How meeting the 2007 Standard & Reducing

Variable Emissions will Help Attain the 2010 8-Hour

Standard?

Guy DonaldsonEPA

What Will We Cover?

• A little Background on Air Quality Standards and State Implementation Plans.

• What are the 8-hour requirements• What are the Requirements for Houston.• What progress has been made so far?• Where do we go from here?

What is a National Ambient Air Quality Standard?

A standard set by EPA protect public health or welfare.

Required by the Clean Air ActSupposed to be reviewed every 5 years.EPA has set Standards for 6 criteria

pollutants

Criteria Pollutants

EPA has set Standards for 6 criteria pollutants:~ ground-level ozone (smog)*~ particulate matter ~ lead~ nitrogen dioxide~ sulfur dioxide~ carbon monoxide*Only one not met in the Houston Area

Health Effects of Ozone

When inhaled at harmful levels, ozone can:~ pose health problems for children, asthmatics, the

elderly and even healthy adults;~ cause acute respiratory problems;~ aggravate asthma, emphysema and bronchitis;~ lead to increased hospital admissions and

emergency room visits; and~ impair the body’s immune system defenses.

Air Quality Management Process

State

Implementation

Plan

(SIP)

Air Quality Monitoring

Source Surveillance Emission Limiting Rules and Regs

Enforcement New Source Review

Voluntary and Non-traditional

Measures

Control Strategy DemonstrationResources

PermittingPermitting Mobile Measures and Fuels

EmergencyEpisode

These constitute the “infrastructure” part of the SIP required Statewide

Legal Authority

Important Point

We don’t sanction areas for poor air quality.

We sanction areas for failure to develop or implement plans to deal with poor air quality.

Actual sanctions are rare.

• In 1979 EPA revised its “photochemical oxidant” standard and set a health-based national ambient air quality standard (NAAQS) for ground-level ozone at 0.12 parts per million averaged over a 1-hour time frame.

• In 1997 EPA revised the ozone NAAQS to 0.08 parts per million averaged over an 8-hour time frame.

• EPA's new 8-hr standards were challenged by a number of parties … implementation delayed until the Supreme Court upheld EPA's authority under the Clean Air Act to revise the NAAQS.

Background New 8 hour standard:

Background … continued

• US Supreme Court also determined that EPA’s original strategy for implementing the 8-hour ozone NAAQS was unreasonable; left it to EPA to develop a more appropriate scheme that did not ignore Title I, Part D, Subpart 2 of the CAA.

• Supreme Court also sent the NAAQS case back to the D.C. Circuit Court of Appeals on several other issues.

• In March 2002, the DC Circuit Court rejected all remaining challenges to the new 8-hour ground‑level ozone NAAQS, paving the way to begin implementation of the requirements.

HOUSTON/GALVESTON 8-HOUR OZONE NONATTAINMENT AREA

• 8-HOUR NONATTAINMENT DESIGNATION

• SIGNED APRIL 15, 2004.– EFFECTIVE JUNE 15, 2004.

• HGA AREA COUNTIES: (same as one-hour)

- Harris -Waller- Galveston - Montgomery- Brazoria - Fort Bend- Chambers - Liberty

CATEGORY/CLASSIFICATION

Severe 17 Los Angeles

Moderate

Marginal

Subpart 1 (Basic)

Subpart 1 EAC (Basic)

Moderate EAC Greensboro, NC

Classification of 8-hour Nonattainment Ozone Areas

Serious - Riverside Co (Coachella Valley), San Joaquin, Sacramento, CA

Status of 8-hour Ozone Implementation Rule

• Final rule to be issued in 2 phases:– Phase 1:

• Classifications, transition/anti-backsliding, revocation of 1-hour std., attainment dates, attainment date extensions, timing of emission reductions needed for attainment

• Signature April 15

– Phase 2: • Remainder of rule elements (e.g., RACT, RFP, attainment

demonstrations; 8-hr NSR)• Planning for signature by the end of the year.

8-hour O3 classification approach from April 15th rule

• Only areas violating the 8-hr NAAQS are “nonattainment”

• To determine the applicable CAA Subpart --- violating areas are compared against a 1-hour design value for the same monitor.

• Cut point: > or equal to 0.121 PPM, 1-hour design value.

Applicable requirements for an area are the following requirements to extent that they apply to area for area’s classification under section 181(a)(1) of the Act for 1-hr NAAQS: Reasonably available control technology (RACT) Inspection and maintenance programs (I/M) Major source applicability cut‑offs for purposes of RACT Rate of Progress (ROP) Plans Stage II vapor recovery Clean fuels fleet program Clean fuels for boilers Transportation Control Measures ... section 182(e)(4) of CAA Enhanced monitoring Vehicle miles traveled provisions of sec. 182(d)(1) NOx requirements under sec. 182(f)

Requirements “carried over” from the 1-hr ozone NAAQS

How will EPA treat attainment dates?

• Attainment must be “as expeditious as practicable but no later than . . . “

– Subpart 2 -- from effective date of designation/classificationmarginal – 3 years (2007)moderate – 6 years (2010) - Houstonserious – 9 years (2013)severe – 15 or 17 years (2019/2021)extreme – 20 years (2024)

Key Points For Houston

• Will have to implement non-discretionary measures.

• Can change discretionary measures if:– Still will attain one-hour by 2007– Continue progress toward 8 hour.

• Will have to provide 8 hour attainment plan by 2007.

• Attain by 2010

What does ozone air quality look like in some of the nonattainment areas???

Estimated

Houston Background

• EPA approved SIP in 2001– Demonstrated attainment of 1 hour by 2007

• EPA’s approval upheld in Court• Plan called for a reviews in 2002 and 2004.• 2002 review relaxed NOx controls increased

VOC controls.• 2004 review proposed to be adopted

December 2004 continues shift to HRVOC controls

Federal Measures Texas Emission Reduction Program (SB-5)

Approx 90% Industrial Controls Airport Ground Service (proposed to be approx. 80%) electrification

Enhanced Tailpipe Testing California Large Spark Stds

Low Emission Diesel Fuel Voluntary Measures(Tug/Tow MOA, Bolivar

Controls on Highly Reactive VOCs Ferry, Train MOA)

Houston SIP Measures

We can expect more progress

• Industry NOx caps continue to decline annually from 2005-2007

• TERP funding through 2007.

• Controls on Highly Reactive VOCs

• Phase In of Federal Measures

What Comes Next?

• TCEQ submits midcourse review

• 8 hour attainment SIP due 2007

• Attainment expected 2010

• Control will need to implemented no later than 2009

Houston’s ozone problem

• Daily Emissions from Cars, Trucks,construction equipment, etc.

• Routine Emissions from industry

• Industrial Emission Events (upsets)

• Control Strategy will need to continue to address all three elements

Future Issues• Continued uncertainty with the emissions.

– Planned improved monitoring will help– Still more source monitoring needed?

• What role do variations in VOC emissions play.• Decision on future control direction

– More NOx– More HRVOCs– Other Less Reactive VOCs– Some combination

• How to reduce hard to reach categories such as Ships.