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Implications of the 2008 Ozone Standard Changes
Deanna L. Duram, P.E., C.M.August 7, 2008
trinityconsultants.com
Outline
Overview of Ozone Standard Changes Timeline for designations and SIP
updates Implications of nonattainment
designations Present prediction of impacts in
Alabama, Georgia, Mississippi, and Tennessee
What should facilities be doing now?
March 2008 8-hour Ozone Standard
Primary standard reduced from 0.08 ppm to 0.075 ppm (80 ppb to 75 ppb)
Note increase in significant digits Secondary standard = primary
standard Retained existing compliance
approach Three-year average of the fourth-highest
daily maximum per year
Timeline
Rule signed March 12, 2008 States required to make recommendations
for designations by March 12, 2009 EPA to issue final designations by March 12,
2010 Designations effective 60 days later SIP updates required no later than 2013 Attainment required between 2013 and 2030
– dependent on severity of nonattainment
Why does a nonattainment designation matter?Control Requirements
Reasonably Available Control Technology (RACT)
Typically applies to existing emission sources of a nonattainment pollutant emitting more than a set threshold
Often source category specific Can be case-by-case
Why does a nonattainment designation matter?Permitting Requirements
Lower major source thresholds (Title V and construction permits)
Major modification thresholds Lower thresholds Netting over 5-year period may be required
Major modification requirements Lowest Achievable Emission Rate (LAER) Offset requirements (ratio between 1-1.3 per ton of
pollutant increase) Analysis of alternative sites, sizes, and production
processes, and environmental control techniques All major sources in state must be in compliance with
all applicable emission limitations and standards
CAIR Vacature and Ozone Attainment Implications
DC Circuit Court issued an opinion to vacate the Clean Air Interstate Rule (CAIR)
CAIR would have imposed significant NOX reductions from utilities east of the Mississippi
State modeling demonstrations related to ozone have relied upon those reductions Impact on ability to attain? State-by-state strategies for CAIR-like
limitations likely
Alabama No existing 8-hour nonattainment counties New counties predicted to exceed new standard
ADEM believes that most areas will rely on nationally-mandated controls to achieve the revised standard
Comment made pre-CAIR vacature
Mobile BaldwinRussell TuscaloosaClay MadisonMorgan
Georgia’s Original Nonattainment Areas for 8-hr Ozone
http://www.air.dnr.state.ga.us/airpermit/naa.htm
Murray, Bibb, and Monroe redesignated attainment
Counties with Ozone Monitors
Exceeding 2008 Standard of 0.075 (ppm)
(based on 2005-7 monitored data)
0.0740.074
0.0740.074
County with MonitorMeeting StandardCounty with MonitorExceeding Standard
Slide per EPD presentation, June 25, 2008
Mississippi No existing 8-hour nonattainment counties Existing Monitors Over Standard
More counties impacted depending on how “metropolitan statistical areas” defined
County City 2005-2007 (ppb)
Bolivar Cleveland 76
DeSoto Hernando 85
Harrison Gulfport 83
Jackson Pascagoula 79
Lauderdale Meridian 76
Lee Tupelo 75
Tennessee Counties with 2005-2007 Design Value > 75 ppb
(similar to existing nonattainment areas/early action compact areas)
2005-2007 DV > 75 ppb, expanded to include MSAs
National measures being relied upon for attainment – pre-CAIR vacature
Generalized Impacts Increase in nonattainment counties and
number of impacted sources Ambient monitoring network sufficient?
Some states showing all monitors exceeding EPA considering revising requirements to require
monitors in more rural areas Vacature of CAIR making states re-evaluate
measures necessary for attainment CAIR vacature may lead to more sources being
faced with emission reduction obligations? More focus on non-industrial pollution sources
Vehicle emissions testing programs for mobile sources
Other non-traditional options?
What can I do now?(Besides shutting down!?)
Become involved in SIP rulemaking process Understand what measures may be considered
for emission reductions How might they impact your facility? Are they
reasonable? Consider advocating for Early Action
Compact approach Avoids redesignation of county to
nonattainment Requires earlier reductions Typically viewed positively by stakeholders –
more tangible engagement in process?
What should I be concerned with as a source in a nonattaiment area?
Planning for capital projects essential to minimize permitting requirements
Data retention of projects essential for netting purposes
Avoidance of major modification permitting generally a preferred pathway Can you avoid LAER requirements by
proposing other controls to reduce emissions?
Avoidance of fees for emission credits If no credits available, limited options