Post on 04-Jun-2022
Ozone: Violations, NonAttainment
& our Air Quality Future
Peter Bella
Alamo Area Council of Governments
Guadalupe County Workshop / Randolph Metrocom Chamber
October 9, 2012
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
What is ozone?
• Ozone is an odorless, colorless gas.
• Ground-level ozone can cause:
– shortness of breath
– coughing or wheezing
– headaches nausea
– throat and lung irritation
• Ground-level ozone’s effects are most profound
on children, the elderly, and those with reduced
lung capacity.
What Causes Ozone?
Oxides of Nitrogen (NOx) &
Volatile Organic Compounds (VOC) Note: NOx = NO + NO2 (<= criteria)
Emission Trends for VOC and NOx in
San Antonio / New Braunfels MSA 1996 to 2018
Sa
n A
nto
nio
8-C
ou
nty
MS
A P
op
ula
tio
n
Population Growth in the SA-NB MSA
0.0
1.0
2.0
3.0
4.0
5.0
1970 1980 1990 2000 2010
Po
pu
lati
on
(1
97
0 =
1)
Year
Atascosa
Bandera
Bexar
Comal
Guadalupe
Kendall
Medina
Wilson
Eagle Ford Shale not evident. Courtesy Bill Barker, OEP/CoSA
Texas Water
Development
Board projects
41% growth in the
SA-NB MSA
between 2010-
2040 from
2,142,508 to
3,029,300.
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
http://www.tceq.state.tx.us/cgi-bin/compliance/monops/select_summary.pl?region13.gif
Regulatory O3 Monitors, AACOG / Bexar Co.:
Camp Bullis C58, Calaveras Lake C59, SA Northwest C23
AACOG-operated Non-regulatory
Ozone monitors: C500 series
CPS Energy Owned and Operated
Ozone monitors: C622, C678
2008 8-hour average Ozone
National Ambient Air Quality Standard
• A community will meet the eight-hour standard when the three-year average of the annual fourth highest daily maximum eight-hour ozone concentration measured at each monitoring site is less than 76 parts per billion (ppb). *
2008 Federal 8-Hour Ozone Standard
* Source: TCEQ's "Compliance with Eight-Hour Ozone Standard" page:
http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl
Violation: the three year average of ozone levels on local monitors was too high.
On August 21, two monitors violated the 2008 ozone standard.
Violation of the 2008 Standard
The “Three-Year Average” needs to be
less than 76 parts per billion (ppb).
Data: http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl
Monitoring Site
Fourth Highest Average
Current
Three-Year
2010 2011
2012 Average
as of
3:12 pm CDT
10/8/2012
Camp Bullis C58 78 75 87 80
Calaveras Lake C59 67 71 70 69
San Antonio Northwest C23 72 79 81 77
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
Requirements vs. Discretion
Requirements:
• The current 2008 ozone standard is now under review: – May be revised in 2013 according to the five-year review cycle.
• IF the standard revised in 2013, and timeline did not change: – Proposal for a revised standard would be published in 2013
– Final standard promulgated in 2014.
– Nonattainment designations promulgated in 2016 .
• Designations would be made based on 2013-2015 data.
• Next summer: possibly the 1st year in the 3-year average for designations under a more stringent ozone standard.
• Now is a great time to initiate dedicated air quality improvements.
Requirements vs. Discretion
EPA’s Discretion:
• It is within the EPA Administrator’s discretion under the Clean Air Act to notify the Governor of any state that a designation revision should be revised. – “…on the basis of air quality data, planning and control considerations,
or any other air quality-related considerations the Administrator deems appropriate...“
• Now is a great time to initiate dedicated air quality improvements, especially in light of the Ozone Advance program.
What is AIR Committee Doing?
• Ozone Advance – EPA program to provide
assistance to areas interested
in staying in attainment
– Voluntary program for
voluntary progress
– If we are subject to a
nonattainment designation,
AND we have implemented
adequate reduction, EPA
administrator MAY allow time.
What is AIR Committee Doing?
• Ozone Advance
– Outreach to local business and industry
• TERP: Cleaner fuels for cleaner fleets
• Catalogue existing “clean” practices
– June 25, 2013: “Path Forward” letter to EPA
with list of control strategies to put in place
• Eagle Ford Shale (EFS) Emissions
Inventory for Ozone Precursors
– Develop best estimations for activities
– AACOG staff under contract with TCEQ
Strong Commitment to Success and Recognition
June 13, 2007: Hon. Jay Millikin presents recognition award
to Tom Spaits of Capitol Cement for SNCR implementation
Photo:
Forrest
Mims
III
Strong Commitment to Success and Recognition
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
EPA Default Boundary: MSA*
Metropolitan Statistical
Area Atascosa, Bandera, Bexar, Comal, Guadalupe, Kendall, Medina, and Wilson Counties
See page 3, “Area Designations for the 2008 Revised Ozone National Ambient Air
Quality Standards”:
http://www.epa.gov/groundlevelozone/designations/2008standards/documents/
2008-12/Area_Designations_for_the_2008_Revised_Ozone_NAAQS.pdf
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
Surrounding Counties
• Alamo Rural Transit – Mass Transit
– Connect work-to-home with mass transit
• TERP: Cleaner fuels for cleaner fleets
• Energy Efficiency / Renewable Energy
– Solar, wind, building code improvements
– Building retrofits / AACOG Weatherization
– SPEER / Energy Systems Lab + Consortium
– Learn from CPS Energy
• Avoid land clearing and agriculture
burns on AQHA days
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
Key Programs under NA
• Nonattainment New Source Review:
– Seeks industry and business emission reductions
– Allowances are reduced under emissions permits
• Transportation Conformity
– Requires that engineers demonstrate that “added capacity” roadway projects will not add pollution
– One year from the date of a non-attainment designation, federally funded highway and transit projects require demonstration: no increase in emissions due to build-out
RACT/BACT/LAER
• BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas).
• RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas).
• LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas.
Under EPA's "New Source Review" (NSR) program, if a company is
planning to build a new plant or modify an existing plant such that air
pollution emissions will increase by a large amount,
then the company must obtain an NSR permit.
http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html
EXTREME
(20 Years)
Clean Fuels and Controls for Boilers
Traffic Controls During Congestion
SEVERE
(15-17 Years)
VMT Growth Offset
Major Source Fees for Failure to Attain
(185 Fees)
SERIOUS
(9 Years)
Enhanced Monitoring and I/M
Modeled Attainment Demonstration
3% per Year VOC Reductions After 6
Years
RFP Milestone Contingency
Measures
Clean Fuels Program
VMT Demonstration
Stage II Gasoline Vapor Recovery
MODERATE
(6 Years)
Basic I/M
RACT & RACM Emissions Reductions
Attainment Demonstration
Contingency Measures
RFP - 15% VOC Reductions within 6
years
MARGINAL
(3 Years)
Emissions Inventory
Emissions Statements
Nonattainment NSR Program & Emissions
Offsets
RACT Fixups
I/M Corrections
10
1.5 : 1
25
1.3 : 1
50
1.2 : 1
100
1.15 : 1
100
1.1 : 1
Courtesy TCEQ
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
Rural
Sources Cars
Trucks
Locomotives
Small Engines
Vegetation
Major
Combustion
Sources Power
Generation
Cement Industry
Manufacturing
Urban
Sources Cars Trucks
Buses Airports
Industries Construction
Lawn & Garden Equipment
Vegetation
Rural
Background
Ozone Level
Relatively low
Wind Direction
Ozone Increases
Downwind from
Major Combustion
Sources
Ozone Increases
Further Due to
Numerous Urban
Sources
High Ozone
Extends
Downward from
Urban Areas
Courtesy TCEQ
Transport
Image courtesy of the Capital
Area Council of Governments
Key Questions Today
1. What does the ozone violation mean?
2. What actions has San Antonio taken to reduce its
contribution to ozone?
3. Why are all counties in San Antonio – New Braunfels
Metropolitan Statistical Area (MSA) included?
4. What can surrounding counties do to reduce their
ozone contribution?
5. What kinds of sanctions might ensue?
6. What is the role of what we call "transport”?
7. Will the Eagle Ford possibly increase area
ozone?
Superlative Comments
-“Eagle Ford shale will be another Spindletop for Texas.”
-“…and could be the most promising oil play in the nation.”
-“…perhaps largest economic boom in our state’s history.” – Texas RR Commission
-“… one of the nation’s biggest oil and gas fields over next 20 – 30 years.”
-“The 400 mile stretch in south Texas is a major job factory.”
Eagle Ford Shale Play
Horizontal Drilling / Hydraulic Fracturing
Figure from energyindustryphotos.com
"Ozone Impacts of Natural Gas Development in the Haynesville Shale," Environ. Sci. Technol., November 18, 2010 ENVIRON, et. al. http://pubs.acs.org/doi/abs/10.1021/es1021137
Maximum Regional 8-Hour Ozone Impacts in 2012
Maximum impacts extend outside Northeast Texas into
other regions of Texas
Wind directions
relative to Bexar
County on high
ozone days > 70
ppb, 2005-2011 48-hour back trajectories within
250 miles of CAMS 58
13%
25%
24%
26% 8% 2%
1%
2%
Bexar
Medina
Bandera
Kerr Kendall
Comal
Guadalupe
Gonzales
Wilson
Atascosa Frio
McMullen
Live Oak Bee
Karnes
Goliad
Dewitt
Caldwell
Hays
Blanco
Bastrop
Travis Gillespie
La Salle
Well location data, Legend:
http://www.rrc.state.tx.us/eagleford/images/EagleFordShalePlay120211-large.jpg
Wind data analysis: AACOG
Eagle Ford Shale Estimates Draft NOx Emissions in tons per day from 24-county Eagle Ford shale play
EFS Emissions Source 2011
Exploration and Pad Construction 0.6
Drilling 23.9
Hydraulic Fracturing 12.3
Midstream 8.8
Total* Estimated Emissions 45.6
Type of Industry 2008 2013 2018
Electricity Generation 46.5 42.9 42.9
Cement Industry 20.9 25 25
Petroleum Industry 5.7 5.7 5.7
Manufacturing 1.1 1.1 1.4
Military Bases 0.9 0.9 0.9
Other Sources 0.6 0.6 0.6
Total 75.9 76.3 76.6
NOx Emissions in tons per day from Point Sources, 8-County SA-NB MSA
* 2011 estimations for Production
not included.
Production may create up to 25
additional tons of NOx/day in 2011.
2012 emissions will be higher.
For example, midstream sources
are estimated at 39.3 tons of VOC
and 21.0 tons of NOx in 2012.
C23 Back Trajectories on Days with 8-Hour Ozone > 75 ppb and the Location of Eagle
Ford, 2008-2011
NOAA, Feb. 26, 2010. “Realtime Environmental Applications and Display sYstem (READY)”. Available online: http://www.arl.noaa.gov/ready.html. Accessed 01/12/12.
Questions / Comments
Contact Information:
Peter Bella
Director Natural Resources, AACOG
pbella@aacog.com
(210) 362-5249
The Alamo Area
Council of
Governments
• AACOG provides direct
services & planning
supporting communities and
local governments in a 12
county area of south central
Texas
Services to local governments
& citizens (CJ, ART, Aging,
etc.)
Planning forum for multi-
jurisdictional issues (AQ, Eco
Dev., Public Safety, etc.)
http://www.aacog.com/
Anthropogenic NOX Emissions by Source Category, San Antonio / New Braunfels MSA, 1996 to 2018 (tons/day)
Type of Industry Tons/day Percentage
Electricity Generation 42.9 56.2%
Cement Industry 25.0 32.8%
Petroleum Industry* 5.7 7.5%
Manufacturing 1.1 1.4%
Military Bases 0.9 1.2%
Other Sources 0.6 0.8%
Total 76.3 100.0%
NOX Point Source:
2013
NOX Point Source: 2013
* Does not include estimates from Eagle Ford development
Background
* Texas Water Development Board
• AACOG region: Full compliance with CAA (‘70s)
• Significant actions taken in the AACOG region
– Early Action Compact + Cement ind. & Power generation
– Air Improvement Resources
– CoSA’s Mission Verde + CPS Energy’s STEP
– Clean Cities (DOE) + Commute Solutions (TxDOT)
• Now More Than Ever
– Eagle Ford shale (EFS) emissions are not now understood
– 2010 & 2011 Design Values: “On The Cusp” pre-EFS
– Growth > +885,000 in MSA from 2010-2040* pre-EFS
• Doing Nothing ≠ Maintaining Air Quality
Smart Ideas for the Future
• Greater Mobility – Mass Transit
– Lone Star Rail
– Transit Oriented Development
• Greater Urban Densification
– Decade of Downtown / Walkable Communities
• Energy Efficiency / Renewable Energy
– Solar, wind, building code improvements
– Building retrofits
• Better Emissions Inventories
65
70
75
80
85
90
95 1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
20
11
De
sig
n V
alu
e (
pp
b)
Year
Northwest C23 North C07 Camp Bullis C58 Calaveras C59 8-Hr O3 Exceedance
C58
75 ppb: Upper limit allowed
2008 8-Hour Ozone Standard
C23
C59
C07 2008 8-Hour Ozone Standard Set
Ozone Trends, San Antonio Region, 1980-2011
65
70
75
80
85
90
95
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
20
11
De
sig
n V
alu
e (
pp
b)
Year
Northwest C23 North C07 Camp Bullis C58 Calaveras C59 8-Hr O3 Exceedance
C58
75 ppb: Upper limit allowed
2008 8-Hour Ozone Standard
C23
C59
C07 2004 was the first year that the 8-hour average
ozone standard was active and enforced.
The standard was 85 ppb when it went into effect.
Ozone Trends, San Antonio Region, 1980-2011
Types of Strategies: LOCAL
• Industrial Controls
• Energy Efficiency Projects
• Mobile Source Controls – Fleet controls
– Idling Reduction Programs
– Diesel retrofits
– Commute Solutions
• Outreach – Ozone Awareness Programs
Guy Donaldson, Chief, Air Planning Section, EPA Region 6, “State
Implementation Plans,” http://blueskyways.org/meetings/webinar/june2.html
Air Quality Planning Flow Chart
Is Air Clean?
Gather Air Quality
Data
(Ozone Monitoring)
And Track A.Q. Plan
Progress
Model Impact of
Controls on Air
Quality
Develop
Emission
Control
Measures
Project Future
Emissions
Estimate Current
Emissions
(Build Emissions
Inventory)
Is
Control
Strategy
Adequat
e?
Enforce Rules
and Program
Implement
Rules and
Program
Develop Rules
to Implement
Controls
Attainment &
Maintenance
NO
YES
YES
NO
Develop Base
Case Model