Hansel & Droessler - Update on Changing Federal NAAQS & What They Mean for You

Update on Changing Federal AQ Standards (And What They Mean to You!)

Minnesota’s Clean Air Dialogue May 2, 2012 Duluth, MN

A Brief History of the Clean Air Act

•  To understand AQ Standards, need a bit of history

•  1955 Air Pollu,on Act – Research on cause and effect of Pollu2on

•  1963 Clean Air Act – States primarily responsible


•  1967 Air Quality Act –  States designate Air Quality Control Regions (AQCRs) –  States develop standards –  States have primacy within AQCR’s, Feds between –  Progress?

•  Less than 36 AQCR’s adopted by 1970 –  (7 in MN, most of the rest in CA, NY)

•  No state had full pollu2on control plan –  (MN, CA, NY and PiOsburgh were closest)

•  First Earth Day, 1970, provided impetus for passage –  (Yes I was too there!)


•  1970 Clean Air Act –  Federal Government now has primary

responsibility for developing standards –  US EPA created to take on those

responsibilities –  US EPA develops standards for six criteria

pollutants: •  Particulate matter, ozone, carbon monoxide,

sulfur dioxide, nitrogen oxides and lead –  States designate areas as attaining standards

or not attaining standards –  States develop plans (State Implementation

Plans or SIPs) to “attain and maintain” the NAAQS.


•  1977 Clean Air Act Amendments –  NAAQS

•  Extended deadlines for re-designation –  New Permit Program for New Sources

•  New Source Review or NSR •  For sources over 250 tpy, or 100 tpy for listed sources •  Non-attainment NSR

–  LAER, offsets, demonstrate progress •  Prevention of Significant Deterioration

–  BACT, increments –  Added new “NAAQS”

•  Air Quality Related Values (AQRVs) •  E.g. visibility in Class I areas


•  1990 Clean Air Act Amendments –  Designated levels of non-attainment

•  For Ozone, CO and PM •  Marginal, moderate, serious, severe,

extreme •  Different timeframes for each level

–  SIPs & SIP elements more prescriptive

•  RACM/RACT, I/M, Conformity –  Regional Haze SIPs to address

Visibility in Class I areas

Structure of CAA

•  There are NAAQS •  You’re in attainment or you’re not •  If you’re not in attainment:

– SIP & schedule to attain & maintain NAAQS – New & modified sources must obtain permits –  Install LAER, obtain offsets, demonstrate

progress – Other requirements

Structure of CAA

•  If you are in attainment: – May be subject to maintenance SIP – May need to get permit – May have to install BACT/LAER – May have modeling limitations – May have limitations to avoid BACT/LAER

•  Synthetic minor

MN History of Non-attainment

•  Current – lead – Eagan •  Past (maintenance SIPs)

– CO •  Twin Cities, Duluth, St. Cloud

– TSP •  Twin Cities, Duluth

– PM10 •  Rochester, Ramsey County

– SO2 •  Twin Cities, (refineries),Rochester,

U.S. EPA has been very, very busy revising NAAQS

•  To date: −  2006: 24-hr PM2.5

−  2008: Lead −  2010: NO2, SO2 −  2008-2011: Ozone −  2011: CO

•  More to come: −  2012-2013: PM2.5 −  2013-2014: Ozone

PM2.5 Air Quality Standard

•  Annual standard – 15 µg/m3, annual mean averaged over a three year period

•  24-hour standard- 35 µg/m3, 98th percentile averaged over a three year period

•  Anticipate revised standard proposed in 2012 and finalized in 2013.

•  24-hour standard could be lowered to 30 µg/m3

•  Annual standard could be lowered to 11-12 µg/m3

Daily PM2.5 NAAQS Design Values 2008-2010

31 31 29 29

37 36

22 21

31

26

17

0

5

10

15

20

25

30

35

40

PM2.5 Co

ncen

tra2

on (µ

g/m

3 )

Current NAAQS

Future NAAQS?

Estimated Daily PM2.5 NAAQS Design Values 2009-2011*

30.5

24.3

29.6 27.9

29.2

32.9 33.7

21.1 19.3

31.1 26.7

16.5

0

5

10

15

20

25

30

35

40

Con

cent

ratio

n (µ

g/m

3 )

98th Percentile Max observed NAAQS

Dark blue: 1:3 day sampling 2 high values to reach max Light Blue: Daily Sampling 6 high values to reach max

* Through September 30, 2011. Preliminary and subject to change

Future NAAQS?

PM2.5 – Where does it come from?

Ambient PM 2.5

Direct PM2.5

Emissions

Vehicle Exhaust

Wood Burning

Power Plants

Secondary PM2.5

Formation (from NOx

+ SO2 +NH3+…)

Vehicle Exhaust

Wood Burning

Ag. Fertilization

Power Plants

Requirements for PM2.5 NA Areas - CAAA

•  The required SIP elements for PM2.5 nonattainment areas are: –  Emissions Inventory –  PM2.5 RACM/RACT –  PM2.5 Nonattainment Area NSR Program –  PM2.5 RFP –  PM2.5 Attainment Demonstration –  PM2.5 Contingency Measures

Emission Inventory

•  Must include: –  Direct PM2.5 –  SO2 –  NOx

•  May need to include –  VOC –  NH3

•  From: –  Mobile Sources –  Area Sources –  Stationary Sources

PM2.5 RACM/RACT

•  RACM = Reasonably Available Control Measures

•  RACT = Reasonably Available Control Technology (RACT is subset of RACM)

•  Need to investigate for: –  Direct PM2.5, SO2, NOx

•  May need to investigate for: –  VOC, NH3, …

•  Need to investigate for all EI Sources –  Mobile, Area and Stationary

PM2.5 RACM/RACT (continued)

•  No tonnage threshold for RACT •  Screening assessments can inform choice of

sources/measures to evaluate •  Need to evaluate sources throughout the

nonattainment area for available controls •  Guiding principle for analysis:

–  show that selected RACT/RACM does not exclude any group of reasonable controls (including controls on smaller sources) that together could advance the attainment date


•  The following were the source categories initially selected for further consideration (New Jersey): –  Boilers – serving electric generating units (EGUs) firing No. 6

fuel oil and coal, –  and industrial, commercial and institutional (ICI) fossil fuel-fired

units; –  Fluid catalytic cracking units (FCCUs) at petroleum refineries; –  Furnaces – such as glass, and iron and steel; –  Municipal waste combustors (MWCs); –  Stationary diesel engines; and –  Fugitive Dust Sources.


•  Other potential sources (Maryland): –  Automobile Refinishing –  Expandable Polystyrene Products –  Yeast Manufacturing & Commercial Bakery Ovens –  Municipal Landfills –  Surface Cleaning/Degreasing –  Screen Printing & Graphic Arts –  Reformulated Gasoline? –  I/M?? (or remote sensing?)

Example Control Measures

•  Diesel retrofits (trucks, school buses, stationary engines)

•  Diesel idling (trucks, trains, port equipment, etc.)

•  Programs to reduce emissions from poorly maintained vehicles

•  New or improved direct PM and precursor controls on stationary sources

•  Year-round operation of seasonal stationary source NOx controls

•  Increase use of alternative fuel, hybrid vehicles

•  Buy-back programs for small engines (boats, vehicles, equipment)

•  Year-round measures to reduce VMT (Commuter Choice, carpooling incentives, etc.)

•  Open burning laws and better enforcement

•  Programs to reduced emissions from residential wood combustion and back yard barrel burning

•  Smoke management plans •  Improved monitoring techniques

and more frequent monitoring on sources with control devices

•  Reducing emissions of volatile aromatic compounds (surface coatings, gasoline, solvents, etc.)

PM2.5 Nonattainment Area NSR Program

•  Applies to sources >100 tpy (not 250 tpy) •  Same modification threshold (15 tpy) •  Requires LAER – Lowest Achievable Emission

Reduction •  Requires modeled demonstration of direct PM2.5

attainment –  May require modeled demonstration of secondary

formation (photochemical modeling) •  Requires Offsets (likely 1:1)

PM2.5 Attainment Demonstration

•  Modeled demonstration of direct PM2.5 and secondary formation –  photochemical models

•  Geographic range of SO2 and NOx emission sources included in RFP plan could extend up to 200 km beyond nonattainment area boundary

•  Not just Twin Cities!!

Overview of CAA Ozone Planning & Control Mandates by Classification

MARGINAL (3 years to aCain)

MODERATE (6 years to aCain)

SERIOUS (9 years to aCain)

SEVERE (15/17 years to aCain)

EXTREME (20 years to aCain) PENALTY FEE PROGRAM FOR MAJOR SOURCES

LOW VOC REFORMULATED GAS

VMT GROWTH OFFSET;

VMT DEMONSTRATION (& TCMs IF NEEDED) NSR REQUIREMENTS. FOR EXISTING SOURCE MODS

ENHANCED MONITORING PLAN 18% RFP OVER 6 YEARS MODELED DEMO OF ATTAINMENT MILESTONE CONTINGENCY

MEASURES FOR RFP ENHANCED I/M CLEAN FUELS PROGRAM (IF APPLICABLE)

STAGE II GASOLINE VAPOR RECOVERY BASIC I/M CONTINGENCY MEASURES FOR FAILURE TO ATTAIN

15% RFP OVER 6 YEARS MAJOR SOURCE VOC/NOx RACT ATTAINMENT DEMONSTRATION

BASELINE EMISSION INVENTORY (EI) PERIODIC EMISSION INVENTORY UPDATES TRANSPORTATION CONFORMITY DEMONSTRATION

MAJOR SOURCE EMISSION STATEMENTS NEW SOURCE REVIEW PROGRAM

TRAFFIC CONTROLS DURING CONGESTION

CLEAN FUELS REQUIREMENT FOR BOILERS

NSR offset ratio

Major source threshold

1.5 : 1 Extreme

10

1.3 : 1 Severe

25

1.2 : 1 Serious

50

1.15 : 1 Moderate

100

1.1 : 1 Marginal

100

Sanctions

•  As a result of failure to submit a SIP or implement a SIP. •  Within 18 months of a finding one of two offsets can be

imposed; the second within 2 years. •  A ratio of at least 2:1 emissions reductions within the

nonattainment area for new or modified major facilities undergoing NSR.

•  Highway funding sanctions. FHWA is required to impose funding moratorium for all but exempt projects (safety, mass transit).

25

Other Issues

•  Improved source monitoring •  Transportation conformity •  General conformity

Voluntary Measures

•  We’ve already done a bunch – Clean Air MN (I) – Project Green Fleet

•  Other options ?

Voluntary Measures

•  Ozone Advance – EPA website:

http://www.epa.gov/ozoneadvance/ – Basic Information – Eligibility – Participation – Ozone Flex – Resources – Frequent Questions

Voluntary Measures

•  Ozone Advance (PM2.5 prototype?) – State, tribal, and/or local governments can

participate in Ozone Advance if they meet the basic program eligibility criteria:

– The area(s) designated is/are not designated nonattainment for either the 1997 8-hour or the 2008 ozone NAAQS.

–  Identify and report on the air monitor(s) that reflect the air quality in the area(s).

– Emissions inventory reporting must have occurred prior to participation in Ozone Advance.

Voluntary Measures

•  Ozone Advance –  promotes local actions to reduce ozone precursors in attainment

areas to help these areas continue to maintain the ozone NAAQS.

–  To apply for participation in Ozone Advance, an area should submit a brief sign-up letter. This letter should express the areas willingness to coordinate with EPA, state, tribal and/or local stakeholders and to quickly implement measures to reduce ozone. Each of the program eligibility criteria should be addressed.

–  Specific measures do not need to be identified in the letter of intent, although if the applicant would like to highlight any existing measures and programs, they are welcome to do so. The letter should be signed by the appropriate state, tribal and/or local officials with the authority to implement the program and assist in leveraging staff and program funds as needed.

•  Score requirements – Fleet average – Self-reporting by contractor

Clean Construction

resourceful. naturally.

• Variable opera2ons • Mul2ple types of vehicles

• Switchers • Hostlers • Cranes • Li_s • Trucks

• Idling

Modeling by LADCO

Rail Partnership

Voluntary Measures

•  EPA’s Voluntary Residential Wood Smoke Reduction Initiative – Great American Woodstove Changeout

Campaign (Main focus) – Outdoor Wood-fired hydronic heaters – Voluntary Fireplace Emission Standard –  “Burn Wise” National Education and Outreach

Campaign

Voluntary Measures

•  Wood Stove Change out •  Voluntary, incentive-based (e.g., cash

rebates, vouchers) effort to encourage owners of old, inefficient woodstoves to replace with a cleaner burning hearth appliance, like:

•  Gas stoves •  Wood pellet stoves •  EPA-certified wood stoves

Thanks!!

•  Mike Hansel – Barr Engineering – [email protected] – 952.832.2878

•  Bill Droessler – Environmental Initiative – [email protected] – 612-334-3388 ext. 103