Transcript Q3 Stakeholders Meeting Linn County Public Health
Q3 Stakeholders Meeting Linn County Public Health
October 29, 2010 11:00 AM – 12:00 PM
Agenda
Program Updates 11:00 AM – 11:45 AM PM 2.5 Workgroup Updates Area Sources Emissions Inventory/Stack Testing Modeling/Ambient Monitoring On the Books, Transport, Precursors Permitting Policy/Government Relations Transportation 20 minutes PM 2.5
Rules Update (Increment, SILs & SMC) FY11 Rulemaking Update Ambient Monitoring Update 10 minutes 5 minutes 10 minutes Environmental Health Survey Results/Follow-up 5 minutes Open Discussion 11:45 AM – 12:00 PM Open Discussion 15 minutes
PM
2.5
Workgroup Objectives
Review the current regulatory requirements and recommend to the DNR any revisions as may be appropriate; Advise the DNR of program areas, guidance, procedures, and policies that should be updated; Identify additional information that is needed to implement the new standard and advise on the approaches and efforts that may be necessary to provide the required information; and Advise the DNR of any adverse public health, welfare, social, economic, or energy effects which may result from various strategies for implementing the new standard.
The duties of the workgroup are solely advisory in nature and are limited to providing the DNR with recommendations that will assist in the implementation of the PM action. 2.5
NAAQS. Recommendations from the workgroup do not obligate the DNR to a particular course of
Transportation Subcommittee Recommendations
Quantify impacts from mobiles sources & assure that transportation is fairly reflected according to its contribution in any corrective actions.
Study primary and secondary PM 2.5
and precursor emissions that result from transportation in light of (1) forthcoming Corporate Average Fuel Economy (CAFE) standards that target vehicle manufacturers, (2) the likelihood that the new standards will reduce PM 2.5
to an as-yet unknown extent, and (3) the possibility that further research may shed light on the proportion of precursors that are converted to PM 2.5
under certain conditions.
The subcommittee further recommends that the DNR collaborate with other state agencies and local governments responsible for transportation.
Transportation Subcommittee Recommendations
All nine existing Technical Advisory Committees to MPOs in Iowa should consider adding an advisor and/or representative who is knowledgeable about air quality issues. Such expertise needs to include transportation-related PM2.5 but should not be limited to this pollutant or to this major emissions category.
Iowa General Assembly gather information on the production and combustion of biofuels and the impacts on PM 2.5
levels, and then weigh possible legislation if results indicate the need for a change in current biofuels usage.
Impacts to Linn County Stakeholders
Transportation impacts will get more attention from a planning perspective, but will continue to be largely unregulated until Linn County is designated non-attainment for PM 2.5
or ozone.
Linn County Public Health plans to engage the local MPO to secure a seat on their Technical Advisory Committee.
Staff has already completed MOVES training to provide inventory and modeling support for transportation planning.
Area Source Subcommittee Recommendations
No final recommendations at this point - several will be considered during the Nov 10 th meeting.
DNR should create a general public education program that informs the public that they should not burn green wood in fire places or outdoor boilers.
DNR should have the authority to issue emergency orders that would stop all recreational wood burning within city limits if there are air inversion or air quality problems in a region of the state.
DNR to advocate for the legislation comparable to the intent of House File 627, as amended by H-1250, which would phase in prohibiting open burning of residential waste within city limits. Legislators should continue support the financial needs of smaller communities via SWAP with regards to refuse pickup. Communities should be encouraged to provide refuse pickup, recycling and composting services.
Area Source Subcommittee Recommendations
Iowa should support continued research and voluntary adoption of mitigation strategies to reduce ammonia emissions from livestock operations. Because of the diversity of animal production systems, Iowa should support on-farm research to refine efficacy and protocols for mitigation strategies.
The legislature should fund a review and an update of the publication “Reduce Ammonia Emissions from Livestock Operations” to determine if any additional technology or methodology has been introduced since 2004.
Impacts to Linn County Stakeholders
Public education about the impacts of burning “green” wood could significantly reduce PM emissions from OWBs, fireplaces and backyard fire pits. Linn County is supportive of expanding the burning prohibition to include residential waste within city limits.
Any effort - voluntary or otherwise - to reduce ammonia emissions from livestock sources in Linn County will be supported by Public Health provided the mitigation does not result in other adverse public health impacts.
Permitting Subcommittee Recommendations
Current exemptions be modified to add PM 2.5
thresholds based upon techniques used to establish the thresholds for other pollutants listed in the exemption.
Amend “Small Unit Exemption” to include a 0.53 tpy threshold; 0.40 tpy “substantial small unit”; 10 tpy “cumulative notice threshold” Amend “kk” R&D exemption to include a 0.53 tpy threshold Amend “ff” production welding exemption Current permits by rule [e.g. spray booths] be evaluated by applicable stakeholders and modified to add PM 2.5
thresholds based upon techniques acceptable to affected stakeholders.
Permitting Subcommittee Recommendations
PM 2.5
limits, such as grains per standard cubic foot of exhaust gas, not be put into rule.
Forms EC, EI and MI2 be modified to add a column for PM 2.5 emissions.
Continue current policy on not permitting fugitive emissions.
Continue using the current permitting policy (no PM 2.5
permit limits) in the interim until the state rules are amended and final unless requested by applicant. Continue use of PM 10 as surrogate for PM 2.5
permitting.
Impacts to Linn County Stakeholders
Linn County won’t adopt “small unit” exemption; will develop a registration permit w/stakeholder input. Linn County will adopt all other proposed exemption changes.
Linn County will develop general permits modeled after DNR’s for concrete batch and aggregate processing. A standard ATI will continue to be required for spray booth permits. Linn County will follow IDNR policies and amend the LCCO, as applicable.
Linn County will amend its construction permit application forms.
Modeling/Ambient Air Monitoring Recommendations
Model for PM 2.5
using DNR PM 10 for minor source/project permits modeling guide against the PM 10 NAAQS. Continue using PM 10 pollutant for PM 2.5
.
as a surrogate Allow sources to voluntarily install, submit and use independent PM 2.5
ambient air monitoring results to assess baseline source project impact potential and to demonstrate compliance w/ NAAQS in lieu of modeled predicted compliance. (note: This recommendation will be considered at Nov 10 th meeting)
Impacts to Linn County Stakeholders
Modeling PM 10 as a surrogate for PM 2.5
would remain status quo.
Industry would bear the financial burden of operating and maintaining ambient air monitor if choose not to use LCPH’s results.
Facility would have to do a preliminary modeling analysis to determine where the highest predicted concentration is located.
On the Books, Transport, Precursors Subcommittee Recommendations
The DNR, in cooperation with other state agencies & interested trade groups, expand the educational & outreach efforts regarding Best Practices for NH 3 controls on fertilizer & livestock sources.
Impacts to Linn County Stakeholders Reducing ammonia will have a direct effect on the PM 2.5
by reducing a primary precursor in the formation of ammonium nitrate and ammonium sulfate – both dominant PM 2.5
contributors.
Policy Subcommittee Recommendations
The State’s Implementation Plan (SIP) include a Fiscal impact Statement (FIS). The FIS will look at all aspects of economic/environmental impacts, including all business impact, as well as public health benefits similar to what is found in Iowa Code 17A.4 and 17A.4A.
“Doing nothing” (regards to the impending changes in the NAAQS) is not a viable option and should be taken off the table as an option. It is not the intent of the subcommittee to advocate for more restrictive regulations than federally mandated requirements. We advocate providing input to the DNR regarding PM 2.5
implementation.
Policy Subcommittee Recommendations
The DNR should adopt or develop an outreach program to address excess idling. As the DNR continues to receive federal diesel emission reduction funding ( DERA ), we recommend the DNR seek stakeholder input prior to DNR applying for the grant. Additionally, the DNR should develop for legislative consideration “No Idle” policy for diesel engines.
Recommend the IDNR develop and implement tools for demonstrating compliance with the Ambient Air Quality Standards that may be used in addition to or in lieu of air dispersion modeling of minor sources for PM 2.5
emissions. This action may be supported by EPA’s Guideline on Air Quality Models [40 CFR Part 51 Appendix W] which states “this section recommends procedures that permit some degree of standardization while at the same time allowing the flexibility needed to assure the technically best analysis for each regulatory application.” Flexibility through the use of measured data in lieu of model estimates is an example of one additional tool that may be considered for further development.
Policy Subcommittee Recommendations
The subcommittee is concerned at the lack of available data and the accuracy of existing data. Therefore we recommend the DNR focus on compliance assistance activities rather than taking enforcement actions until representative emission factors are available. It is the Policy Subcommittee’s recommendation that the Iowa General Assembly adequately fund IDNR Air Quality Bureau to implement the PM 2.5
NAAQS. It is the belief of which affects all citizens of the State of Iowa and therefore SHOULD be funded by the State who is charged with protecting their health and welfare.
Policy Subcommittee Recommendations
It is the Policy Subcommittee’s recommendation that the DNR develop an educational outreach program. The goal of the program would be to increase public awareness of air quality issues and reduce individual contributions to air pollution. The DNR should pursue existing internal avenues to increase public awareness by using press releases, the Internet, list serves, Twitter, Facebook, and other social media outlets. It is recommended that DNR continue to utilize the existing business assistance programs to provide information. DNR could use these outlets to promote positive actions by business and industry rather than only the enforcement actions.
Emissions Inventory & Stack Testing Subcommittee
The EIST subcommittee is recommending to the large PM 2.5
workgroup that Iowa should not do anything regarding PM 2.5
stack testing methods and guidance until EPA promulgates final PM 2.5
test methods. Stay with current preferred hierarchy for emission factors, (despite existing limitation): CEM (not available for PM 2.5
) Stack Test Data Mass Balance (not possible for PM 2.5
) EPA Emission Factors (WebFire, AP-42, EPA PM Calculator, NESHAP data, etc.) Vendor Data Engineering Estimate IDNR should receive one-time funding to support the development of an emission factor database for PM 2.5
leverages current work with a stack test database.
that
Additional PM
2.5
Information Workgroup
Meeting notes, work products and technical presentations are available at:
http://www.iowadnr.gov/air/prof/meet_wg/pm 25/index.html
PM
2.5
Rules Update
PSD Increments (final 12/20/10) An increment is the maximum allowable increase in ambient concentrations of a pollutant in an area.
Averaging Period Annual 24-hour PSD Increments NAAQS (ug/m 3 ) 15 Class I 1 Increments (ug/m 3 ) Class II Class III 4 8 35 2 9 18
PM
2.5
Rules Update
PSD Significant Impact Levels (SILs) SILs are a screening tool used to determine whether a proposed project will have a “significant” impact on air quality in the area. Averaging Period Annual 24-hour PSD Significant Impact Levels NAAQS (ug/m 3 ) SILs (ug/m 3 ) Class I Class II Class III 15 35 0.06
0.07
0.3
1.2
0.3
1.2
PM
2.5
Rules Update
PSD Significant Monitoring Concentration (SMC) The SMC is also a screening tool that is used to determine if a source must provide one year of pre construction monitoring data prior to constructing or modifying a facility. PSD Significant Monitoring Concentration PM 2.5
SMC 4 ug/m 3
FY11 Rulemaking Update
Adopting by Reference New 1-hr NAAQS for NO and SO 2.
2 GHG Tailoring Rule requirements – includes revised major source & significance threshold for GHG emissions.
Revised NSPS – 40 CFR Part 60 Subpart OOO (NM Mineral) Subpart Y (Coal Prep) New/Revised NESHAP – 40 CFR Part 63 Subpart 4Z (RICE) Subpart 6V (Chem Mfg) Subpart 7C (Paint Mfg) Subpart 7D (Prep Feeds) Local Changes Add/clarify definitions for GHGs; regulated NSR pollutants; and pollutants subject to regulation under PSD and Title V.
Revise §10.5(9)“k” to require registration permits for GDF ≥10,000 gal/mo and <100,000 gal/mo. GDF ≥100,000 gal/mo must obtain ATI/PTO.
Modify oral excess emission reporting requirements to allow the initial to be filed via e-mail.
Ambient Monitoring Update
New monitoring shelter at Public Health site completed.
Looking to add a NO
2
monitor in FY12
This will help provide a background value for PSD permitting.
The monitoring phase of CSAT project ends November. Final report due March 2011.
Ambient Monitoring Update
Ozone 3 Year Design Values
0.072
0.071
0.07
0.070
0.068
0.068
0.067
0.066
0.066
0.066
0.064
0.062
0.060
0.062
0.062
0.058
0.056
2005-2007 2006-2008 Kirkwood Coggon 2007-2009 2008-2010
Ambient Monitoring Update
Ozone 4th Highest by Year
0.080
0.076
0.075
0.073
0.072
0.070
0.066
0.064
0.060
0.061
0.060
0.060
0.064
0.064
0.062
0.050
0.040
0.030
0.020
0.010
0.000
2005 2006 2007 Kirkwood Coggon 2008 Public Health 2009 2010
15 10 5 0
Ambient Monitoring Update
Army Reserve PM 2.5 24 Hour 98th Percentile 3 year Averages (NAAQS) Note: Standard is 35 ug/m3
35
28.5
30
28 25
25
31 32
20 2005-2007 2006-2008 2007-2009
3 Year Periods
Arm y Res erve Public Health 2008-2010
Ambient Monitoring Update
PM 2.5 Maxmum 24 Hour Values
60
53.4
50
48.3
41.7
40.2
37.3
40
36.8
35
30 20 10 0 2005 2006 2007 Arm y Res erve 2008 Public Health 2009
36.5
40.2
2010
8 6 4 2 0 10 14
Ambient Monitoring Update
Annual PM 2.5 Averages (NAAQS) Note: Standard is 15 ug/m3
12
11.8
11.1
10.4
10.3
9.7
2005 2006 2007 Arm y Res erve 2008 Public Health 2009
10.6
11.7
2010
Ambient Monitoring Update
Crustal component 2% Elemental carbon 2% Organic carbon 11% Crustal component 11% Elemental carbon 5%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 1/2/2010 - 1/26/2010 Average Concentration (µg/m³)
Other 18% Ammonium 15% Sulfate 13%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 4/2/2010 - 4/26/2010 Average Concentration (µg/m³)
Other 17% Organic carbon 23% Nitrate 14% Nitrate 39% Sulfate 20% Ammonium 10%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 2/1/2010 - 2/25/2010 Average Concentration (µg/m³)
Crustal component 2% Elemental carbon 2% Organic carbon 10% Other 10% Nitrate 48% Ammonium 17% Crustal component 7% Elemental carbon 4% Sulfate 11%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 5/2/2010 - 5/26/2010 Average Concentration (µg/m³)
Nitrate 8% Other 26% Sulfate 25% Ammonium 9% Organic carbon 21%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 3/3/2010 - 3/27/2010 Average Concentration (µg/m³)
Crustal component 2% Elemental carbon 3% Organic carbon 9% Other 14% Nitrate 41% Ammonium 17% Sulfate 14%
Army Reserve Center - Met One AIRS Code 191130037 POC 5 (ROUTINE) Date(s): 6/1/2010 - 6/25/2010 Average Concentration (µg/m³)
Nitrate 7% Other 32% Sulfate 19% Crustal component 6% Elemental carbon 7% Organic carbon 23% Ammonium 6%
70% 60%
Community Health Needs Assessment Public Survey on Environmental Health
50% 40% Please select the five most important environmental issues. (n=1338) 30% 20% 10% 0%
Open Discussion