Robert Hodanbosi, Chief, DAPCJennifer Dines, Manager, DAPC SIP Section

Air Quality and SIP Update

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)

U.S. EPA has developed standards for six specific contaminants

Sulfur dioxide – primary source; coal fired power plants

Carbon monoxide – primary source: cars and trucks

Lead – primary source; individual industrial facilities

Nitrogen oxides – primary source; any type of combustion

Particulate matter – primary source; coal fired boilers, cement plants, steel making operations

Ozone – primary source; cars, trucks, utility boilers, painting operations, refineries

Air Quality Standard Process Typical

• Clean Air Act requires standards to be reviewed• Clean Air Scientific Advisory Committee (CASAC)

develops recommendations standards every 5 years• US EPA develops proposes/adopts standard• States have 1 Year to provide recommendations on

“nonattainment” designations

Air Quality Standard Process Typical (Cont’d)

• U.S. EPA has 1 year to finalize nonattainment designations

• States have 3 years to submit plans/attain standards• Extra time is available if state is making “good faith”

efforts• Litigation takes place and can disrupt the schedule

Ohio’s Attainment Status

• The entire state is attainment for nitrogen dioxide, sulfur dioxide, and carbon monoxide.

• Ohio has nonattainment areas for PM2.5, lead • Currently entire state is designated attainment

for ozone and SO2 but this will change.

Revising Standards

U.S. EPA has been busy revising standards: 2006: 24-hr PM2.5

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

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

PM2.5

Ozone

SO2

NO2

Pollutant Current NAAQS Proposed NAAQS

Final Date Designations SIPs Due Attainment

CO 9ppmv (8Hr)35ppmv (1hr)

1/28/11 8/15/11 Affirmed current standard, no new requirements.

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)

Expected early 2011 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)

Expected October 2013

3/27/089/22/11 Clarified

May 2012 Unk-schedule to be proposed Dec 2011

Unk-schedule to be proposed Dec 2011

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

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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 Standard

Timeline Level (ppm) Measurement

Revision of New Standard -CANCELLED

0.060 -0.070 Average of fourth highest concentration measured over a three year period

New Standard 0.075

Old standard 0.084

Old, 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 September 25, 2011)

Year 0.125 ppm1-Hour

0.084 ppm8-Hour

0.075 ppm8-Hour

2000 1 135 326

2001 2 250 738

2002 22 801 1437

2003 22 204 458

2004 None 25 178

2005 5 192 689

2006 None 39 234

2007 None 110 543

2008 None 32 171

2009 None 4 31

2010 None 20 162

2011 None 38 221

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Progress Toward Attainment

0.125 ppm Standard – 1979– Attainment - everywhere for many years

0.08 ppm Standard – 1997– Met everywhere since 2008

0.075 ppm Standard – 2008– Not being met in Cleveland, Cincinnati,

and Columbus areas (2008-2010 data)

Ozone Standard: 2008-2011 Activity

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

Ozone Standard: 2008-2011 Activity

November 1, 2010, U.S. EPA announced another delay

On September 2, 2011 President Obama announced that U.S. EPA would delay going forward with new ozone standard until 2013, at earliest

On September 22, 2011 U.S. EPA announced they would move forward with implementing the 2008 standard

Ozone Standard: Implementing the 2008 Standard

Designations:Proposal expected in December 2011Final designations expected by May 2012Expect the following areas will be designated

nonattainment: Cincinnati (79 ppb) -Butler, Warren, Clinton, Hamilton and

Clermont counties Cleveland (77 ppb) –Lorain, Cuyahoga, Lake, Geauga, Ashtabula,

Medina, Summit, and Portage counties Columbus (77 ppb) – Delaware, Franklin, Madison, Knox, Licking,

and Fairfield counties

Ozone Standard: Implementing the 2008 Standard

Other SIP requirements:Exact timing is to be determinedU.S. EPA expects a proposed implementation schedule in

December 2011Historical (CAA) implementation schedule:

Attainment Demonstrations (3 years from designations) ~ May 2015

Attainment Dates ~2015 to 2032 depending on severity

Ozone Standard: Implementing the 2008 Standard

U.S. EPA December 2011 proposal should also include classifications.

Based on historical classification methods, all three areas will likely be marginal nonattainment. Attainment would then be required three years from designations ~ May 2015

There is a chance that U.S. EPA may tighten deadlines for attainment demonstrations and attainment.

Attaining the Standard:2001 and 2010 VOC Emissions

Attaining the Standard: 2001 and 2010 NOx Emissions

Attaining the Standard: Major Components of Inventory

……it is not all about industry

• Electric Generating Utilities• Other Industrial Point Sources (smaller industrial

boilers and furnaces)• Area Sources (smaller commercial sources (dry

cleaners, gas stations) and people (lawn mowers, residential heating, home painting))

• On-Road - Cars and trucks• Off-Road – Construction equipment, portable

generators, farm equipment

Attaining the Standard: Applying the Model

• Where the model indicates the standard will not be met, additional emission reductions need to be applied to the inventory – this reflects new control programs.

• The model then is re-run until sufficient emission reductions are included to reach attainment.

Attaining the Standard: Identifying Control Measures

• Ohio EPA first looks at multi-state control measures which U.S. EPA is implementing.

• We examine control strategies which are required to be implemented by the Clean Air Act under the area’s classification.

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

What happens if the SIP is not approved?

• US EPA is required to begin the “sanctions” process.

• A sanctions letter is issued to the state that provides up to 18 months to fix problem

• After 18 months, two for one offsets are required in nonattainment area

• After 6 months, US EPA will stop federal highway money from going to the nonattainment area.

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 (newer) • Anticipate new review with possible revised standards

in early 2012. Keeps getting delayed.

Annual PM2.5(15.0 ug/m3)

PM2.5 Annual Concentrations (ug/m3)Highest in Area

City 05-07 06-08 07-09 08-10

Akron 14.9 14.0 13.7 13.2

Canton * 16.1 14.8 14.3 13.8

Cleveland 16.8 15.1 14.4 13.6

Columbus 14.9 13.7 13.0 12.5

Cincinnati 17.3 15.7 15.0 14.4

Dayton 15.5 14.1 13.7 13.1

Steubenville 16.1 14.8 14.2 13.0

Toledo 14.4 13.1 12.6 11.7

Youngstown 14.8 13.6 13.0 12.3

*Incomplete Data

Standard is 15.0 ug/m3

24-Hr PM2.5(35 ug/m3)

PM2.5 24-hour Concentrations (ug/m3)Highest in Area

City 05-07 06-08 07-09 08-10

Akron 37 34 33 33

Canton * 36 35 34 34

Cleveland 42 38 36 33

Columbus 38 32 30 29

Cincinnati 41 35 32 31

Dayton 37 32 31 29

Steubenville 38 37 34 30

Toledo 35 31 32 31

Youngstown 36 32 31 29

*Incomplete Data

Standard is 35 ug/m3

Annual PM2.5 Attainment

• All areas attaining based on 2007-2009 data.• Submitted Clean Data request on April 1, 2010.• But, no time to celebrate, EPA is making a health

assessment review of annual standard – recommending between 11-13 ug/m3 with strong support for 11-12 ug/m3

Annual PM2.5 Redesignation Process

• Preparing redesignation requests for all areas except Canton (*did not meet criteria)– Cincinnati-Hamilton area submitted in December 2010.

U.S. EPA anticipates final action on the request in December 2011.

– Columbus, Dayton-Springfield, Huntington-Ashland, Cleveland-Akron-Lorain submitted throughout 2011 and U.S. EPA is reviewing those. No proposals to date.

– Ohio EPA continues to work on Steubenville-Weirton, Parkersburg-Marietta and Wheeling area requests along with WVA. Anticipate early 2012 submittals to U.S. EPA.

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 unless clean data requests are submitted. Likely will do.

• Initial modeling shows only Cleveland will not meet the standard by 2015 with current controls.– Will likely use weight-of–evidence approach with on-the books

controls.

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.

Cross-State Air Pollution 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) –proposedCross-State Air Pollution Rule (CSAPR) - final

• July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule.

• On July 6, 201, U.S. EPA finalized the replacement rule, the Cross-State Air Pollution Rule (CSAPR)

• Will 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.

• Two phases: 2012 and 2014

Ohio EGU CSAPR Budgets vs Historical Emissions (tons)

Budgets

Historic

**CSAPR will produce substantial emission reductions in Ohio

2012 2014NOx Ozone 40,063 37,792NOx Annual 92,703 87,493

SO2310,230

(464,964 proposed) 137,077

(178,307 proposed)

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 were 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 monitoring sites added for second round…..so far no monitored violations at the new sites.

• Designations from second round were effective November 8, 2011 – no new Ohio 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 and 2011 spikes as high as 2.57 ug/m3,• Looking at other potential sources located near the monitor

(scrap yards, steel)• 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• A 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 new 1-hour…for now

• Currently the only 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 Ohio

City 2008Population

RoadMonitors

CommunityMonitors

Current Monitors*

Akron 698,553 1 0 0

Cincinnati 2,155,137 1 1 1

Cleveland 2,088,291 1 1 1

Columbus 1,773,120 1 1 0

Dayton 836,544 1 0 0

Toledo 649,104 1 0 0

Youngstown 565,947 1 0 0

• U.S. EPA is scaling back the regulatory monitoring requirements. • Will do phases starting with one area in Ohio - Columbus

NO2 Timeline

• Ohio EPA submitted nonattainment recommendations based on current monitors by January 5, 2011– All areas unclassifiable until new monitors in place

• Final designations were issued by U.S. EPA on August 15, 2011 – no Ohio areas.

• 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 submitted in July 2011 and network established by January 2013.

Monitors needed in Ohio

Area PWEI Monitors Needed Monitors in Area*

Cincinnati 532,728 2 2-OH, 1-KY

Cleveland 299,230 2 6

Marietta 36,725 1 0-OH, 1-W Va.

Steubenville 27,660 1 1-OH, 7-W Va.

Columbus 24,965 1 0

Wheeling, WVa. 22,282 1 1-OH, 1-W Va.

Toledo 18,901 1 0

Point Pleasant 10,372 1 0

Dayton 9,902 1 0

Akron 9,066 1 2

*The monitors in the area now are not necessarily properly located to fulfill the requirements

Sulfur Dioxide Concentrations4th high averages 2007-2009

2007-2009

101-300 ppb

76-100 ppb

0-75 ppb

Ohio Currently Not Attaining

• Nonattainment area recommendation submitted to U.S. EPA on June 3, 2011 (2008-2010 data):– Partial Belmont County (Mead, Pease, Pultney, and York

Townships) at 80 ppb. – Partial Jefferson County (Cross Creek, Island Creek, Knox, Saline,

Steubenville, Warren, and WellsTownships) at 116 ppb– Partial Columbiana County (Liverpool and Yellow Creek

Townships) at 90 ppb– Partial Meigs County (Salisbury Township) and Partial Gallia

County (Cheshire Township) at 89 ppb– Lake County at 163 ppb– Partial Morgan County (Center Township) and Partial Washington

County (Waterford Township) at 195 ppb

Ohio Currently Not Attaining

• Unclassifiable and Attainment areas also recommended (2008-2010 data):– 47 counties recommended as unclassifiable

• Cuyahoga County was also recommended as unclassifiable although one monitor barely exceeded the standard at 76 ppb. This monitor did not meet the minimum collection criteria and the federal rules allowed for data analysis that showed had additional data been collected the monitor would have attained.

– 36 counties with low SO2 emissions recommended as attainment

Lists can be found at: http://www.epa.ohio.gov/portals/27/SIP/SO2/2010_SO2_Standard_Recommended_Nonattainment_Areas-Final.pdf

Ohio Currently not Attaining

• U.S. EPA should make final designations by June 2012. There will be an opportunity to comment

• 2009-2011 (through 10/2011)air quality data for Belmont County indicates significant improvement. Ohio EPA may be requesting Belmont County be designated unclassifiable rather than nonattainment

SO2 Timeline

• Final designations by USEPA June 2012 • After other monitors are installed and data collected,

additional designations will occur. • Basic plan (e.g. “maintenance” or “infrastructure”) 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.

Dispersion Modeling– SO2

– Infrastructure SIP 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

– Tighter SO2 emission limits will need to be developed for many sources in order to model attainment.

Carbon Monoxide (2011)

• In 2011, U. S. EPA reviewed the carbon monoxide standard and decided not to change the standard

• Ohio measures attainment statewide

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The End