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Air Quality and SIP Update

Air Quality and SIP Update. Ohio EPA DAPC Air Program Workshop December 7, 2010 Robert Hodanbosi , Chief, DAPC Jennifer Hunter, Manager, DAPC SIP Section. Ohio’s Attainment Status. The entire state is attainment for ozone, nitrogen dioxide, sulfur dioxide, and carbon monoxide…for now.

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Air Quality and SIP Update

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  1. Air Quality and SIP Update Ohio EPA DAPC Air Program Workshop December 7, 2010 Robert Hodanbosi, Chief, DAPC Jennifer Hunter, Manager, DAPC SIP Section

  2. Ohio’s Attainment Status The entire state is attainment for ozone, nitrogen dioxide, sulfur dioxide, and carbon monoxide…for now. Ohio has nonattainment areas for PM2.5 and lead.

  3. Revising Standards • U.S. EPA has been busy revising standards: • 2006: 24-hr PM2.5 • 2008: Lead • 2010: NO2, SO2, Ozone • More to come: • 2011: CO, PM2.5 NO2 SO2 Ozone PM2.5

  4. Revised Standards …attainment will change

  5. Revised Standards …implementation will strain recourses

  6. OZONE

  7. Ozone Air Quality Standard

  8. Ozone Monitors in Ohio

  9. Ozone Exceedances by Year (through October 1, 2010)

  10. Important Dates – Eight-Hour Ozone Standard (0.08 ppm) June 14, 2004 – Nonattainment areas become effective for the eight-hour ozone standard June 15, 2007 – Ozone SIPs were due for all areas June 2009 – Attainment date for all areas (except Cleveland) June 2010 – Attainment date for Cleveland area Moved forward with some rules – consumer products, AIM coatings, portable fuel containers

  11. Full Attainment …. 8-Hour Ozone(0.084 ppm)

  12. Attainment for Key Areas

  13. “New” Ozone standard . “New” On September 16, 2009, U.S. EPA announced a review of the basis of the 0.075 ppm standard On January 6, 2010, U.S. EPA proposed a new standard in the range of 0.060 to 0.070 ppm On August 23, 2010, U.S. EPA announced a delay in the release of the new standard November 1, 2010, U.S. EPA announced another delay New deadline is December 31, 2010 . “Revised New” • On March 13, 2008, U. S. EPA announced a revised ozone standard of 0.075 ppm, average of the fourth highest concentration over a three year period

  14. 08-10 by County 76 to 100 71 to 75 66 to 70 61 to 65 0 to 60 Ohio Ozone 2008-2010 Truncated values through October 11, 2010

  15. Impact of the “New” Standard 0.075 ppm Standard Not being met in Cleveland, Cincinnati, Columbus, Youngstown and Marietta 0.070 ppm Standard ++ Toledo, Steubenville, Dayton, and Lima All monitors in the State exceeding except two in the Dayton area (2 of 49) 0.065 ppm Standard +++ The two Dayton monitors exceeding 0.060 ppm Standard ++++ Nothing left *based on 2007-2009 data

  16. The moving target ….. Obstacles in implementation Litigation takes place and disrupts the schedule. The targeted level and schedule changes. U.S. EPA proposed to shorten the implementation schedule affecting the time States need to plan…. Approximately 4 months instead of 1 year for State designation recommendations. Attainment demonstrations within 28 months of designations rather than 36. U.S. EPA didn’t meet their August 31, 2010 goal….now what happens to the schedule? Depends on US EPA implementation rules which are to be proposed with final standard: How much time we will have to attain? What will the thresholds be for classification?

  17. What will be the schedule for the “new revised” 8-hour standard? December 2010 – Standard promulgated May 2011 (??)– State recommends nonattainment areas December 2011 (??)– US EPA finalizes nonattainment designations April 2014 (??) – Attainment demonstrations due Jan 2014(??) – Attainment date for basic areas Jan 2015(??) – Attainment date for marginal areas Jan 2018 (??) – Attainment date for moderate areas

  18. Ability to attain the new standard? Preliminary projections with CAIR (of 53 monitors modeled) *attainment date: 2014-2031 Will CAA required controls be enough? Probably not.

  19. Requirements for Ozone Areas - CAA Extreme Severe Serious Traffic controls during congested periods Clean fuels requirement for boilers (plan in 3 years) No waivers from 15% or 3% reduction requirements Requirement for fee on major sources if fail to attain Measures to offset VMT growth (108(f) measures) due in 2 yrs Contingency measures if miss milestone Specific NSR requirements for modifications to existing sources Moderate VMT demonstration due in 6 years (TCM program if needed) Clean fuel program due in 4 years (if applicable) Enhanced I/M due in 2 years Plan for 3% annual average reductions due in 4 years Marginal Demonstration of attainment in 4 years Basic I/M (if not already required) due immediately Stage II gasoline vapor recovery due in 2 years RACT: Existing & future CTG’s & RACT on major sources (existing due in 2 years) Plan for 15% VOC reduction within 6 years is due in 3 years New Source Review (NSR) program due 2 years (corrections to existing, also) RACT corrections due in 6 months; I/M corrections, immediately Emission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventories

  20. PM2.5

  21. PM2.5 Air Quality Standard Annual standard – 15 ug/m3, averaged over a three year period 24-hour standard- 65 ug/m3 (old), 35 ug/m3 (new) Anticipate new review with possible revised standards by October 2011.

  22. Annual PM2.5(15.0 ug/m3)

  23. Annual StandardAir Quality Trends Attaining!!! Standard 15.0 ug/m3

  24. 24-Hr PM2.5(35 ug/m3)

  25. 24-Hr StandardAir Quality Trends Almost attaining!!! Standard 35 ug/m3

  26. Annual PM2.5 Attainment PM2.5 Annual attainment demonstration, based on CAIR, submitted July 16, 2008. Modeling showed all but one area would attain by the 2010 attainment date…used Weight-of-Evidence approach for Cleveland-Akron area. No additional controls beyond CAA requirements were necessary. All areas attaining based on 2007-2009 data. Submitted Clean Data request on April 1, 2010.

  27. Annual PM2.5 Redesignation Process Preparing redesignation requests for all areas except Canton (*did not meet criteria) CAIR remanded December 23, 2008 U.S. EPA said no PM2.5 redesignations that rely on CAIR until CAIR fix in place. July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule.

  28. Annual PM2.5 Redesignation Process U.S. EPA new position on redesignations: Move forward on those that don’t rely on CAIR/Transport Rule for maintenance. Columbus Dayton CAN propose other redesignations that rely on CAIR/Transport rule but can’t go final until Transport Rule is final (~spring 2011) Cincinnati, Huntington-Ashland, Parkersburg-Marietta, Wheeling, Steubenville, Cleveland. In these areas we can’t show attainment or maintenance without CAIR like we did for ozone.

  29. Attaining the 24-Hr PM2.5 Standard Designations December 14, 2009. Only three areas designated nonattainment: Cleveland-Akron Canton (showed attainment but did not meet 75% capture) Steubenville (due to WV monitor) SIPs due December 2012. Initial modeling, with CAIR, shows only Cleveland will not meet the standard by 2015 with current controls. Will likely use weight-of–evidence again.

  30. Attaining the 24-Hr PM2.5 Standard: Cleveland Local issue (“flats”): Seven county nonattainment area even though only 3 monitors in Cleveland have shown nonattainment. PM2.5 RACT may be necessary.

  31. Clean Air Transport Rule

  32. Clean Air Interstate Rule (CAIR) • US EPA developed rules called Clean Air Interstate Rules (CAIR) to reduce emissions of nitrogen oxides (NOx) and sulfur dioxide (SO2) from power plants in the eastern US • Helps reduce ozone and PM and reduces visibility impairment • Ohio has many coal-fired power plants and is a large emitter of NOx and SO2 • CAIR was going to require substantial emission reductions across eastern US and Ohio • CAIR remanded December 23, 2008

  33. Clean Air Transport Rule (CATR) • July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule. • Should provide greater reductions than CAIR. • Necessitate year-round operation of existing SCR, SNCR and scrubbers. • Necessitate addition of pre-combustion NOx controls • Necessitate installation of new scrubbers for many sources. • Expected to be finalized by Spring 2011 to allow NOx and SO2 reductions in 2012 and further SO2 reductions in 2014.

  34. CAIR vs. CATR Reductions (tons) SO2 Transport SO2 CAIR CAIR NOx Annual Transport NOx Ozone

  35. Ohio EGU CATR Budgets vs Historical Emissions (tons) Budgets Historic **CATR would produce substantial emission reductions in Ohio

  36. Lead

  37. Lead Standard Revised October 15, 2008 – from 1.5 ug/m3 to 0.15 ug/m3 as a rolling 3-year monthly average. Two rounds – existing monitors and expanded monitoring network based on modeling potential violations from stationary sources. Designations from first round will be effective December 31, 2010. All areas are partial counties: Fulton County – City of Delta area – Bunting Bearings Facility Cuyahoga County – area surrounding Ferro Corporation Logan County – south of City of Bellefontaine – Daido Facility (shutdown) Four new sites added for second round…..so far no monitored violations at the new sites. Second round designations due January 16, 2010: Draft for public comment November 4, 2010 No new nonattainment areas

  38. Lead Standard – Ferro “Situation” • Cleveland – has processes that use 98% lead (lead oxide) powder. • Highest three month average from 2005-2009 is 0.173 ug/m3. • 2010 – spikes surface between January and March: 2.57 ug/m3, 1.39 ug/m3, 0.78 ug/m3 • Looking at other potential sources located near the monitor (scrap yards) • Investigating Ferro operations in detail. • Attainment demonstration due July 2012. • Attainment date ~January 2016

  39. Nitrogen Dioxide

  40. New Standard – NO2 • New standard effective April, 12, 2010. • The annual primary standard remains the same at 53 ppb • An annual 1-Hour standard is added: 100 ppb, which is met when the three year average of annual 98th percentile values are less than or equal to 100 ppb

  41. Ohio Attaining…for now • Currently three areas monitored in Ohio (Athens, Cincinnati and Cleveland) show attainment. • Highest 3-year averages between 2002 and 2009 are 66 ppb in Cincinnati and 72 ppb in Cleveland • Only county that currently fails is Cook Co., Illinois (Chicago), monitor next to bus stop. • Expanded monitoring network requires two types of monitors: • Area wide (community) where CBSAs > 1,000,000 • Near roadway where CBSAs > 500,000 • Monitoring plan due by July 2012 and network established by January 2013.

  42. Monitors needed in Ohio

  43. NO2 Timeline • States submit nonattainment recommendations based on current monitors by January 22, 2011 • Draft for public comment November 18, 2010 • All areas unclassifiable until new monitors in place • Final designations by USEPA January 22, 2012 • After other monitors are installed and three years of data collected (2013-2015), additional designations will occur. • Attainment demonstration due July 22, 2013 • Attainment date ~January 2017

  44. NSR Issues • For permits issued by states with SIP-approved programs, permits issued on or after April 12, 2010 must contain compliance demonstration for 1-hour NO2 NAAQS • Although this effort appears to be mobile source driven, stationary sources are quickly being pulled in • Modeling shows emergency generators exceed standard • Two sources that emit only 7 lb/hr combined with 65 foot stacks, just meet standard

  45. Sulfur Dioxide

  46. New Standard – SO2 • New standard effective August 23, 2010. • Old Standard – 140 ppb – 24 hour average. • New Standard– 75 ppb – 1 hour average. • Requires expanded monitoring network based on population: • 3 monitors in CBSAs >1,000,000 • 2 monitors in CBSAs >100,000<100,000 • 1 monitors in CBSAs >5,000 • Monitoring plan due by July 2011 and network established by January 2013.

  47. Ohio Currently not Attaining • Counties measuring above 75 ppb (2007-2009): • Belmont (97 ppb) • Columbiana (117 ppb) • Jefferson (129 ppb) • Lake (175 ppb) • Meigs (85 ppb) • Morgan (216 ppb)

  48. 2007-2009 101-300 ppb 76-100 ppb 0-75 ppb Sulfur Dioxide Concentrations4th high averages 2007-2009

  49. Monitors needed in Ohio *The monitors in the area now are not necessarily properly located to fulfill the requirements

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