1. 1 Stationary Sources Work Group – Final Report PM 2.5 SIP Jennifer Karaffa, Cuyahoga County Planning Commission, Chair June 12, 2007 NOACA Air Quality Public Advisory Task Force

2. 2 Scope of Work Sources other than mobile, including:  Electric generating units (EGUs)  Steel mills  Diesel generators  Wood-fired boilers (hydronic heaters)  Fireplaces and wood stoves  Asphalt plants  Restaurants  Road salt

3. 3 Scope of Work, continued The scope included: Traditional air pollution control devices Innovative techniques and practices Energy conservation and renewable energy Public education Enforcement policies Trading programs

4. 4 Automotive Engine Casting Plants The closing of the Ford Engine Casting Plant in Brookpark, Ohio, as announced by Ford Motor Company, represents the elimination of the following emissions: Ford Engine Casting Plant Emissions in Tons Per Year YearPMPM10SO2NOxCOVOCsHg 20064252474491601,4315630 2006 data provided by the Cleveland Division of Air Quality

5. 5 Steel Mills NOx RACT (Reasonable Available Control Technology) Recommended in order to keep NOx levels at or below current lows at Mittal Steel and Republic Steel High Efficiency Wet Scrubber on Blast Furnace Not Recommended, but reported as an improvement at Mittal Steel, Cleveland

6. 6 NOx Credit Trading Bank Ohio EPA would house the bank in which NOx credits are quantified and verified, for purchase by new or modified businesses in Northeast Ohio nonattainment area. Recommendation – NOx Credit Trading Bank that allow market forces to shape the credit prices. Possible mandatory cap and/or retirement of some credits to be revisited.

7. 7 Diesel Generators (Stationary Engines) Large Land-Based Diesel Gen-Sets (used for stand- by power and load management) Recommendation – Retrofit to reduce NOx and PM. Medium Portable Diesel Gen-Sets (used for special events and power outages) Recommendation – Retrofit to reduce NOx and PM. Home Diesel Generators (used for power outages) Recommendation – Public education campaign to discourage diesel and encourage propane or CNG.

8. 8 Residential Combustion (Also known as “Who, me?”) Outdoor wood-fired boilers (for indoor heat and hot water) – significant contributor to PM2.5 statewide Recommendation – Adopt NESCAUM Model Rule for all new wood-fired boilers. Mandatory “No Burn” on Air Pollution Advisory Days Recommendation – Adopt state law with local enforcement. Exemptions for fireplaces, etc., that they are sole sources of heat. Voluntary Wood Stove Change-Out Program Recommendation –Adopt and secure a funding source.

9. 9 Hot Mix Asphalt Plants Statewide sources of PM 2.5, NOx, SO 2 RACT (Reasonably Available Control Technology) for Hot Mix Asphalt Plants Could include: Low-NOx Burners Limestone Injection Fuel Changes Good Operational Practices to Reduce Fuel Use Recommendation – Adopt RACT rule that is flexible.

10. 10 Restaurants With the exception of switching to low-fat meats, NO cost-effective controls exist for: Underfired charbroiling Deep fat frying Flat griddle frying Clamshell griddle frying However, for Chain-Driven Charbroiling, catalytic oxidizers are available. Recommendation – Require oxidizers for chain- driven charbroilers. (Small total count, so low total impact.)

11. 11 Road Salt Liquefied Brine is becoming the state-of-the-art for road salt application. Reduces total salt application by as much as 30%. Recommendation –Encourage use of liquefied brine. ● Road Salt Minimization Policies exist at most jurisdictions. ● Recommendation –Encourage strict adherence to such policies.

12. 12 EGUs Coal-fired power plants (electric generating units – EGUs) must comply with the following federal regulations: Acid Rain (NOx and SO 2 reductions in 1995 and 2000) NOx SIP Call (NOx reductions began in 2003) Clean Air Interstate Rule (CAIR) (Phase I will result in NOx and SO 2 reductions starting 2009 and 2010 respectively, followed by additional Phase II reductions in 2015) Recommendation – No “Controls Beyond CAIR” due to comprehensive federal reg’s, plus USEPA guidance.

13. 13 EGUs, continued Renewable Portfolio Standard (RPS) Would require purchase of renewable energy in certain quantities. FirstEnergy Corporation may offer a voluntary “Green Energy Option” if approved by PUCO, for consumer purchase. However, air quality benefits occur out-of-state where the renewable energy is produced. Work Group encourages in-state renewable options. Recommendation – Long-Term Solution Only. No air quality benefits that could be quantified for SIP purposes.

14. 14 Energy Conservation Wind Power Energy Audits for Businesses & Municipalities Encouraging Manufacturing of Energy-Efficient Components Recommendation – Long-Term Solution Only. As with Renewable Portfolio Standards, no air quality benefits that are timely and quantifiable in the nonattainment area for SIP.

15. 15 Enforcement Practices Increase Staffing at Ohio EPA and local air agencies to enhance compliance with existing law. Recommendation – Long-Term Solution, only, because state budget process that would include 2008-2009 is already underway.

16. 16 Conclusions Stationary sources are significant contributors to the PM 2.5 nonattainment problem. Controls for previously overlooked sources such as outdoor wood-fired boilers and home fireplaces must be considered. NOx solutions recommended for the 8-Hour Ozone SIP will simultaneously help PM 2.5. Long-term solutions are needed.

17. 17 Questions? Jennifer Karaffa, Cuyahoga County Planning Commission Amy Wainright, NOACA Pamela Davis, NOACA www.noaca.org