Department of Environmental Quality Update on SO2 Standard Implementation Air Quality Committee Meeting July 13, 2016 Donnie Redmond Department of Environmental Quality

Update on Sulfur Dioxide (SO2) Data Requirements Rule (DRR) Implementation SO2 NAAQS background Introduction of SO2 DRR Current status of implementation

SO2 Standard Implementation Round 1: October 4, 2013 – EPA designated areas in the US with violating monitors as nonattainment None in NC Round 2: “The down-payment designations” Court Entered Consent Decree on March 2, 2015 One Facility Impacted in North Carolina State Recommendation Due September 18, 2015 EPA Sent Letter Generally Concurring with State’s Recommendation on February 16, 2016 Final Response Due to EPA on April 19, 2016 Final Designations Announced by July 2, 2016 … but wait… there’s more…

SO2 Standard Implementation EPA’s final Data Requirements Rule (DRR) – August 2015 All facilities with SO2 emissions > 2000 tons per year must be analyzed January 15, 2016 – list of facilities due 7 total facilities with emissions over threshold 2 additional facilities below threshold with 3rd party modeling analysis showing potential violations July 1, 2016 – monitoring or modeling approach due January 1, 2017 – monitoring sites installed and operational January 13, 2017 – modeling due to EPA

SO2 Standard Implementation Round 3: December 2017– EPA designates areas based on the modeling analyses submitted Round 4: December 2020 – EPA designates all remaining areas (using the data collected from the monitoring that started in 2017)

SO2 DRR: To Model or to Monitor? NC DAQ’s letter of January 15, 2016 identified nine facilities to be evaluated NC DAQ’s letter of July 1, 2016 Five facilities modeled in compliance Modeling due to EPA Jan 2017 Areas around the facilities will be designated in Dec 2017 Facilities that modeled compliance Duke Energy Belews Creek Duke Energy Marshall Duke Energy Mayo Duke Energy Allen Duke Energy Asheville

SO2 DRR: To Model or to Monitor? NC DAQ’s letter of January 15, 2016 identified nine facilities to be evaluated NC DAQ’s letter of July 1, 2016 Four facilities will go the monitoring path Monitors must be operating by Jan 1, 2017 2017-2019 monitoring will determine design value Areas near these facilities will be designated in Dec 2020 Facilities that will undergo monitoring Duke Energy Roxboro CPI Southport Evergreen Packaging Canton Mill PCS Phosphate

SO2 DRR: Monitoring SO2 DRR monitoring sites are included in the annual Ambient Monitoring Network plan 30-day public comment period Due to EPA by July 1, 2016 EPA technical staff has visited each new monitoring site Two sites are already operational (one was an existing site)

Factors in determining SO2 monitor location Modeling Ranking of maximum values Ranking of frequency Combined “index” to rank prospective sites Much more limited options than typical Physical characteristics of potential sites Terrain, tree cover Access Power Long-term availability of the site Critical: Can we stay for at least three years?

SO2 Site Approval Process EPA on-site visits Not normally done Tight timelines, consequences led us to request Region 4 technical staff obliged 30-day public comment period Posted on DAQ website; email announces Monitoring Network Plan Due to EPA by July 1 They typically approve it Sept-Nov

PCS Phosphate (Aurora) Limited siting options because of 2-mile wide Pamlico River downwind of facility and large tracts of land surrounding facility Propose using existing SO2 monitor at Bayview Ferry, directly across river Placed relatively high among remaining receptors’ ranking EPA has previously approved this site, but for other purposes DAQ’s Washington Regional Office operates this site, and will continue to do so

Duke Energy Roxboro Located on CertainTeed property Monitor is in operation Duke operates the site, but DAQ will audit, perform daily QA, and ultimately be the party to certify the data EPA approves (and encourages) such arrangements for this rule

CPI Southport Mostly private property in desired area (based on modeling) One property owner is agreeable to our conditions Currently formalizing an agreement and prepping the site Expect it to be operational by end of July DAQ’s Wilmington Regional Office will operate To be submitted as addendum to network plan, with separate 30-day public comment period

Evergreen Packaging (Canton) Monitoring site is on NC DOT property Currently formalizing agreements for long- term use of property Expect it to be operational by end of Sept DAQ’s Asheville Regional Office will operate

Questions? Donnie Redmond Ambient Monitoring Section Chief 919-707-8468 donnie.redmond@ncdenr.gov Department of Environmental Quality