SUBCHAPTERSUBCHAPTER

1919

SC 19 StudySC 19 StudyWhere do numbers come Where do numbers come

from?from?

Re-evaluate the basis of Re-evaluate the basis of the numbersthe numbers

How would you come up How would you come up with the numbers today?with the numbers today?

Today’s PresentationToday’s Presentation

How would you come up with the How would you come up with the numbers today?numbers today?

Summary of studySummary of study

RecommendationsRecommendations

How would you come up with the How would you come up with the numbers today?numbers today?

Appendix CAppendix C– Use most stringent rule from EPA R6 and Use most stringent rule from EPA R6 and

CenSARA statesCenSARA states Kansas, Missouri, and New Mexico – same Kansas, Missouri, and New Mexico – same

as Oklahomaas Oklahoma

– Use existing information gathered from Use existing information gathered from recent stack testsrecent stack tests Reduce current algorithm by 37.5%Reduce current algorithm by 37.5%

How would you come up with the How would you come up with the numbers today?numbers today?

Appendix GAppendix G

- - Adopt the most commonly used standard Adopt the most commonly used standard of nearby, similar statesof nearby, similar states

Okla., LA, Kan., Missouri, Iowa, Neb.Okla., LA, Kan., Missouri, Iowa, Neb.

How would you come up with the How would you come up with the numbers today?numbers today?

Appendix GAppendix GUse most stringent algorithm in EPA R6 and Use most stringent algorithm in EPA R6 and

CenSARA statesCenSARA states

– Existing units use current Oklahoma algorithmExisting units use current Oklahoma algorithm E = 4.10PE = 4.10P0.67 0.67 P ≤ 30 TPH P ≤ 30 TPH E = 55PE = 55P0.110.11 – 40 P > 30 TPH – 40 P > 30 TPH

– New units use :New units use : E = 3.59PE = 3.59P0.620.62 (E = 4.10P (E = 4.10P0.670.67) P ≤ 30 TPH) P ≤ 30 TPH E = 17.31PE = 17.31P0.160.16 (E = 55P (E = 55P0.110.11 – 40) P > 30 TPH – 40) P > 30 TPH

SummarySummary Does present rule include condensables Does present rule include condensables

and should it?and should it?

– Historical research determines – yesHistorical research determines – yes– All EPA R6 and CenSARA states rules include All EPA R6 and CenSARA states rules include

condensablescondensables– EPA approved original SIP on the basis of full EPA approved original SIP on the basis of full

traintrain– NSR calculations for permitting and emission NSR calculations for permitting and emission

inventory require total PMinventory require total PM– If algorithms were created today, they would If algorithms were created today, they would

be full trainbe full train

Recommendation OptionsRecommendation Options Relax the ruleRelax the rule

Must justify relaxation to EPA and the public Must justify relaxation to EPA and the public

Existing units meet the current ruleExisting units meet the current rule

2007 PM2007 PM2.52.5 monitoring results show monitoring results show potential potential problemproblem

Recent modeling results for NSR Recent modeling results for NSR indicate potential PM increment indicate potential PM increment problem problem in Oklahomain Oklahoma

Recommendation OptionsRecommendation Options

Adopt a more stringent ruleAdopt a more stringent rule– Appendix CAppendix C

Okla. has the most stringent rule in EPA R6 and Okla. has the most stringent rule in EPA R6 and CenSARACenSARA

Stack tests results could justify a 37.5% reduction in Stack tests results could justify a 37.5% reduction in allowablesallowables

– Appendix GAppendix G Okla. has the most commonly used algorithmOkla. has the most commonly used algorithm Okla. could adopt more stringent rule for new units Okla. could adopt more stringent rule for new units

(Minnesota Rule)(Minnesota Rule) PMPM2.52.5 data suggest future potential problems data suggest future potential problems

Recommendation OptionsRecommendation Options

Do not change the ruleDo not change the rule– Okla. has the most stringent rule in EPA Okla. has the most stringent rule in EPA

R6 and CenSARA for indirect fired unitsR6 and CenSARA for indirect fired units– Okla. has most common algorithm in R6 Okla. has most common algorithm in R6

and CenSARA for direct fired unitsand CenSARA for direct fired units– Vast majority of existing units comply Vast majority of existing units comply

with current rulewith current rule– Future units will be more likely to meet Future units will be more likely to meet

SC 19 than existing unitsSC 19 than existing units

RecommendationRecommendation

Clarify that existing SC 19 algorithms Clarify that existing SC 19 algorithms include full train PMinclude full train PM

Do not change existing rule until and Do not change existing rule until and unless future data identifies a PM unless future data identifies a PM problem that can be addressed by problem that can be addressed by altering SC 19.altering SC 19.