Air Quality and SIP Update

1. Robert Hodanbosi, Chief, DAPC Jennifer Dines, Manager, DAPC SIP Section Air Quality and SIP Update

2. National Ambient Air Quality Standards (NAAQS) • U.S. EPA has developed standards for six specific contaminants • Sulfur dioxide – primary source; coal fired power plants • Carbon monoxide – primary source: cars and trucks • Lead – primary source; individual industrial facilities • Nitrogen oxides – primary source; any type of combustion • Particulate matter – primary source; coal fired boilers, cement plants, steel making operations • Ozone – primary source; cars, trucks, utility boilers, painting operations, refineries

3. Air Quality Standard Process Typical • Clean Air Act requires standards to be reviewed • Clean Air Scientific Advisory Committee (CASAC) develops recommendations standards every 5 years • US EPA develops proposes/adopts standard • States have 1 Year to provide recommendations on “nonattainment” designations

4. Air Quality Standard Process Typical (Cont’d) • U.S. EPA has 1 year to finalize nonattainment designations • States have 3 years to submit plans/attain standards • Extra time is available if state is making “good faith” efforts • Litigation takes place and can disrupt the schedule

5. Ohio’s Attainment Status • The entire state is attainment for nitrogen dioxide, sulfur dioxide, and carbon monoxide. • Ohio has nonattainment areas for PM2.5, lead • Currently entire state is designated attainment for ozone and SO2 but this will change.

6. Revising Standards • U.S. EPA has been busy revising standards: • 2006: 24-hr PM2.5 • 2008: Lead • 2010: NO2, SO2 • 2008-2011: Ozone • 2011: CO • More to come: • 2012: PM2.5 • 2013-2014: Ozone NO2 SO2 Ozone PM2.5

7. Revised Standards…attainment will change

8. Revised Standards …implementation will strain recourses

9. OZONE

10. Ozone Air Quality Standard

11. Ozone Monitors in Ohio

12. Ozone Exceedances by Year (through September 25, 2011)

13. 4th High Ozone Value in ppb

14. Progress Toward Attainment 0.125 ppm Standard – 1979 • Attainment - everywhere for many years 0.08 ppm Standard – 1997 • Met everywhere since 2008 0.075 ppm Standard – 2008 • Not being met in Cleveland, Cincinnati, and Columbus areas (2008-2010 data)

15. Ozone Standard: 2008-2011 Activity • 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

16. Ozone Standard: 2008-2011 Activity • November 1, 2010, U.S. EPA announced another delay • On September 2, 2011 President Obama announced that U.S. EPA would delay going forward with new ozone standard until 2013, at earliest • On September 22, 2011 U.S. EPA announced they would move forward with implementing the 2008 standard

17. Ozone Standard: Implementing the 2008 Standard • Designations: • Proposal expected in December 2011 • Final designations expected by May 2012 • Expect the following areas will be designated nonattainment: • Cincinnati (79 ppb) -Butler, Warren, Clinton, Hamilton and Clermont counties • Cleveland (77 ppb) –Lorain, Cuyahoga, Lake, Geauga, Ashtabula, Medina, Summit, and Portage counties • Columbus (77 ppb) – Delaware, Franklin, Madison, Knox, Licking, and Fairfield counties

18. Ozone Standard: Implementing the 2008 Standard • Other SIP requirements: • Exact timing is to be determined • U.S. EPA expects a proposed implementation schedule in December 2011 • Historical (CAA) implementation schedule: • Attainment Demonstrations (3 years from designations) ~ May 2015 • Attainment Dates ~2015 to 2032 depending on severity

19. Ozone Standard: Implementing the 2008 Standard • U.S. EPA December 2011 proposal should also include classifications. • Based on historical classification methods, all three areas will likely be marginal nonattainment. Attainment would then be required three years from designations ~ May 2015 • There is a chance that U.S. EPA may tighten deadlines for attainment demonstrations and attainment.

20. Attaining the Standard:2001 and 2010 VOC Emissions

21. Attaining the Standard: 2001 and 2010 NOx Emissions

22. Attaining the Standard: Major Components of Inventory ……it is not all about industry • Electric Generating Utilities • Other Industrial Point Sources (smaller industrial boilers and furnaces) • Area Sources (smaller commercial sources (dry cleaners, gas stations) and people (lawn mowers, residential heating, home painting)) • On-Road - Cars and trucks • Off-Road – Construction equipment, portable generators,farm equipment

23. Attaining the Standard: Applying the Model • Where the model indicates the standard will not be met, additional emission reductions need to be applied to the inventory – this reflects new control programs. • The model then is re-run until sufficient emission reductions are included to reach attainment.

24. Attaining the Standard: Identifying Control Measures • Ohio EPA first looks at multi-state control measures which U.S. EPA is implementing. • We examine control strategies which are required to be implemented by the Clean Air Act under the area’s classification.

25. Requirements for Ozone Areas - CAA Extreme Severe Serious Traffic controls during congested periods Clean fuels requirement for boilers (plan in 3 years) No waivers from 15% or 3% reduction requirements Requirement for fee on major sources if fail to attain Measures to offset VMT growth (108(f) measures) due in 2 yrs Contingency measures if miss milestone Specific NSR requirements for modifications to existing sources Moderate VMT demonstration due in 6 years (TCM program if needed) Clean fuel program due in 4 years (if applicable) Enhanced I/M due in 2 years Plan for 3% annual average reductions due in 4 years Marginal Demonstration of attainment in 4 years Basic I/M (if not already required) due immediately Stage II gasoline vapor recovery due in 2 years RACT: Existing & future CTG’s & RACT on major sources (existing due in 2 years) Plan for 15% VOC reduction within 6 years is due in 3 years New Source Review (NSR) program due 2 years (corrections to existing, also) RACT corrections due in 6 months; I/M corrections, immediately Emission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventories

26. What happens if the SIP is not approved? • US EPA is required to begin the “sanctions” process. • A sanctions letter is issued to the state that provides up to 18 months to fix problem • After 18 months, two for one offsets are required in nonattainment area • After 6 months, US EPA will stop federal highway money from going to the nonattainment area.

27. PM2.5

28. 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 (newer) • Anticipate new review with possible revised standards in early 2012. Keeps getting delayed.

29. Annual PM2.5(15.0 ug/m3)

30. PM2.5 Annual Concentrations (ug/m3)Highest in Area Standard is 15.0 ug/m3

31. 24-Hr PM2.5(35 ug/m3)

32. PM2.5 24-hour Concentrations (ug/m3)Highest in Area Standard is 35 ug/m3

33. Annual PM2.5 Attainment • All areas attaining based on 2007-2009 data. • Submitted Clean Data request on April 1, 2010. • But, no time to celebrate, EPA is making a health assessment review of annual standard – recommending between 11-13 ug/m3 with strong support for 11-12 ug/m3

34. Annual PM2.5 Redesignation Process • Preparing redesignation requests for all areas except Canton (*did not meet criteria) • Cincinnati-Hamilton area submitted in December 2010. U.S. EPA anticipates final action on the request in December 2011. • Columbus, Dayton-Springfield, Huntington-Ashland, Cleveland-Akron-Lorain submitted throughout 2011 and U.S. EPA is reviewing those. No proposals to date. • Ohio EPA continues to work on Steubenville-Weirton, Parkersburg-Marietta and Wheeling area requests along with WVA. Anticipate early 2012 submittals to U.S. EPA.

35. 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 unless clean data requests are submitted. Likely will do. • Initial modeling shows only Cleveland will not meet the standard by 2015 with current controls. • Will likely use weight-of–evidence approach with on-the books controls.

36. 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.

37. Cross-State Air Pollution Rule

38. 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

39. Clean Air Transport Rule (CATR) –proposedCross-State Air Pollution Rule (CSAPR) - final • July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule. • On July 6, 201, U.S. EPA finalized the replacement rule, the Cross-State Air Pollution Rule (CSAPR) • Will 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. • Two phases: 2012 and 2014

40. Ohio EGU CSAPR Budgets vs Historical Emissions (tons) Budgets Historic **CSAPR will produce substantial emission reductions in Ohio

41. Lead

42. 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 were 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 monitoring sites added for second round…..so far no monitored violations at the new sites. • Designations from second round were effective November 8, 2011 – no new Ohio areas.

43. 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 and 2011 spikes as high as 2.57 ug/m3, • Looking at other potential sources located near the monitor (scrap yards, steel) • Investigating Ferro operations in detail. • Attainment demonstration due July 2012. • Attainment date ~January 2016

44. Nitrogen Dioxide

45. New Standard – NO2 • New standard effective April, 12, 2010. • The annual primary standard remains the same at 53 ppb • A 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

47. Ohio Attaining new 1-hour…for now • Currently the only 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.

48. Monitors needed in Ohio • U.S. EPA is scaling back the regulatory monitoring requirements. • Will do phases starting with one area in Ohio - Columbus

49. NO2 Timeline • Ohio EPA submitted nonattainment recommendations based on current monitors by January 5, 2011 • All areas unclassifiable until new monitors in place • Final designations were issued by U.S. EPA on August 15, 2011 – no Ohio areas. • 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

50. 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