2019 - PM2.5 SIP and Regulations: Questions & Answers
Yes the monitors are showing an improvement in air quality. In fact, the levels appear to show approximately 50% improvement. Unfortunately, there is still quite a ways to go and the Clean Air Act is structured to ensure that improvement happens as rapidly as possible. The intent of the Act is to continue to strengthen requirements the longer it takes to meet the health based standards.
When the Environmental Protection Agency (EPA) reclassified the area as a Serious Nonattainment Area that triggered a number of new more stringent requirements. States developing Serious Air Quality Plans must review controls from all other areas throughout the United States and implement all controls found unless it can be documented that a control measure is technically or economically infeasible. A measure may also be removed if a current regulation is more stringent. The new requirements proposed are those remaining measures that could not be documented technically or economically infeasible.
After review of the type of particulates that are on the filters, and confirmation studies, it has been determined that the Power Plants are not the main source of the air quality problem. The Power Plants, under the Serious Area requirements, have undergone a rigorous review called a Best Achievable Control Technology (BACT) analysis. The preliminary draft BACT analysis released in March 2018 illustrated that if all BACT was required the economic burden to the community would be substantial. Please see the Serious SIP for the proposed BACT Determinations that conclude economic infeasibility and other less burdensome requirements are better suited for air quality and the community.
ESPs can be used, however, they cannot be used as a replacement for curtailment during bad air quality days. The reason is that there has not been enough testing of these devices, in the United States, to provide proof that emissions reductions provided by ESPs are equal to not burning at all, which is the objective of the curtailments included in the current air quality plan. The Borough and others are working on testing studies that will provide additional data on these retrofit devices.
Yes, the Stakeholder recommendations were used in the development of the Serious SIP. There is a detailed description of the process within the Serious SIP, Section III.D.7.7. There is also a summary of the regulations and requirements that show which specific Stakeholder recommendation was incorporated into the proposed regulations. Unfortunately, the recommendations from the Stakeholder group could not bring the area into attainment so additional measures were required and included in the proposed SIP.
The Proposed Serious SIP shows that the area can meet attainment by 2029 if all of the proposed control measures are implemented and followed. It may be possible to attain earlier, but this is our best estimate using our current methods and models for projecting emissions into the future.
Yes, wood burning is the main source of fine particulate matter (PM2.5), however, PM2.5 is a complex mixture of small particulates and liquid droplets and is made up of more than just organic carbon (type of particulate from wood burning). PM2.5 is also made up of elements identified as precursor pollutants. Sulfur dioxide (S02) is the second largest component of the PM2.5 problem. SO2 comes from the sulfur in home heating fuel and other diesel and coal combustion. Diesel #2 has 2,566 ppm of sulfur, while Diesel #1 has only 896 ppm. Diesel #1 is a compromise control for the FNSB nonattainment area due to its lower economic impact. Other communities use ultra-low sulfur diesel fuel (ULSD) which has only 15 ppm sulfur. However, ULSD can increase costs $0.30 - $0.40 cents per gallon. Diesel #1 is expected to increase costs $0.02 - $0.07 cents gallon.
Fine particulate matter (PM2.5) is a complex mixture of extremely small particles and liquid droplets less than 2.5 micrometers in diameter. A single human hair is almost 30 times larger in diameter than the largest fine particle, PM2.5. PM2.5 is a product of combustion, primarily caused by burning fuels. Examples of PM2.5 sources include power plants, vehicles, wood burning stoves, and wildland fires. Further information may be found at: Particulate Matter.
- The pollutant is known as fine particulate matter (or “PM2.5”). There are National Ambient Air Quality Standards (NAAQS) set by the Environmental Protection Agency for PM2.5. These include the primary and secondary standards. It is important to remember that primary standard is meant to protect against short-term health effects from these sorts of air pollution spikes. The area where levels periodically exceed the standard is known as a “nonattainment area.”
- The high levels of air pollution create a public health risk for the residents of Fairbanks North Star Borough, and a strong air quality plan is essential for reducing public exposure to these high levels of air pollution as soon as possible.
- The state has applied and received Targeted Air Shed Grants to assist in wood stove change out and conversion programs. The funding has been provided to supplement the Fairbanks North Star Borough’s woodstove change out program in changing out wood and coal-fired home heating devices. The state has also been aggressively working on projects to expand the availability of natural gas in the nonattainment area, including the Interior Energy Project (LNG trucking) and gas pipeline projects.
- Solid fuel burning curtailments (ie. burn bans) continue but will be called at lower concentrations. Waivers are available and described in the Episode Plan (Section III.D.7.12).
- Only Diesel fuel #1 will be allowed for use in space heating in the nonattainment area, but not starting until July 2020.
- Dry wood only may be sold in the nonattainment area, requirement is proposed to start in October 2021.
- No new outdoor solid fuel hydronic heaters sold or installed unless they are pellet fueled.
- Stricter emission requirements for new wood fired heating devices.
- All uncertified solid fuel heating devices must be removed either prior to December 2024 or when homes are sold or leased. They may be replaced with new devices.
- Solid fuel heating device registration requirements under certain programs.
- Data submission requirements for used oil burners, charbroilers, and incinerators.
- Emission control requirements for coffee roasters.
- Major industrial (point) sources will be controlled as determined through the Best Available Control Technology (BACT) process.
- EPA certified devices that are older than 25 years to be removed or replaced by December 2024 has been identified as a contingency measure.
The Request for Proposal (RFP) to evaluate the ESPs was developed by the Fairbanks North Star Borough and they are implementing the project. While it appears to make sense to install at locations near monitors to see if they have an impact on the air quality, without the ability to quantify emission reductions, it would take several years of continuous reductions before the conclusion of any emission reductions could be contributed to the ESPs. This is because there is variation year to year, day to day, week to week, etc. regarding monitored emissions. Also, while the air is vertically stagnant during inversions, there is still some movement within the lower level. It is possible that ESPs could be working but drift of pollution from outside the test area could interfere with the anticipated result thus masking any actual reductions that could be happening with the ESPs.
The ESP study being conducted by the Fairbanks North Star Borough will be conducted in a lab using testing protocols approved by EPA. This allows for the development of emission rates useful to understanding the impacts of ESPs in reducing emissions. This lab testing under specific conditions will increase the chance that EPA will accept quantified emission reductions should the ESPs perform as the manufacturer has been stating.
The life span of the scrubber (ESP) is unknown. The manufacturer has estimates but given the bigger size of U.S. stoves versus European stoves, the different type of wood, higher moisture content on average of wood used in the Fairbanks North Star Borough, and individual’s maintenance practices, it is difficult to know what the life span will be.
Yes, if the Fairbanks North Star Borough’s evaluation of electrostatic precipitators (ESP) is successful it may be possible to incorporate the findings in the 5 Percent Plan. The lab testing will need to be concluded and the final report available in order to determine how the ESPs can be incorporated. The 5% Percent Plan must be submitted to EPA prior to December 2020. However, an update to the 5 Percent Plan is also being planned so there are opportunities to incorporate ESPs as data becomes available.
While masonry heaters are exempt from EPA certification requirements, they are covered by State regulations for opacity and curtailments. While there currently isn’t a lot of detail provided, the SIP does identify a voluntary Burn Right Program and DEC envisions that this is the program where masonry heaters and custom homes could participate and receive an exemption from Stage 1 curtailments. The Burn Right program is envisioned as a means to recognize those who voluntarily participate in registration and inspection. DEC welcomes comments on how to treat masonry heaters under the various programs proposed for wood heating devices.
DEC is still considering implementation aspects related to non-professional chimney sweeps. One option that could be implemented, at a minimum, is to have home owners who wish to conduct a chimney sweep themselves provide an affidavit that they have done so and possibly supplement that with a date stamped picture documenting the sweeping being conducted.
Wood stove installer certifications already exist and are available through the National Fireplace Institute. The National Fireplace Institute certifies installers for wood stoves, pellet stoves, and gas inserts. Businesses that sell wood stoves typically employ or know of certified installers.
Currently the proposed SIP identifies that in order to receive a waiver or renewal of a waiver that documentation be provided to show proof of maintenance of the heating device, including any catalyst. This is a requirement for both catalyst equipped and non-catalyst equipped devices. This is to ensure all seals, tubes, and catalysts are in good working order. Draft or leakage can also have an adverse effect on emissions of a device, not just catalyst contamination.
The analysis for BACM 31/32 may be found in the BACM analysis document located in Appendix III.D.7.07 Control Strategies. This appendix is very large and broken into three sections. The BACM analysis document is located in the appendix, pages 1-433. For the proposed length of time for wood to season, the State also considered the study conducted by the Cold Climate Housing Research Center entitled “Wood Storage Best Practices in Fairbanks, Alaska, June 2011” which may be found at this link: Particulate Matter: Projects & Reports
DEC is working closely with the various agencies working to bring Natural Gas to the community. However, because of the uncertainty in timing and the requirement for measures to be enforceable, a natural gas requirement is unachievable at this time for the Serious SIP. Expanded availability and use of natural gas is discussed in SIP Section III.D.7.7 (page III.D.7.7-90) and the SIP future projections include some expansion of natural gas based on projections for new customers obtained from the Interior Gas Utility (see SIP Section III.D.7.9.2).
Yes. The proposed regulations would require that only Diesel #1 be sold after July 1, 2020. The proposed wording of the regulation would mean that only Diesel #1 would be available year.
There are two fuel suppliers/refineries within the State of Alaska. DEC has had discussions with both in-state refineries. One refinery has indicated that it would not be able to provide all the demand for #1 fuel in the near term, while the other refinery has indicated they do have the capacity to supply all the demand at a competitive price. DEC is seeking comment on this regulatory proposal and may receive additional data for consideration with respect to the market’s ability to address the demand for #1 heating fuel.
When looking at the issue around fuel switching from #2 Diesel to #1 Diesel for heating, the focus is to reduce the amount of sulfur dioxide emitted, a precursor to PM2.5. Sulfur dioxide converted to particulate sulfate is the second largest component of the total particulate on the filters collected at the monitoring sites. A fuel switch to reduce sulfur dioxide emissions will reduce the amount of particulates on the filter but it is not possible to accurately predict the air quality impacts due to the unknown chemistry that happens in the atmosphere to create the sulfate particles. Most of the sulfate measured at the air monitors is in the form of ammonium sulfate; in absolute terms sulfate contributes 5.4 μg/m3 in Fairbanks and 4.9 μg/m3 in North Pole on the average of high concentration days (see SIP Page III.D.7.8-43). There are proposed studies to learn more about the chemistry of sulfate formation in the area, which in the future may assist in refining the benefits associated from sulfur dioxide control measures.
The proposed regulations do have curtailment waivers for both No Other Adequate Source of Heat (NOASH) and Stage 1 curtailments. You may find more information on the waivers in the Emergency Episode Plan found in SIP Section III.D.7.12.
In the moderate SIP the compliance rate for curtailment during air episodes was estimated at 20%. In the Serious SIP the compliance rate is estimated at 30%. Determining the compliance rate is difficult and costly. An attempt was made to quantify compliance rates during the winter of 2017-2018 by conducting surveys of residences with known solid fuel burning devices during curtailments. The surveys were conducted during work days and weekends. The rate ranged between 50-70% but varied by household and time. The more frequent the observations, the less compliance. Conservatively it was estimated that 50% was likely a more realistic number. However, it is felt that this sample was biased high because the majority of the known solid-fuel devices were those participating in the wood stove change out program and therefore have had additional education. Other surrogates are used to estimate or support assumed compliance rates such has number of complaints received, number of compliance actions, etc.
In the initial moderate State Implementation Plan, DEC and the Fairbanks North Star Borough were required to consider all reasonable available control technology (RACT). The decision at the time was to focus new requirements primarily on standards for new solid fuel-fired heating devices and episodic actions to reduce PM2.5 on inversion days. These controls were the ones deemed most likely to help in solving the problem with the least amount of impact on local residents, and, indeed, great progress has been made in the intervening years. Because the area ultimately did not reach attainment and was reclassified to “Serious” status, the State is now compelled to consider all the Best Available Control Measures (BACM) across the nation, which includes the use of lower sulfur content heating oil.
Industrial ESPs are a valid pollution control measure and have been used for years. Industrial ESPs also have strict monitoring and maintenance requirements. Small commercial and residential usage of ESPs rely on this proven technology, however, there are a number of outstanding issues. The state decision on ESPs will be based in part on the findings of the pending evaluation by the FNSB. If the evaluation is successful, it may be possible to incorporate the findings in the 5 Percent Plan. Thus, there are opportunities to incorporate ESPs as new data becomes available.
Yes, unless they contain private or confidential material. For example, most public assistance information is confidential. Proof of public assistance is used for determining hardship waiver eligibility. In such cases, some of the information in a waiver request may be confidential.
Yes, according to their factsheet, Usibelli Healy mine has the ability to supply coal with a sulfur content 0.2% with a range of 0.08% - 0.28%. For more information: Usibelli Coal Fact Sheet
To DEC’s knowledge, GVEA is not currently using Diesel #1.
It is assumed that the question is regarding pellet fueled devices which use automatic-feed for the pellets. Pellet fueled devices typically have lower emission rates than split or cord wood devices.
If a person qualifies for one of several public assistance programs, such as unemployment, Denali Kid Care, WIC, social security/disability, then all that would be needed is for the person to provide proof that they are receiving one of these types of benefits. Participation in these types of programs are verified by the programs themselves and therefore, reverification is not needed for an economic hardship waiver.
DEC does not currently know the number of ESP professionals in the state. ESPs are also considered a retrofit control device (RCD). In the proposed regulations, RCDs are required to be professionally installed to help ensure they can successfully operate on the existing heating device and work as intended in reducing emissions. Most if not all RCD manufacturers require professional installation. Incorporating this requirement in the regulations was meant to ensure consistency across all RCD devices.
Also, ESPs are being recognized and considered within the plan, but DEC has not proposed to require their use through regulation. Individuals may voluntarily add ESPs or other RCDs to their existing heating devices. A discussion of ESPs is included in the Control Measure section of the SIP: III.D.7.7.10 “Potential Future Control Measures Currently undergoing Research Efforts or Development.” In addition, all known information regarding ESPs that has been submitted to either the Fairbanks North Star Borough (FNSB) or DEC has been included in the SIP appendix. If the further evaluation of ESPs, which is currently being done by FNSB is successful, it may be possible to incorporate the findings in the 5 Percent Plan and commit to new programs relying on this technology. Should that occur, there will be a further a need to regulate the ESP installation professionals to ensure that ESPs are properly installed.
ESPs are acknowledged and considered in the SIP. A discussion of them may be found in the Control Measure section of the SIP: III.D.7.7.10 “Potential Future Control Measures Currently undergoing Research Efforts or Development”. In addition, all known information regarding ESPs that has been submitted to either the Fairbanks North Star Borough (FNSB) or DEC has been included in the SIP appendix. ESPs are also considered retrofit control devices (RCD). In the proposed regulations, 18 AAC 50.077, RCDs will require professional installation. Additional mandatory usage of RCDs is not included in the regulations or SIP at this time because they are currently being evaluated by the Fairbanks North Star Borough. If the evaluation is successful, it may be possible to incorporate the findings in the 5 Percent Plan and commit to new programs or program modifications for this technology. The lab testing will need to be concluded and the final report available in order to determine how the ESPs can be incorporated. The 5 Percent Plan must be submitted to EPA prior to December 2020. However, an update to the 5 Percent Plan is also being planned so there are opportunities to incorporate ESPs as additional data becomes available.
The Usibelli’s factsheet indicates that the sulfur content of coal from their Healy mine is typically 0.2% with a range of 0.08% - 0.28%. For more information: Usibelli Coal Fact Sheet
The heating value of coal is measured in British thermal units per pounds (Btu/Ib), but for regulatory purposes, the sulfur content by weight is considered because organic and pyritic sulfur in the coal get oxidized when burned to produce one of the three major pollutants of concern - sulfur oxides emissions.
The cost of a SO2 scrubber depends on the specific equipment, such as a boiler, its age, the fuel it uses, etc. DEC, using EPA cost estimation tools, developed cost estimates for scrubbers for each individual major industrial facility (or point source). These estimates may be found in the SIP Control Measure Appendix document (Appendix III.D.7.7). EPA has requested that DEC provide manufacturer specific cost quotes from the point sources which would provide accurate site specific cost estimates. However, neither DEC nor EPA have received this information to date. Getting site specific cost quotes may cost a significant amount which may be the reason that the information has not been provided for consideration.
The sulfur content for a facility will be regulated through their individual permits. The SIP will set the BACT requirement and then each facility’s permits will be amended to incorporate the limit.
GVEA proposed burning Diesel #1 on bad air days (episode/curtailment days) as an alternative to using Ultra Low Sulfur Diesel (ULSD). The direct costs to consumers would depend on the number of bad air days during a winter season and other factors and information that DEC does not have access to. This approach would be less costly to consumers than requiring GVEA to use ULSD on a either an episodic or consistent basis.
There should be no additional importation costs as DEC is proposing in the SIP and regulations sulfur limits that we believe are achievable for local coal supplies. Industrial facilities already receive coal shipments from the Usibelli mine and DEC’s intent is that this would continue under the proposal. DEC is accepting comments on the proposed sulfur level for coal and will consider any data and feedback it receives in setting a final coal sulfur limit.
The answer to this question will depend on the individual wood sellers. It also depends on the source of the wood. In order to give time for individual wood sellers to determine the best approach for their business, two years of lead time is proposed. There are already efforts underway with at least one wood seller to split and stock pile wood. Between June 2018 and June 2109, the average price difference between a cord of dry wood and a cord of wet wood was approximately $67.
Currently it appears there are at least 4-6 companies within the borough who have National Fireplace Institute certified installers. At least one company employs 5 certified installers. This certification may be received by taking classes online or at specific training opportunities. Exams may also be taken online. Manuals and online exams may be purchased on the National Fireplace Institute (NFI) website at nficertified.org. Prices vary according to whether the individual is a member, already certified or a nonmember and range from $225 to $675. The cost of the certification will not be covered by the change-out program.
DEC proposes to maintain a waiver program available that allows for those with No Other Adequate Source of Heat (NOASH) to continue to burn during curtailment episodes. Economic hardship is a factor that DEC can consider in granting waivers to the curtailment requirements. More information on the proposed waivers to curtailment can be found in the SIP Emergency Episode Chapter, Section III.D. 7.12.
No, the coffee roasting businesses are not targeted. The Best Available Control Measure analysis requires the State to consider all small commercial sources that generate PM2.5. With regards to coffee roasters, there is a local coffee roaster that is controlled to reduce emissions. As a result, DEC is proposing that coffee roasters have a control technology, however, business owners would be allowed to provide documentation on whether the control technology is economically or technologically infeasible for their roasting unit. In addition, the proposed requirement for the installation of a control technology is one year from the effective date of regulation to provide the time needed for a business to implement the requirement, if needed. DEC is accepting comments on this proposal and additional information and data might assist in determining economic feasibility/infeasibility of control for the current coffee roasters in the community.
DEC does not have this specific cost information. However, the regulations and SIP are not proposing changes that we would expect to alter the cost of transporting coal from the Usibelli mine to Aurora Energy or the other coal-fired facilities in the area.
- The tab “2 to 1” contains the detailed cost effectiveness calculations for the switch to #1. This is a somewhat different approach than used by the economists (DEC/UAF) in their study. Please note that the elasticity/estimated oil demand price elasticity was determined by UAF. The paper where this elasticity number is derived may be found in the Emission Inventory appendix, however for convenience, here is the link to the document: Estimation of PCAIDS Model (PDF). However, this final paper does not have appendix title or page numbers, for the actual portion in the appendix, please see Appendix III.D.706 Emissions Inventory Data, starting on page: Appendix III.D.7.6-225. Also here are documents on the primers: Substitution Primer (DOC), Elasticity Primer (DOC), and Efficiency Primer (DOC) that the economists developed to assist in trying to explain elasticity, substitution, and efficiency. These may also be found on the website where all the SIP chapters are located: Fairbanks PM2.5 Serious SIP.
- The tab “DevSumOut-2019PB” contains the Planning emissions/calculations for the Space Heat, Oil sector for calendar year 2019. Rows 60-63 in this sheet (highlighted in blue) represent this sector. “Lookup” tab shows our assumed energy contents for #2 and #1 heating oil (and their sources).
Please note, that BACM cost effectiveness was done on an annual basis as required. However, the Planning emissions represent the average of the winter modeling (so not annual).
PM2.5 nonattainment areas such as Fairbanks that fail to demonstrate attainment by the statutorily required December 31, 2019 deadline for Serious Area SIPs must prepare a follow-up air quality plan called a “5 Percent Plan”, named after the fact that such areas can no longer defer needed emission reductions and must demonstrate that adoptable and enforceable control measure are being implemented in a manner that achieves a least a 5% reduction per year in emissions of PM2.5 or known precursors of significance. (For Fairbanks, SO2, is a precursor of significance, based on currently available data). As described in Section VII of EPA’s PM Implementation Rule (Federal Register, Vol. 81, No. 164, August 24, 2016) PM2.5 serious areas that fail to attain the National Ambient Air Quality Standards (NAAQS) by the required attainment date (December 31, 2019) and that do not have an EPA approved extension must prepare such a 5 Percent Plan as required under Section 189(d) of the Clean Air Act. The 5 Percent Plan is then due 1 year following the required attainment date. In this case, December 31, 2020.
The emission inventory requirements for a 5 Percent Plan consist of selecting a base year inventory from one of the three years for which air quality data were used to determine the area failed to attain by 2019 (i.e., 2017, 2018 or 2019). Once the state establishes that base year (that reflects controls adopted/implemented from the Serious SIP), Section VII of the PM Implementation Rule notes that the 5 Percent Plan must contain a control strategy consisting of one or more adoptable/enforceable control measures and an implementation schedule that produces annual reductions in PM2.5 or applicable precursors (SO2, for Fairbanks) of at least 5% per year, relative to the base year inventory until attainment is demonstrated (and cannot stretch beyond 2029); the 5% per year targets in any year can be achieved for either PM2.5 or SO2, but not a combination of both.
As DEC has communicated, the analysis of the impacts of switching from the current mix of #2 and #1 fuel oil in the nonattainment area entirely to #1 will produce a significant reduction in SO2, emissions equivalent to roughly three years of progress toward these 5% per year targets. The 5 Percent Progress #2 to #1 Calculation Spreadsheet (XLSX) contains the details behind these calculations. The first sheet, 5PctProgress, shows the base year emissions of PM2.5 and SO2 of 3.56 and 22.38 in tons/average winter episode day, respectively. These emissions are for the attainment area in calendar year 2019. Below that, we’ve calculated the level of emission reductions (in tons/day) that represent 5% of the base year inventory, 0.18 tons/day for PM2.5 and 1.12 tons/day for SO2. Focusing on SO2, going forward, Rows 11-13 show calculated reductions in SO2 emissions for switching to #1 (assuming implementation in 2021) for both the point source sector (Row 12) and the space heating sector which includes residential and commercial space heating (Row 13). Row 11 reports the summed reductions for both sectors (3.49 tons/day). In Rows 15 and 17, we calculate the relative reduction in emissions (relative to the 2019 base year inventory) and the equivalent years of progress toward 5%/year targets those reductions represent, respectively. As shown, the 3.49 tons/day reduction in SO2 translates to a 15.6% reduction in emissions that represents 3.1 years of progress toward the 5%/year targets.
The other sheets in the spreadsheet provide upstream data/calculation details that produced these results.
Here are two papers that discuss the analysis of the filters and what was found on them: Ward et al. (PDF) and Fairbanks CMB Final Report (PDF). Neither pictures of the filters nor the sampling devices are available, however the sampling devices are described in the papers along with the methodology of the analysis.
- Fbks_PtSrcs_2013-2019_Episode_Inventories_ToSLR.xlsm – A version of our comprehensive point source episodic EI calculation spreadsheet with 2013-2019 EI data. This spreadsheet references facility specific spreadsheets with hourly episodic emission or fuel/throughput rates from the original 2008 episodes. So, I’ve included those as well (and which are listed below).
- Fac071_FlintHillsRefinery_HourlyEmissionRates.xlsx - Original 2008 episodic data for Flint Hills Refinery. As explained in the SIP, refinery operations ended in 2014 which triggered shifts in GVEA fuel use away from high-sulfur HAGO oil (a Flint Hills by-product).
- Fac110_GVEANorthPolePP_HourlyEmissionRates.xlsx – Original 2008 episodic data for the two GVEA facilities within the nonattainment area (North Pole and Zehnder).
- Fac264_Eielson_Hourly_Emissions.xlsx – Original 2008 episodic data for Eielson AFB. Although Eielson is just outside the nonattainment area and not subject to BACT, we still model it as a point source in the attainment analysis due to its proximity to the nonattainment area.
- Fac315_Aurora_HourlyMet.xlsx – Original 2008 episodic data for Aurora Energy Chena Power Plant.
- Fac316_UAF_HourlyFuelUse_CorrectedSpreaderStoker.xlsx – Original 2008 episodic data for UAF with corrected emission factors for the spreader stoker coal units.
- Fac1121_Doyon_HourlySteam&DailyFuelRates.xlsx – Original 2008 episodic data for Doyon Utilities privatized coal units at Ft Wainwright.
The original questioner was provided spreadsheets and the following response: the details for calculating wood device emission factors as a function of moisture level and converting from lb/ton to lb/mmBTU at a specific moisture level. The “EFs-BTU” and “EFs-OMNI” tabs of the first spreadsheet shown the data in Tables 7.6-43 and 7.6-40, respectively. At the top of the “EFs-BTU” sheet, there are calculated wood energy contents (mmBTU/ton) as a function of different assumed wood moisture levels. The SIP “baseline” (i.e,. pre-dry wood control) moisture content is 36.5%. The “Moisture” tab of the second spreadsheet shows how we calculate wood energy content as a function of moisture level that is then used to calculate changes in emission factors (in lb/mmBTU) associated with changes in wood moisture level (e.g., from a dry wood control program).
If you would like a copy of the spreadsheets mentioned in the response above, please contact DEC at email@example.com
- Capital costs,
- Operating and maintenance costs, and
- Cost effectiveness (i.e., cost per ton of pollutant reduced by that measure or technology).
We must have “a detailed written justification” for any infeasibility determination and the criteria for BACT/BACM infeasibility must be more stringent than for RACM in the Moderate SIP. 40 CFR 51.1010(a)(3); PM2.5 Implementation Rule, 81 Fed. Reg. 58010, 58085 (Aug. 24, 3016).
As noted, the Division of Air Quality does not have statutory authority to issue administrative penalties for violations of Alaska environmental law. This means that DEC staff cannot simply write “tickets” or citations to individuals that are found to be violating state regulations. However, DEC generally initiates compliance activities in response to compliance activities during curtailments or complaints received that indicate the potential for violations of a state regulation. DEC staff investigate complaints to verify or corroborate a problem or violation of a state requirement. In most cases, the department finds that compliance can be achieved through assistance to businesses and individuals in understanding the regulatory requirements and how they can comply. In the event that compliance assistance is not successful in resolving a compliance issue, department staff use administrative enforcement tools such as written notices of violation, compliance agreements, nuisance abatement orders, and in rare cases, civil court actions. Changes to DEC’s enforcement authorities would need to be granted in statute through the legislative process. While this has authority has not been granted to date, DEC can enforce its regulations through existing tools.
DEC is responsible for enforcing the state regulations. DEC Division of Air Quality staff already conduct compliance activities and respond to citizen complaints in the FNSB nonattainment area and work with local citizens and businesses to achieve compliance with the existing state regulations, this would continue to be the case for any new final regulations. DEC uses the compliance and enforcement tools authorized in statute to address cases of noncompliance. In most cases, the department finds that compliance can be achieved through assistance to businesses and individuals in understanding the regulatory requirements and how they can comply.
The Division already provides compliance assistance and enforces existing real-estate and stove requirements. The proposed requirements build off of these existing programs. Division staff visit retail outlets to ensure that stoves available meet State standards. Division staff meet frequently with real estate professionals to assist them in determining compliant and non-compliant stoves. Division staff follow up on all complaints received by home buyers and stove purchasers to ensure resolution and compliance with State regulations.
DEC generally initiates compliance activities in response to compliance activities during curtailment periods or complaints received that indicate the potential for violations of a state regulation. DEC staff investigate complaints to verify or corroborate a problem or violation of a state requirement. In most cases, the department finds that compliance can be achieved through assistance to businesses and individuals in understanding the regulatory requirements and how they can comply. In the event that compliance assistance is not successful in resolving a compliance issue, department staff use administrative enforcement tools such as written notices of violation, compliance agreements, nuisance abatement orders, and in rare cases, civil court actions.
DEC does not have a specific budget identified for enforcement of the Fairbanks North Star Borough nonattainment area SIP. DEC uses its existing air quality staff resources funded by federal grant dollars and some of the Division’s general fund appropriation to carry out the implementation, compliance assistance, and enforcement activities for the nonattainment area.
DEC is interested in working with partners in the community to help increase compliance rates on curtailment days. DEC ‘s most direct action is to issue letters to those observed to be burning during curtailments. We primarily rely on public education and compliance assistance to inform burners about the requirements and move to more formal enforcement when these efforts are unsuccessful. DEC believes the most effective approach to increasing compliance is for community members to work with their neighbors to help promote awareness of the requirements and compliance. We are very open to hearing from members of the community on how we can partner to effectively encourage compliance.
The SIP includes enforceable controls and the Division of Air Quality uses it authorized compliance and enforcement tools to address situations of noncompliance. The Division of Air Quality does not have statutory authority to issue administrative penalties for violations of Alaska environmental law. This means that DEC staff cannot simply write “tickets” to individuals that are found to be violating state regulations. However, DEC generally initiates compliance activities in response to observations during curtailments or complaints received that indicate the potential for violations of a state regulation. DEC staff investigate complaints to verify or corroborate a problem or violation of a state requirement. In most cases, the department finds that compliance can be achieved through assistance to businesses and individuals in understanding the regulatory requirements and how they can comply. In the event that compliance assistance is not successful in resolving a compliance issue, department staff use administrative enforcement tools such as written notices of violation, compliance agreements, nuisance abatement orders, and in rare cases, civil court actions.
Burn ban announcements are made by 2:00 pm on the days that it is forecasted that there will be an exceedance of the standard. Therefore, by 5:00 pm, the end of a typical work day, it would be expected that no new fueling of the device happens. Visible emissions is the way to determine compliance. For a device stoked earlier in the day (morning), if it is using dry wood, is properly installed, maintained, and EPA certified, there should be little to no visible emissions toward the end of the burn down. DEC is accepting comments on this proposal and the time frame for burn down.
Given the experience over the last two seasons, it does not appear that everyone shuts down their fires at the same time. Most fires appear to die down naturally with no additional fuel added once a curtailment is called.
DEC’s proposed regulation at 18 AAC 70.075(e)(3) would provide three hours for a solid fuel heater to burn down to where smoke is no longer visible from the chimney. The concept is that when a burn ban is declared those individuals burning wood and coal would need to withhold fuel (not add wood/coal to the fire) and let the fire burn out rather than actively having to put the fire out. If you are at work or school, you would not be home to feed your fire so it is likely that it could just burn down without intervention; however, you would want to ensure that your alternate or primary heat source is running to heat your home. DEC is accepting comments on this proposal and the time frame for burn down.
Current regulation (18 AAC 50.076) already requires residents to only burn dry wood. This requirement, coupled with other regulatory and voluntary programs in the original SIP did not provide enough emission reductions to bring the area into attainment. Therefore, the area was reclassified by the EPA to “Serious” and the State must now address Best Available Control Measure (BACM) requirements. In reviewing BACM from other communities, there are areas that have instituted dry wood sale provisions in their air quality plans. DEC’s analysis found that this is a feasible measure for the Fairbanks North Star Borough nonattainment area, thus DEC proposed the additional requirements for commercial wood sellers to only sell dry wood. This requirement should help to assist in ensuring only dry wood is burned and thereby reduce emissions. DEC is taking comment on this proposed requirement and the potential technical and economic impacts to wood sellers.
In earlier discussions in the community, DEC had discussed an approach that relied on obtaining from the EPA a one-time extension of the attainment deadline of up to five years. That pathway is outlined in EPA’s PM2.5 Implementation Rule and requires the implementation of Most Stringent Measures. However, this past winter in further discussion with EPA it was noted that there is another path offered under the Clean Air Act (CAA). If a serious area fails to attain the PM2.5 NAAQS by the applicable attainment date, CAA Section 189(d) requires that the state in which the area is located, after the notice and opportunity for public comment, submit within 12 months after the applicable date, plan revisions that provide for attainment of the standard, and from the date of such submission until attainment, control strategy that demonstrates each year that the area will achieve at least 5 percent reduction in emissions of direct PM2.5 or a 5 percent reduction in emissions of a PM2.5 plan precursor based on the most recent emissions inventory for the area. The department believes the 5% plan approach provides more flexibility to the community in meeting Clean Air Act requirements and bringing the area into attainment. Under this planning approach, once the State completes the Serious SIP, the next SIP update would be a 5% plan. We are not aware of any other SIP pathways that are available to the State beyond the two described above.
The 5% plan is not new, but is being advanced as an alternative to the five year extension path that is outline in EPA’s PM2.5 Implementation Rule. According to CAA Section 189(d), if a serious area fails to attain the PM2.5 NAAQS by the applicable attainment date, the state in which the area is located, after the notice and opportunity for public comment, is required to submit within 12 months after the applicable date, plan revisions that provide for attainment of the standard, and from the date of such submission until attainment, control strategy that demonstrates each year that the area will achieve at least 5 percent reduction in emissions of direct PM2.5 or a 5 percent reduction in emissions of a PM2.5 plan precursor based on the most recent emissions inventory for the area. The department believes the 5% plan approach provides more flexibility to the community in meeting Clean Air Act requirements and bringing the area into attainment.
The 5% plan builds of the existing Moderate Plan and the final Serious Plan. The 5% Plan will have a new base year, likely 2018, which means we are working with more recent emission data and monitoring data. The modeling design value for the plan must be based on the last 4-5 full years of monitoring data for North Pole. This will be a lower design value than the one being used for the Serious SIP.
Failure to meet a 5% reduction target, does not have a straight foreword answer. The failure to meet a 5% reduction target would also require a review to see if there was a failure to meet Reasonable Further Progress (RFP) or a Qualitative Milestone (QM). As long as we continue to meet RFP and meet all QMs then failing to meet a single year 5% reduction might not have a direct consequence. However, if RFP and/or a QM is not met, then the implementation of a contingency measures would be required. Continued failure to meet RFP and QMs could result in a finding by EPA for a failure to implement (if it is felt the failure to meet RFP/QM is due to poor implementation of adopted control measures). Or it could result in EPA formally mandating a SIP update under Clean Air Act 110(k).
Once the area reaches attainment, then the State will develop a maintenance plan. During the development of a maintenance plan, it is possible to re-evaluate all measures and commit to those measures that will keep the community in attainment for 20 years. The plan must include contingency measures that would be automatically triggered if the area should exceed the standard.
Once the area reaches attainment, then the State will develop a maintenance plan. During the development of a maintenance plan, it is possible to re-evaluate all measures and commit to those measures that will keep the community in attainment for 20 years. The plan must include contingency measures that would be automatically triggered if the area should exceed the standard. The area will not be required to continue to reduce emission 5% per year once attainment is reached and a maintenance plan is submitted and approved.
As currently proposed, DEC believes that the SIP meets all the completeness criteria. However, as proposed we do not know with certainty that EPA will concur with all of the Best Available Control Measures (BACM) and Best Available Control Technology (BACT) determinations. Ultimately BACM/BACT are the State’s responsibility and those determinations will be finalized and submitted to EPA. The State will also work to ensure EPA understands the rationale and basis for its determinations. It is our hope that EPA will ultimately find the final SIP acceptable. EPA’s actions on the SIP are subject to public review, so there will be an opportunity for the public and stakeholders to provide comment to EPA’s decision.
In order to approve an extension, the extension must show that attainment is possible within the extension timeframe. A projected attainment date must also be as expeditious as practicable, but no later than the end of the fifteenth calendar year following the effective date of designation of the area. Therefore, in order to meet one of several extension request requirements, the nonattainment area would have to show attainment by 2024. The current modeling results indicate that the Fairbanks North Star Borough nonattainment area cannot realistically attain by 2024. Therefore, by their own regulations, EPA would likely be unable to approve an extension request.
There are no regulatory air monitors in the Gold Stream zone.
No. DEC has not analyzed for correlations between oil prices and PM2.5 reductions in prior years. DEC has analyzed for the effect of meteorological conditions on the downward trend in PM2.5 levels and found that the trend is not the result of favorable weather.
DEC is incorporating the lessons learned from implementing the Moderate area SIP by developing and refining programs that the department can reasonably implement within its resources and authorities. DEC is also considering the information learned from meetings with EPA and the stakeholders groups in the local area.
While the construction of a regional kiln was evaluated in the BACM analysis, DEC did not consider it as a Best Available Control Measure (BACM) in the Serious SIP because there are no SIPs that mandate the construction of regional kilns for the provision of dry wood. The existing moderate SIP requires that only dry wood be burned in wood-fired heating devices. The Serious SIP has proposed a requirement that prohibits the commercial sale of wood that has more than 20 percent moisture content. A kiln is one option for local wood sellers in meeting this proposed requirement. At this time, DEC does not want to limit the options local business may use to meet a dry wood requirement by requiring the use of a kiln. However, if the state were to consider a requirement or program to install a kiln(s) to dry wood, that measure may be considered as Most Stringent Measure (MSM) in subsequent updates to the SIP.
The regulation of PM2.5 and other pollutants by the EPA and DEC in the State is to prevent public health issues including stroke, kidney diseases, lung and heart complications, which may arise from the inhalation of PM2.5 pollutants. The SIP itself is meant to reduce air pollution to healthy levels and gain health benefits for individuals in the community.
At this time the proposed regulations would apply to the entire nonattainment area, which includes the North Pole, Fairbanks, and Goldstream zones. Individuals may choose to submit comments on this approach and whether regulations or programs should apply to the entire area or only in certain zones. Maps of the boundaries of the nonattainment area and the air quality zones can be found in SIP Section III.D.7.3, “Non-Attainment Area Boundary and Design Episode Selection”.
The existing soil remediation incinerator in Moose Creek is outside the boundary of the nonattainment area and operates seasonally during the non-winter months. As a result it is not considered in the Serious SIP, which is focused on controlling wintertime PM2.5 emissions.
No. DEC understands that individuals with asthma and other health concerns are impacted by poor air quality and increased levels of fine particulate during winter inversion episodes. DEC staff are not medical professionals and do not make home visits for those purposes. However, DEC staff do follow up on complaints and conduct observations during poor air quality episodes to address noncompliance with curtailment events with a goal of improving air quality both in localized areas and the nonattainment area as a whole.
The modeling analyses conducted for the SIP cover a 200 x200 km domain, which is much larger than the boundary of the nonattainment area. Emissions from all sources, including the permitted industrial facilities, throughout this large domain are accounted for in the analyses. The modeling also accounts for boundary conditions, which are emissions coming into the area from outside this broader domain. Information on the modeling can be found in SIP Section III.D.7.8.
This question is outside the scope of the PM2.5 Serious SIP. Through its air permit, DEC is requiring the local soil remediation incinerator located in Moose Creek, which has added controls, to conduct source tests that will provide data to help determine how well the incinerator breaks down persistent PFAS compounds in contaminated soil. The goal is to find a local option for remediating contaminated soil in a manner that does not result in PFAS compounds being spread downwind of the facility.
No. Using the exceptional event criteria by EPA, a request is made for wildfire emissions to be excluded from the design values used for the SIP. EPA must review all requests and determine on a case by case basis if an exceptional event waiver will be granted. Exceptional event requests may be found at: Air Monitoring Exceptional Events