Air Quality and SIP Update Ohio EPA DAPC Air Program Workshop December 7, 2010 Robert Hodanbosi, Chief, DAPC Jennifer Hunter, Manager, DAPC SIP Section
Feb 24, 2016
Air Quality and SIP Update
Ohio EPA DAPC Air Program WorkshopDecember 7, 2010
Robert Hodanbosi, Chief, DAPCJennifer 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.
Ohio has nonattainment areas for PM2.5 and lead.
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
PM2.5
Ozone
SO2
NO2
Pollutant Current NAAQS
Proposed NAAQS
Final Date Designations SIPs Due Attainment
CO 9ppmv (8Hr)35ppmv (1hr)
Oct 2010 May 2011
Lead 0.15 ug/m3(rolling 3-month)
5/20/08 10/15/08 Dec 2010 (round 1)Jan 2012( round 2)
July 2012July 2013
Jan 2016Jan 2017
NO2 0.053 ppmv (annual)0.100 ppmv (1-hr)
6/29/09 1/22/10 Jan 2012(unclassifiable)Jan 2016/17 (nonattainment)
July 2013 Jan 2021/22
PM2.5 15.0 ug/m3(annual)35 ug/m3 (24 hr)
Nov 2010 19972006
Dec 2004Oct 2009
April 2008Dec 2012
Apr 2010Apr 2015
Ozone 0.075 ppmv (8-hr)0.08 ppmv (8-hr)0.12 ppmv (1-hr)
0.060-0.07 ppmv (8-hr)7-15ppmv-hr(secondary)(01/06/10)
~12/31/10 Dec 2011 Feb 2014 2014-2031
SO2 30 ppbv (annual)140 ppbv (24-hr)
50-100 ppbv (1-hr)(11/16/09)
6/2/10 Jun 2012 Feb 2014 Summer 2017
Revised Standards …attainment will change
Revised Standards …implementation will strain recourses
2010 2011 2012 2013 20140
1
2
3
4
NAAQS Attainment Demonstration SIPs
Number of Attainment Demonstrations Due
2012Lead (Phase 1) - Jul-1224-Hr PM2.5 - Dec-12 2013Lead (Phase 2) - Jul-13 NO2 - Jul-13 8-Hr Ozone (est.) - Feb-142014SO2 - Feb-14
OZONE
Ozone Air Quality StandardTimeline Level (ppm) MeasurementRevision of New Standard
0.060 -0.070 Average of fourth highest concentration measured over a three year period
New Standard 0.075Old standard 0.084Old, Old standard 0.125 Not to be exceeded
more than four times in a three year period
Ozone Monitors in Ohio
Ozone Exceedances by Year (through October 1, 2010)
Year 0.0125 ppm1-hr
0.08 ppm8-hr
0.075 ppm8-hr
0.075 ppm8-hr exceedance
days2000 1 135 326 332001 2 250 738 552002 22 801 1436 652003 22 204 458 402004 None 25 178 302005 5 192 688 652006 None 39 236 392007 None 110 541 592008 None 32 171 262009 None 4 31 112010 None 20 163 32
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
0
20
40
60
80
100
120
140
160
4th High Ozone Value in ppb
4th High
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
8-Hour Ozone(0.084 ppm)
Full Attainment ….
Attainment for Key Areas
Area Design Value RedesignationPPM Years Submitted Approved
Columbus 84 2006-2008 3/17/09 9/15/09Cleveland 84 2006-2008 3/17/09 9/15/09Cincinnati 82 2007-2009 12/14/09 5/11/10
“New” Ozone standard.
“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
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”
Ohio Ozone 2008-2010
Truncated values through October 11, 2010
08-10 by County
76 to 100
71 to 75
66 to 70
61 to 65
0 to 60
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
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?
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
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.
Level (ppm) Number of monitors exceeding level in 2018
0.070 11 of 530.065 34 of 530.060 51 of 53
Requirements for Ozone Areas - CAA
Emission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventoriesRACT corrections due in 6 months; I/M corrections, immediately
New Source Review (NSR) program due 2 years (corrections to existing, also)Plan for 15% VOC reduction within 6 years is due in 3 years
RACT: Existing & future CTG’s & RACT on major sources (existing due in 2 years)Stage II gasoline vapor recovery due in 2 years
Basic I/M (if not already required) due immediatelyDemonstration of attainment in 4 years
Plan for 3% annual average reductions due in 4 yearsEnhanced I/M due in 2 years
Clean fuel program due in 4 years (if applicable)VMT demonstration due in 6 years (TCM program if needed)
Specific NSR requirements for modifications to existing sources
Measures to offset VMT growth (108(f) measures) due in 2 yrsContingency measures if miss milestone
Requirement for fee on major sources if fail to attainNo waivers from 15% or 3% reduction requirements
Clean fuels requirement for boilers (plan in 3 years)Traffic controls during congested periods
Marginal
Moderate
Serious
Severe
Extreme
PM2.5
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.
Annual PM2.5(15.0 ug/m3)
Annual StandardAir Quality Trends
2003-2005
2004-2006
2005-2007
2008-2008
2007-2009
10.011.012.013.014.015.016.017.018.019.0
Cleveland/AkronCincinnatiColumbusYoungstownToledoDaytonCantonSteubenvilleAthens
Standard 15.0 ug/m3
Attaining!!!
24-Hr PM2.5(35 ug/m3)
24-Hr StandardAir Quality Trends
Standard 35 ug/m3
Almost attaining!!!
2003-2005
2004-2006
2005-2007
2008-2008
2007-2009
25
30
35
40
45
50
Cleveland/AkronCincinnatiColumbusYoungstownToledoDaytonCantonSteubenville Athens
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.
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.
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.
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.
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.
Clean Air Transport Rule
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
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.
2009
2010
2011
2012
2013
2014
2015
-
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
450,000
500,000
4566439945
108667 90556
40661
97313
333,520
233,464
464964
178307
SO2 Transport
SO2 CAIR
Transport
CAIR
CAIR vs. CATR Reductions (tons)
NOx Annual
NOx Ozone
Ohio EGU CATR Budgets vs Historical Emissions (tons)
Budgets
Historic
**CATR would produce substantial emission reductions in Ohio
2012 2014NOx Ozone 40,661 -NOx Annual 97,313 -SO2 464,964 178,307
2005 2009NOx Ozone 51,875 36,076NOx Annual 254,452 98,780SO2 1,085,485 600,689
Lead
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
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
Nitrogen Dioxide
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
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.
Monitors needed in OhioCity 2008
PopulationRoad
MonitorsCommunity
MonitorsCurrent
Monitors*Akron 698,553 1 0 0Cincinnati 2,155,137 1 1 1Cleveland 2,088,291 1 1 1Columbus 1,773,120 1 1 0Dayton 836,544 1 0 0Toledo 649,104 1 0 0Youngstown 565,947 1 0 0
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
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
Sulfur Dioxide
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.
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)
Sulfur Dioxide Concentrations4th high averages 2007-2009
2007-2009101-300 ppb
76-100 ppb
0-75 ppb
Monitors needed in OhioArea PWEI Monitors
NeededMonitors in
Area*Cincinnati 532,728 2 2-OH, 1-KYCleveland 299,230 2 6Marietta 36,725 1 0-OH, 1-W Va.Steubenville 27,660 1 1-OH, 7-W Va.Columbus 24,965 1 0Wheeling, WVa. 22,282 1 1-OH, 1-W Va.Toledo 18,901 1 0Point Pleasant 10,372 1 0Dayton 9,902 1 0Akron 9,066 1 2
*The monitors in the area now are not necessarily properly located to fulfill the requirements
Dispersion Modeling– SO2 Requires dispersion modeling to identify sources with
potential to violate standard. Threshold somewhere around 100 TPY.
Based on the 2008 inventory, Ohio has 221 sources emitting >100 TPY (actual emissions). 139 non-EGUs and 82 EGUs
Will assist with nonattainment designations: Nonattainment = monitored or modeled violations Attainment = monitored and modeled “no” violations Unclassifiable = all other areas
SO2 Timeline States submit nonattainment recommendations by June 2011 Final designations by USEPA June 2012 After other monitors are installed and data collected,
additional designations will occur. Basic plan (e.g. “maintenance”) due June 2013
Implementation plan for attainment and unclassifiable areas; includes: Need for all modeling to be done so those with proven attainment can
have plans developed. Any required regulations be in place (e.g., limits necessary for
attainment area sources). Attainment demonstration for nonattainment areas due
February 2014. Attainment date ~August 2017.
The End