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

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. 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.

4. Complying with Federal Standards for ozone

5. 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.

6. 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
Serious 9
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

7. 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.

8. 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

9. 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”

10. 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.

11. 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.

12. 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:
What causes high O3 in the Tri Cities?

13. 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.

14. 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

15. Nox emissions inventory

16. 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.

18. 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.

19. Q&A Ranil Dhammapala, Atmospheric Scientist 360-407-6807
Q&A
Kari Johnson, Community Outreach Specialist

20. Extra slides

21. VOC emissions inventory

22. Breakdown of NOx emissions on hot days

23. Breakdown of VOC emissions on hot days