OZONE UPDATE. ROHIT SHARMA Lyondellbasell. January 2008

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1 OZONE UPDATE ROHIT SHARMA Lyondellbasell January

2 BACKGROUND 2

3 Basic Ozone Chemistry Solar Energy Little or No Wind Clear Skies Ground Level Ozone (O 3 ) Formation Oxygen (O 2 ) Volatile Organic Compounds (VOC) Nitrogen Oxides (NO x ) Biogenic 2% Biogenic 74% Industry 9% Area & Nonroad 11% On Road 6% Point 9% Area & Non road 11% On road 6% Biogencis 74% On Road 33% Industry 47% Point 34% Area 10% On road 35% Non road 21% - Area & Nonroad 18% 3

4 OZONE STANDARD 1 hr ozone standard The Houston/Galveston/Brazoria (HGB) area was classified as severe non-attainment for Ozone Must meet the national 1 hr ozone standard (0.12 ppm; 120 ppb) by November 15, 2007 Current 8 hr ozone standard June, 2005 EPA classified the HGB area as moderate non-attainment for the 8 hr ozone standard (0.08 ppm; 85ppb) SIP for HGB due to EPA by June 15, 2007 Controls by June 2009; Attainment by June 2010 Must still implement 1 hr controls 4

5 CURRENT 8 HR OZONE STANDARD Governor Perry requests re-classification on June 15, 2007: Marginal (2007) Moderate (2010) Serious (2013) Severe 15 (2019) Severe 17 (2021) Extreme (2024) Next Steps For the SIP EPA published re-classification proposal in FR on Dec 31, Comments due by Jan 30, 2008 New timeline established for an updated SIP submittal 5

6 REAL PROGRESS 6

7 EMISSIONS REDUCTION PROGRAMS $3 Billion-$5 Billion Clean Air Expenditures in the Houston Area have made a difference % NOx Reduction Program Industry Voluntary Episodic Emissions Reduced 2002 HRVOC Reportable Quantities Lowered TERP Grants Accelerate Off-Road Diesel NOx Reductions 2004 NOx CEMs 2004 Federal Cleaner Gasoline 2005 TX Low Emission Diesel (LED) 2005 HRVOC Flare, CT, Vent, PSV Monitoring 2005 Voluntary Use of Newly Commercial VOC Gas Imaging Camera Begins 2006 HRVOC Hourly Limit Program Begins 2006 Federal On-Road Cleaner Diesel 2007 HRVOC Annual Cap & Trade Year 1 7

8 HOUSTON S AIR QUALITY CONTINUES SIGNIFICANT IMPROVEMENT TRENDS One and eight-hour ozone trends show significant improvement The number of exceedances continues to decrease The highest levels (peaks) have decreased The size of the region exposed to ozone is decreasing The size of the population exposed to ozone above the standard is decreasing 8

9 ONE HOUR OZONE EXCEEDANCES 9

10 EIGHT HOUR OZONE EXCEEDANCES Houston Eight-Hour Ozone Design Value Trends by Site Each Design Value Covers a 3-Year Period Ending with the Year Indicated Design Value (ppb) Compliance Level HGB MONITORS East C01 Aldine C08 Texas City C10 Deer Park C18/35 Clinton C403 Crawford C407/411 Lang C408 Croquet C409 HRM 1 HRM 7 HRM 8 Bayland Park Manvel Croix Park C84 3-Year Period Ending at End of Year Shown HRM 10

11 8 Hour Ozone Design Values Houston-Galveston-Brazoria Nonattainment Area 8 Hour Ozone Design Values Houston-Galveston-Brazoria Nonattainment Area Montgomery Montgomery Liberty Liberty Waller Waller Harris Chambers Harris Chambers Fort Bend Fort Bend Galveston 105 Galveston 114 Brazoria Brazoria Ozone Monitors and Design Values (ppb-v) 85 < 85 Ozone Concentration (ppb-v) Ozone Monitors and Design Values (ppb-v) 85 < 85 Ozone Concentration (ppb-v) Source: HRM 11

12 8 Hour Ozone Design Values Houston-Galveston-Brazoria Nonattainment Area 8 Hour Ozone Design Values Houston-Galveston-Brazoria Nonattainment Area Montgomery 84 Montgomery 85 Liberty Liberty Waller Waller Harris Chambers Harris Chambers Fort Bend 97 Fort Bend Galveston 90 Galveston Brazoria 83 Brazoria Ozone Monitors and Design Values (ppb-v) 85 < 85 Ozone Concentration (ppb-v) Ozone Monitors and Design Values (ppb-v) 85 < 85 Ozone Concentration (ppb-v) Source: HRM 12

13 HGB AREA WHEN COMPARED TO THE CURRENT OZONE STANDARDS 1 hr Ozone exceedences in 2004 = 38 1 hr Ozone exceedences in 2005 = 35 1 hr Ozone exceedences in 2006 = 22 1 hr Ozone exceedences in 2007 = 10 8hr Ozone exceedences in 2004 = 53 8 hr Ozone exceedences in 2005 = 55 8 hr Ozone exceedences in 2006 = 42 8 hr Ozone exceedences in 2007 = 32 13

14 STATE OF THE SCIENCE TCEQ Modeling Indicates 8 hr Attainment is Not Achievable Without Significant Emission Reductions from Mobile Sources 14

15 HGB 2009 NOx Emissions Inventory On-Road Mobile 152 tpd (35%) Non-Road Mobile 90 tpd (21%) Area Source 46 tpd (10%) Point Source 146 tpd (34%) HGB NOx Sources Directly Regulated by TCEQ 192 tpd (44%) Source: TCEQ 57% (247 TPD) emission reductions needed to meet 8hr attainment is greater than entire amount available for TCEQ regulation 15

16 HGAC Estimate of Mobile Source Reductions That Are Onthe-Books Budget Nox VOC 16

17 Source: Kelly Kiel, Air Quality Leadership Meeting 17

18 Source: Kelly Kiel, Air Quality Leadership Meeting 18

19 WHAT S NEXT? Implementation of TCEQ SIP Rules For Current Standard Point Source Controls (Chapter 115) More stringent controls for fittings on floating roof tanks Operational limits on landing floating roofs More stringent requirements for degassing and cleaning of tanks Regulate flash emissions from crude oil and condensate tanks Mobile Source / Area Source Controls Add marine distillate fuels (DMX, DMA, MGO) into the definition of diesel fuels requiring them to be Texas Low Emission Diesel (TxLED) compliant. Clean Fuel Fleets increase fleet turnover to newer, lower emitting engines using TERP funds Voluntary measures such as Compressed work week, Telecommuting incentives, Expanding vanpooling Pay-as-you-drive insurance, divert trucks from non-attainment area, shoreside power for auxiliary engines, hybrid-electric locomotives 19

20 WHAT S NEXT? So far most of the modeling work by TCEQ has been based on the year 2000 episode. TCEQ is currently conducting modeling using year 2005 & 2006 episodes Should provide use of better emissions inventories May result in better sensitivity of the model to emissions reductions for both NOx and VOC May impact the attainment date 2006 Texas Air Quality Study (Tex AQS II) results are being investigated by scientists Remember, the 2000 AQS study resulted in a concentrated effort towards reducing HRVOC 20

21 CURRENT 8 HR RULE LITIGATION South Coast Air Quality Management District v. EPA - Litigants against EPA included City of Cleveland, Env. Groups, NPRA, City of Baton Rouge - D.C. Circuit issued decision on Dec. 22, 2006 rejecting challenge on 8hr classifications and timing. Partial vacature of 8hr Rule. Penalties for not meeting 1 hr attainment. NPRA & EPA filed a petition for re-hearing on March 22, 2007 Denied NPRA filed a petition for Certiorari to the Supreme Court on Sept. 6, 2007.Denied Next steps: EPA to work on re-proposing vacated parts of 8hr Rule EPA to provide guidance on penalties for Severe & Extreme 1 hr areas for not meeting attainment 21

22 NEW 8HR OZONE STANDARD EPA published a proposed revision to the 8hr Ozone standard on July 11, 2007 EPA science panel (CASAC) recommended lowering to ppb EPA published lowering primary standard to ppb and to also establish a secondary standard Public hearings held in Philadelphia and Los Angeles on Aug 30, 2007 Public hearings held in Houston, Atlanta, & Chicago on Sept 5, 2007 Written comments were due to the EPA by Oct 9, 2007 EPA must decide by March 2008 per consent decree 22

23 NEW 8HR OZONE STANDARD IMPACT 23

24 BACK-UP SLIDES 24

25 Location of Ozone Monitors in HGB C78 C555 C26 C561 C557 HRM Service Area C560 C553 C559 C554 C562 C408 C8 C1 C405 C604 C551 C15 C607 C617 C610 C410 C411 C81 C603 C611 C53 C403 C1015 C552 C409 C558 C601 C406 C35 C608 C556 C45 C84 C620 C570 C572 C571 C1022 C5005 C618 C619 C1034 TCEQ HRM C1016 City Harris County C11 Independent 25

26 Total HRVOC Network Average Concentrations at Houston Ship Channel PAMS-GC Monitoring Sites (June-November) Butadiene t-2-butene c-2-butene 1-Butene Ethylene Propylene Concentration, ppb-c Note: Data for Wallisville Road in 2005 and 2006 are not complete. Source: Houston Regional Monitoring (HRM) 26