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NAAQS Standard Designations and Rulemakings Update. Steve Scofield Rick Gillam Jane Spann Joel Huey Region 4. November 15, 2012. Outline of Presentation. NAAQS Standard Designations and Rulemakings Lead and SO 2 Designations Ozone Updates PM Updates.
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NAAQS Standard Designations and Rulemakings Update Steve Scofield Rick Gillam Jane Spann Joel Huey Region 4 November 15, 2012
Outline of Presentation NAAQS Standard Designations and Rulemakings Lead and SO2 Designations Ozone Updates PM Updates
Anticipated NAAQSImplementation Milestones (updated September 2012) Section 110 plans will be needed for multiple NAAQS in coming years.
Region 4 Lead Nonattainment Areas • Bristol, Tennessee • Troy, Alabama • Tampa, Florida
EPA Lead Attainment Guidance • 2008 Lead NAAQS Q&A Document issued Jul 8, 2011 • Addendum issued Aug 10, 2012 http://www.epa.gov/airquality/lead/kitmodel.html
Q&A Documents • Provide Guidance on: • Infrastructure SIPs • PSD and NSR • Attainment SIP Development • Emissions Inventory • Modeling
2011 Modeling Related Guidance • 11 Q. What is the appropriate emissions rate (peak seasonal, monthly, or annual rate) to use for the three-month rolling average? • 12 Q. What is the required for modeling for attainment demonstrations? When should allowable emissions be used and when should permits be used? • 13 Q. What is EPA’s policy on conducting model evaluations to avoid under or over predictions compared to monitoring results? • 14 Q. What is EPA’s policy on modeling for contingency measures? • 15 Q. When will the new AERMOD, AERMET, and AERMINUTE updates be released? • 16 Q. Will AERMOD calculate the Lead NAAQS design value? • 17 Q. If the modeling uses 5 years of National Weather Service data do all years have to be modeled in one run or can individual years be modeled?
2012 Addendum • 18 Q. How should model concentrations and background concentrations be properly accounted for in attainment demonstrations? • 19 Q. How should fugitives be modeled in attainment demonstrations? • 20 Q. What is the level of capture efficiency that should be used in modeling of total enclosure emissions? • 21 Q. What is the best way to model ambient air? • 22 Q. How should ASOS 1-minute data be used in modeling? • 23 Q. What is the proper receptor spacing in modeling? • 24 Q. How should haul roads for lead facilities be modeled?
SO2 Designation Issues Timing Region 4 states have expressed concern with using 2009 - 2011 data for designations. OAR is considering whether to extend the effective date to allow the use of 2012 data if a state chooses to certify early. Sources outside of state Kentucky has implicated a source outside their state for violations at 2 of their 3 violating monitors. In one case, they recommended attainment for a portion of their county with the violating monitor. In the other county, they provided no official recommendation, but verbally have said they believe that county should be attainment. Remedy is already in place, why designate nonattainment? Florida has indicated that they may revise their position during the 120 - day process. Although they modeled impacts to define boundaries in their recommendations, they now believe their areas should be attainment.
SO2 Designation Issues cont’d Why can’t areas with clean monitors be designated unclassifiable/attainment? Several states requested attainment for counties with clean monitors. They expressed concern with being required to model in those counties after designations, due to resource concerns and validity of modeled violations for areas with clean air quality data. Future use of third party modeling Although EPA has already decided that we would not respond to third party modeling during this designation process, many states are extremely concerned about future implications. The resources to review and respond to outside modeling would be yet another demand on resources. Also, other parties would not necessarily follow established protocols on what areas to model, what models and parameters to use, etc.
SO2 NAAQS Implementation • New primary SO2 1-hr standard (75 ppb) promulgated in June 2010 • Designations • July 27, 2012 FR notice extends to June 2013 the date for completing designations for all areas • SIPs due 18 months after effective date of designations. EPA provided draft guidance for comment in Fall 2011. Intend to issue final guidance for State plans to show attainment in nonattainment areas by the time that nonattainment area designations are effective • Implementation for areas without violating monitors • Recognition that some areas without monitors likely have violations • Announcement on April 12, 2012 stated that EPA is no longer expecting the June 2013 section 110 infrastructure SIPs to include modeling demonstrations showing attainment in “remaining” areas • EPA issued May 2012 White Paper describing monitoring and modeling options for implementing the standard in areas not initially designated nonattainment • Stakeholder meetings to discuss White Paper held in May-June 2012 • Expect to issue rulemaking or guidance to clarify the designations approach for the remaining areas of the country
Stakeholder Meetings with EPA Topics for focused stakeholder outreach: 1. How best to assess compliance with the S02 NAAQS 2. How to implement the new approach Stakeholders were asked to provide the EPA with input on monitoring, modeling and implementation issues http://www.epa.gov/airquality/sulfurdioxide/implement.html
SO2NAAQS Implementation: Stakeholder Meetings • State Comments • Use threshold concept to address focus on addressing largest sources (e.g., 2000 tons/yr) • Allow flexibility to use monitoring and/or modeling in SO2 implementation process • Redeploying monitors will be possible in limited cases only • If EPA establishes new modeling or monitoring requirements, do it through rulemaking
SO2NAAQS Implementation: Stakeholder Meetings (cont.) Enviro. Group Comments Industry Comments Need rulemaking and additional time for any new implementation requirements Most support basing designations on monitoring data only If modeling for designation is used, it should be based on actual emissions • Use 3rd party modeling in designations process prior to June 2013 • Address largest sources first • Issue guidance ASAP regarding modeling of actual emissions (as surrogate for monitoring air quality for 3 recent years) for use in designations • Concurrently involved in title V permit renewal actions to ensure sources show compliance
SO2 Monitor Design Values 2008-2010 SO2 Monitoring Data 59 violating monitors in 18 states and 1 territory, (48 counties) 2008-2010 design values
Region 4 SO2 Design Values (2009-2011) 2010 SO2 NAAQS is 75 ppb
2008 Ozone NAAQS Designations and Implementation • March 12, 2008 - Revised primary & secondary standard promulgated • Lowered standards from 0.08 ppm to 0.075 ppm. • Final Area Designations • May 2012 (effective July 20, 2012) – Final designations for 2008 ozone standards • 46 areas designated nonattainment including 2 separate tribal areas • Only 3 had never before been designated nonattainment for ozone • 77 FR 30088 and 77 FR 34221-Chicago • Implementation • Nonattainment new source review (Applies on the effective date of designations) • Transportation conformity (Applies 1 year after the effective date of designations July 20, 2012, designations – July 20, 2013) • Development of Attainment Plans (No Attainment Plans required for marginal areas) • http://www.epa.gov/ozonedesignations/
Nonattainment Areas for 2008 Ozone NAAQS(Effective July 20, 2012) Greater Connecticut Sheboygan Upper Green River Basin Jamestown Dukes MA Allentown Tuscan Buttes Sacramento Cleveland Reading Chico New York Chicago Nevada Co Lancaster Philadelphia Columbus Pittsburgh San Francisco Calaveras Co Uintah Basin Seaford DE Mariposa Co Denver Baltimore Washington DC/VA St. Louis San Joaquin Valley Cincinnati San Luis Obispo E. Kern Co Ventura Co West Mojave Knoxville Charlotte Morongo Tribe LA-South Coast Riverside Co Memphis Pechanga Tribe San Diego Imperial Co Phoenix Atlanta Dallas Baton Rouge Houston
2008 Ozone NAAQS Designations and Implementation cont. • Ozone Designations Petitions • Received 30 petitions for reconsideration • 6 Nonattainment Areas: Atlanta, GA; Charlotte, NC-SC; Chicago-Naperville, IL-IN-WI, Dallas-Fort Worth, TX; Knoxville, TN; Memphis, TN-AR-MS • 1 Unclassifiable Area: Uinta Basin, UT • 15 Attainment Areas (in 8 states) - Petitioner requesting EPA designate these areas nonattainment based on 2011 rather than 2010 air quality data • 16 petitions for review filed with the court
2008 Ozone NAAQS Designations and Implementation (cont.) • 2008 Ozone NAAQS Classifications Rule • Signed April 30, 2012, effective July 20, 2012 (77FR30160) • Established classification thresholds and end-of-year attainment dates • Reclassified 6 areas in California that had previously requested bump-up for 1997 NAAQS • Revoked the 1997 standard, effective July 20, 2013, only for purposes of transportation conformity • 2008 Ozone NAAQS SIP Requirements Rule • Rule and guidance addressing SIP requirements under Subpart 2 • Current schedule under development
Overview of 2008 Ozone SIP Requirements Rule • Topics addressed include: • Alternative deadlines for emission inventory, RFP, RACT, RACM, and attainment demonstration SIPs • Flexibility in meeting Reasonable Further Progress (RFP), including precursor pollutant substitution • Reasonably Available Control Technology (RACT) reviews and compliance deadlines • Contingency measure flexibility for Extreme areas • Baseline and periodic emissions inventory submissions • Defining the “MSA” criteria for Rural Transport Areas • Revoking 1997 NAAQS and anti-backsliding provisions • We briefed states on the draft proposal in July and next step is OMB review
Ozone Advance Program • Program, launched in April 2012, encourages emission reductions in ozone attainment areas • Designed to help attainment areas work proactively to stay in attainment • Does not establish new requirements or defer/avoid any existing requirements • Over 17 states and tribes are currently participating • Participation Benefits: • Receive EPA support • Rallying point for public/stakeholder awareness and involvement • Develop framework for action • Emphasis on multi-pollutant reductions • Recognition and opportunity to highlight measures/programs • Stakeholder group formation and engagement • Potential to implement measures early and efficiently • Information can be found at www.epa.gov/ozoneadvance
PM2.5 Nonattainment Area Status * WD – withdrawn or expected withdrawal
2012 PM2.5 NAAQS Proposal • Proposal published June 29, 2012; final due December 14, 2012 • Primary PM2.5 standards: • Lower annual primary standard within the range of 12.0 to 13.0 µg/m3 (seeking comment down to 11.0 µg/m3) • Retain existing 24-hour standard level of 35 µg/m3 • Secondary PM2.5 standard: • Set a separate standard to address visibility effects, primarily in urban areas • PM10 standard: • Retain existing 24-hour standard of 150 µg/m3 • Monitoring: • Add 52 near-road PM2.5 monitors • Implementation: • Proposed action on two permitting issues • Solicited input on other issues
2012 PM2.5 NAAQS Proposal: Proposed Changes to Permitting Provisions • Changes would ensure that changes to the PM standards will not delay pending permits or reduce potential burdens to permit applicants • Changes would: • Grandfather permit applications if a draft permit or preliminary determination has been issued for public comment by the date the revised PM standards become effective • Provide a “surrogacy approach” that would allow, for purposes of the proposed secondary visibility index, permit applicants to rely on their analysis demonstrating that PM2.5 emissions increases would not cause or contribute to a violation of the 24-hour mass-based standards
2012 PM2.5 NAAQS Implementation • Infrastructure SIP obligations and litigation for PM2.5 NAAQS • Based on a consent decree related to the 2006 PM2.5 NAAQS infrastructure SIPs, there are remaining deadlines for EPA action (proposal or final) on one or more elements of 13 states' SIPs (including interstate transport SIPs) between now and October 2013 • For 2012 standards (projected), planning to issue implementation rule by time designations are effective • Estimate early 2015 • Consulting with NACAA PM2.5 implementation policy group on potential implementation issues with new standards (PSD, designations, SIP guidance)
PM Advance • Similar to the Ozone Advance program, PM Advance is intended to continue and expand EPA’s cooperative work with state, tribal, and local governments. • The program is structured for areas that are officially designated attainment for all PM2.5 NAAQS and encourages emission reductions that will help those areas continue to maintain compliance with the 2006 24-hour PM2.5 NAAQS, the 2012 (anticipated) annual PM2.5 NAAQS, and any future revised PM2.5 NAAQS. • Draft has been distributed for review. Expected roll-out in January 2013.
Progress on Ozone and PM2.5 Attainment (National numbers as of September 2012)
Questions? http://www.epa.gov/leaddesignations/ http://www.epa.gov/air/sulfurdioxide/index.html http://www.epa.gov/ozonedesignations/ http://www.epa.gov/pmdesignations/ http://www.epa.gov/air/nitrogenoxides/designations/
