1. High ozone levels in the Tri Cities
Ranil Dhammapala, Jean-Paul Huys,
Kari Johnson, and Brook Beeler

2. 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.

3. Ozone basics

4. Why should we care about O3?
Ground level, not stratospheric (“good”) ozone.
O3 exposure irritates eyes, nose, throat and airways.
Worse health effects for vulnerable people. 

6. More about O3 Not released directly from sources.
Formed when certain gases react on hot days.
Precursors include oxides of nitrogen (NOx) and volatile organic compounds (VOC).
Chemistry is complex. Reducing wrong pollutant can increase ozone.

7. Complying with Federal Standards

8. *Wildfire smoke affected data not excluded
Ozone Design Value
Federal standards require the O3 “design Value” to be less than 70ppb.
Calculated as the average of the annual fourth highest daily maximum 8-hour value (D8M).
Kennewick O3, ppb
Enumclaw O3, ppb
2015 4th high D8M 75 74
2016 4th high D8M 68 61
2017 4th high D8M
94*
Latest DV 72
76*
*Wildfire smoke affected data not excluded
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.

9. EPA designations
Initial designations of attainment or nonattainment done 2 years after issuance of new NAAQS.
EPA can redesignate an area at any time if new information indicates a designation should be revised.
Section 110(m) gives EPA the discretionary authority to impose sanctions.

10. Planning & Control Mandates by Classification
NSR offset
Major source thresholds
1.5 : 1 - Extreme 10
1.3 : 1 - Severe 25
1.2 : 1 - Serious 50
1.15 : 1 - Moderate
100
1.1 : 1 - Marginal
Planning & Control Mandates by Classification
EXTREME
20 years to attain
TRAFFIC CONTROLS DURING CONGESTION
CLEAN FUELS REQUIREMENTS
PENALTY FEE PROGRAM FOR MAJOR SOURCES
SEVERE
15/17 years to attain
LOW VOC REFORMULATED GAS
VMT GROWTH OFFSET
VMT DEMONSTRATION
NSR REQUIREMENTS FOR EXISTING SOURCE MODS
ENHANCED I/M PROGRAM
CLEAN FUELS PROGRAM
SERIOUS
9 years to attain
MODELED DEMO OF ATTAINMENT
CONTINGENCY MEASURES FOR RFP
3% ANNUAL RFP UNTIL ATTAINMENT
ENHANCED MONITORING PLAN
BASIC I/M PROGRAM
CONTINGENCY MEASURES FOR FAILURE TO ATTAIN
MODERATE
6 years to attain
ROP (15% RFP OVER 6 YEARS)
VOC/NOx RACT FOR MAJOR/CTG SOURCES
ATTAINMENT DEMONSTRATION
TRANSPORTATION CONFORMITY DEMONSTRATION
MARGINAL
3 years to attain
NEW SOURCE REVIEW PROGRAM
MAJOR SOURCE EMISSION STATEMENTS
BASELINE EMISSION INVENTORY
PERIODIC EMISSION INVENTORY UPDATES

11. Are we measuring O3 in an isolated hotspot?

12. Mobile O3 monitoring on July 30 2013

13. August 14, 2013
Elevated O3 area not huge, mostly around Kennewick and Burbank

14. Didn’t bother driving around Kennewick at peak ozone time because we already had a monitor there. Burbank has shown up as a hotspot often.

15. 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”

16. Whodunnit? Tri Cities Ozone Precursor Study (TCOPS) StoryMap
Whodunnit?
Ecology spent about $150K to contract with WSU and RJ Lee Group Inc to conduct 3 weeks of intensive field measurements in summer 2016, to understand O3 precursor sources in the Tri Cities.

17. How do you know vehicles contribute?
Emissions inventory
TCOPS: NOx spikes coincide with rush hour
Weekday/ weekend effect
~ 17% reduction in NOx and VOC emissions
Almost entirely driven by mobile sources
Weekend O3 ~ 3.5ppb less under similar conditions

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

19. What next? Limited funds available
Working with BCAA, BFCoG, BFTA, and other stakeholders to identify path forward
Research other communities’ efforts
Focus groups, workshops, media, campaigns, outreach, etc.

20. Q&A Ranil Dhammapala, Atmospheric Scientist 360-407-6807
Jean-Paul Huys, Air Quality Planner
Q&A
Kari Johnson, Community Outreach Specialist
Brook Beeler, Communications Manager

21. Extra slides

22. NAAQS Thresholds
2015 ozone NAAQS threshold for each classification are:
Marginal – from 71 ppb up to 81 ppb
Moderate – from 81 ppb up to 93 ppb
Serious – from 93 ppb up to 105 ppb
Severe – from 105 ppb up to 163 ppb
Extreme – from 163 ppb

23. Attainment Dates Period starts from effective date of designation
Marginal - 3 years;
Moderate - 6 years;
Serious - 9 years;
Severe - 15 years (or 17 years); and
Extreme - 20 years.

24. Possible Sanctions Section 179
Failure to submit a complete Title I, Part D nonattainment area plan or revision or a Part D SIP element.
Failure to implement any element of approved Part D SIP.
IMPORTANT: These sanction have nothing to do with the possibility of not meeting the attainment date.
There are certain required elements that need to be included in the SIP, such as a complete New Source Review (NSR) program, or emissions inventories. EPA might start the 18-month clock when these elements are not included in the SIP, or EPA might also start the clock when the state fails to implement an element.
The 18-month clock gives the state some time to rectify the problem. If the state still fails to submit the required elements or implement an element, then EPA might impose sanctions. This has not happened before in the US, as far as I know.

25. Possible Sanctions Section 179 Sanctions:
18 months after trigger = offset sanctions (2:1 for new or modified sources)
24 months after trigger = highway sanctions
The withholding of Section 105 grant funds (not mandatory even under the mandatory sanctions provision).
There are required offsets for VOCs when an area becomes nonattainment. The offsets increase as the nonattainment classification goes higher. The offset for a Marginal area (most likely for Kennewick) is 1:1.1 , however, the offset will become 1:2 18 months after the trigger.
24 months after the trigger, federal highway funds will be reduced for the state, not just for the nonattainment area.
There is also a possible withholding of Section 105 funds for the air quality programs.
Again, these sanctions have never been implemented, a far as I know. And this only applies when SIP elements are missing or implementation is ignored, this has nothing to do with the possibility of not meeting the attainment date.

26. Nox emissions inventory

27. VOC emissions inventory

28. NOx measurements during TCOPS
Nox measurements during TCOPS- see peaks coinciding with rush hour, hardly a trend in Horn Rapids (less traffic)

29. Historical data showing O3 vs temperature, broken down by day of week
Historical data showing O3 vs temperature, broken down by day of week. On hot days (afternoon T> 85F) weekday O3 is about 2.5ppb higher than weekend O3 on similar days. This is a VERY CRUDE estimate of how reduced emissions translate to reduced O3. A modeling study is needed for more refined estimates

30. Breakdown of NOx emissions on hot days

31. Breakdown of VOC emissions on hot days

32. Breakdown of NOx emissions on hot weekdays & weekends

33. Breakdown of VOC emissions on hot weekdays & weekends
Pleasure craft use over weekends increases VOC emissions.

34. Airport and shipping emissions, tons/ yr
Category
Pollutant
Benton
Franklin
Walla Walla
Airport support operations
NOx
1.5
3.9
6.8
VOC
1.6
26.4
5.7
Shipping/ barges
1.7
0.5
2.5
0.02
0.006
0.03
Emissions are annual totals, not daily totals as shown in the previous few slides

35. 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.

36. Larger NO/Nox ratio ( fresh emissions) around 4AM at Burbank, about 2 hrs earlier than in Kennewick. In the former, it happens mostly during east sector winds while at Kennewick it happens from all directions. Suggests early truck traffic on Hwy 12 (larger proportion of early morning traffic consists of trucks in Burbank).