Houston Ozone Past, Present, and Future?

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1 Houston Ozone Past, Present, and Future? AWMA-GCC Annual Conference March 1st, 2018

2 Ozone Past, Present, and Future? Items for today s discussion: 2015 Ozone Standard 2008 Ozone Standard Both standards are 8-Hour Ozone Standards 2

3 Ozone Past, Present, and Future? What is an 8-Hour Ozone Standard? It s the 3-year average, of the annual 4 th highest daily maximum 8-hour concentration, measured at each monitoring site 3

4 Ozone Past, Present, and Future? Monitoring Site, What Monitoring Site? Many areas of the country have ambient air monitors that look for ozone. Most areas have multiple monitors. To show compliance with the standard, the 3-year average of the annual 4 th highest daily maximum 8-hour concentration must be equal to or less than the standard at each monitor. 4

5 Ozone Past, Present, and Future? What happens if an area does not meet the standard? The area is designated a nonattainment area State Implementation Plan ( SIP ) rules are developed to get the area back into compliance (attainment) with the standard New Major Sources, and Major Modifications of Existing Major Sources, must apply: Lowest Achievable Emission Rate ( LAER ) controls, and Offsets for a projects emission increase 5

6 Ozone Past, Present, and Future? Background Information: Existing Ozone Standards 2008 Standard Set at 75 ppb 2015 Standard Set at 70 ppb 6

7 2015 Ozone Standard 7

8 2015 Ozone Standard Timeline: October 1, 2015: EPA reduced the ozone NAAQS from 75 ppb (2008 standard) to 70 ppb (2015 standard). October 1, 2016: States submitted their recommendations for proposed ozone designations to the EPA, based on data. June 28, 2017: EPA published notice extending the deadline for promulgating designations under the 2015 ozone standard. 8

9 2015 Ozone Standard August 10, 2017: After being sued by a coalition of 15 states and the District of Columbia, EPA withdraws the extension for promulgating designations under the 2015 ozone standard. October 1, 2017: EPA date to finalize designations submitted by the states, based on data. October 2, 2017: EPA misses the deadline to promulgate designations under the 2015 ozone standard. 9

10 2015 Ozone Standard October 3, 2017: EARTHJUSTICE files a Notice of Intent to Sue for EPA s failure to designate under the 2015 ozone standard. November 16, 2017: EPA publishes a Final Rule (Round 1) designating attainment and unclassifiable areas under the 2015 ozone standard. January 5, 2018: EPA publishes a Notice of Availability and Public Comment document, which contains EPA s responses to State Designation Recommendations for the 2015 Ozone Standard. 10

11 2015 Ozone Standard Future Date: In the January 5 th, 2018 publication, the EPA indicated that they intend to make final designation determinations no earlier than 120 days from the date of notification of intended designations for a particular state (approximately April 2018 for Texas). 11

12 2015 Ozone Standard 2015 Ozone Standard Classification Ranges Classification Marginal Moderate Serious Severe - 15 Severe - 17 Extreme Concentration Range 71 ppb to 81 ppb* 81 ppb to 93 ppb* 93 ppb to 105 ppb* 105 ppb to 111 ppb* 111 ppb to 163 ppb* 163 ppb * But not Including: Example 71 ppb up to but not including 81 ppb 12

13 Texas Existing and Proposed Ozone Nonattainment Areas 13

14 Existing 2008 Ozone Standard Texas Existing 2008 Ozone Standard Nonattainment Areas (Both areas are classified as Moderate nonattainment): Dallas-Fort Worth ( DFW ) Collin, Callas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant and Wise counties Houston-Galveston-Brazoria ( HGB ) Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller counties 14

15 Existing 2008 Ozone Standard Existing 8-Hour Nonattainment Area(s) 2008 Ozone Standard (75 ppb) 15

16 2015 Ozone Standard Proposed 2015 Ozone Standard Nonattainment Areas In addition to the existing DFW and HGB Nonattainment Areas New Counties Include: Hood County Bexar County El Paso County (with exception of tribal lands*) * Ysleta Del Sur Reservation or Trust Lands 16

17 2015 Proposed (Using Data) Existing 8-Hour Nonattainment Area(s) 2008 Ozone Standard (75 ppb) Proposed 8-Hour Nonattainment Area(s) 2015 Ozone Standard (70 ppb) In addition to existing 2008 area Includes New Counties Hood, Bexar, El Paso 17

2015 EPA Intended (Using 2014 2016 Data) Existing 8-Hour Nonattainment Area(s) 2008 Ozone Standard (75 ppb) EPA Intended 8-Hour

18 2015 EPA Intended (Using Data) Existing 8-Hour Nonattainment Area(s) 2008 Ozone Standard (75 ppb) EPA Intended 8-Hour Nonattainment Area(s) 2015 Ozone Standard (70 ppb) Includes Existing 2008 areas Does Not Include Hood, Bexar, and El Paso Counties 18

19 2015 Ozone Standard Nonattainment NSR Levels and Requirements For Marginal and Moderate Ozone Classifications Note: Major Source, Netting Trigger Levels, Major Modifications, and Offset Ratios start becoming much more stringent for Severe nonattainment classifications and above. 19

20 2015 Ozone Standard Where Do We Stand? In Texas, the data preliminarily shows: DFW 80 ppb (Marginal) HGB 79 ppb (Marginal) It is believed by some at the TCEQ, even if some of the monitored values are corrected upward, they will likely be no greater than Moderate 20

21 2008 Ozone Standard 21

22 2008 Ozone Standard Current Status: 2008 Ozone Standard Texas: DFW Moderate Nonattainment HGB Moderate Nonattainment 22

23 2008 Ozone Standard Moderate Classifications Attainment Date: July 2018 If a Moderate nonattainment area fails to attain the standard, is there an extension possibility? YES 23

24 2008 Ozone Standard One (1) year extension if: The area s 4 th highest daily maximum 8-Hour average is at, or below the level of the standard (75 ppb) during the year preceding the extension year. In this case, the extension year would be 2018, the preceding year for comparison is

25 2008 Ozone Standard So, Where Do We Stand? DFW Currently Not Attaining Not expected to be eligible for an extension 2017 already shows concentrations above the standard (75 ppb) HGB Currently Not Attaining Not expected to be eligible for an extension 2017 already shows concentrations above the standard (75 ppb) 25

26 2008 Ozone Standard Extension Example HGB Bump-Up 26

27 2008 Ozone Standard 27

28 2008 Ozone Standard The BIG Question? What s going to happen with the 2008 ozone standard? Will it be revoked and replaced by the 2015 ozone standard? 28

29 2008 Ozone Standard There are three (3) generally accepted paths of possibility: 1) The 2008 Standard is revoked in its entirety 2) The 2008 Standard is revoked, but the NSR provisions are left in place (this is what EPA did with the 1997 ozone standard) 3) The 2008 Standard remains in effect 29

30 In Summary 30

31 Questions? 31

SIP Challenges in Houston-Galveston-Brazoria. Chief Engineer s Office, Air Quality Division

SIP Challenges in Houston-Galveston-Brazoria. Chief Engineer s Office, Air Quality Division SIP Challenges in 2008 Houston-Galveston-Brazoria Chief Engineer s Office, Air Quality Division Susana M. Hildebrand, Air Quality P.E., Division Director HGB SIP Challenges in 2008 February 12, 2008 Page