How will Current Regulations be Revised to Improve Air Quality?

Randy Wood October 21, 2003

Texas Commission on Environmental Quality

December 2000 Revision

• On December 6, 2000 the TCEQ adopted a 1-hour ozone SIP revision for the 8-county area

• Total reduction of NOx emissions of more than 750 tons per day were necessary to demonstrate attainment in the area

• Houston has until 2007 to attain the 1-hour ozone standard

Houston/Galveston Emissions(tons per day)

222

564

266

On-Road Sources

Point Sources

Area and Non-Road Sources

1052 tons

(2007 Future Case)

Attainment289 tons

Control Strategies Adopted

• 90% reduction in point source NOx • Required an overall 90% reduction in

power plant, refineries, and chemical plants - including grandfathered sources

• Emissions banking and trading• Provides flexibility in meeting the 90%

requirement

Control Strategies cont.

• Speed limit reduction– Reduced all speed limits 60 mph and

higher to 55 mph

• Airport GSE– Agreements reached to get equivalent

reductions at area airports

• California Large Spark Off-Highway Equipment

Control Strategies cont.

• Lawn and Garden Equipment Use Restrictions– 6 a.m. – noon ban during ozone season

• VOC RACT– various controls for some bakeries,

printers and chemical batch processes.

• Vehicle Idling Restriction

Control Strategies cont.

• Inspection and Maintenance

• Cleaner Diesel Fuel

• Construction Equipment Operation Restrictions

• Accelerated Purchase requirement for federal Tier 2/3 equipment

Control Strategies cont.

• Transportation Control Measures– Signal timing, bicycle/pedestrian

projects, HOV lanes, etc.

• Voluntary Projects– Various voluntary projects such as bus

fare promotions, alternative fuel programs, an ozone action days.

Lawsuit

• January 2001: BCCA-AG sues the TCEQ over the 90% requirement– Results of TXAQS 2000 gives a

directional indication that HRVOCs contribute to ozone formation in the HGA area

September 2001 Revision

• Incorporated revisions to the cleaner diesel fuel rules, point source NOx rules, and emissions banking and trading program

• The December 2000 and September 2001 revisions were approved by EPA October 15, 2001

December 2002 Revision

• TCEQ adopted HRVOC rules in exchange for 80% NOx reduction (as opposed to 90%) requirements as a result of settlement w/ BCCA-AG

• Rules were for four source categories: Flares, vents, cooling towers, and

fugitives

March 2003 Proposal

• HRVOC rules are reopened for technical clean-up

• Scheduled for adoption October 22

• Rules correct inconsistencies and replace ambiguous language that may otherwise result in unduly burdensome requirements for which compliance dates are imminent

What is the Goal?

• Submit approvable SIPs to EPA to prevent federal intervention

• Submit a 1-hr/8-hr SIP to EPA in Oct. 2004

Why Don’t We Have the Answers Today?

• The photochemical modeling process has not been completed

• CAA requires photochemical grid modeling

The Modeling ProcessThree Models Combined

• Meteorological Model

Temperature and sunlight affect reaction rates and mixing layer height

• Emissions ModelEmissions from cars, planes, construction equipment, factories, power plants

• Chemical ModelChemistry changes during day and night33 chemical groups, more than 80 reactions

Complex System of differential equations

Photochemical Model

The Modeling Process

Emissions Inventory

• Where no data exists, we must build estimates

• Uncertainty regarding the VOC emissions inventory

• Incorporating real world air monitoring data in the current emissions inventory

Modeling Goals

• Purpose of model is to compare effectiveness of various control strategies

• Determine what controls are most effective

The Modeling Process

• Process is not static

• Stakeholder input necessary

• The typical SIP development process takes 3 years

• EPA requires periodic update of SIPs

Why Don’t We Have the Answers Today?

• The modeling must be defendable

• The process can be completed quickly, but the results won’t be defendable

• Important to replicate what is really happening in the atmosphere

Texas Air Quality Study 2000

• VOCs from industry are primarily responsible for high ozone in Houston.

• VOC emissions are substantially under-reported by industry.

• VOC concentrations in Houston are very different from other cities

• Ozone is produced faster and yields more in Houston than in other cities

Complete the Modeling

• TexAQS did not answer all questions– Should VOCs or NOx be controlled to reach

attainment?– What combination of NOx and VOC reductions

will attain the standard?– How much VOCs are actually being emitted

from industry (80+ plants) in Houston?– Which VOCs are the most effective to control?

What Are We Going to Do to Achieve the Goal?

• Complete development of photochemical model w/ control strategies

• Develop control strategies/rules to achieve the necessary emission reductions– Not all control strategies are rules

Rule Development

• Dependant on photochemical modeling results

• Requires extensive research– Searching inventories for sources– Investigating accuracy of inventories– Evaluating new technologies– Calling vendors

Rule Development

• Research literature and other states’ requirements

• Stakeholder input (with advisory group restrictions), public comment period and policy decisions necessary

Control Strategy Obstacles

• Federal Pre-empted from regulating source– Ex: Locomotives, ocean going vessels, diesel

engines

• Texas Legislature removed TCEQ’s regulatory authority– Ex: Fuels, Speed Limit, Construction

Equipment Related Rules

Control Strategies Obstacles

• Available technology and verification/certification of technology– There are a limited number of EPA

verified or CARB certified technologies

– EPA’s verification process is costly and timely

Efforts to Overcome Obstacles

• TCET funded to test technologies for verification purposes

• TCEQ has urged EPA to expedite its verification process

• TCEQ in partnership w/ CARB and NY have pressured EPA to improve verification process and implement cleaner engine/fuel standards