Proposed Repeal of Volatile Organic Compounds (VOC) Regulations for Pulaski County

Transcription

1 Proposed Repeal of Volatile Organic Compounds (VOC) Regulations for Pulaski County

2 Overview History of the Pulaski County VOC Regulations Pulaski County Air Quality Monitoring Trends Air Quality Modeling Pulaski County Emissions Inventory Emissions Controlled by Other Programs 2

3 Pulaski County VOC Regulations HISTORY

4 April 1971 January 1979 September 1984 One-hour ozone standard of 0.08 ppm set One-hour ozone standard revised to 0.12 ppm Pulaski County redesignated to attainment Pulaski County designated nonattainment March 1978 Pulaski County VOC Regulations Adopted March 1979, revised December 1979, September 1980, and April

5 VOC Control Strategy Although laboratory studies have shown that ozone is created by reactions involving volatile organic compounds and nitrogen oxides in the presence of sunlight, there has been no practical demonstration that a relatively low ambient standard can be achieved through reduction of only volatile organic compounds. -Arkansas Department of Pollution Control and Ecology (1979). Revision of the Arkansas Plan of Implementation for Air Pollution Control to attain the 0.12 ppm National Ambient Air Quality Standard for Ozone Control measures adopted based on EPA guidance published prior to January 1978 Measures intended to achieve a 20% reduction in anthropogenic VOC emissions Measures included Reasonably available control technology (RACT) for point and area sources Lowest Achievable emission rate for proposed new sources with a potential to emit 100 tons/year of VOCs 5

6 Provisions for Specific Processes Gasoline Storage and Marketing (revised December 1979) Petroleum Liquid Storage Cutback Asphalt Surface Coating of Metal Parts and Products (added in1980) External Floating Roof (Added in 1981) 6

7 VOC Regulations of Pulaski County moved to Regulation No. 19 Previously, various state implementation plan regulations were consolidated into Regulation No. 19 VOC Regulations of Pulaski County currently located in Regulation No. 19 Chapter 10 Reg Title Reg Purpose Reg Definitions Reg General Provisions Reg Provisions for Specific Processes Reg Severability 7

8 Pulaski County MONITORING TRENDS

9 Tightening Ozone Standards Pulaski County was redesignated to attainment in 1984 based on monitor data and has remained in attainment despite repeated tightening of the ozone national ambient air quality standard (NAAQS). 1979: 0.12 ppm 1-hour standard 1997: 0.08 ppm 8-hour standard 2008: ppm 8-hour standard 2015: 0.07 ppm 8-hour standard 9

10 Number of Days with Exceedances Pulaski County Monitored Daily One- Hour Exceedances of 0.12 ppm Monitor ID Attainment is defined when the expected number of days per calendar year, with maximum hourly average concentration greater than 0.12 ppm, is equal to or less than 1 10

11 ppm Pulaski County Monitored Fourth Highest Daily Maximum Eight-Hour Monitor ID Attainment is based on a design value equal to or less than the standard. The design value is the annual fourth-highest daily maximum 8 hour average concentration, averaged over 3 years 11

12 EPA OAQPS Ozone Sensitivity AIR QUALITY MODELING

13 2017 EPA Ozone Advance Supplemental Guidance Describes EPA national modeling analysis Evaluates ozone sensitivity to nitrogen oxides (NOx) and VOC emissions Projects future ozone design values 13

14 Ozone Sensitivity Effectiveness of NOx versus VOC control strategies depends on ambient mixture of NOx and VOCs In areas where the emission inventory is dominated by biogenic VOC emissions, studies suggest anthropogenic VOC reductions may not be effective Sensitivity test cases for peak 8-hour maximum ozone for the month of July % across-the-board reduction in anthropogenic VOC emissions 50% across-the-board reduction in anthropogenic NOx emissions 14

15 Change in the CMAQ-estimated monthly maximum peak 8-hour maximum ozone (MDA8 O3) values (July 2011) resulting from an across-the-board 50% reduction in anthropogenic VOC emissions nationwide. 15

16 16 Change in the CMAQ-estimated monthly maximum MDA8 (O3) values (July 2011) resulting from an across-the-board 50% reduction in anthropogenic NOx emissions nationwide.

17 The ratio of the change in monthly peak MDA8 O3 from the 50% reduction in NOx to the change in monthly peak MDA8 O3 from a 50% reduction in VOC.

18 General Conclusions Ozone sensitivity to emission reductions of NOx vs VOC Outside urban areas: impacts of NOx cuts more than 10x higher than impacts of VOC cuts In most cities: impacts of NOx cuts times larger than impacts of VOC cuts Limited areas of urban Los Angeles, Seattle, San Francisco, Miami, Cleveland, and New York: VOC cuts more impactful than NOx cuts Guidance suggests focusing Ozone reduction efforts in most areas on NOx emission reductions 18

19 Pulaski County EMISSION INVENTORY

20 Pulaski County 2014 VOC Emission Inventory 5% 4% 6% 2% 3% 7% 12% Biogenics - Vegetation and Soil Mobile - On-Road non- Diesel Light Duty Vehicles Solvent - Consumer & Commercial Solvent Use Mobile - Non-Road Equipment - Gasoline Solvent - Graphic Arts 61% Fires - Prescribed Fires Gas Stations Other 20

21 Emissions for Specific Processes Governed by VOC Regulations Emissions reported by source classification code (SCC) Approximately 1587 tons of VOCs emitted in 2014 from SCC codes that may be associated with Pulaski County VOC regulations for specific processes 4% of total Pulaski County VOC inventory Includes other processes associated with each code beyond processes regulated by Pulaski County VOC regulations 21

22 Pulaski County 2014 NOx Emission Inventory 8% 4% 2% 2% 10% 12% Mobile - On-Road Diesel Heavy Duty Vehicles Mobile - On-Road non-diesel Light Duty Vehicles Mobile - Locomotives 37% Mobile - Non-Road Equipment - Diesel Mobile - Aircraft Fuel Comb - Industrial Boilers, ICEs - Biomass Fuel Comb - Residential - Natural Gas Other 25% 22

23 Tons ppm VOC and NOx Emissions 23 vs Ozone 8-Hour Design Value 40,000 35,000 30,000 25,000 20,000 15,000 10,000 5, NOx Emissions (tons) 20,074 18,337 18,737 17,999 14,451 VOC Emissions (tons) 23,471 21,712 36,401 37,895 36,411 Ozone Design Value (ppm)

24 Pulaski County VOC Regulations EMISSIONS CONTROLLED BY OTHER PROGRAMS

25 New Source Review Reg Governs new source review for major new source review and sources subject to Reg sourcespecific provisions. Other ADEQ permitting programs for attainment of the NAAQS Nonattainment new source review program (Regulation No. 31 provisions to be retained with revisions in streamlined regulation) ADEQ Title V and minor new source review programs 25

26 Gasoline Storage and Marketing Reg (A) Implements VOC control and reporting requirements for gasoline storage and marketing based on pre-1978 control technique guidelines Also regulated by National Emission Standards for Hazardous Air Pollutants (NESHAPs): 40 CFR 63 Subpart CCCCCC, last amended in CFR 63 Subpart BBBBBB, last amended CFR 63 Subpart R, last amended

27 Petroleum Liquid Storage Reg (B) Implements control technique guidelines prior to 1978 Also regulated by standards of performance for new and existing sources of VOCs at petroleum storage facilities 40 CFR 60 Subpart K, promulgated in CFR 60 Subpart Ka, promulgated in CFR 60 Subpart Kb, promulgated in

28 Cutback Asphalt Reg (C) Restricts application of cutback asphalt based on temperature Restriction has created a conflict with requirements by Arkansas Department of Transportation VOC emissions from asphalt application represent less than one percent of the Pulaski County VOC emission inventory (2 tons per year in 2014) 28

29 Gasoline Tank Trucks and Vapor Collection Systems Reg (D) Implements control technique guidelines for VOC leaks from gasoline tank trucks and vapor collection systems from pre-1978 control technique guidelines Also regulated by NESHAPs: 40 CFR 63 Subpart CCCCCC, last amended in CFR 63 Subpart BBBBBB, last amended in CFR 63 Subpart R, last amended in

30 Surface Coating of Metal Parts and Products Reg (E) Implements control technique guidelines for VOCs for metal surface coating operations Also regulated by NESHAPs 40 CFR 63 Subpart KKKK, promulgated in CFR 63 Subpart SSSS, last amended in CFR 63 Subpart XXXXXX, promulgated in CFR 63 Subpart RRRR, promulgated in 2003 Also regulated by NSPS 40 CFR 60 Subpart TT, last amended in CFR 60 Subpart EE, last amended in

31 External Floating Roof Reg (F) Implements pre-1978 VOC control technique guidelines from petroleum liquid storage in external floating roof tanks Also regulated by standards of performance for new and existing sources of VOCs at petroleum storage facilities 40 CFR 60 Subpart K, promulgated in CFR 60 Subpart Ka, promulgated in CFR 60 Subpart Kb, promulgated in

32 Other Control Programs At least 148 federal rules promulgated subsequent to the adoption of the Pulaski County VOC regulations that have established control requirements that reduce VOC and/or NOx emissions. Examples: NESHAPs NSPS Acid Rain Program Interstate Transport Trading Programs 32

33 Questions? ADEQ has posted a draft technical support document (TSD) to solicit feedback on the weight of evidence supporting repeal of the Pulaski County VOC Regulations: 33