POWER November 2012 - 60

AIR QUALITY
months, " she said. " This is a very rough estimate.
Compliance costs will vary depending
on what controls may be required to comply
with the PM2.5 NAAQS. "
The rule states that, for now, meeting
the 24-hour PM2.5 NAAQS is sufficient to
demonstrate that the secondary visibility
standard is attained, Andracsek said. So if
the EPA issues its guidance along with the
revised final rule, there should be no further
analysis above the " normal " PM2.5 analysis
and, therefore, no additional cost above that
needed to run the model described above.
There is a lot of uncertainty, however, as to
whether or not the surrogacy policy would be
allowed to stand in court, especially in light
of the fact that visibility is already considered
for Class I analysis and the Best Available
Retrofit Technology regulations.
Andracsek explained that if the EPA releases
the new standard before the guidance
is finalized, applicants might then have to
follow the Federal Land Managers' Air Quality
Related Values Work Group's 2010 analysis
for long-range visibility (such as regional
haze) impacts, which would add $50,000 and
three months, or more, to the project's cost.
She added, " It may not be possible to even
meet the regulation given the uncertainty
about the methodology. A big part of the
PM2.5 problem is the uncertainty and lack
of understanding about how these very fine
particulates behave in the atmosphere. "
The Impact of CSAPR's
Nullification
On August 21, 2012, the U.S. Court of Appeals
for the D.C. Circuit vacated the CrossState
Air Pollution Rule (CSAPR). Andrews
discussed the impact of the CSAPR's nullification
on coal-fired and gas-fired power
plants that have to install new air pollution
control equipment in order to comply with
the proposed PM2.5 NAAQS.
" There have been two rules that were driving
PM2.5 controls: CSAPR and the PM2.5
NAAQS. Since CSAPR has been vacated,
it is unlikely that EPA will have a replacement
rule in the near future. In fact, it took
EPA three years to replace the original CAIR
[Clean Air Interstate Rule], " he said.
After a new CSAPR or similar rule is finalized,
the states will be given an opportunity
to develop a State Implementation Plan (SIP),
which will have to be approved by the EPA
and give a reasonable timeframe for compliance,
according to Andrews. " It could easily
be five years or more before any CSAPR compliance
would be expected, " he said.
The NAAQS regulatory process can be
the timeframe driver as well, Andrews explained.
A typical process would require
states to monitor PM2.5 (which has been
happening for several years), submit to the
EPA a list of non-attainment areas, develop
SIPs for compliance, obtain EPA approval of
the SIPs, and then require controls in or near
non-attainment areas.
" The EPA may set a timeframe for this process,
but history tells us that the timeframe is
not always reliable for a variety of reasons. It
could easily be five years or more before any
PM2.5 NAAQS compliance would be expected, "
Andrews said. " The bottom line is that a
controls timeframe is uncertain. History tells
us that NAAQS-driven control requirements
are rarely required immediately. "
Will Plants Require New Equipment
to Meet Stricter PM Standards?
Andrews explained that for fugitive dust
emissions, meeting the new standard could
require more enclosed coal piles and further
fugitive dust reduction techniques, such
as road paving, surfactants, and baghouses,
where feasible. " For SO2
and NOx emissions,
further reductions could be required such as
scrubbers and selective catalytic reduction
(SCR) technology, " he said.
POWER asked Andrews if he thinks the air
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POWER November 2012

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