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Tennessee Air Pollution Control Update

Tennessee Air Pollution Control Update. Presented to the Southern Section A&WMA August 10, 2007. Presentation Outline. “Old” 8-Hour ozone attainment progress Early Action Compact Areas Greater Knoxville Area Bid for Attainment Shelby County

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Tennessee Air Pollution Control Update

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  1. TennesseeAir Pollution Control Update Presented to the Southern Section A&WMA August 10, 2007

  2. Presentation Outline • “Old”8-Hour ozone attainment progress • Early Action Compact Areas • Greater Knoxville Area Bid for Attainment • Shelby County • “New” 8-Hour ozone proposal and its implications for Tennessee • PM2.5 Attainment Status and Trends • Regional Haze Update • What’s Reasonable? The Need to Change the Sulfur Dioxide Regulations

  3. “Old” 8-Hour Ozone Attainment Status White Counties are attainment Yellow Counties are nonattainment - deferred effective date (EAC) Red Counties are nonattainment

  4. Early Action Compacts Middle Tennessee Area Chattanooga Area Tri-Cities Area

  5. Early Action Compacts • EAC Counties (yellow on map) are nonattainment with a deferred effective date of the designation • Are predicted to attain by 12/31/07 • Are already a federally approved SIP • Must measure attainment by that date (2005-2007 data). • Final (effective) designation of attainment status will occur on or about April 2008

  6. Early Action Compacts • All EAC counties measured 8-hour ozone attainment based upon the 2004-2006 monitoring period. • The option to go for an early redesignation to attainment was given to local leaders • All 3 EAC areas decided to let the EAC run its full course • “Temporary” period of nonattainment ramifications • “Insurance” for the 2007 monitoring period

  7. Middle TN EAC Area Critical Values

  8. Chattanooga EAC Critical Values

  9. Tri-Cities EAC Critical Values

  10. Nonattainment counties (red on map) Greater Knoxville Area measures attainment based on the 2004-2006 data • Redesignation to attainment petition has been filed with EPA – awaiting decision • Potentially troubling 2007 data • Wildfire plumes may lead to flagging of certain 2007 data – final decision under evaluation • If preliminary data survives QA & is not flagged, the Greater Knoxville Area redesignation request is not likely to be approved

  11. Discussion Slides:Exceptional Event Flagging Request for Knoxville Region Data Preliminary Evaluation of Possible Request to EPA to Flag Affected Data Draft for Discussion Purposes Only

  12. What is an exceptional event? Exceptional event means an event that affects air quality, is not reasonably controllable or preventable, is an event caused by human activity that is unlikely to recur at a particular location or a natural event, and is determined by the Administrator in accordance with 40 CFR 50.14 to be an exceptional event. It does not include stagnation of air masses or meteorological inversions, a meteorological event involving high temperatures or lack of precipitation, or air pollution relating to source noncompliance. Natural event means an event in which human activity plays little or no direct causal role. 13560 Federal Register / Vol. 72, No. 55 / Thursday, March 22, 2007 / Rules and Regulations 40 CFR Parts 50 and 51 Treatment of Data Influenced by Exceptional Events Final rule.

  13. What must be done to request exceptional event status for data? A State may request EPA to exclude data showing exceedances or violations of the national ambient air quality standard that are directly due to an exceptional event from use in determinations by demonstrating to EPA’s satisfaction that such event caused a specific air pollution concentration at a particular air quality monitoring location. Demonstration to justify data exclusion may include any reliable and accurate data, but must demonstrate a clear causal relationship between the measured exceedance or violation of such standard and the event in accordance with paragraph (c)(3)(iii) of this section. The demonstration to justify data exclusion shall provide evidence that: (A) The event satisfies the criteria set forth in 40 CFR 50.1(j); (B) There is a clear causal relationship between the measurement under consideration and the event that is claimed to have affected the air quality in the area; (C) The event is associated with a measured concentration in excess of normal historical fluctuations, including background; and (D) There would have been no exceedance or violation but for the event. (With the submission of the demonstration, the State must document that the public comment process was followed.) 13560 Federal Register / Vol. 72, No. 55 / Thursday, March 22, 2007 / Rules and Regulations 40 CFR Parts 50 and 51 Treatment of Data Influenced by Exceptional Events Final rule.

  14. Initial Data Evaluation PM 2.5 TEOM Data Ozone Data Fire Smoke Analysis for Selected Days

  15. Knoxville Region With All Data Included Note that with the potential exceptional data included for May 21-22, May 31 -June 1 and June 17 – 18, 2007; the critical values for Look Rock and Mildred Drive ozone sites are at levels equal to the 8 hour ozone standard (projected 2005 to 2007 DV exceedance).

  16. Options • Preserve option to keep the redesignation request active while investigation is underway • Request for flagging monitor data must be initiated by “monitoring agency” responsible for “operating monitor and reporting data from the monitor”. • This would involve coordination with the Knoxville Local Program, NPS and TDEC.

  17. Nonattainment counties (red on map) • Shelby County was to have attained (2004-2006 data) by 06/15/07 and did not • Will likely be “bumped up” to a Subpart II Moderate Area • Statutory control measures for Subpart II Moderate Areas

  18. And Then There’s The New, Proposed Ozone Standard…

  19. The “New” 8-Hour Ozone NAAQS • Announced on June 20, 2007 • Proposed to be 70-75 ppb • Taking Comment on 60-84 ppb • New secondary standard for the growing season • More details at: • http://www.epa.gov/air/ozonepollution/naaqsrev2007.html

  20. What If EPA Chooses 75 ppb – the high end of its recommendation? • Designations will be based upon future data, but… • Tennessee would be nonattainment in all counties that are monitored or are in an MSA with an ozone monitor • Because there are new MSA boundaries, the number of nonattaining counties are likely to increase significantly

  21. Milestone Date Signature—Final Rule March 2008 Effective Day of Rule (60 days following publication in Federal Register) Approximately June 2008 State Designation Recommendations to EPA June 2009 (based on 2006-2008 monitoring data) Final Designations Signature Approximately June 2010 Effective Date of Designations Approximately 2010 SIPs Due Approximately 2013 Attainment Dates 2013-2030 depending on severity of problem Proposed Timeline for “New” Standard

  22. PM2.5 Air Quality Data* Attainment Status** Trends in Ambient Concentrations

  23. Tennessee PM2.5 Overall Trends

  24. PM2.5 Speciation Data

  25. What do these years represent?20022007201220182064

  26. Regional Haze Deadlines

  27. All Class I Areas Class I Areas in Tennessee and Surrounding States

  28. Reasonable Progress Analysis Considered pollutant contributions from 2000 – 2004 for 20% best and 20% worst days Calculated natural background conditions and developed a glidepath Performed emissions sensitivities Developed Area of Influence (AOI) Back trajectory and residence time analysis Source sector emissions List of contributing sources

  29. Uniform Rate of Progress Glide Path Great Smoky Mountains - 20% Worst Days Base G2a projections, 12 km grid,New IMPROVE equation 35 Uniform rate of progress = 4.4 dv by 2018 30.28 29.01 30 25.85 25 22.69 23.66 19.53 Haziness Index (Deciviews) 20 16.37 15 13.20 11.31 10 5 0 2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064 Year Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

  30. Reasonable Progress Analysis Required by Regional Haze Rule [§51.308(d)(1)(i)(A)] to consider four factors when establishing our Reasonable Progress Goal (RPG) Cost of compliance Time necessary for compliance Energy and non-air quality environmental impacts of compliance Remaining useful life of any existing source subject to the requirements

  31. Reasonable Progress Analysis State will conduct analysis of four factors using source-specific information provided by facilities and general industry-specific information.

  32. Determining the List of Sources (cont.) • Consider all sources that contribute greater than 1% to the total visibility impairment at the Class I Area

  33. Timeline Plan to complete BART analysis by mid-August Begin 60-day consultation process with FLM in August Begin Public Participation process in September Submit SIP to EPA on December 17, 2007

  34. The Need for Change Chapter 1200-3-14 Control of Sulfur Dioxide Emissions

  35. REASONABLE • According to Webster’s Dictionary the meaning is as follows: not extreme or excessive; moderate, fair; possessing sound judgment

  36. REASONABLE ? • Reasonable Available Control Technology • Reasonable and Proper Control • Reasonable Further Progress • Reasonable Progress Goals • Reasonable Measures

  37. Tennessee Air Quality Act 68-201-103. Intent and purpose. It is the intent and purpose of this part to maintain purity of the air resources of the state consistent with the protection of normal health, general welfare and physical property of the people, maximum employment and the full industrial development of the state. The board and department shall seek the accomplishment of these objectives through the prevention, abatement and control of air pollution by all practical and economically feasible methods.

  38. 68-201-106. Matters to be considered in exercising powers. In exercising powers to prevent, abate and control air pollution, the board or department shall give due consideration to all pertinent facts including, but not necessarily limited to:  ************************************** (4) The technical practicability and economic reasonableness of reducing or eliminating the emission of such air contaminants;  **************************************

  39. APC Regs 1200-3-6-.03 GENERAL NON-PROCESS GASEOUS EMISSIONS. (1) No person shall cause, suffer, allow, or permit gaseous emissions in excess of the standards in this Chapter. (2) Any person constructing or otherwise establishing a non-portable air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air contaminant source more than 1.0 km from the previous position after November 6, 1988, shall install and utilize the best equipment and technology currently available for controlling such gaseous emissions.

  40. 1200-3-7-.07 GENERAL PROVISIONS AND APPLICABILITY FOR PROCESS GASEOUS EMISSION STANDARDS. (1) No person shall cause, suffer, allow, or permit gaseous emissions in excess of the standards in this chapter. (2) Any person constructing or otherwise establishing an air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air contaminant source more than 1.0 km from the previous position after November 6, 1988, shall install and utilize equipment and technology which is deemed reasonable and proper by the Technical Secretary.

  41. 1200-3-14-.02 NON-PROCESS EMISSION STANDARDS. (1) Fuel Burning Installation in Operation Prior to April 3, 1972. Rated Capacity greater than 1000 x 106 BTU/hr. Class I Class IIA Class IIB Class III 1.2 1.2 3.4 2.4 Class IV Class V Class VI Class VII 4.0 4.0 5.0 2.8

  42. The Hand Basket Is Full

  43. Questions? Barry Stephens (615) 532-0525 Barry.Stephens@state.tn.us

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