Air Quality and SIP Update

Ohio EPA DAPC Air Program WorkshopDecember 7, 2010

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

Ohio’s Attainment Status

The entire state is attainment for ozone, nitrogen dioxide, sulfur dioxide, and carbon monoxide…for now.

Ohio has nonattainment areas for PM2.5 and lead.

Revising Standards

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

2008: Lead 2010: NO2, SO2, Ozone

More to come: 2011: CO, PM2.5

PM2.5

Ozone

SO2

NO2

Pollutant Current NAAQS

Proposed NAAQS

Final Date Designations SIPs Due Attainment

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

Oct 2010 May 2011

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)

Nov 2010 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)

0.060-0.07 ppmv (8-hr)7-15ppmv-hr(secondary)(01/06/10)

~12/31/10 Dec 2011 Feb 2014 2014-2031

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

2010 2011 2012 2013 20140

1

2

3

4

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

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 October 1, 2010)

Year 0.0125 ppm1-hr

0.08 ppm8-hr

0.075 ppm8-hr

0.075 ppm8-hr exceedance

days

2000 1 135 326 332001 2 250 738 552002 22 801 1436 652003 22 204 458 402004 None 25 178 302005 5 192 688 652006 None 39 236 392007 None 110 541 592008 None 32 171 262009 None 4 31 112010 None 20 163 32

1978

1979

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

0

20

40

60

80

100

120

140

160

4th High Ozone Value in ppb

4th High

Important Dates – Eight-Hour Ozone Standard (0.08 ppm)

June 14, 2004 – Nonattainment areas become effective for the eight-hour ozone standard

June 15, 2007 – Ozone SIPs were due for all areas June 2009 – Attainment date for all areas (except

Cleveland) June 2010 – Attainment date for Cleveland area Moved forward with some rules – consumer

products, AIM coatings, portable fuel containers

8-Hour Ozone(0.084 ppm)

Full Attainment ….

Attainment for Key Areas

Area Design Value Redesignation

PPM Years Submitted Approved

Columbus 84 2006-2008 3/17/09 9/15/09

Cleveland 84 2006-2008 3/17/09 9/15/09

Cincinnati 82 2007-2009 12/14/09 5/11/10

“New” Ozone standard.

“New” 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

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

New deadline is December 31, 2010

.

“Revised New”

Ohio Ozone 2008-2010

Truncated values through October 11, 2010

08-10 by County

76 to 100

71 to 75

66 to 70

61 to 65

0 to 60

Impact of the “New” Standard 0.075 ppm Standard

Not being met in Cleveland, Cincinnati, Columbus, Youngstown and Marietta

0.070 ppm Standard ++ Toledo, Steubenville, Dayton, and Lima

All monitors in the State exceeding except two in the Dayton area (2 of 49)

0.065 ppm Standard +++ The two Dayton monitors exceeding

0.060 ppm Standard ++++ Nothing left

*based on 2007-2009 data

The moving target ….. Obstacles in implementation

Litigation takes place and disrupts the schedule. The targeted level and schedule changes. U.S. EPA proposed to shorten the implementation

schedule affecting the time States need to plan…. Approximately 4 months instead of 1 year for State

designation recommendations. Attainment demonstrations within 28 months of designations

rather than 36. U.S. EPA didn’t meet their August 31, 2010 goal….now

what happens to the schedule? Depends on US EPA implementation rules which are to be

proposed with final standard: How much time we will have to attain? What will the thresholds be for classification?

What will be the schedule for the “new revised” 8-hour standard?

December 2010 – Standard promulgated May 2011 (??)– State recommends nonattainment

areas December 2011 (??)– US EPA finalizes

nonattainment designations April 2014 (??) – Attainment demonstrations due Jan 2014(??) – Attainment date for basic areas Jan 2015(??) – Attainment date for marginal areas Jan 2018 (??) – Attainment date for moderate

areas

Ability to attain the new standard? Preliminary projections with CAIR (of 53

monitors modeled)

*attainment date: 2014-2031

Will CAA required controls be enough? Probably not.

Level (ppm) Number of monitors exceeding level in 2018

0.070 11 of 53

0.065 34 of 53

0.060 51 of 53

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

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 (new)

Anticipate new review with possible revised standards by October 2011.

Annual PM2.5(15.0 ug/m3)

Annual StandardAir Quality Trends

2003-2005

2004-2006

2005-2007

2008-2008

2007-2009

10.0

11.0

12.0

13.0

14.0

15.0

16.0

17.0

18.0

19.0

Cleveland/Akron

Cincinnati

Columbus

Youngstown

Toledo

Dayton

Canton

Steubenville

Athens

Standard 15.0 ug/m3

Attaining!!!

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

24-Hr StandardAir Quality Trends

Standard 35 ug/m3

Almost attaining!!!

2003-2005

2004-2006

2005-2007

2008-2008

2007-2009

25

30

35

40

45

50

Cleveland/Akron

Cincinnati

Columbus

Youngstown

Toledo

Dayton

Canton

Steubenville

Athens

Annual PM2.5 Attainment PM2.5 Annual attainment demonstration, based

on CAIR, submitted July 16, 2008.

Modeling showed all but one area would attain by the 2010 attainment date…used Weight-of-Evidence approach for Cleveland-Akron area.

No additional controls beyond CAA requirements were necessary.

All areas attaining based on 2007-2009 data. Submitted Clean Data request on April 1, 2010.

Annual PM2.5 Redesignation Process Preparing redesignation requests for all areas

except Canton (*did not meet criteria)

CAIR remanded December 23, 2008 U.S. EPA said no PM2.5 redesignations that rely on

CAIR until CAIR fix in place.

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

Annual PM2.5 Redesignation Process

U.S. EPA new position on redesignations: Move forward on those that don’t rely on

CAIR/Transport Rule for maintenance. Columbus Dayton

CAN propose other redesignations that rely on CAIR/Transport rule but can’t go final until Transport Rule is final (~spring 2011) Cincinnati, Huntington-Ashland, Parkersburg-

Marietta, Wheeling, Steubenville, Cleveland. In these areas we can’t show attainment or

maintenance without CAIR like we did for ozone.

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. Initial modeling, with CAIR, shows only

Cleveland will not meet the standard by 2015 with current controls. Will likely use weight-of–evidence again.

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.

Clean Air Transport 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) July 6, 2010, U.S. EPA proposed a replacement

to the CAIR program, the Transport Rule.

Should 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.

Expected to be finalized by Spring 2011 to allow NOx and SO2 reductions in 2012 and further SO2 reductions in 2014.

2009

2010

2011

2012

2013

2014

2015

-

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

4566439945

108667 90556

40661

97313

333,520

233,464

464964

178307

SO2 Transport

SO2 CAIR

Transport

CAIR

CAIR vs. CATR Reductions (tons)

NOx Annual

NOx Ozone

Ohio EGU CATR Budgets vs Historical Emissions (tons)

Budgets

Historic

**CATR would produce substantial emission reductions in Ohio

2012 2014NOx Ozone 40,661 -NOx Annual 97,313 -SO2 464,964 178,307

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 will be 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 sites added for second round…..so far no monitored violations at the new sites.

Second round designations due January 16, 2010: Draft for public comment November 4, 2010 No new nonattainment 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 – spikes surface between January and

March: 2.57 ug/m3, 1.39 ug/m3, 0.78 ug/m3 Looking at other potential sources located near

the monitor (scrap yards) 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 An annual 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…for now Currently three 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 OhioCity 2008

PopulationRoad

MonitorsCommunity

MonitorsCurrent

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

NO2 Timeline States submit nonattainment recommendations

based on current monitors by January 22, 2011 Draft for public comment November 18, 2010 All areas unclassifiable until new monitors in place

Final designations by USEPA January 22, 2012 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 due by July 2011 and network established by January 2013.

Ohio Currently not Attaining Counties measuring above 75 ppb (2007-2009):

Belmont (97 ppb) Columbiana (117 ppb) Jefferson (129 ppb) Lake (175 ppb) Meigs (85 ppb) Morgan (216 ppb)

Sulfur Dioxide Concentrations4th high averages 2007-2009

2007-2009

101-300 ppb

76-100 ppb

0-75 ppb

Monitors needed in OhioArea PWEI Monitors

NeededMonitors 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

Dispersion Modeling– SO2 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  

Will assist with nonattainment designations: Nonattainment = monitored or modeled violations Attainment = monitored and modeled “no” violations Unclassifiable = all other areas

SO2 Timeline States submit nonattainment recommendations by June 2011 Final designations by USEPA June 2012 After other monitors are installed and data collected,

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

The End