Eight-Hour Ozone SIP Development Issues in DFW Air Quality Planning Section

Eight-Hour Ozone SIP Development Issues in DFW Air Quality Planning Section 9 Pages March 18, 2005 Erik Gribbin Air Quality Planning and Implementation Division

Texas Nonattainment Areas AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 2 of 9

Eight-Hour Ozone SIP Development Issues in DFW Modeling Steps Control Strategy Development Complicating Factors Summary AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 3 of 9

Modeling Steps Supplementary Modeling Analysis (2 m) Work order development Run base case meteorology Finalize Base Case EI Run base case and analyze Future Case Emissions Inventory (up to 9 m) Contract Development Future Base Case for Core and Supplementary Episodes In-house preparation AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 4 of 9

Modeling Steps (contd.) Future Case Development ( up to 7 m) Consolidate future base case modifications for core and supplementary episodes (if supplementary episodes performs well) APCA (Source Apportionment) Analysis Needed Reductions Control Strategy Analysis (up to 2 m) Depends on outcomes of control strategy development Documentation and Technical Review (11 m or more) Regular updates for stakeholders AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 5 of 9

Control Strategy Development Control Strategy Catalog Development (3 m) Identifying possible strategies Quantifying possible strategies Look at available modeling and emissions inventories Planning stakeholder meetings this summer Focused Control Strategy Development (3 m or more) Eliminate non-feasible strategies Develop a foundation for RACM analysis Update quantification of possible strategies based on latest modeling and EI Stakeholder communications Prepare staff recommendations AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 6 of 9

Control Strategy Development (contd.) Rule writing (4 m or more) Prepare and review rule language for proposal Stakeholder communications Documentation and Review (11 m or more) AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 7 of 9

Complicating Factors Unknown consequences of Phase II implementation rules Implications of CAIR Rules recently adopted (additional SIP due in Oct. 2006) Unresolved attainment year (2009 vs. 2010) Other workload (8-hour ROP SIPs, other 8-hour SIPs, Regional Haze, Mercury Rules, ) Availability of control measures AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 8 of 9

Summary TCEQ is moving forward with future case modeling TCEQ is moving forward with control strategy development Complicating issues preclude a well defined time table this week AQP&I Division Eight-Hour Ozone SIP Development Issues in DFW; (ENG), : March 18, 2005 Page 9 of 9

DFW Modeling Update North Texas Clean Air Steering Committee Meeting March 18, 2005 Brian Foster TCEQ March 18, 2005

Background Modeling Update September 17, 2004 Environ contracted to do DFW modeling Phase I Modeling: Episode selected was August 13-22, 1999 1999 base case was developed and evaluated 2007 future case was developed and evaluated Problems with the performance evaluation regarding meteorology TCEQ March 18, 2005

Background (cont.) Phase II Modeling: Base case, meteorology, and emissions inventory upgrades Increased surface roughness Added radar profiler data Updated out-of-state point source emissions Modified to include seven day week and VMT adjustments Resulted in slightly improved performance evaluation TCEQ March 18, 2005

Phase III Modeling - New Environ has done the following tests: Extend model top to 14 km Extend eastern modeling boundary Used different vertical mixing package (ETA) Evaluate CB4 chemistry with NOx recycling Composite modeling runs are completed Results show improved model performance TCEQ March 18, 2005

Tuesday, August 17, 1999 Modeled Real Wind TCEQ March 18, 2005

Tuesday, August 17, 1999 TCEQ March 18, 2005

Frisco and Denton Ozone Frisco Ozone Concentrations Parts/Billion 160 140 120 100 80 60 40 20 0 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 Aug13 Aug14 Aug15 Aug16 Aug17 Aug18 Aug19 Aug20 Aug21 Aug22 Run17b0_kv3 Run34 Observed Denton Airport Ozone Concentrations Parts/Billion 180 160 140 120 100 80 60 40 20 0 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 Aug13 Aug14 Aug15 Aug16 Aug17 Aug18 Aug19 Aug20 Aug21 Aug22 Run17b0_kv3 Run34 Observed TCEQ March 18, 2005

Friday, August 20, 1999 Real Wind Modeled Wind TCEQ March 18, 2005

Friday, August 20, 1999 TCEQ March 18, 2005

Midlothian and Redbird Ozone Redbird Ozone Concentrations Parts/Billion 160 140 120 100 80 60 40 20 0 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 Aug13 Aug14 Aug15 Aug16 Aug17 Aug18 Aug19 Aug20 Aug21 Aug22 Run17b0_kv3 Run34 Observed Midlothian Tower Ozone Concentrations Parts/Billion 160 140 120 100 80 60 40 20 0 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 0 6 12 18 Aug13 Aug14 Aug15 Aug16 Aug17 Aug18 Aug19 Aug20 Aug21 Aug22 Run17b0_kv3 Run34 Observed TCEQ March 18, 2005

DFW Model Performance Improvement DFW 1-Hour Ozone Modeling Performance Improvement August August 13-22, 13-22, 1999 Ozone Episode Episode 45 30 Gross Error (%) 15 0-45 -30-15 0 15 30 45 Bias (%) Run 1a EPA Standard TCEQ March 18, 2005

DFW Model Performance Improvement DFW 1-Hour Ozone Modeling Performance Improvement August August 13-22, 13-22, 1999 1999 Ozone Episode Episode 45 30 Gross Error (%) 15 0-45 -30-15 0 15 30 45 Bias (%) Run 1a Run 7c EPA Standard TCEQ March 18, 2005

Current Modeling Status TCEQ has met with EPA to discuss modeling performance There is agreement that episode is representative and that it should be retained EPA recently released 8-hour ozone draft final modeling guidance TCEQ March 18, 2005

Current Modeling Status (cont.) EPA would like to see more days in the performance evaluation TCEQ agreed to evaluate whether other episodes might be useful to corroborate current results (Oklahoma 12k modeling in DFW) EPA would like to see an early 8-hour ozone SIP Other technical details are being discussed Baseline year Future year TCEQ March 18, 2005

Conclusion Phase III sensitivity tests complete under HARC contract Draft report is being reviewed Preliminary results show improvement in several areas Composite runs are complete Good performance Process analysis underway TCEQ Plan to activate TCEQ umbrella contract to assure DFW SIP issues are addressed March 18, 2005

Contributors TCEQ Modeling Staff Pete Breitenbach ENVIRON Modeling Staff Thuyen Dinh Michele Jimenez Gerard Mansell Greg Yarwood TCEQ March 18, 2005

TCEQ March 18, 2005

Clean Air Interstate Rule CAIR

CAIR Overview Over 450 counties in the Eastern United States do not meet new health-based standards for 8-hour ozone and PM 2.5. CAIR reduces interstate transport of precursors for ozone (NO x ) and PM 2.5 (NO x and SO 2 ) pollution. CAIR reductions are accomplished by: Ozone Season NO x Cap (May-September) Annual NO x and SO 2 Caps EPA considers control of electric generating units (EGUs) to be highly-cost effective approach for all solutions. CAIR is promulgated based on state obligations to address interstate transport of pollutants under Clean Air Act, Section 110(a)(2)(D).

National CAIR Overview

CAIR Inclusion Determinations 8-hr Ozone States were included if the EPA model indicated a significant impact (>2ppb) on another state s 8-hr ozone nonattainment in 2010. 6 states on the western border of the CAIR region were not modeled by EPA for 8-hr ozone impact on other states. KS, ND, NE, OK, SD, TX PM 2.5 States were included if the EPA model indicated a significant impact (>0.2μg/m 3 ) on another state s PM 2.5 nonattainment in 2010.

CAIR Reductions (provided in millions of tons) First Phase (2009 for NO x and 2010 for SO 2 ) Base Case Emissions CAIR Caps Emissions After CAIR Reductions SO 2 Annual 8.7 3.6 5.1 3.5 NO x Annual 2.7 1.5 1.5 1.2 NO x Ozone Season (May-Sept) 0.7 0.6 0.6 0.1 Second Phase (2015) SO 2 Annual 7.9 2.5 4.0 3.8 NO x Annual 2.8 1.3 1.3 1.5 NO x Ozone Season (May-Sept) 0.7 0.5 0.5 0.2

Region 6 Impacts 8-hr Ozone Transport Arkansas significantly contributes to Texas nonattainment in Galveston, Harris, and Jefferson counties. Louisiana significantly contributes to Texas nonattainment in Galveston, Harris, and Jefferson counties. PM 2.5 Transport Louisiana significantly contributes to Alabama nonattainment in Jefferson and Russell counties. Texas significantly contributes to Illinois nonattainment in Madison and St. Clair counties.

Region 6 Benefits CAIR will assist Arkansas sources in reducing NO x emissions during the ozone season by 67% by 2015. CAIR will assist Louisiana sources in reducing NO x emissions by 57% and SO 2 emissions by 41% by 2015. CAIR will assist Texas sources in reducing NO x emissions by 25% and SO 2 emissions by 39% by 2015.

Region 6 Attainment without CAIR Existing Clean Air Act Programs will bring these counties into attainment by 2010: Crittenden County, AR Ascension Parish, LA East Baton Rouge Parish, LA Iberville Parish, LA Livingston Parish, LA West Baton Rouge Parish, LA Bexar County, TX Comal County, TX Guadalupe County, TX Existing Clean Air Act Programs will bring these counties into attainment by 2015: Collin County, TX Dallas County, TX Denton County, TX Ellis County, TX Johnson County, TX Kaufman County, TX Parker County, TX Rockwall County, TX Tarrant County, TX

Region 6 Attainment with CAIR CAIR and existing Clean Air Act Programs will bring the following counties into attainment by 2015: Hardin County, TX Jefferson County, TX Orange County, TX CAIR and existing Clean Air Act Programs will help reduce ozone precursor pollution in the following counties: Brazoria County, TX Chambers County, TX Fort Bend County, TX Galveston County, TX Harris County, TX Liberty County, TX Montgomery County, TX Waller County, TX

Region 6 State CAIR Budgets Seasonal NO x Cap (tons) State 2009 Budget 2015 Budget AR 11,515 9,596 LA 17,085 14,238 Annual NO x Cap (tons) State 2009 Budget 2015 Budget LA 35,512 29,593 Ozone Only Particles Only Ozone and Particles Not Subject to CAIR TX 181,014 150,845 Annual SO 2 Cap (tons) State 2010 Budget 2015 Budget LA 59,948 41,963 TX 320,946 224,662 State budgets do not include estimates of banked emissions

Ozone Season NO x Budget Ozone Season is May through September CAIR Ozone Season NO x Budget is designed to take the place of NO x SIP Call Region 6 was not subject to NO x SIP Call Options for meeting Ozone Season NO x Budget : 1. States can elect to participate in an EPA-managed cap and trade program 2. Use Ozone Season NO x Budget to design a cap and trade program, or other state program, subject to EPA approval EGUs must be capped if State chooses to meet budget by controlling them States can choose to control non-egus or combination of EGUs and non-egus

Annual NO x and SO 2 Budgets Only for states affected by PM 2.5 finding (LA and TX) Options for meeting annual NO x and SO 2 budget: 1. States can elect to participate in an EPA-managed cap and trade program Control only EGUs 2. Use annual NO x or SO 2 Budget to design a cap and trade program, or other state program, subject to EPA approval EGUs must be capped if State chooses to meet budget by controlling them States can choose to control non-egus or combination of EGUs and non-egus Additional annual NO x allocations are provided by EPA through the Compliance Supplement Pool (CSP).

Compliance Supplement Pool The CSP provides 200,000 tons of NO x that may be used for compliance with annual NOx requirements. EPA apportions the CSP based on the assumption that a State s need for allowances from the pool is proportional to the magnitude of the State s required emission reductions for 2009. State State NO x Compliance Supplement Pools (tons) Base Case 2009 Emissions 2009 State Annual NO x Budget Reduction Requirement Compliance Supplement Pool LA 49,460 35,512 13,948 2,251 TX 185,798 181,014 4,784 772

SIP Submittal Timeline September 10, 2006 CAIR SIPs are due AR submits SIP for 8-hr ozone transport LA submits SIP for 8-hr ozone and PM 2.5 transport TX submits SIP for PM 2.5 transport March 10, 2007 Transport SIPs are due AR submits SIP for PM 2.5 transport NM submits SIP for 8-hr ozone and PM 2.5 transport OK submits SIP for 8-hr ozone and PM 2.5 transport TX submits SIP for 8-hr ozone transport

Section 126 Petitions The final CAIR does not address EPA s view of the interaction between Sections 110(a)(2)(D) and 126. This will be outlined in EPA s response to the North Carolina Section126 Petition of March 19, 2004. Due by August 1, 2005 EPA will provide a comment period and opportunity for public hearing on the specifics of the North Carolina Section 126 petition findings. EPA will also provide the opportunity to comment on EPA s view of the interaction between Sections 110(a)(2)(D) and 126.

8-Hour Ozone Concentration Reductions