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Presentation to Industry Action Plan for Summer 2004 April 1, 2004

Presentation to Industry Action Plan for Summer 2004 April 1, 2004. maurice.oubre@la.gov 225/219-3434. Overview. Current Status of Baton Rouge Area Re-classification to Severe Chapter 22 NOx Rule HRVOC Workgroup HRVOC Survey Action Plan for Summer 2004. Current Status of BR Area.

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Presentation to Industry Action Plan for Summer 2004 April 1, 2004

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  1. Presentation to IndustryAction Plan for Summer 2004April 1, 2004 maurice.oubre@la.gov 225/219-3434

  2. Overview • Current Status of Baton Rouge Area • Re-classification to Severe • Chapter 22 NOx Rule • HRVOC Workgroup • HRVOC Survey • Action Plan for Summer 2004

  3. Current Status of BR Area • 1-Hr Standard • No more than 3 exceedances in 3 years at any monitor (10 monitors in BRNA) • Exceedance =/>125ppb (truncated) • Capitol and LSU were out for 01-03 and already have 4 hits for current 02-04 period • See Table

  4. 1-Hr Ozone Status

  5. Current Status of BR Area • 8-Hr Standard • 4th highest value each year is averaged over a 3 year period • Exceedance =/> 85ppb (truncated) • LSU monitor was out for 2001-03 • See Table

  6. 8-Hr Ozone Status

  7. 1-Hr Summary • LSU monitor already has 3 hits for 2005 • Capitol, Port Allen, and Carville have 2 Exceedances in 2004 and 2005 (especially at LSU) are crucial or the area will be out of attainment in 2005 – the Clean Air Act attainment year.

  8. Re-Classification to Severe • BR was originally classified serious with an attainment date of 1999. • Modeling showed that the area was being affected by ozone transport from Houston. • Under EPA guidance, an extension to 2005 was granted based on transport. • Under pressure EPA pulled the approval and the area was bumped-up to severe with a 2005 attainment date. (June 23, 2003)

  9. Consequences of Bump-Up • Definition of major source reduced from 50 tpy to 25 tpy for both NOx and VOC (revise Chapters 21 and 22) • Offset requirements increase to 1.3 with LAER and 1.5 to avoid LAER (Lowest Achievable Emission rate) • Reformulated Gasoline (RFG) • Section 185 fees for failure-to-attain by2005

  10. Section 185 Fees (rule in comment period until 4/2) • Fees start in 2007 (for 2006) and continue until the area is in attainment • Exemptions: (EPA opposed, no exemptions) • if equipped with minimum 95% control; or • if equipped with BACT • Baseline is the average of annual emissions of VOC and NOx from non-exempt sources for the most representative 3 years between 1998 and 2002. (EPA opposed, must be 2005)

  11. Section 185 Fees (continued) Fee = [A-(80% x B)] x C A = Total actual VOC and NOX emissions in previous year from non-exempt sources B = Baseline amount (tons) C = $5,000 per ton adjusted by CPI to subject year (approximately $8,000)

  12. Chapter 22 NOx Rule • Promulgated March 2002 • Applicable in 9 parishes during ozone season • Establishes emission factors for boilers, heaters, furnaces, turbines and engines • Sources must be in compliance by 5/1/05 • Average point NOx reduction is 30% • Model shows attainment in 2005 Revision for severe classification by June 23

  13. HRVOC Workgroup • 1-hour ozone design value has dropped from around 170 ppb in the early 90s to the low 130s ppb today • VOC and NOx have been dropping steadily since the early 90s • See VOC and NOx graphs

  14. Point Source VOC Emissions Trend Baton Rouge Nonattainment Area (1990-2002) 45000 40000 35000 30000 25000 TONS PER YEAR 20000 15000 10000 5000 90 93 94 95 96 97 98 99 00 01 02 Data Source: DEQ YEAR

  15. Point Source NOx Emissions Trend Baton Rouge Nonattainment Area (1990-2002) Data Source: DEQ

  16. HRVOC Workgroup (continued) • Continuing to have exceedances (11 in 03) • Plot shows rapid ozone formation events (greater than 40ppb/hr rise) - see graph • Similar spikes in Houston, Texas 2000 Air Study implicated HRVOC – 1,3-butadiene, acetaldehyde, butenes, ethylene, propylene, toluene and xylenes

  17. Capitol LSU B Plaquemine P Allen

  18. HRVOC Workgroup (continued) • Workgroup (DEQ, Industry, Environmentalists) formed to evaluate role of HRVOC. • Recommendations: • Add NOx at Dutchtown, Met at LSU and Carville • Add continuous VOC at LSU, Capitol, Carville • Add VOC canister every 6th day at others • Record 5 minute data in addition to 1 hour average • Develop database for past and future data, perform statistical analyses

  19. Site NOx O3 Met VOC 3-hr (daily) 3-hr (3-days) 24-hr (6-days) Trigger (1 ppm of TNMHC)(3) Capitol    *   LSU   * * * * Bayou Plaquemine      Port Allen    *  Pride      Dutchtown *   * Baker     Carville   * * * Grosse Tette    French Settlement    Southern   South Scotlandville  *

  20. HRVOC Survey • Purpose was to identify sources of HRVOC (TEDI-toxics, EIS-total VOC, TRI-facility) • Sent to 148 facilities in BR area • 62 met criteria of >1,000 lbs/yr HRVOC emissions and submitted information • Results: • See graphs

  21. Total = 3,500,000 lbs

  22. Action Plan for Summer 2004 • Review Environmental Management System • Are all emissions being accounted for? • Can emissions be lowered by reducing at source, recycling, recovery or treatment? • Are measured values being used, where available, to estimate the quantity of emissions? • Are the latest and best factors and estimation methodologies being used?

  23. Action Plan for Summer 2004 (continued) • Fugitives – before Summer - consider remote imaging to survey regulated and non-regulated components where HRVOC could leak, make extraordinary attempts to fix tagged leakers • Flares – always operate within design, delay discretionary flaring to evening • Cooling Towers – check inlets weekly for HRVOC, fix leaks as soon as possible • Wastewater – reduce HRVOC wherever possible

  24. Action Plan for Summer 2004 (continued) • Analyzer Vents – route to flare or minimize • Shutdowns – do early or postpone until after ozone season • Maintenance/Equipment Opening – delay until evening, refueling in late evening • Seasonal Activities – delay painting until later in year, do grass cutting in evenings, etc.

  25. Summary • Ozone exceedances in downtown BR in 2004/05 will put the area out of attainment. • If this happens, emission fees will kick-in. • Facilities are asked to develop action plans to reduce emissions, especially HRVOC, but also, other VOC and NOx.

  26. Fugitive Monitoring • EPA is preparing an alternate to Method 21 that will allow Remote Imaging by end 04. • laserimagingsystems.com • leaksurveysinc.com • patinc.com/Sherlock.htm

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