Hansel & Droessler - Update on Changing Federal NAAQS & What They Mean for You
Update on Changing Federal AQ Standards (And What They Mean to You!) Minnesota’s Clean Air Dialogue May 2, 2012 Duluth, MN
A Brief History of the Clean Air Act• To understand AQ Standards, need a bit of history• 1955 Air Pollu,on Act – Research on cause and eﬀect of Pollu2on • 1963 Clean Air Act – States primarily responsible
A Brief History of the Clean Air Act• 1967 Air Quality Act – States designate Air Quality Control Regions (AQCRs) – States develop standards – States have primacy within AQCR’s, Feds between – Progress? • Less than 36 AQCR’s adopted by 1970 – (7 in MN, most of the rest in CA, NY) • No state had full pollu2on control plan – (MN, CA, NY and PiOsburgh were closest) • First Earth Day, 1970, provided impetus for passage – (Yes I was too there!)
A Brief History of the Clean Air Act• 1970 Clean Air Act – Federal Government now has primary responsibility for developing standards – US EPA created to take on those responsibilities – US EPA develops standards for six criteria pollutants: • Particulate matter, ozone, carbon monoxide, sulfur dioxide, nitrogen oxides and lead – States designate areas as attaining standards or not attaining standards – States develop plans (State Implementation Plans or SIPs) to “attain and maintain” the NAAQS.
A Brief History of the Clean Air Act• 1977 Clean Air Act Amendments – NAAQS • Extended deadlines for re-designation – New Permit Program for New Sources • New Source Review or NSR • For sources over 250 tpy, or 100 tpy for listed sources • Non-attainment NSR – LAER, offsets, demonstrate progress • Prevention of Significant Deterioration – BACT, increments – Added new “NAAQS” • Air Quality Related Values (AQRVs) • E.g. visibility in Class I areas
A Brief History of the Clean Air Act• 1990 Clean Air Act Amendments – Designated levels of non-attainment • For Ozone, CO and PM • Marginal, moderate, serious, severe, extreme • Different timeframes for each level – SIPs & SIP elements more prescriptive • RACM/RACT, I/M, Conformity – Regional Haze SIPs to address Visibility in Class I areas
Structure of CAA• There are NAAQS• You’re in attainment or you’re not• If you’re not in attainment: – SIP & schedule to attain & maintain NAAQS – New & modified sources must obtain permits – Install LAER, obtain offsets, demonstrate progress – Other requirements
Structure of CAA• If you are in attainment: – May be subject to maintenance SIP – May need to get permit – May have to install BACT/LAER – May have modeling limitations – May have limitations to avoid BACT/LAER • Synthetic minor
MN History of Non-attainment• Current – lead – Eagan• Past (maintenance SIPs) – CO • Twin Cities, Duluth, St. Cloud – TSP • Twin Cities, Duluth – PM10 • Rochester, Ramsey County – SO2 • Twin Cities, (refineries),Rochester,
U.S. EPA has been very, very busy revising NAAQS• To date: − 2006: 24-hr PM2.5 − 2008: Lead − 2010: NO2, SO2 − 2008-2011: Ozone − 2011: CO• More to come: − 2012-2013: PM2.5 − 2013-2014: Ozone
PM2.5 Air Quality Standard• Annual standard – 15 µg/m3, annual mean averaged over a three year period• 24-hour standard- 35 µg/m3, 98th percentile averaged over a three year period• Anticipate revised standard proposed in 2012 and finalized in 2013.• 24-hour standard could be lowered to 30 µg/m3• Annual standard could be lowered to 11-12 µg/m3
Estimated Daily PM2.5 NAAQS Design Values 2009-2011* 40 35 33.7 30 32.9 Future NAAQS? 30.5 29.6 29.2 Concentration (µg/m3) 31.1 27.9 26.7 25 24.3 20 21.1 19.3 15 16.5 10 5 Dark blue: 1:3 day sampling 2 high values to reach max 0 Light Blue: Daily Sampling 6 high values to reach max 98th Percentile Max observed NAAQS* Through September 30, 2011. Preliminary and subject to change
PM2.5 – Where does it come from? Vehicle Exhaust Direct Wood PM2.5 Burning Emissions Power Plants Ambient Vehicle PM 2.5 Exhaust Secondary Wood PM2.5 Formation Burning (from NOx + SO2 Ag. +NH3+…) Fertilization Power Plants
Requirements for PM2.5 NA Areas - CAAA• The required SIP elements for PM2.5 nonattainment areas are: – Emissions Inventory – PM2.5 RACM/RACT – PM2.5 Nonattainment Area NSR Program – PM2.5 RFP – PM2.5 Attainment Demonstration – PM2.5 Contingency Measures
Emission Inventory• Must include: – Direct PM2.5 – SO2 – NOx• May need to include – VOC – NH3• From: – Mobile Sources – Area Sources – Stationary Sources
PM2.5 RACM/RACT• RACM = Reasonably Available Control Measures• RACT = Reasonably Available Control Technology (RACT is subset of RACM)• Need to investigate for: – Direct PM2.5, SO2, NOx• May need to investigate for: – VOC, NH3, …• Need to investigate for all EI Sources – Mobile, Area and Stationary
PM2.5 RACM/RACT (continued)• No tonnage threshold for RACT• Screening assessments can inform choice of sources/measures to evaluate• Need to evaluate sources throughout the nonattainment area for available controls• Guiding principle for analysis: – show that selected RACT/RACM does not exclude any group of reasonable controls (including controls on smaller sources) that together could advance the attainment date
PM2.5 RACM/RACT (continued)• The following were the source categories initially selected for further consideration (New Jersey): – Boilers – serving electric generating units (EGUs) firing No. 6 fuel oil and coal, – and industrial, commercial and institutional (ICI) fossil fuel-fired units; – Fluid catalytic cracking units (FCCUs) at petroleum refineries; – Furnaces – such as glass, and iron and steel; – Municipal waste combustors (MWCs); – Stationary diesel engines; and – Fugitive Dust Sources.
Example Control Measures• Diesel retrofits (trucks, school • Year-round measures to reduce buses, stationary engines) VMT (Commuter Choice, carpooling• Diesel idling (trucks, trains, port incentives, etc.) equipment, etc.) • Open burning laws and better• Programs to reduce emissions from enforcement poorly maintained vehicles • Programs to reduced emissions• New or improved direct PM and from residential wood combustion precursor controls on stationary and back yard barrel burning sources • Smoke management plans• Year-round operation of seasonal • Improved monitoring techniques stationary source NOx controls and more frequent monitoring on• Increase use of alternative fuel, sources with control devices hybrid vehicles • Reducing emissions of volatile• Buy-back programs for small aromatic compounds (surface engines (boats, vehicles, coatings, gasoline, solvents, etc.) equipment)
PM2.5 Nonattainment Area NSR Program• Applies to sources >100 tpy (not 250 tpy)• Same modification threshold (15 tpy)• Requires LAER – Lowest Achievable Emission Reduction• Requires modeled demonstration of direct PM2.5 attainment – May require modeled demonstration of secondary formation (photochemical modeling)• Requires Offsets (likely 1:1)
PM2.5 Attainment Demonstration• Modeled demonstration of direct PM2.5 and secondary formation – photochemical models• Geographic range of SO2 and NOx emission sources included in RFP plan could extend up to 200 km beyond nonattainment area boundary• Not just Twin Cities!!
Overview of CAA Ozone Planning & Control Mandates by Classification NSR Major offset source ratio threshold 1.5 : 1 10 TRAFFIC CONTROLS DURING CONGESTION Extreme EXTREME CLEAN FUELS REQUIREMENT FOR BOILERS 1.3 : 1 25 (20 years to aCain) PENALTY FEE PROGRAM FOR MAJOR SOURCES LOW VOC REFORMULATED GAS Severe SEVERE VMT GROWTH OFFSET; 1.2 : 1 50 (15/17 years to aCain) VMT DEMONSTRATION (& TCMs IF NEEDED) NSR REQUIREMENTS. FOR EXISTING SOURCE MODS Serious ENHANCED I/M CLEAN FUELS PROGRAM (IF APPLICABLE) MILESTONE CONTINGENCY MODELED DEMO OF ATTAINMENT MEASURES FOR RFP SERIOUS 18% RFP OVER 6 YEARS ENHANCED MONITORING PLAN (9 years to aCain) STAGE II GASOLINE VAPOR RECOVERY 1.15 : 1 100 BASIC I/M CONTINGENCY MEASURES FOR FAILURE TO ATTAIN Moderate 15% RFP OVER 6 YEARS MODERATE MAJOR SOURCE VOC/NOx RACT ATTAINMENT DEMONSTRATION (6 years to aCain) TRANSPORTATION CONFORMITY DEMONSTRATION 1.1 : 1 100 NEW SOURCE REVIEW PROGRAM MAJOR SOURCE EMISSION STATEMENTS Marginal MARGINAL BASELINE EMISSION INVENTORY (EI) PERIODIC EMISSION INVENTORY UPDATES(3 years to aCain)
Sanctions• As a result of failure to submit a SIP or implement a SIP.• Within 18 months of a finding one of two offsets can be imposed; the second within 2 years.• A ratio of at least 2:1 emissions reductions within the nonattainment area for new or modified major facilities undergoing NSR.• Highway funding sanctions. FHWA is required to impose funding moratorium for all but exempt projects (safety, mass transit). 25
Other Issues• Improved source monitoring• Transportation conformity• General conformity
Voluntary Measures• We’ve already done a bunch – Clean Air MN (I) – Project Green Fleet• Other options ?
Voluntary Measures• Ozone Advance (PM2.5 prototype?) – State, tribal, and/or local governments can participate in Ozone Advance if they meet the basic program eligibility criteria: – The area(s) designated is/are not designated nonattainment for either the 1997 8-hour or the 2008 ozone NAAQS. – Identify and report on the air monitor(s) that reflect the air quality in the area(s). – Emissions inventory reporting must have occurred prior to participation in Ozone Advance.
Voluntary Measures• Ozone Advance – promotes local actions to reduce ozone precursors in attainment areas to help these areas continue to maintain the ozone NAAQS. – To apply for participation in Ozone Advance, an area should submit a brief sign-up letter. This letter should express the areas willingness to coordinate with EPA, state, tribal and/or local stakeholders and to quickly implement measures to reduce ozone. Each of the program eligibility criteria should be addressed. – Specific measures do not need to be identified in the letter of intent, although if the applicant would like to highlight any existing measures and programs, they are welcome to do so. The letter should be signed by the appropriate state, tribal and/or local officials with the authority to implement the program and assist in leveraging staff and program funds as needed.
Clean Construction• Score requirements – Fleet average – Self-reporting by contractor