New 2015 Ozone Standard and Implications. July 2016

Transcription

1 New 2015 Ozone Standard and Implications July 2016

2 What is Ozone? Ground level ozone is formed from the mixture of sunlight, NOx and VOC. 2

3 Effects of Ground Level Ozone 3

4 Effects of Ground Level Ozone 4

5 Current NAAQS Pollutant Primary/Secondary Averaging Time Carbon Monoxide (CO) Level Primary 8 hours 9 ppm Lead (Pb) Primary and Secondary Rolling 3 month avg. Nitrogen Dioxide (NO 2 ) 1 hour 35 ppm 0.15 ug/m3 Primary 1 hour 100 ppb Primary and Secondary 1 year 53 ppb Ozone (O 3 ) Primary and Secondary 8 hours 70ppb PM 2.5 Primary 1 year 12 ug/m3 Secondary 1 year 15 ug/m3 Primary and Secondary 24 hours 35 ug/m3 PM 10 Primary and Secondary 24 hours 150 ug/m3 Sulfur Dioxide (SO 2 ) Primary 1 hour 75 ppb Secondary 3 hours 0.5 ppm 5

6 2015 Ozone Standard and Other Changes October 1, 2015 EPA issued new Ozone standard of 70 ppb (8 hour average). Previous standard was the 2008 standard and was set at 75 ppb (8 hour average). Ozone season was extended by one month, new season is March 1 to November 1. 6

7 Key Dates TCEQ is required to make attainment/nonattainment recommendations to the Governor s office who in turn will make a recommendation to EPA by October 1, EPA will consider the recommendations and in turn will indicate by June 1, 2017 what the proposed area designations are. If EPAs designations differ from the States recommendations then the state will be able to comment between June 1, 2017 and July 31, EPA will issue final designations and classifications October

8 Compliance Determination for 2015 Ozone Standard States submit Infrastructure SIPs October States submit attainment plans (SIPs) in (TBD) Attainment date for Marginal areas in early 2021(TBD) Attainment dates for Moderate areas in early 2024(TBD) 2008 NAAQS will be revoked in timeframe 8

9 How is Nonattainment Determined? The 4 th highest eight-hour averaged ozone concentration at each EPA reporting monitor for each year for the past three years is used to determine the final measured ozone reading (known as a design value). Monitor with the highest average design value is used for compliance. EPA must use the most recent monitoring data to make final designations. If designations occur after May 1, 2017 they need to use ozone design values. 9

10 Recent Ozone Readings for Austin 10

11 How is Nonattainment Determined? For Travis County that means the monitors would have to show a 4 th highest eight-hour ozone average of ppb in 2016 in order to make the design value not meet the new ozone standard of 70 ppb. For Texas it is anticipated that Bexar, Hood and El Paso Counties will be new nonattainment counties for the new 2015 ozone standard. 11

12 Proposed 2015 Ozone Designations 12

13 Current Nonattainment Classifications 13

14 Implications of County Going Nonattainment Stricter permitting requirements for factories, power plants, chemical plants and refineries. Restrictions on federal approvals and funding for road construction, rail projects, airport expansions for 20 years after the area is redesignated to attainment. Higher classifications incur other requirements. 14

15 Nonattainment Permitting Nonattainment Permitting 15

16 Nonattainment NSR Permitting Basics Major New Source Review Permitting: The Prevention of Significant Deterioration (PSD) Program and Nonattainment New Source Review Program (NNSR) are EPA programs designed for new major sources and modifications at existing major sources that exceed significant emission rates. Minor New Source Review Permitting: Emissions from criteria pollutants that don t exceed significant emission rates or for other non-criteria pollutants. Done at the state level. 16

17 Nonattainment Permitting Applicability The nonattainment permitting program is applicable to criteria pollutants in areas designated not attaining the NAAQS (particulate matter, ground level ozone, carbon monoxide, sulfur oxides, nitrogen oxides and lead). An area designated out of compliance with the NAAQS is referred to as a nonattainment area (Dallas and Houston areas are nonattainment for ozone). 17

18 Ozone Nonattainment Permitting Ozone nonattainment areas are regulated through Ozone precursors, VOC and NOx. Marginal, Moderate, Serious, Severe and Extreme, ozone nonattainment areas have different major source definitions. They each have significant emission rates that trigger netting and major modification significant rates. 18

19 Major Source Definitions and Major Modification Definitions for Ozone Classification Major Source (tons/year) Major Modification net increase (tons/year) Marginal Moderate Serious Severe For Serious and Severe areas the trigger to determine if netting is required is 5 tons/year 19

20 Nonattainment Netting Examine the history of modifications at the source over defined period of time (contemporaneous period). If the sum of the changes (netting) equals or exceeds the significance levels, nonattainment review is required. 20

21 Nonattainment Netting Period of time five years prior to the start of construction of the new project through the start of operation of the new project. All changes to the source during this time period must be considered. If the netting results in an amount greater than or equal to the significance level, nonattainment review is required. 21

22 Nonattainment Applicability Determination Example Area is located in a Nonattainment Area classified as Severe Potential to emit: 30 TPY VOC 35 TPY NOx Area is considered Major for both VOC and NOx. 22

23 Nonattainment Applicability Example Continued Proposed Allowable:»35 TPY VOC»38 TPY NOx Actual Emissions in Severe NA Area:»30 TPY VOC»35 TPY NOx Proposed emission changes: +5 tpy of VOC and +3 tpy of NOx Netting is triggered for VOC but not for NOx (trigger level for serious/sever nonattainment areas is 5 tpy): 23

24 Nonattainment Applicability Example Continued Netting analysis for VOC in Severe NA Area: Define Contemporaneous window: Start of Construction 2016 Start of Operation 2017 Window: Add all emission increases and decreases in the window: Proposed emission change:+ 5 TPY VOC Decrease in 2014: -3TPY Increase in 2012: +7 TPY Contemporaneous Change = = 9 TPY VOC Result: Netted out of NA review: 9 TPY < 25 TPY (Major Modification Net Increase Level) 24

25 What is Needed for Nonattainment Permit Offsets- actual emission reductions depending on the classification of the nonattainment area. LAER-Lowest Achievable Emission Rate Reduction Technology. Perform Alternate Site Analysis (prove the project will outweigh environmental and social costs) 25

26 Nonattainment Offsets Offsets-actual emission reductions. Depends on the classification in the nonattainment area. Multiply the offset ratio by the project emission increases Classification Offset Ratio Marginal 1.10:1 Moderate 1.15:1 Serious 1.20:1 Severe 1.30:1 26

27 LAER Facilities getting a nonattainment permit are required to demonstrate LAER (Lowest Achievable Emission Rate Reduction) No consideration given to cost of controls Must perform a search of the EPA RACT/BACT/LAER Clearinghouse to determine controls used on similar facilities nationwide 27

28 What s Next See if EPA will fully remove the 1997 Ozone (Serious/Severe status) Standard for Texas. Keep on eye on local monitors to make sure areas design average (3 year average )remains attainment, (For Travis County ppb for 2016 would keep it attainment). Follow status of the Federal Bill H.R

29 Question? John Barrientez: