Chapter Introduction. 1.2 Purpose. 1.3 Background. 1.4 Ozone Production and Health Effects. 1.5 Responsibilities of Agencies

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1 Chapter Introduction 1.2 Purpose 1.3 Background 1.4 Ozone Production and Health Effects 1.5 Responsibilities of Agencies

2 1.1 INTRODUCTION On July 18, 1997, the United States Environmental Protection Agency (U.S. EPA) promulgated a revised 8-hour Ozone National Ambient Air Quality Standard (NAAQS) of 0.08 parts per million (ppm). This new standard is more stringent than the previous 1-hour Ozone standard. On April 30, 2004, Imperial County was designated as a Marginal non-attainment area for 8-hour Ozone NAAQS under the federal Clean Air Act (CAA). However, on March 13, 2008, the U.S. EPA found that the Imperial County failed to meet attainment for the 8 - Hour Ozone NAAQS by June 15, 2007, the attainment deadline set forth in the Federal Clean Air Act (FCAA). As a result, Imperial County was reclassified as Moderate non-attainment for the 8-hour Ozone NAAQS. Under a Moderate 8- hour Ozone non-attainment classification, Imperial County is required to develop an 8 Hour Ozone Air Quality Management Plan. The federal CAA requires states to submit an 8-hour Ozone Air Quality Management Plan for non-attainment areas by December 31, Moderate non-attainment Areas are required to attain the standard as expeditiously as practicable, but no later than 6 years after designation or June 15, The Air Quality Management Plan (AQMP) or State Implementation Plan (SIP) is a legal document that achieves several things. An Air Quality Management Plan identifies the difference between an area s existing pollutants concentrations and the goals set by the NAAQS, The AQMP details emissions reductions required to reduce pollutants concentrations to comply with the NAAQS. The 2008 AQMP focuses primarily on the 8-hour Ozone non-attainment problem and how to attain state and federal 8-hour Ozone standards. It is a comprehensive planning document intended to provide guidance to the Air Pollution Control District, the County, and other local agencies on how to attain and maintain the state and federal standards for 8-hour Ozone. The AQMP presents a detailed description of the sources and pollutants which impact the county, future air quality impacts to be expected under current growth trends, and an appropriate control strategy for reducing Ozone precursor emissions, thereby improving air quality. Several of the Ozone control measures proposed in the AQMP will also reduce PM10 emissions. This document is intended to support Californians request that Imperial County, California be re-designated from non-attainment to attainment of the 8-hour Ozone standard. The Imperial County has recorded three (3) years of complete quality assured ambient air quality monitoring data for the years 2004, 2005 and 2006 demonstrating attainment with the 8-hour Ozone NAAQS by year Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for an area to be considered for re-designation including: A determination that the area has attained the 8-hour Ozone standard. An approved Air Quality Management Plan Chapter 1, Page 2 of 12

3 A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the AQMP and other federal requirements. A fully approved maintenance plan A determination that all requirements have been met. This document addresses each of those requirements. It also provides additional information to support continued compliance with the 8-hour Ozone standard. 1.2 PURPOSE Clean air is a valuable and essential resource which affects many aspects of our daily lives. It is vital to our health and welfare, to the local agricultural economy, and to the esthetic beauty and quality of life enjoyed by county residents. The capacity of the air to absorb environmental contaminants is limited, however, and must be managed wisely to avoid significant deterioration of the resource. The 2008 AQMP for Imperial County addresses the attainment and maintenance of state and federal ambient air quality standards. These standards are adopted to protect public health, vegetation, materials and visibility. State and federal standards for Ozone and fine particulate matter (PM10) are currently exceeded within the District, and violation of the standards will continue in future years without adequate planning and air quality management. 1.3 BACKGROUND The U.S. EPA promulgated a new 8-hour Ozone NAAQS in June The new NAAQS is 0.08 parts per million (ppm) averaged over 8 hours. An exceedance of the 8-hour Ozone NAAQS occurs when a monitor measures Ozone above ppm (per the rounding convention). A violation of the NAAQS occurs when the average of the annual fourth highest daily maximum 8-hour Ozone values over three consecutive years is greater than or equal to ppm. This three year average is termed by the design value for the monitor. Since the 1977 amendments to the Clean Air Act (CAA), areas of the country that violated the ambient standard for a particular pollutant were formally designated as nonattainment for that pollutant. This formal designation concept was retained in the 1990 Amendments (CAAA), but additionally, areas designated as non-attainment for the 1-hour Ozone NAAQS were to be classified as to the degree of nonattainment. Five categories were created (section 181 of the 1990 CAAA). In increasing severity, these were marginal, moderate, serious, severe and extreme. The attainment dates for these areas were based upon this classification. The highest monitor design value in a non-attainment area was used to determine its classification. Chapter 1, Page 3 of 12

4 National Ambient Air Quality Standards (NAAQS) for Ozone from a one-hour standard to an 8-hour standard. This was done to reflect the latest understanding of the effects of Ozone exposure and provide public health protection with adequate margin of safety. The U.S. EPA designated areas as attainment (meeting the standard) or non-attainment (not meeting the standard) in April of This designation was based on the most recent three years of monitoring data (i.e., 2004; 2005; 2006). If an area is designated non-attainment, the Clean Air Act (CAA) requires states to revise their AQMP outlining how the area will return to attainment within a certain time period. The U.S. EPA designated Imperial County as a non-attainment area in April of 2004, a revision to the Imperial County SIP is due no later than December 31, Additionally, once an area is designated as non-attainment, the CAA has specific requirements that must be implemented. These requirements affect industry, economic development, and transportation. One requirement, Non-attainment New Source Review sets out the level of emissions reductions required for new and modified industrial facilities. Another requirement of non-attainment areas is to coordinate local transportation and air quality planning to ensure that transportation plans, programs and projects are consistent with air quality goals. According to the CAA, transportation action plans, programs, and projects cannot create new violations of the Federal air quality standards; increase the frequency or severity of existing violations of the standard; or, delay attainment of standards. Table 1 - National Ambient Air Quality Standards (NAAQS) Pollutant Primary Stds. Averaging Times Secondary Stds. Carbon Monoxide 9 ppm (10 mg/m 3 ) 35 ppm (40 mg/m 3 ) 8-hour 1-hour None None Lead 1.5 µg/m 3 Quarterly Average Same as Primary Nitrogen Dioxide Particulate Matter (PM 10 ) Particulate Matter (PM 2.5 ) Ozone Sulfur Oxides ppm (100 µg/m 3 ) Annual (Arithmetic Mean) Same as Primary Revoked Annual(Arith. Mean) Revoked 150 µg/m 3 24-hour Same as Primary 15.0 µg/m 3 Annual(Arith. Mean) Same as Primary 35 µg/m 3 24-hour Same as Primary 0.08 ppm 8-hour Same as Primary 0.12 ppm 1-hour Same as Primary (Applies only in limited areas) 0.03 ppm Annual (Arith. Mean) ppm 24-hour hour 0.5 ppm (1300 µg/m 3 ) Chapter 1, Page 4 of 12

5 1.4 OZONE PRODUCTION AND HEALTH EFFECTS In 1997, EPA revised the NAAQS for Ozone from a one-hour to an eight-hour standard based on scientific data that indicated that the eight-hour standard provides better protection of public health from longer-term exposures to moderate levels of Ozone. To support the eight-hour Ozone standard, the U.S. EPA provided information that indicated that even low levels of Ozone can decrease lung capacity temporarily in some healthy adults and cause inflammation of lung tissue, aggravate asthma, and make people more susceptible to respiratory illnesses such as bronchitis and pneumonia. Children are at a higher risk from exposure to Ozone, since they breathe more air per pound of body weight than adults and because children s respiratory systems are still developing. Children also spend a considerable amount of time outdoors during summer and during the start of the school year (May - September) when the highest Ozone levels are recorded. Adults most at risk to Ozone exposure are outdoor workers, people outside exercising, and individuals with preexisting respiratory diseases. OZONE Ozone is not emitted directly to the atmosphere, but is formed by photochemical reactions between volatile organic compounds (VOCs) and oxides of nitrogen (NO x ) in the presence of sunlight. The long, hot, humid days of summer are particularly contributing to Ozone formation, thus, Ozone levels are of concern primarily during the months of May through September. Ozone is a strong chemical oxidant that adversely impacts human health through effects on respiratory function. Ozone can also damage forests and crops. Ozone is not emitted directly by industrial sources or motor vehicles but instead, is formed in the lower atmosphere, the troposphere. Ozone is formed by a complex series of chemical reactions involving nitrogen oxides (NOx), the result of combustion processes, and reactive organic gases. Organic gases, also termed volatile organic compounds (VOCs), include many industrial solvents, toluene, xylene and hexane as well as the various hydrocarbons that are evaporated from the gasoline used by motor vehicles or emitted through the tailpipe following combustion. Additionally, VOCs are emitted by natural sources such as trees and crops. Ozone formation is promoted by strong sunlight, warm temperatures and light winds. High concentrations tend to be a problem in the Imperial County only during the hot summer months when these conditions frequently occur. Ozone, in relatively low concentrations, can cause such effects as damage to vegetation and cracking of rubber. At higher concentrations Ozone can impact public health by directly affecting the lungs, causing respiratory irritation and changes in lung function. Asthma, bronchitis and other respiratory ailments, as well as cardiovascular disease, are aggravated by exposure to Ozone. When Ozone levels are high, people with respiratory and cardiac difficulties, the elderly, Chapter 1, Page 5 of 12

6 and children are advised to remain indoors. Outdoor exercise by healthy adults is also discouraged since strenuous activity may cause shortness of breath and chest pains. Good Ozone. Ozone occurs naturally in the Earth's upper atmosphere - 6 to 30 miles above the Earth's surface - where it forms a protective layer that shields us from the sun's harmful ultraviolet rays. Manmade chemicals are known to destroy this beneficial Ozone. An area where the protective "Ozone layer" has been significantly depleted-for example, over the North or South Pole is sometimes called "the Ozone hole. The United States, along with over 180 other countries, recognized the threats posed by Ozone depletion and in 1987 adopted a treaty called the Montreal Protocol to phase out the production and use of Ozonedepleting substances. The U.S. EPA has established regulations to phase out Ozone-depleting chemicals in the United States. Bad Ozone. In the Earth's lower atmosphere, near ground level, Ozone is formed when pollutants emitted by cars, power plants, industrial boilers, refineries, chemical plants, and other sources react chemically in the presence of sunlight. Ozone at ground level is a harmful air pollutant. Health Effects. Repeated exposure to Ozone pollution may cause permanent damage to the lungs. Even when Ozone is present in low levels, inhaling it triggers a variety of health problems. Although breathing impairment is the primary and most noticeable health effect, Ozone, can cause chest pains, coughing, nausea, throat irritation, and congestion. It can also worsen bronchitis, heart disease, emphysema, and asthma, and reduce lung capacity. Asthma is a Chapter 1, Page 6 of 12

7 significant and growing threat to children and adults. Ozone can aggravate asthma, causing more asthma attacks, increased use of medication, more medical treatment and more frequent visits to hospital emergency clinics. Although breathing impairment is the primary and most noticeable health effect, symptoms of sore throat, nausea or dizziness, coughing and headaches may occur in healthy individuals exposed to high Ozone concentrations. If exposure to higher concentrations is of limited duration, most people can recover to their previous functioning level. However, recent studies have shown that routine exposure to lower concentrations of Ozone can cause chronic lung damage in children, with permanent reductions in lung capacity of up to 50% measured. Healthy people also experience difficulty in breathing when exposed to Ozone pollution. Because Ozone pollution usually forms in hot weather, anyone who spends time outdoors in the summer may be affected, particularly children, the elderly, outdoor workers and people exercising. Children are most at risk from exposure to Ozone because they are active outside, playing and exercising, during the summertime when Ozone levels are at their highest. Table 1 presents Imperial County s population at risk from Ozone exposure as of 2005 population. *Table 2. Imperial County s population at risk from Ozone exposure GROUPS AT RISK POPULATION Pediatric Asthma: 3,813 Adult Asthma: 8,802 Chronic Bronchitis: 4,064 Emphysema: 1,380 Cardiovascular Disease: 32,041 Diabetes: 6,322 Total Population: 149,232 Population Under 18: 44,809 Population 65 & Over: 15,407 *table 2 information provided by American Lung Association. Environmental Effects. Ground-level Ozone damages plant life and is responsible for and estimated 500 million dollars in reduced crop production in the United States each year. Ozone interferes with the ability of plants to produce and store food, making more susceptible to disease, insects, other pollutants, and harsh weather. It damages the foliage of trees and other plants, ruining the landscapes of cities, parks and forests, and recreation areas. One of the key components of Ozone, nitrogen oxides, contributes to fish kills and algae blooms in sensitive waterways. Ozone is also considered a serious threat to California agriculture and native Chapter 1, Page 7 of 12

8 vegetation due to its pervasive nature. Many sensitive plant species are known to suffer damage at concentrations below human health standards. Ozone interferes with photosynthesis by attacking leaves, causing them to yellow, develop dead areas and drop early. Ozone stunts growth in many crop varieties, reduces yields, or causes esthetic damage which lowers market value. Many of the crops grown within this county are particularly sensitive to Ozone injury, including orchard crops, lettuce and several grape varieties. 1.5 RESPONSIBILITIES OF AGENCIES Numerous agencies with direct and indirect interest in air quality participate in the planning process. United States Environmental Protection Agency (U.S. EPA) The U.S. EPA administers the federal Clean Air Act and other air quality related legislation. As a regulatory agency, U.S. EPA's principal functions include setting federal ambient air quality standards; preparing guidance for and approval of AQMP to meet and/or maintain those ambient air quality standards; establishing national emission limits for major sources of air pollution; inspecting and monitoring emission sources, enforcing federal air quality laws, and promulgating new regulations; and, providing financial and technical support for air quality research and development programs. The U.S. EPA says that 146 million Americans now live in counties where monitored air in 2002 was unhealthy because of high levels of principal air pollutants; that overall more than 160 million tons per year of emissions of criteria air pollutants were emitted into the air by cars, trucks, industrial facilities and utilities, small businesses and other sources; and that 124 metropolitan areas are still considered "non-attainment" for one of the six pollutants targeted by the federal Clean Air Act. Since the federal Clean Air Act amendments in 1990 designation process came in effect, 230 metropolitan are not meeting clean air standards and there has been a vast majority of improvement of the amount of emissions of criteria pollutants compared to The federal Clean Air Act requires U.S. EPA to approve state implementation plans. The California SIP is comprised of plans developed at the regional or local level. Each of these plans is individually reviewed and approved by U.S. EPA prior to incorporation into the AQMP. Federal Clean Air Act Amendment Anticipated economic impacts were a primary component in the debate over the 1990 Clean Air Act Amendments and in the recent debate over the strengthening of the Ozone and particulate matter standards. Still, the federal Clean Air Act and new federal and state regulations are creating new markets for alternative fuels, pollution control equipment, and new services. Supporters believe that the Chapter 1, Page 8 of 12

9 economic value of the act's public-health benefits -- measured in fewer sick days, hospitalizations, and deaths more than offset initial economic costs The U.S. EPA makes National area designations for five criteria pollutants: Ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, and PM10. The U.S. EPA established a new eight-hour Ozone standard in July 1997 to replace the one-hour Ozone standard. Federal law required states to submit recommendations on initial proposed area designations as to "attainment," "nonattainment," and "unclassifiable" to U.S. EPA. U.S. EPA is required to do the following: 1. The U.S. EPA will provide technical assistance to the state and local area in the development of the early action plan. 2. The U.S. EPA will move quickly to review and approve completed plans after submission of the AQMP revision by the state. 3. Provided that the monitors in the area reflect attainment by December 31, 2010, the U.S. EPA will move expeditiously to designate the area as attainment and impose no additional requirements. 4. If the area violates the standard as of December 31, 2010, and the area has had the effective date of its nonattainment designation deferred, the area will be designated nonattainment. The U.S.EPA will take action to withdraw the deferred effective date, and the area s nonattainment designation will become effective. The CAA Amendments also established local air quality planning processes, requiring separate plans for each local area that had not attained the standards. These plans, called non-attainment plans (NAP), were to be prepared by local agencies designated by the governor of each state and incorporated into the AQMP. The U.S.EPA was given power to impose sanctions for failure to submit a plan or carry out commitments in a plan. Sanctions could be a ban on construction of major new facilities and the withholding of federal highway, sewage treatment, and air planning funds. California Air Resources Board (CARB) The California Air Resources Board (CARB) is the state agency responsible for the coordination and administration of both state and federal air pollution control programs in California. The ARB undertakes research, sets state ambient air quality standards, provides technical assistance to local districts, compiles emission inventories, develops suggested control measures, and provides oversight of district control programs. A key function of the CARB is to coordinate and guide regional and local air quality planning efforts required by the California Clean Air Act, and to prepare and submit the AQMP to EPA. CARB also establishes emission standards for Chapter 1, Page 9 of 12

10 motor vehicles. The federal Clean Air Act allows California to adopt more stringent vehicle emission standards than the rest of the nation due to California s severe air pollution problem. California Clean Air Act The California Clean Air Act (CCAA), signed into law in September of 1988, is the most comprehensive state air quality legislation to be enacted in more than a decade. The CCAA requires all areas of the state to achieve and maintain the California ambient air quality standards by the earliest practicable date. These standards are generally more stringent than the federal standards; for example, the state 8-hour Ozone standard is 0.07 ppm compared to the 0.08 ppm 8-hour federal Ozone standard. Thus, emission controls to comply with the state law are more stringent than those necessary for attainment of the federal standard. CARB has formally designated all air pollution control districts as attainment or non-attainment for each state air quality standard State. Non-attainment designations are to be further categorized into 3 levels of severity: moderate (can demonstrate attainment by 1994); serious (can demonstrate attainment by 1997); and severe (cannot demonstrate attainment until sometime after 1997). For districts identified as receptors of transported pollutants from other areas, like Imperial County, these definitions are based on violations which would still occur without the transport contribution. Areas designated non-attainment for the state Ozone; carbon monoxide, sulfur dioxide, or nitrogen dioxide standards must prepare and submit an attainment plan to CARB by December 31, Areas designated non-attainment for PM10, sulfates, lead, hydrogen sulfide, or visibility are not expressly required to develop attainment plans for those pollutants. However, the CCAA requires attainment of all state standards by the earliest practicable date. Thus all reasonable actions possible should be taken to meet those pollutant standards not specifically addressed in the attainment plans. Under the CCAA, CARB and districts share primary responsibility for improving air quality. Regulatory agencies are to pursue new and better controls of pollution sources in their respective jurisdictions. The extent of the planning effort depends on the severity of the air pollution problem within each basin. Under the new classification, Imperial County falls within the moderate non-attainment category for 8-hour Ozone, and is required to implement the following: 1. A permitting program designed to achieve no net increase in emissions of non-attainment pollutants or their precursors from new or modified stationary sources which emit or have the potential to emit 25 tons per year or more of non-attainment pollutants or their precursors (Health & Safety Code (a) (1)). 2. Reasonably available control technology for all existing sources (H&SC (a) (2)). Chapter 1, Page 10 of 12

11 3. Reasonably available transportation control measures (H&SC (a) (3)). 4. Provisions to develop area source and indirect source control programs (H&SC (a) (4)). 5. Provisions to develop and maintain an emissions inventory system to enable analysis and progress reporting and a commitment to develop other analytical techniques to carry out its responsibilities pursuant to Health & Safety Code Section subdivision (b). 6. Provisions for public education programs to promote actions to reduce emissions from transportation and area wide sources (H&SC (a) (6)). Imperial County Air Pollution Control District (District) The Imperial County Air Pollution Control District shares responsibility with CARB for ensuring that all state and federal ambient air quality standards are achieved and maintained within the County. State law assigns to local districts the primary responsibility for control of air pollution from stationary sources, while reserving an oversight role for CARB. Generally, the Districts must meet minimum state and U.S. EPA program requirements. The District is also responsible for the inspection of stationary sources, monitoring of ambient air quality, and planning activities such as modeling and maintenance of the emission inventory. Districts in state non-attainment areas are also responsible for developing and implementing transportation control measures necessary to achieve the state ambient air quality. In regards to the SIP, the District will implement the following activities: 1. Development of emission inventories, modeling process, trend analysis and quantification and comparison of emission reduction strategies; 2. Necessary information on all Federal and State adopted emission reduction measures which affect the area; 3. Review of emissions inventory, modeling, and self-evaluation work; 4. Technical and strategic assistance, as appropriate, in the selection and implementation of emission reduction strategies; 5. Technical and planning assistance in developing and implementing processes to address the impact of emissions growth beyond the attainment date; 6. Maintenance of monitors and reporting and analysis of monitoring data; 7. Support for public education efforts by proving information to the community for means of outreach; 8. Coordinate communication between local areas and U.S. EPA to facilitate continuing U.S. EPA review of local work; 9. Expeditious review of the locally developed plan, and if deemed adequate, propose modification of the AQMP to adopt the early action plan; Chapter 1, Page 11 of 12

12 10. Adoption of emission reduction strategies into the AQMP as expeditiously as possible. Chapter 1, Page 12 of 12