1. Robert Hodanbosi, Chief, DAPC Jennifer Dines, Manager, DAPC SIP Section Air Quality and SIP Update

2. N ATIONAL A MBIENT A IR Q UALITY S TANDARDS (NAAQS)  U.S. EPA has developed standards for six specific contaminants  Sulfur dioxide – primary source; coal fired power plants  Carbon monoxide – primary source: cars and trucks  Lead – primary source; individual industrial facilities  Nitrogen oxides – primary source; any type of combustion  Particulate matter – primary source; coal fired boilers, cement plants, steel making operations  Ozone – primary source; cars, trucks, utility boilers, painting operations, refineries

3. Air Quality Standard Process Typical Clean Air Act requires standards to be reviewed Clean Air Scientific Advisory Committee (CASAC) develops recommendations standards every 5 years US EPA develops proposes/adopts standard States have 1 Year to provide recommendations on “nonattainment” designations

4. Air Quality Standard Process Typical (Cont’d) U.S. EPA has 1 year to finalize nonattainment designations States have 3 years to submit plans/attain standards Extra time is available if state is making “good faith” efforts Litigation takes place and can disrupt the schedule

5. Ohio’s Attainment Status The entire state is attainment for nitrogen dioxide, sulfur dioxide, and carbon monoxide. Ohio has nonattainment areas for PM2.5, lead Currently entire state is designated attainment for ozone and SO2 but this will change.

6. Revising Standards  U.S. EPA has been busy revising standards:  2006: 24-hr PM 2.5  2008: Lead  2010: NO 2, SO 2  2008-2011: Ozone  2011: CO  More to come:  2012: PM 2.5  2013-2014: Ozone PM 2.5 Ozone SO 2 NO 2

7. PollutantCurrent NAAQS Proposed NAAQS Final DateDesignationsSIPs DueAttainment CO9ppmv (8Hr) 35ppmv (1hr) 1/28/118/15/11Affirmed current standard, no new requirements. Lead0.15 ug/m3 (rolling 3-month) 5/20/0810/15/08Dec 2010 (round 1) Jan 2012( round 2) July 2012 July 2013 Jan 2016 Jan 2017 NO20.053 ppmv (annual) 0.100 ppmv (1-hr) 6/29/091/22/10Jan 2012 (unclassifiable) Jan 2016/17 (nonattainment) July 2013Jan 2021/22 PM2.515.0 ug/m3 (annual) 35 ug/m3 (24 hr) Expected early 20111997 2006 Dec 2004 Oct 2009 April 2008 Dec 2012 Apr 2010 Apr 2015 Ozone0.075 ppmv (8-hr) 0.08 ppmv (8-hr) 0.12 ppmv (1-hr) Expected October 2013 3/27/08 9/22/11 Clarified May 2012Unk-schedule to be proposed Dec 2011 Unk- schedule to be proposed Dec 2011 SO230 ppbv (annual) 140 ppbv (24-hr) 50-100 ppbv (1-hr) (11/16/09) 6/2/10Jun 2012Feb 2014Summer 2017 Revised Standards …attainment will change

8. Revised Standards …implementation will strain recourses

9. OZONE

10. Ozone Air Quality Standard TimelineLevel (ppm)Measurement Revision of New Standard - CANCELLED 0.060 -0.070Average of fourth highest concentration measured over a three year period New Standard0.075 Old standard0.084 Old, Old standard0.125Not to be exceeded more than four times in a three year period

11. Ozone Monitors in Ohio

12. Ozone Exceedances by Year (through September 25, 2011) Year0.125 ppm 1-Hour 0.084 ppm 8-Hour 0.075 ppm 8-Hour 20001135326 20012250738 2002228011437 200322204458 2004None25178 20055192689 2006None39234 2007None110543 2008None32171 2009None431 2010None20162 2011None38221

13. 4th High Ozone Value in ppb

14. Progress Toward Attainment 0.125 ppm Standard – 1979 –Attainment - everywhere for many years 0.08 ppm Standard – 1997 –Met everywhere since 2008 0.075 ppm Standard – 2008 –Not being met in Cleveland, Cincinnati, and Columbus areas (2008-2010 data)

15. Ozone Standard: 2008-2011 Activity  On March 13, 2008, U. S. EPA announced a revised ozone standard of 0.075 ppm, average of the fourth highest concentration over a three year period  On September 16, 2009, U.S. EPA announced a review of the basis of the 0.075 ppm standard  On January 6, 2010, U.S. EPA proposed a new standard in the range of 0.060 to 0.070 ppm  On August 23, 2010, U.S. EPA announced a delay in the release of the new standard

16. Ozone Standard: 2008-2011 Activity  November 1, 2010, U.S. EPA announced another delay  On September 2, 2011 President Obama announced that U.S. EPA would delay going forward with new ozone standard until 2013, at earliest  On September 22, 2011 U.S. EPA announced they would move forward with implementing the 2008 standard

17. Ozone Standard: Implementing the 2008 Standard  Designations:  Proposal expected in December 2011  Final designations expected by May 2012  Expect the following areas will be designated nonattainment:  Cincinnati (79 ppb) -Butler, Warren, Clinton, Hamilton and Clermont counties  Cleveland (77 ppb) –Lorain, Cuyahoga, Lake, Geauga, Ashtabula, Medina, Summit, and Portage counties  Columbus (77 ppb) – Delaware, Franklin, Madison, Knox, Licking, and Fairfield counties

18. Ozone Standard: Implementing the 2008 Standard  Other SIP requirements:  Exact timing is to be determined  U.S. EPA expects a proposed implementation schedule in December 2011  Historical (CAA) implementation schedule:  Attainment Demonstrations (3 years from designations) ~ May 2015  Attainment Dates ~2015 to 2032 depending on severity

19. Ozone Standard: Implementing the 2008 Standard  U.S. EPA December 2011 proposal should also include classifications.  Based on historical classification methods, all three areas will likely be marginal nonattainment. Attainment would then be required three years from designations ~ May 2015  There is a chance that U.S. EPA may tighten deadlines for attainment demonstrations and attainment.

20. Attaining the Standard: 2001 and 2010 VOC Emissions

21. Attaining the Standard: 2001 and 2010 NOx Emissions

22. Attaining the Standard: Major Components of Inventory ……it is not all about industry Electric Generating Utilities Other Industrial Point Sources (smaller industrial boilers and furnaces) Area Sources (smaller commercial sources (dry cleaners, gas stations) and people (lawn mowers, residential heating, home painting)) On-Road - Cars and trucks Off-Road – Construction equipment, portable generators, farm equipment

23. Attaining the Standard: Applying the Model Where the model indicates the standard will not be met, additional emission reductions need to be applied to the inventory – this reflects new control programs. The model then is re-run until sufficient emission reductions are included to reach attainment.

24. Attaining the Standard: Identifying Control Measures Ohio EPA first looks at multi-state control measures which U.S. EPA is implementing. We examine control strategies which are required to be implemented by the Clean Air Act under the area’s classification.

25. Requirements for Ozone Areas - CAA Emission inventory due in 2 yrs; requirements for emission statements due in 2 yrs; periodic inventories RACT corrections due in 6 months; I/M corrections, immediately New Source Review (NSR) program due 2 years (corrections to existing, also) Plan for 15% VOC reduction within 6 years is due in 3 years RACT: Existing & future CTG’s & RACT on major sources (existing due in 2 years) Stage II gasoline vapor recovery due in 2 years Basic I/M (if not already required) due immediately Demonstration of attainment in 4 years Plan for 3% annual average reductions due in 4 years Enhanced I/M due in 2 years Clean fuel program due in 4 years (if applicable) VMT demonstration due in 6 years (TCM program if needed) Specific NSR requirements for modifications to existing sources Measures to offset VMT growth (108(f) measures) due in 2 yrs Contingency measures if miss milestone Requirement for fee on major sources if fail to attain No waivers from 15% or 3% reduction requirements Clean fuels requirement for boilers (plan in 3 years) Traffic controls during congested periods Marginal Moderate Serious Severe Extreme

26. What happens if the SIP is not approved? US EPA is required to begin the “sanctions” process. A sanctions letter is issued to the state that provides up to 18 months to fix problem After 18 months, two for one offsets are required in nonattainment area After 6 months, US EPA will stop federal highway money from going to the nonattainment area.

27. PM 2.5

28. PM2.5 Air Quality Standard Annual standard – 15 ug/m3, averaged over a three year period 24-hour standard- 65 ug/m3 (old), 35 ug/m3 (newer) Anticipate new review with possible revised standards in early 2012. Keeps getting delayed.

29. Annual PM2.5 (15.0 ug/m3)

30. PM2.5 Annual Concentrations (ug/m3) Highest in Area City05-0706-0807-0908-10 Akron14.914.013.713.2 Canton *16.114.814.313.8 Cleveland16.815.114.413.6 Columbus14.913.713.012.5 Cincinnati17.315.715.014.4 Dayton15.514.113.713.1 Steubenville16.114.814.213.0 Toledo14.413.112.611.7 Youngstown14.813.613.012.3 *Incomplete Data Standard is 15.0 ug/m3

31. 24-Hr PM2.5 (35 ug/m3)

32. PM2.5 24-hour Concentrations (ug/m3) Highest in Area City05-0706-0807-0908-10 Akron373433 Canton *363534 Cleveland42383633 Columbus38323029 Cincinnati41353231 Dayton37323129 Steubenville38373430 Toledo35313231 Youngstown36323129 *Incomplete Data Standard is 35 ug/m3

33. Annual PM2.5 Attainment All areas attaining based on 2007-2009 data. Submitted Clean Data request on April 1, 2010. But, no time to celebrate, EPA is making a health assessment review of annual standard – recommending between 11-13 ug/m3 with strong support for 11-12 ug/m3

34. Annual PM2.5 Redesignation Process Preparing redesignation requests for all areas except Canton (*did not meet criteria) – Cincinnati-Hamilton area submitted in December 2010. U.S. EPA anticipates final action on the request in December 2011. – Columbus, Dayton-Springfield, Huntington-Ashland, Cleveland-Akron-Lorain submitted throughout 2011 and U.S. EPA is reviewing those. No proposals to date. – Ohio EPA continues to work on Steubenville-Weirton, Parkersburg-Marietta and Wheeling area requests along with WVA. Anticipate early 2012 submittals to U.S. EPA.

35. Attaining the 24-Hr PM2.5 Standard Designations December 14, 2009. Only three areas designated nonattainment: – Cleveland-Akron – Canton (showed attainment but did not meet 75% capture) – Steubenville (due to WV monitor) SIPs due December 2012 unless clean data requests are submitted. Likely will do. Initial modeling shows only Cleveland will not meet the standard by 2015 with current controls. – Will likely use weight-of–evidence approach with on-the books controls.

36. Attaining the 24-Hr PM2.5 Standard: Cleveland Local issue (“flats”): Seven county nonattainment area even though only 3 monitors in Cleveland have shown nonattainment. PM2.5 RACT may be necessary.

37. Cross-State Air Pollution Rule

38. Clean Air Interstate Rule (CAIR) US EPA developed rules called Clean Air Interstate Rules (CAIR) to reduce emissions of nitrogen oxides (NOx) and sulfur dioxide (SO2) from power plants in the eastern US – Helps reduce ozone and PM and reduces visibility impairment Ohio has many coal-fired power plants and is a large emitter of NOx and SO2 CAIR was going to require substantial emission reductions across eastern US and Ohio CAIR remanded December 23, 2008

39. Clean Air Transport Rule (CATR) –proposed Cross-State Air Pollution Rule (CSAPR) - final July 6, 2010, U.S. EPA proposed a replacement to the CAIR program, the Transport Rule. On July 6, 201, U.S. EPA finalized the replacement rule, the Cross-State Air Pollution Rule (CSAPR) Will provide greater reductions than CAIR. – Necessitate year-round operation of existing SCR, SNCR and scrubbers. – Necessitate addition of pre-combustion NOx controls – Necessitate installation of new scrubbers for many sources. Two phases: 2012 and 2014

40. Ohio EGU CSAPR Budgets vs Historical Emissions (tons) Budgets Historic **CSAPR will produce substantial emission reductions in Ohio 20122014 NOx Ozone 40,06337,792 NOx Annual 92,70387,493 SO2 310,230 (464,964 proposed) 137,077 (178,307 proposed) 20052009 NOx Ozone 51,87536,076 NOx Annual 254,45298,780 SO2 1,085,485600,689

41. Lead

42. Lead Standard Revised October 15, 2008 – from 1.5 ug/m3 to 0.15 ug/m3 as a rolling 3-year monthly average. Two rounds – existing monitors and expanded monitoring network based on modeling potential violations from stationary sources. Designations from first round were effective December 31, 2010. All areas are partial counties: – Fulton County – City of Delta area – Bunting Bearings Facility – Cuyahoga County – area surrounding Ferro Corporation – Logan County – south of City of Bellefontaine – Daido Facility (shutdown) Four new monitoring sites added for second round…..so far no monitored violations at the new sites. Designations from second round were effective November 8, 2011 – no new Ohio areas.

43. Lead Standard – Ferro “Situation” Cleveland – has processes that use 98% lead (lead oxide) powder. Highest three month average from 2005-2009 is 0.173 ug/m3. 2010 and 2011 spikes as high as 2.57 ug/m3, Looking at other potential sources located near the monitor (scrap yards, steel) Investigating Ferro operations in detail. Attainment demonstration due July 2012. Attainment date ~January 2016

44. Nitrogen Dioxide

45. New Standard – NO2 New standard effective April, 12, 2010. The annual primary standard remains the same at 53 ppb A 1-Hour standard is added: 100 ppb, which is met when the three year average of annual 98 th percentile values are less than or equal to 100 ppb

47. Ohio Attaining new 1-hour…for now Currently the only areas monitored in Ohio (Athens, Cincinnati and Cleveland) show attainment. – Highest 3-year averages between 2002 and 2009 are 66 ppb in Cincinnati and 72 ppb in Cleveland Only county that currently fails is Cook Co., Illinois (Chicago), monitor next to bus stop. Expanded monitoring network requires two types of monitors: – Area wide (community) where CBSAs > 1,000,000 – Near roadway where CBSAs > 500,000 Monitoring plan due by July 2012 and network established by January 2013.

48. Monitors needed in Ohio City2008 Population Road Monitors Community Monitors Current Monitors* Akron698,553100 Cincinnati2,155,137111 Cleveland2,088,291111 Columbus1,773,120110 Dayton836,544100 Toledo649,104100 Youngstown565,947100 U.S. EPA is scaling back the regulatory monitoring requirements. Will do phases starting with one area in Ohio - Columbus

49. NO2 Timeline Ohio EPA submitted nonattainment recommendations based on current monitors by January 5, 2011 – All areas unclassifiable until new monitors in place Final designations were issued by U.S. EPA on August 15, 2011 – no Ohio areas. After other monitors are installed and three years of data collected (2013-2015), additional designations will occur. Attainment demonstration due July 22, 2013 Attainment date ~January 2017

50. NSR Issues For permits issued by states with SIP-approved programs, permits issued on or after April 12, 2010 must contain compliance demonstration for 1-hour NO 2 NAAQS Although this effort appears to be mobile source driven, stationary sources are quickly being pulled in Modeling shows emergency generators exceed standard Two sources that emit only 7 lb/hr combined with 65 foot stacks, just meet standard

51. Sulfur Dioxide

52. New Standard – SO2 New standard effective August 23, 2010. Old Standard – 140 ppb – 24 hour average. New Standard– 75 ppb – 1 hour average. Requires expanded monitoring network based on population: – 3 monitors in CBSAs >1,000,000 – 2 monitors in CBSAs >100,000<100,000 – 1 monitors in CBSAs >5,000 Monitoring plan submitted in July 2011 and network established by January 2013.

53. Monitors needed in Ohio AreaPWEIMonitors NeededMonitors in Area* Cincinnati532,72822-OH, 1-KY Cleveland299,23026 Marietta36,72510-OH, 1-W Va. Steubenville27,66011-OH, 7-W Va. Columbus24,96510 Wheeling, WVa.22,28211-OH, 1-W Va. Toledo18,90110 Point Pleasant10,37210 Dayton9,90210 Akron9,06612 *The monitors in the area now are not necessarily properly located to fulfill the requirements

55. Sulfur Dioxide Concentrations 4 th high averages 2007-2009 2007-2009 101-300 ppb 76-100 ppb 0-75 ppb

56. Ohio Currently Not Attaining Nonattainment area recommendation submitted to U.S. EPA on June 3, 2011 (2008-2010 data): – Partial Belmont County (Mead, Pease, Pultney, and York Townships) at 80 ppb. – Partial Jefferson County (Cross Creek, Island Creek, Knox, Saline, Steubenville, Warren, and WellsTownships) at 116 ppb – Partial Columbiana County (Liverpool and Yellow Creek Townships) at 90 ppb – Partial Meigs County (Salisbury Township) and Partial Gallia County (Cheshire Township) at 89 ppb – Lake County at 163 ppb – Partial Morgan County (Center Township) and Partial Washington County (Waterford Township) at 195 ppb

57. Ohio Currently Not Attaining Unclassifiable and Attainment areas also recommended (2008- 2010 data): – 47 counties recommended as unclassifiable Cuyahoga County was also recommended as unclassifiable although one monitor barely exceeded the standard at 76 ppb. This monitor did not meet the minimum collection criteria and the federal rules allowed for data analysis that showed had additional data been collected the monitor would have attained. – 36 counties with low SO2 emissions recommended as attainment Lists can be found at: http://www.epa.ohio.gov/portals/27/SIP/SO2/2010_SO2_Standard_Recommended_ Nonattainment_Areas-Final.pdf http://www.epa.ohio.gov/portals/27/SIP/SO2/2010_SO2_Standard_Recommended_ Nonattainment_Areas-Final.pdf

58. Ohio Currently not Attaining U.S. EPA should make final designations by June 2012. There will be an opportunity to comment 2009-2011 (through 10/2011)air quality data for Belmont County indicates significant improvement. Ohio EPA may be requesting Belmont County be designated unclassifiable rather than nonattainment

59. SO2 Timeline Final designations by USEPA June 2012 After other monitors are installed and data collected, additional designations will occur. Basic plan (e.g. “maintenance” or “infrastructure”) due June 2013 – Implementation plan for attainment and unclassifiable areas; includes: Need for all modeling to be done so those with proven attainment can have plans developed. Any required regulations be in place (e.g., limits necessary for attainment area sources). Attainment demonstration for nonattainment areas due February 2014. Attainment date ~August 2017.

60. Dispersion Modeling– SO2 – Infrastructure SIP requires dispersion modeling to identify sources with potential to violate standard. Threshold somewhere around 100 TPY. – Based on the 2008 inventory, Ohio has 221 sources emitting >100 TPY (actual emissions). 139 non-EGUs and 82 EGUs – Tighter SO2 emission limits will need to be developed for many sources in order to model attainment.

61. Carbon Monoxide (2011) In 2011, U. S. EPA reviewed the carbon monoxide standard and decided not to change the standard Ohio measures attainment statewide

63. The End