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 Present prediction of impacts in

Alabama, Georgia, Mississippi, and Tennessee

What should facilities be doing now?

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

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

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

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

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

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

Mobile BaldwinRussell TuscaloosaClay MadisonMorgan

Georgia’s Original Nonattainment Areas for 8-hr Ozone

http://www.air.dnr.state.ga.us/airpermit/naa.htm

Murray, Bibb, and Monroe redesignated attainment

Counties with Ozone Monitors

Exceeding 2008 Standard of 0.075 (ppm)

(based on 2005-7 monitored data)

0.0740.074

0.0740.074

County with MonitorMeeting StandardCounty with MonitorExceeding Standard

Slide per EPD presentation, June 25, 2008

Mississippi No existing 8-hour nonattainment counties Existing Monitors Over Standard

More counties impacted depending on how “metropolitan statistical areas” defined

County City 2005-2007 (ppb)

Bolivar Cleveland 76

DeSoto Hernando 85

Harrison Gulfport 83

Jackson Pascagoula 79

Lauderdale Meridian 76

Lee Tupelo 75

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

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?

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?

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

Questions?

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