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

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

3. NAAQS Update

4. 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

5. 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

6. 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

7. 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.

8. Current SO2 Design Values

9. 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:

10. 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 – State attainment plans due
2020 – 2033 – Final compliance dates based upon non-attainment classification

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

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

13. 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

14. Smoke Plume

15. Exceptional Event Demonstration

16. Exceptional Event Demonstrtion

17. Exceptional Event Demonstration
Once final – document is sent to U.S. EPA for review
For more information see:

18. 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

19. 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.

20. 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

21. 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

22. 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

23. Asbestos Program Changes
No changes will be made to OAC rule
ODH rules will now be in OAC rule
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

24. 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

25. 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.

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

27. 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

28. Thank you! Anna Kelley & Brad Miller
Contact info:
Anna Kelley & Brad Miller
(513)