Southwest Ohio Air Quality Agency Cincinnati, Ohio Air Quality Update Southwest Ohio Air Quality Agency Cincinnati, Ohio

Introduction SO2 NAAQS Update Ozone NAAQS Update Air Quality Exceptional Events PQAO’s PAMS Asbestos Program Changes Area Source MACT Standards

NAAQS Update

2010 SO2 NAAQS Overview Standard is 75 ppb based upon a one-hour average (3-year average of the annual 99th percentile of the 1-hour daily maximum) Four Rounds to the Designation Process

SO2 - Round 1 Designations Nonattainment for portions of Campbell County, Kentucky and Clermont County, Ohio (Pierce Township) Based upon monitoring data in Campbell County Duke Energy Beckjord boilers shut down in 2014 Subsequent monitoring data demonstrated compliance Area redesignated to attainment November 21, 2016

SO2 – Round 2 Designations Included Clermont County and the Zimmer Power Plant as part of a Consent Decree settlement Ohio EPA modeling demonstrated compliance with the 1- hour standard Area designated Attainment/Unclassifiable effective September 12, 2016

SO2 – Round 3 Designations August 22, 2017 –U.S. EPA recommendations (Actual > 2000 TPY) Dynegy Miami Fort Station – Hamilton County: Attainment/Unclassifiable DPL Stuart and Killen Stations – Adams County: Attainment/Unclassifiable Operating a SO2 monitoring network near the General J.M. Gavin and Kyger Creek power plants.

Current SO2 Design Values

SO2 NAAQS - Future Round 4 Designations Coming in the future Will be based upon the monitoring data Five year review – U.S. EPA Policy Assessment recommends maintaining current SO2 standard More information see: http://www.epa.state.oh.us/dapc/SIP/so2.aspx

2015 Ozone Standard – 70 ppb June 2017 – U.S. EPA delayed implementation of ozone rules until October 2018 August 2017 – U.S. EPA withdrew one year extension October 1, 2017 – Final Designations??? December 2020-2021 – State attainment plans due 2020 – 2033 – Final compliance dates based upon non-attainment classification

Ozone Update - Exceedances 2015 2016 2017 Sycamore 4 8 5 Colerain 3 9 1 Batavia 2 Lebanon Middletown 7 Hamilton Taft Exceedances based on 0.070 ppm

Current Ozone Design Values 2014-2016 2015-2017* Butler 0.072 Clermont 0.070 Hamilton 0.073 Warren 0.071 *Data through September 30, 2017 Units are parts per million (ppm)

Exceptional Event Demonstration What is an exceptional event (40 CFR 50.14)? May of 2016 Canadian Wildfires impacted Ozone and PM2.5 monitors in Cincinnati and Cleveland (May 24th and 25th) Ohio EPA developed draft document which was revised in August 2017

Smoke Plume

Exceptional Event Demonstration

Exceptional Event Demonstrtion

Exceptional Event Demonstration Once final – document is sent to U.S. EPA for review For more information see: http://www.epa.state.oh.us/dapc/sip/misc.aspx

What is a PQAO or Primary Quality Assurance Organization? “A monitoring organization or a group of monitoring organizations or other organization that is responsible for a set of stations that monitors the same pollutant and for which data quality assessments can be pooled.” 40 CFR Part 58 Appendix A 1.2

What is a PQAO? Measurement Uncertainty relatively homogeneous as a result of common factors Operation by common set of field operators according to common procedures Common Quality Assurance Project Plan or Standard Operating Procedures Common calibration facilities or standards Oversight by common quality assurance organization Oversight by common management organization or laboratory 40CFR Part 58 Appendix A 1.2.1 Each PQAO is defined such that measurement uncertainty among all stations can be expected to be relatively homogeneous as a result of common factors.

What is a PQAO? January 1, 2015 Benefit(s) Ohio consolidated from 13 to 3 PQAOs NEPQAO: Cleveland, Lake County, M-TAPCA, Akron, Canton, Ohio EPA-NEDO CPQAO: Toledo, Ohio EPA-Central and SEDO SWPQAO: RAPCA, Portsmouth, SWOAQA, Ohio EPA-SWDO January 1, 2017: Ohio EPA-SWDO closed air program Benefit(s) Reduce number of co-located monitors (QA requirement) Reduce work load Reduce supplies Funding Focus efforts on priority sites

PAMS update PAMS –Photochemical Air Monitoring Station Required in recent Ozone Rule at urban NCore sites Monitoring June – August Volatile Organic Compounds - hourly Mixing Height True NO2 - hourly Carbonyls – 3 8-hour samples daily June 1, 2019 – required implementation date

Asbestos Program Changes House Bill 49 (State Budget) is combining the Ohio EPA and Ohio Department of Health (ODH) Asbestos Programs Ohio EPA rules include: Notifications Removal requirements Disposal requirements ODH rules include: Licensing of companies and workers Requirements for training classes

Asbestos Program Changes No changes will be made to OAC rule 3745-20 ODH rules will now be in OAC rule 3745-22 Proposed rules issued October 12, 2017 Program changes will be effective January 1, 2018 One notification form for both agencies All notifications will be sent to Ohio EPA – Central Office Agency inspectors will determine compliance with both rules Electronic inspection forms

Area Source MACT Standards Delegation/Enforcement of Standards Area Source Standards – Ohio EPA has not accepted delegation for most of these standards Detailed terms will not show up in the permit Local company recently was issued a Consent Agreement and Final Order with a civil penalty

Area Source MACT Standards 40 CFR Part 63, Subpart XXXXXX – NESHAP for Nine Metal Fabrication and Finishing Source Categories One category is Fabricated Metal Products Manufacturing Requirements for Welding Operations that uses welding rod with: cadmium, chromium, lead, nickel, or manganese Daily visible emission readings Method 22 If no visible emissions may go to weekly, monthly, etc.

Area Source MACT Standards If visible emissions are observed may have to perform Method 9 readings. Welding operations are normally “De Minimis (OAC rule 3745-15-05) or permit exempt These standards usually require Initial Notifications and Notifications of Compliance Status

U.S. EPA Actions In 2017, U.S. EPA conducted seven inspections In 2017, issued two “Request for Information” letters (114 letters) One focused on Heat Treating Furnaces Other focused on Coating and Cleanup material emissions

Thank you! Anna Kelley & Brad Miller Contact info: Anna Kelley & Brad Miller anna.kelley@hamilton-co.org bradley.miller@hamilton-co.org (513) 946-7777