High ozone levels in the Tri Cities Ranil Dhammapala and Kari Johnson

Ecology partnering with the community and local govt Ecology has no interest in prescribing solutions from afar. We’ve partnered with Benton Clean Air Agency and would like to work with BFCoG and other entities responsible for setting local policy. Franklin & Walla Walla Counties are within the jurisdiction of Ecology’s Eastern Regional Office in Spokane.

Why should we care about O3? Ground level, not stratospheric (“good”) ozone. Robin explained health effects of “bad” O3 Chemistry is complex. Reducing wrong precursor can either increase ozone or yield little benefit.

Complying with Federal Standards for ozone

Ozone Design Value Federal standards require the O3 “Design Value” to be less than 70ppb. DV calculated as the average of the annual fourth highest maximum daily 8-hour average(MDA8). Kennewick O3 4th high MDA8, ppb # of days > 70 ppb 2015 75 5 2016 68 2 2017 74 9 Latest DV 72 If ozone levels exceed Federal standards, the entire community has to bear the health consequences and financial burden of reducing ozone. This also makes it more difficult for industries to expand.

If we fail to meet the Federal Standards… O3 Design Value, ppb Nonattainment Classification Time allowed for bringing area into compliance, yrs 71- 81 Marginal 3 81- 93 Moderate 6 93- 105 Serious 9 105- 163 Severe 15 (maybe 17) > 163 Extreme 20 The Kennewick area will be most likely be classified Marginal, which is the lowest classification with the least number of requirements

Planning & Control Mandates by Classification Area classification Proposed VOC emissions increase by source Additional offsets required in same airshed Marginal > 100 tons/ yr 10% Moderate 15% Serious > 50 tons/ yr 20% Severe > 25 tons/ yr 30% Extreme > 10 tons/ yr 50% Planning & Control Mandates by Classification PERIODIC EMISSION INVENTORY UPDATES BASELINE EMISSION INVENTORY MAJOR SOURCE EMISSION STATEMENTS NEW SOURCE REVIEW PROGRAM TRANSPORTATION CONFORMITY DEMONSTRATION ATTAINMENT DEMONSTRATION VOC/NOx RACT FOR MAJOR/CTG SOURCES ROP (15% RFP OVER 6 YEARS) CONTINGENCY MEASURES FOR FAILURE TO ATTAIN BASIC I/M PROGRAM CLEAN FUELS PROGRAM ENHANCED I/M PROGRAM VMT GROWTH OFFSET CLEAN FUELS REQUIREMENTS LOW VOC REFORMULATED GAS PENALTY FEE PROGRAM FOR MAJOR SOURCES TRAFFIC CONTROLS DURING CONGESTION NSR REQUIREMENTS FOR EXISTING SOURCE MODS ENHANCED MONITORING PLAN 3% ANNUAL RFP UNTIL ATTAINMENT MODELED DEMO OF ATTAINMENT MARGINAL 3 years to attain MODERATE 6 years to attain SEVERE 15/17 years to attain SERIOUS 9 years to attain CONTINGENCY MEASURES FOR RFP EXTREME 20 years to attain VMT DEMONSTRATION The Clean Air Act requirements for Marginal eight-hour ozone nonattainment areas A Baseline Emissions Inventory - CAA Section 182(a)(1) An Emissions Statement - CAA Section 182(a)(3)(B) This requires permitted sources with emissions of VOC and NOx within the nonattainment area to submit an annual emissions inventory to the state A Periodic Emissions Inventory, No Later than Every Three Years Until Attainment of the Standard - CAA Section 182(a)(3)(A) New Source Review - CAA Title I, Part D A Nonattainment Area Preconstruction Permit Program - CAA Section 182(a)(2)(C) More burdensome than the NSR program Offset Requirements: 1.1 to 1 (Ratio of Total Emission Reductions of Volatile Organic Compounds to Total Increased Emissions) - CAA Section 182(a)(4) Meet Transportation Conformity Requirements - CAA Section 176(c) This is to ensure that federally funded or approved highway and transit activities will not cause or contribute to new air quality violations, worsen existing violations, or delay timely attainment of the relevant NAAQS or any interim milestones. Usually handled by the MPOs.

How much do wildfires contribute to O3? Short answer: some, not much Most days would have been high even without wildfire smoke EPA has procedures for removing smoke- impacted O3 data from the record But burden of proof is heavy when the contribution is small and hard to decipher Wildfire contribution to O3 at Enumclaw is larger and easier to identify, unlike Kennewick

When does O3 build up? Almost guaranteed in right conditions Light north winds on hot days Suggest constant & not sporadic precursor sources Northerly flow dams up against Horse Heaven Hills, allowing O3 to “cook”

Pollution roses showing the wind directions during hours of high ozone concentrations (only hours > 60ppb shown for clarity). In Kennewick, winds blowing from the North- Northeast are almost always responsible. Hermiston, OR sees high (not as high as Kennewick) O3 when air leaks southward through the Wallula gap and to a lesser extent, when plumes from further west move in.

Why is this a problem only now? The WSU air quality model alerted us of an ozone hotspot in 2013 Confirmed with investigative monitoring Hermiston had been seeing elevated ozone (though less than recent Kennewick levels) since 2007 Growth of the Tri Cities area increased emissions Back in 2007 the O3 standard was 75ppb, so few people were concerned when Hermiston reached 65.

What causes high O3 in the Tri Cities? ECY spent ~ $150K on a the Tri Cities Ozone Precursor Study (TCOPS) in summer 2016 Study report & StoryMap: http://ecology.wa.gov/AQstudies What causes high O3 in the Tri Cities?

Main TCOPS findings No single “smoking gun” Precursor contribution and O3 production not always linear No big contributions from afar Airshed not VOC or NOx limited. Modeling study needed to nail down specifics. Moderate NOx and VOC cuts for now Very crude estimate: 30% reduction  -5ppb O3.

How do you know vehicles contribute? Emissions inventory TCOPS: NOx spikes coincide with rush hour Weekday/ weekend effect Weekend O3 ~ 3.5ppb lower under comparable conditions

Nox emissions inventory

How much does industry contribute? Ecology modeled NOx from large point sources Though these had larger impacts nearby, they accounted for < 8% of the NOx measured by TCOPS mobile monitors VOC and O3 impacts from industry and agriculture have not been assessed yet.

What next? For now pursue modest reductions in both NOx & VOC Modeling study (ECY already working on it) Build a Tri Cities O3 forecast tool Limited ECY funds available for focus groups, workshops, media, campaigns, outreach, etc.

Q&A Ranil Dhammapala, Atmospheric Scientist 360-407-6807 ranil.dhammapala@ecy.wa.gov Q&A Kari Johnson, Community Outreach Specialist 509-329-3502 kari.johnson@ecy.wa.gov

Extra slides

VOC emissions inventory

Breakdown of NOx emissions on hot days

Breakdown of VOC emissions on hot days