Transcript This is Where the Course Title Will Go

Implications of the 2008 Ozone
Standard Changes
Deanna L. Duram, P.E., C.M.
August 7, 2008
trinityconsultants.com
Outline
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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
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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
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Three-year average of the fourth-highest
daily maximum per year
Timeline
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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
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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
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Lower major source thresholds (Title V and construction
permits)
Major modification thresholds
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Lower thresholds
Netting over 5-year period may be required
Major modification requirements
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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
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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
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Impact on ability to attain?
State-by-state strategies for CAIR-like limitations
likely
Alabama
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No existing 8-hour nonattainment counties
New counties predicted to exceed new standard
Mobile
Baldwin
Russell
Tuscaloosa
Clay
Madison
Morgan
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ADEM believes that most areas will rely on
nationally-mandated controls to achieve the revised
standard
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Comment made pre-CAIR vacature
Georgia’s Original Nonattainment Areas
for 8-hr Ozone
Murray,
Bibb, and
Monroe
redesignated
attainment
Counties with Ozone
Monitors
0.074
Exceeding 2008 Standard
of 0.075 (ppm)
(based on 2005-7 monitored data)
0.074
County with Monitor
Meeting Standard
County with Monitor
Exceeding Standard
Slide per EPD presentation, June 25, 2008
Mississippi
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No existing 8-hour nonattainment counties
Existing Monitors Over Standard
County
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City
2005-2007
Bolivar
Cleveland
76
DeSoto
Hernando
85
Harrison
Gulfport
83
Jackson
Pascagoula
79
Lauderdale
Meridian
76
Lee
Tupelo
75
More counties impacted depending on how
“metropolitan statistical areas” defined
Tennessee
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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
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Increase in nonattainment counties and number of
impacted sources
Ambient monitoring network sufficient?
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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
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Vehicle emissions testing programs for mobile sources
Other non-traditional options?
What can I do now?
(Besides shutting down!?)
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Become involved in SIP rulemaking process
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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
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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?
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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
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Can you avoid LAER requirements by proposing
other controls to reduce emissions?
Avoidance of fees for emission credits
If no credits available, limited options
Questions?
Deanna L. Duram, P.E., C.M.
[email protected]