL
IL - Madison : (171191107) K2012R4S1a
S04 NH4 N03 POC BC FPRM ASOA BSOA TOP3J
Species
.
4
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
III Chi NA
Ind_Chi_NA
Detroit_NA
Clew_NA
Kentucky
fbnnsylvania
Missouri
VISTAS
MANE-VU
CENRAP WRAP
Iowa
Minnesota
Canada
BC
I
∎
N
IL -
Madison
:
(171191107) K2012R4S1a
contrib
S04 - NH4 - N03 - POC -
EC -
FPRM -
BC
Concentration (ughn3)
Avg Co. = 15 .5 ug/m3
67
I
I
0 .40
89
0 .20
0
.10
0 .05
0 .00
-0 .05
-0 .10
-0 .20
-0 .40
Model Sensitivity Runs
:
-10% NOx Reduction
PM2.5
Ozone
10.00 90
5 .00
2.00
1 .00
0 .00
-1 .00
-2 .00
-5.00
-10 .00 1
W
N
I
ry
Regional Haze Source Apportionment
n
0
5
Q
6
A
R
0
UP
CD
40
35
30
10
5
0
Avg E,1 = 814 fl m
S04 NI-I4
Regional Haze Results
:
Mammoth Cave, KY
N03 POC
EC
Species
FPRM ASOA BSOA TOP30
contrib
504
NH4 -
N03
EC -
FPRM -
BC
Region
Ohio
Michigan
Indiana
Illinois
Wisconsin
NorthDakota
Minn StPaul
Detroit_NA
WsstVirginia
Kentucky
Pennsylvania
Missouri
VISTAS
MANE-VU
CENRAP_WRAP
Iowa
Minnesota
Canada
BC
1
I
U
MACA1 -
K201SR4Sh
-a
Extinction (IMm)
Acg Ext = 83A VMm
i
0
5
10
15
20
25
30
35
MACA1 - K2018R4Sh
sector
EGU
- nonEGU -
nh3
- off_mar
onmad -
area -
BC - ASOA
BSOA
TOP30
Air Quality Analyses : Summary
•
On-road and nonroad NOx emissions are
largest contributors
•
EGU and non-EGU NOx emissions are also
significant contributors
•
Emissions from nearby areas have the
greatest impact
In conclusion
. . . .
•
Mobile sources make-up 60% of regional NOx
emissions, and are largest contributor to air quality
concentrations
•
Examination of candidate control measures for mobile sources
indicates relatively small reductions and uncertain effectiveness
•
Point sources make-up 35% of regional NOx
emissions, and are also significant contributors to
air quality concentrations
•
EGU point sources covered by NOx SIP Call and Clean Air
Interstate Rule, but additional emission reductions possible
(i
.e .,
many facilities only have limited (combustion) controls)
•
Additional emission reductions possible for non-EGU point
sources
Midwest EGU NOx Emissions (2005)
Daily NOx Mass In MidWest Region Ozone Season from (5/1/2005to 9/30/2005)
3200
2800
2400
1
0
2000
1600
O
z1200
800
400
5/1612005
6/112005 6117/2005
7/3/2005
7/19/2005
Controlled Base Units Com .
S
Controlled Peak Units Com
• Controlled Base Units Add-on
C
Controlled Peak Units Add-on
Non-Controlled Base Units
5Non-Controlled Peak Units
8/412005
8/2012005 9/5/2005 912112005
Dated: May 10, 2007
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
)
SS
COUNTY OF SANGAMON
)
CERTIFICATE OF SERVICE
I, the undersigned, an attorney, state that I have served by overnight mail the
attached
TESTIMONY OF ROBERT KALEEL, YOGINDER MAHAJAN, SCOTT
LEOPOLD, AND MICHAEL KOERBER
of the Illinois Environmental Protection
Agency upon the following persons :
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST
and mailing it by overnight mail from Springfield, Illinois on May 10, 2007, with
sufficient postage affixed
.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Rachel L . Doctors
Assistant Counsel
Air Regulatory Unit
Division of Legal Counsel
Timothy Fox, Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60606
Virginia I
. Yang, Deputy Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Schiff Hardin LLP
Renee Cipriano
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
SchiffHardin LLP
Kathleen Bassi
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Hodge Dwyer Zeman
Katherine Hodge
3150 Roland Avenue
PO Box 5776
Springfield, Illinois 62794-9276
SERVICE LIST
R 07-18
Gale Newton
3150 Roland Avenue
PO Box 5776
Springfield, Illinois 62794-9276
Illinois Environmental Regulatory Group
N. Ladonna Driver
3150 Roland Avenue
Springfield, Illinois 62703
Schiff Hardin LLP
Joshua More
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Schiff Hardin LLP
Stephen Bonebrake
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Matthew Dunn
Illinois Attorney General Office
Environmental Control Division
James R. Thompson Center
100 West Randolph Street
Chicago, Illinois 60601
Timothy Fox, Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60606
Virginia I
. Yang, Deputy Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Schiff Hardin LLP
Renee Cipriano
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Schiff Hardin LLP
Kathleen Bassi
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Hodge Dwyer Zeman
Katherine Hodge
3150 Roland Avenue
PO Box 5776
Springfield, Illinois 62794-9276
SERVICE LIST
R 07-18
Gale Newton
3150 Roland Avenue
PO Box 5776
Springfield, Illinois 62794-9276
Illinois Environmental Regulatory Group
N. Ladonna Driver
3150 Roland Avenue
Springfield, Illinois 62703
Schiff Hardin LLP
Joshua More
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Schiff Hardin LLP
Stephen Bonebrake
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
Matthew Dunn
Illinois Attorney General Office
Environmental Control Division
James R
. Thompson Center
100 West Randolph Street
Chicago, Illinois 60601
