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Implications of the 2008 Ozone Standard Changes

Implications of the 2008 Ozone Standard Changes. Deanna L. Duram, P.E., C.M. August 7, 2008. trinityconsultants.com. Outline. Overview of Ozone Standard Changes Timeline for designations and SIP updates Implications of nonattainment designations

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Implications of the 2008 Ozone Standard Changes

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  1. Implications of the 2008 Ozone Standard Changes Deanna L. Duram, P.E., C.M. August 7, 2008 trinityconsultants.com

  2. Outline • 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?

  3. March 2008 8-hour Ozone Standard • 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 • Three-year average of the fourth-highest daily maximum per year

  4. Timeline • 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

  5. Why does a nonattainment designation matter?Control Requirements • 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

  6. Why does a nonattainment designation matter?Permitting Requirements • Lower major source thresholds (Title V and construction permits) • Major modification thresholds • Lower thresholds • Netting over 5-year period may be required • Major modification requirements • 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

  7. CAIR Vacature and Ozone Attainment Implications • 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 • Impact on ability to attain? • State-by-state strategies for CAIR-like limitations likely

  8. Alabama • No existing 8-hour nonattainment counties • New counties predicted to exceed new standard • ADEM believes that most areas will rely on nationally-mandated controls to achieve the revised standard • Comment made pre-CAIR vacature

  9. Georgia’s Original Nonattainment Areas for 8-hr Ozone Murray, Bibb, and Monroe redesignated attainment http://www.air.dnr.state.ga.us/airpermit/naa.htm

  10. Counties with Ozone Monitors Exceeding 2008 Standard of 0.075 (ppm) (based on 2005-7 monitored data) 0.074 0.074 County with Monitor Meeting Standard County with Monitor Exceeding Standard Slide per EPD presentation, June 25, 2008

  11. Mississippi • No existing 8-hour nonattainment counties • Existing Monitors Over Standard • More counties impacted depending on how “metropolitan statistical areas” defined

  12. Tennessee • 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

  13. Generalized Impacts • Increase in nonattainment counties and number of impacted sources • Ambient monitoring network sufficient? • 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 • Vehicle emissions testing programs for mobile sources • Other non-traditional options?

  14. What can I do now?(Besides shutting down!?) • Become involved in SIP rulemaking process • 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 • Avoids redesignation of county to nonattainment • Requires earlier reductions • Typically viewed positively by stakeholders – more tangible engagement in process?

  15. What should I be concerned with as a source in a nonattaiment area? • 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 • Can you avoid LAER requirements by proposing other controls to reduce emissions? • Avoidance of fees for emission credits • If no credits available, limited options

  16. Questions?Deanna L. Duram, P.E., C.M.dduram@trinityconsultants.com

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