Riverview Energy Corporation Spencer County, Indiana Air Quality Modeler: Cody Jones ATSD - Appendix C Page 13 of 16 PSD Permit No. 147-39554-00065 Based on the Tier 1 SIL analysis, REC’s proposed emissions are not expected to have an impact above the SIL for the 8-hour Ozone NAAQS. However, a Tier 1 cumulative analysis of REC’s impact on the 24-hour and Annual PM 2.5 NAAQS is required. Cumulative Assessment IDEM utilizes guidance from the Georgia Department of Natural Resources – Environmental Protection Division on completing the cumulative analysis for the 24-hour PM 2.5 NAAQS. This guidance uses the following equation: 𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝐡𝑃𝑃𝑃𝑃2.5 + 𝐷𝐷𝐷𝐷𝑃𝑃𝑃𝑃2.5 + οΏ½οΏ½ 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝑆𝑆𝑆𝑆2 𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑆𝑆𝑆𝑆2 + 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝑁𝑁𝑁𝑁𝑋𝑋 𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑁𝑁𝑁𝑁𝑋𝑋 οΏ½ Γ— 𝑆𝑆𝑆𝑆𝑆𝑆𝑃𝑃𝑃𝑃2.5 οΏ½ where 𝐷𝐷𝐷𝐷𝑃𝑃𝑃𝑃2.5 is the maximum modeled dispersion impact of either the project source or the project source and inventory sources, depending on the location of the background PM 2.5 monitor in relation to the project source. In this case, IDEM is using the Dale PM 2.5 monitor as the background monitor. This monitor is relatively close to the project source, and would already account for inventory sources. Therefore, for this project 𝐷𝐷𝐷𝐷𝑃𝑃𝑃𝑃2.5 is the maximum 24-hour and annual modeled impact from Riverview, πœ‡πœ‡πœ‡πœ‡ πœ‡πœ‡πœ‡πœ‡ πœ‡πœ‡πœ‡πœ‡ 2.59 3 and 0.34 3 respectively. The 24-hour background PM 2.5 value is 19 3 , while the annual π‘šπ‘š π‘šπ‘š π‘šπ‘š πœ‡πœ‡πœ‡πœ‡ background value is 8.7 3 . If the result of this equation is less than or equal to the NAAQS, then the π‘šπ‘š project does not cause or contribute to a violation of the NAAQS. Using the values given, the result of πœ‡πœ‡πœ‡πœ‡ πœ‡πœ‡πœ‡πœ‡ this equation for the 24-hour NAAQS is 22.55 3 , which is less than the standard of 35 3 . For the Annual πœ‡πœ‡πœ‡πœ‡ π‘šπ‘š πœ‡πœ‡πœ‡πœ‡ π‘šπ‘š NAAQS, the result of the equation is 9.05 3 , less than the standard of 12 3 . Therefore Riverview’s π‘šπ‘š π‘šπ‘š emissions are not expected to cause or contribute to a violation of the 24-hour or Annual PM 2.5 NAAQS. Summary of Secondary Pollutant Analysis In summary, based on this Tier 1 MERPS analysis, REC’s NO x , SO 2 , and VOC emissions are not expected to exceed the SIL for the 8-hour Ozone NAAQS, or cause or contribute to a violation of the 24hour PM 2.5 NAAQS and the annual PM 2.5 NAAQS. Section G – Hazardous Air Pollutant (HAP) Analysis The Office of Air Quality currently requests data concerning the emission of 189 HAPs listed in the 1990 Clean Air Act Amendments (CAAA) that are either carcinogenic or otherwise considered toxic and may be used by industries in the State of Indiana. These substances are listed as air toxic compounds on the State of Indiana, Department of Environmental Management, Office of Air Quality’s construction permit application Form GSD-08. REC’s potential emissions of aggregate HAPs are estimated to be over 60 tons per year. Methanol is approximately 28 tons per year for a single HAP. The Unit risk factor (URF) is the upper-bound excess lifetime cancer risk estimated to result from continuous inhalation exposure to a pollutant over a 70 year lifetime. Multiplying the estimated concentration by the URF will produce a cancer risk estimate. The cancer risk estimate is the conservative probability of developing cancer from exposure to a pollutant or mixture of pollutants over a 70 year lifetime, usually expressed as the number of additional cancer cases in a given number of people, e.g. one in a million. For screening purposes at REC, the cancer estimates for each pollutant are considered to be additive when deriving the cumulative maximum individual cancer risk. Non-cancer health effects are determined using the Reference Concentration (RfC). The RfC is an estimate of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime. Dividing the estimated pollutant concentration by the RfC will determine the pollutant’s Hazard Quotient (HQ). All of the HAPs’ Hazard Quotients were added together to determine REC’s Hazard Index (HI). Riverview Energy Corporation Spencer County, Indiana Air Quality Modeler: Cody Jones ATSD - Appendix C Page 14 of 16 PSD Permit No. 147-39554-00065 This HAP screening analysis uses health protective assumptions that overestimate the actual risk associated with emissions from REC. Estimates 1) assume a 70 year exposure time, 2) assume that all carcinogens cause the same type of cancer, 3) assume that all non-carcinogens have additive health effects, 4) assume maximum permit allowable emissions from the facility, and 5) use conservatively derived dose-response information. The risk analysis cannot accurately predict whether there will be observed health problems around REC; rather it identifies possible avenues of risk. Table 12 lists the Hazardous Air Pollutants associated with Riverview Energy and the HAP analysis. IDEM received updated data from the consultant regarding HAPs data during the public notice period, including updated emissions from one of the emission units. In addition, IDEM’s modeling review determined HAPs impacts increased due to revised downwash considerations as a result of the updated data. Compound Methanol Hexane Formaldehyde Toluene Benzene Nickel Ammonia Hydrogen Sulfide Xylenes Phenol o-Cresol (2Methylphenol) m-, p-Cresols Chromium Dichlorobenzene Cadmium PAH, total Manganese Lead Phosphorus Acetaldehyde Acrolein Arsenic Cobalt Beryllium Selenium Antimony Mercury TOTALS (HAZARD INDEX) IDEM STANDARD COMPARISON TABLE 12 Hazardous Air Pollutant Modeling Results Annual Cancer Source Cancer NonConcentration URF of URF Risk Cancer (Β΅g / m3) (Β΅g / m3)-1 Chronic RfC (Β΅g / m3) 1.310E+00 20000 6.483E+00 700 1.230E-03 1.30E-05 IRIS 1.60E-08 9.8 3.970E+00 5000 1.611E+00 7.80E-06 IRIS 1.26E-05 30 3.530E-05 2.40E-04 IRIS 8.47E-09 0.2 1.862E+00 100 3.380E-02 2 5.230E+00 100 4.856E-02 200 1.155E-01 175 4.850E-02 2.110E-05 1.780E-05 1.630E-05 9.550E-06 8.320E-06 7.810E-06 2.290E-06 1.140E-06 3.550E-07 3.540E-07 1.880E-07 6.950E-08 6.740E-08 3.320E-08 2.280E-09 1.20E-02 1.15E-05 1.80E-03 1.10E-03 IRIS CAL IRIS CAL 2.53E-07 2.05E-10 2.93E-08 1.05E-08 1.20E-05 CAL 9.37E-11 2.20E-06 IRIS 2.51E-12 4.30E-03 9.00E-03 2.40E-03 IRIS PPRTV IRIS 1.52E-09 1.69E-09 1.67E-10 1.2889E05 Source of IDEM RfC Hazard Quotient 6.55E-05 9.26E-03 1.26E-04 7.94E-04 5.37E-02 1.77E-04 1.86E-02 1.69E-02 5.23E-02 2.43E-04 6.60E-04 600 0.1 200 0.01 IRIS IRIS ATSDR IRIS IRIS ATSDR IRIS IRIS IRIS CAL Region 9 CAL IRIS HEAST ATSDR 0.05 IRIS 1.66E-04 0.07 9 0.0205 1.50E-02 6.00E-03 0.02 20 0.2 0.3 CAL IRIS IRIS CAL PPRTV IRIS CAL IRIS IRIS 3.27E-05 1.27E-07 1.73E-05 2.36E-05 3.13E-05 3.48E-06 3.37E-09 1.66E-07 7.60E-09 1.55E-01 8.08E-05 2.11E-04 8.90E-08 1.63E-03 < 1E-06 <1 ABOVE BELOW The Hazard Index for the project does not exceed 1. Pollutants with a Hazard Quotient (HQ) greater than 1 are considered to be at concentrations that could represent a health concern. Hazard Riverview Energy Corporation Spencer County, Indiana Air Quality Modeler: Cody Jones ATSD - Appendix C Page 15 of 16 PSD Permit No. 147-39554-00065 Quotients above 1 do not represent areas where adverse health effects will be observed but indicate that the potential exists. The cumulative cancer risk estimate from all HAPs is 1.29 additional cancer cases in one hundred thousand people (1.29 x 10-5). This means if an individual was exposed to these HAPs continuously for 70 years, the risk of getting cancer from this exposure would be 1.29 in one hundred thousand. Benzene is the main pollutant among the modeled HAPs concentrations with the fugitive emissions as the largest portion of those modeled impacts. The β€œactual risk” that individuals face is a complex combination of many factors, including genetic predisposition, diet, lifestyle choices, and environmental contribution. For chronic exposure, IDEM evaluated pollutants for the reasonable upperbound probability of causing harm for non-cancer health effects when exposed to pollutants over a lifetime. IDEM conservatively assumed that individuals would be exposed to the pollutant continuously (24 hours a day, 7 days a week, and 52 weeks a year for 70 years). IDEM also considered sensitive population (i.e., those with conditions making them more susceptible to the effects of pollution, like children or the elderly) when evaluating the modeled concentrations. Generally, U.S. EPA considers risk estimates over one hundred in a million (1.0 x 10-4) to be at levels where action or more investigation is required. Risks that fall between one in a million (1.0 x 10-6) and 100 in a million (1.0 x 10-4) levels may generate discussion with a facility and possible action to be taken, taking into account the assumptions used to determine the emission estimates and modeling analysis. The assumptions used in the HAPs analysis, as described earlier, are conservative in nature and over-estimate emissions and exposure. In fact, benzene emissions would have to increase seven times from the permitted rates in order to approach the U.S. EPA threshold level of 1.0 x 10-4, which would require action or investigation. Section H – Summary of Air Quality Analysis Riverview Energy Corporation applied for a permit to construct a Direct Coal Hydrogenation facility in Spencer County, Indiana. The facility had emissions above the significant emission rates for NO x , VOCs, PM 2.5 , PM 10 , CO, SO 2 , and HAPs. The facility had modeled concentrations above the SIL for 1-hour NO 2 , all averaging times for SO 2, and 24-hour and annual PM 2.5 . Because these pollutants were above the SIL, a refined air quality impact analysis was required. Nearby large emitters were compiled and included in the NAAQS and PSD increment modeling. Several sources in Indiana and Kentucky were included in the NAAQS and PSD Increment modeling. After background concentrations were added to the NAAQS modeling results, the final resulting concentrations were under the NAAQS and PSD increments for all averaging times and pollutants. An analysis of secondarily formed PM 2.5 and ozone was conducted. It was determined that no significant impact from the facility was found from secondarily formed ozone. Cumulative assessment of 24-hour and annual PM 2.5 showed Riverview would not cause or contribute to a violation of the 24-hour and annual PM 2.5 NAAQS. In addition, an additional impacts analysis on vegetation, soils, visibility, and wildlife in the area was examined and found to show no adverse impacts on the surrounding area. The cumulative cancer risk estimate from all HAPs are above the IDEM threshold level but well below the U.S. EPA risk estimates over one hundred in a million, representing the excess cancer risk to the upper range of acceptability with an ample margin of safety. Benzene emissions are the largest portion of the HAPs impacts. Therefore, based on the conservative nature of the estimates of HAPs emissions, especially Benzene fugitive emissions, no additional action is anticipated to be necessary. No significant impacts are expected from the proposed facility for the secondary pollutant formation or the HAPs.