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Air Quality Update
December, 2008, Vol 11, No 4
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OZONE SEASON 2008 RECAP

Just before the ozone season began in 2008, the highly anticipated changes to the ozone standards were announced by EPA. On March 12, 2008, EPA significantly strengthened its national ambient air quality standards (NAAQS) for ground-level ozone, the primary component of smog. These changes will improve both public health protection and the protection of trees and plants. EPA revised the 8-hour “primary” ozone standard, designed to protect public health, to a level of 0.075 parts per million (ppm). The previous standard, set in 1997, was 0.08 ppm. Because ozone is measured out to three decimal places, the standard effectively became 0.084 ppm as a result of rounding. EPA also strengthened the secondary 8-hour ozone standard to the level of 0.075 ppm making it identical to the revised primary standard. EPA decided to strengthen the secondary ozone standard after concluding that the 1997 secondary standard was not adequate to protect public welfare.

The 2008 ozone season began early with four days in April showing concentrations of ozone above the new 0.075 ppm eight hour average standard. May and June were good months for the new standard with only one day late in June having high ozone levels. There were five days in July, six days in August, three days in September and one day in October with ozone levels over the new standard. The new, more stringent ozone standard made this year appear to be a bad one for ozone, but in reality the ozone concentrations were lower overall than in recent years. The old standard, 0.084 ppm, was exceeded only three times and all three exceedances occurred at the Tulsa North site. The three year averages of the 4th high concentrations show that four sites are over the new standard. Those sites include Tulsa North, Tulsa East, OKC North (OCUSA) and OKC (Choctaw).



OCTOBER AIR QUALITY ADVISORY COUNCIL MEETING NETS PASSAGE OF SEVERAL RULES, CONTINUATION OF OTHERS

The Air Quality Advisory Council held its final 2008 meeting in October at the Department of Environmental Quality headquarters in Oklahoma City. The agenda for the meeting included hearings on several proposed rules for Chapter 100 of the Oklahoma Administrative Rules. The Council voted to recommend the following three rules be forwarded to the Environmental Quality Board for consideration at its November 18 meeting in Tahlequah:

  • Proposed changes to Subchapter 25, Visible Emissions and Particulates, would correct a rule reference error in the existing rule.

  • Appendices E, Primary Ambient Air Quality Standards, and F, Secondary Ambient Air Quality Standards, will be updated to be consistent with federal standards for ozone.

  • Appendix Q, Incorporations by Reference, is being updated to incorporate the latest changes to federal regulations by reference. Changes include the addition of New Source Performance Standards (NSPS) and Part 63 National Emissions Standards for Hazardous Air Pollutants (NESHAP) for area sources.

All three rules were subsequently approved by the Board at the November 18 meeting.

The Council voted to hold two proposed rules over to the January 2009 meeting for further consideration. Changes to Subchapter 9, Excess Emission Reporting Requirements, are intended to clarify its requirements and make them more compatible with EPA guidelines. Revision of Subchapter 33, Control of Emission of Nitrogen Oxides, is being proposed to resolve issues regarding emission standards for nitrogen oxides from fuel-burning equipment. The changes would address emission standards for direct-fired fuel-burning equipment, fuel-burning equipment that uses more than one type of fuel, and equipment with technological limitations.

A new Council member was appointed by the Governor in October. Mr. Gary Collins with Terra-Nitrogen will represent the agriculture industry. Mr. Collins' appointment fills the unexpired term of Mr. Rick Treeman, who resigned in July. Mr. Collins' term will expire in 2010. The recent appointment leaves just one vacancy on the Council.

The next Council meeting is scheduled to be held at the DEQ headquarters in Oklahoma City on Wednesday, January 21, 2009.


AP-42 EMISSION FACTOR UPDATES

Currently, EPA lists two chapters under review. Comments on Chapter 2, Section 4: Municipal Solid Waste Landfills, are due by January 5, 2009. The comment period on Chapter 12, Section 5.2: Steel Minimills, closes on December 4, 2008. Instructions for using draft sections that have completed the comment period but are not designated as “final” are available on the webpage listed below.

Find more AP-42 information on EPA’s TTN-CHIEF Bulletin Board at http://www.epa.gov/ttn/chief/ap42/index.html.


LEAD-BASED PAINT CERTIFICATION RENEWAL

All current LBP certifications will expire March 31, 2009. Lead-Based Paint (LBP) applications for the next certification year will be accepted beginning January 15, 2009. Applicants are reminded to be certain all LBP quarterly reports for the current certification year have been submitted to DEQ prior to submitting a renewal application. Renewals cannot be approved until all of the applicant’s quarterly reports are complete. Individuals renewing their LBP certification for 2009-2010 have already met the State of Oklahoma’s citizen documentation requirements. DEQ only requires certified individuals to verify their citizenship status once. Individuals certified to perform LBP activities in Oklahoma are listed on our website at www.deq.state.ok.us. Currently, the number of individuals and firms certified by DEQ to perform lead-based paint activities by discipline are:

57

Abatement Workers

3

Inspectors

81

Inspectors/Risk Assessors

3

Project Designers

61

Supervisors

68

Firms


2009 EMISSIONS INVENTORY WORKSHOP

The annual workshops will be held on Thursday, January 22, 2009 at the Metro Technology Center’s Springlake Campus in Oklahoma City, and again on Thursday, January 29, 2009 at the OSU-Tulsa campus. As with last year there will be optional basic training from 9 AM to Noon, as well as the main workshop between 1 PM and 4 PM on each day.

The morning session will cover basic training on how to submit an emissions inventory. Attendance is especially encouraged for personnel completing an inventory for the first time in 2009. Air Quality Staff will provide hands-on training in Redbud, Oklahoma’s web-based electronic reporting system. Wi-Fi internet access will be available. Attendees are encouraged to bring their laptops and Redbud passwords to follow the data entry and submittal process. The afternoon session will cover general emissions inventory topics, including improvements to the reporting process, a review of quality control procedures, and suggestions about how to avoid common errors. It will conclude with a question-and-answer session.

To register, please contact Steve Hopkins or (405) 702-4172.


COMING SOON: GENERAL PERMIT FOR AREA SOURCE NESHAP FACILITIES

The Air Quality Division (AQD) is currently drafting a general permit (GP) for facilities that must obtain a permit because they are subject to an area source NESHAP issued by EPA.

NESHAPs (National Emission Standards for Hazardous Air Pollutants) under 40 CFR Part 63 require certain industrial categories to apply the maximum achievable control technology (MACT) to control hazardous air pollutant (HAP) emissions. Most of the NESHAPs initially issued by EPA apply only to major sources of HAPs. However, several apply to “area sources,” which are those with emissions less than the major source threshold of 10 TPY of any single HAP or 25 TPY of total HAPs. Under its air toxics strategies, EPA identified additional categories of area sources for standards development, and has now completed NESHAPs for most of these area source categories. The remaining area source NESHAPs are scheduled for completion by June 15, 2009. In developing the area source standards, EPA must consider MACT, but may also consider “generally available control technologies or management practices” (GACT).

AQD exempts most small facilities from the requirement to get a permit – those with actual emissions less than 40 tons/year (TPY) of any regulated pollutant, and potential emissions less than major source levels – 100 TPY of any regulated pollutant, less than 10 TPY of any single HAP, and less than 25 TPY of total HAPs. However, a new or modified facility that is subject to a NESHAP does not qualify for this exemption (see definitions of “permit exempt facility” and “de minimis facility” under OAC 252:100-7-1.1 of AQD’s rules). The new GP is for facilities that would be exempt from permitting if not for an applicable NESHAP.

Although the focus of the GP is on area source NESHAP facilities, small facilities that are subject to one or more of the NSPS (New Source Performance Standards) under 40 CFR Part 60 may be in the same situation. Therefore, the GP has been written to also include facilities that would be exempt from permitting if not for an applicable NSPS.

The general permit is designed to minimize the burden on small facilities that are affected by these Federal requirements. As much as possible, it is designed to use the notification requirements under the NESHAPs and NSPS to fulfill AQD’s application requirements for construction and operating permits.

Once completed, a copy of the draft General Permit for Area Source NESHAP Facilities and Small NSPS Facilities will be posted on DEQ’s web site at www.deq.state.ok.us, along with fact sheets and GP application forms as they are developed. You will find information on other General Permits issued by AQD there as well. AQD is also developing plans for an outreach program to facilities affected by the Area Source NESHAPs.

Table 1:  Area Source NESHAPs (40 CFR Part 63) Covered by GP

Subpart

Area Source Category

Subpart

Area Source Category

LLLLLL

Acrylic and Modacrylic Fibers Production

HHHHHH

Paint Stripping, Miscellaneous Surface Coating Operations

NNNNNN

Chemical Manufacturing: Chromium Compounds

WWWWWW

Plating & Polishing

RRRRRR

Clay Ceramics Manufacturing

DDDDDD

Polyvinyl Chloride and Copolymers Production

O

Commercial Sterilization Facilities

VVV

Publicly Owned Treatment Works

OOOOOO

Flexible Polyurethane Foam Fabrication and Production

ZZZZ

Reciprocating Stationary Internal Combustion Engines (RICE) – New*

BBBBBB

Gasoline Distribution Bulk Terminal, Bulk Plant and Pipeline Facilities

X

Secondary Lead Smelting

CCCCCC

Gasoline Distribution, Gasoline Dispensing Facilities

TTTTTT

Secondary Nonferrous Metals

WWWWW

Hospital Sterilizers – Ethylene Oxide

RRR

Secondary Aluminum Production

PPPPPP

Lead Acid Battery Manufacturing

ZZZZZ

Steel and Iron Foundries

AAAA

Municipal Landfills

QQQQQQ

Wood Preserving

XXXXXX

Metal Fabrication and Finishing – 9 Source Categories:

 

        Electrical and Electronic Equipment Finishing Operations
        Fabricated Metal Products [not elsewhere classified]
        Fabricated Plate Work (Boiler Shops);
       Fabricated Structural Metal Manufacturing

       Heating Equipment, Except Electric
       Industrial Machinery and Equipment: Finishing Operations
       Iron and Steel Forging
       Primary Metal Products Manufacturing
       Valves and Pipe Fittings

*Facilities that do not qualify for AQD’s general permit for minor oil & gas facilities (see related discussion below).


Table 2:  Proposed Standards (as of 11/1/2008)

Subpart

Proposal Date*

Area Source Category

YYYYYY

09/15/08

Ferroalloys Production

VVVVVV

10/06/08

Chemical Manufacturing Industry – 9 Source Categories:

 

 

        Agricultural Chemicals & Pesticides Manufacturing
        Cyclic Crude & Intermediate Production
        Industrial Inorganic Chemical Manufacturing
        Industrial Organic Chemical Manufacturing

        Inorganic Pigments Manufacturing
        Miscellaneous Organic Chemical Manufacturing (MON)
        Pharmaceutical Production
        Plastic Materials and Resins Manufacturing
        Synthetic Rubber Manufacturing

*Federal Register Notice Publication Date


Table 3:  Standards Scheduled for Promulgation

Promulgation Deadline

Area Source Categories

Promulgation Deadline

Area Source Categories

June 15, 2009

Aluminum Foundries

June 15, 2009

Institutional/Commercial/ Industrial Boilers

June 15, 2009

Asphalt Processing & Asphalt Roofing Manufacturing

June 15, 2009

Nonferrous Foundries

June 15, 2009

Brick & Structural Clay

June 15, 2009

Paints & Allied Products Manufacturing,

June 15, 2009

Chemical Preparations

June 15, 2009

Prepared Feeds Manufacturing

June 15, 2009

Copper Foundries

June 15, 2009

Sewage Sludge Incineration



AQD AT THE NATIONAL WEATHER FESTIVAL 2008

On November 8, 2008, the third annual National Weather Festival was held at the National Weather Service (NWS) Center in Norman, Oklahoma. Each year the festival provides educational material to the public and exhibits one of the world’s most sophisticated severe weather forecasting centers.

In the main exhibit area of the NWS Center, AQD personnel provided information on the Air Quality Index (AQI), and provided the opportunity for anyone to sign up for e-mailed health advisories for ozone and particulate matter. A laptop computer played a video on air pollution and the AQI that was cooperatively created by the National Oceanic and Atmospheric Administration (NOAA) and the Environmental Protection Agency (EPA).

AQD Presenters in the children’s activity area spoke with children, parents, teachers and community leaders about air quality. Hands-on games demonstrated how changes in human, industrial and weather activity can affect air quality. Handouts and other educational materials on air quality and the environment were made available to all attendees.

The Weather Festival was judged a huge success and offered attendees a greater understanding of air quality, air pollution and how these factors can affect public health.

Weather Festival


PERMIT APPLICATIONS POSTED ON DEQ WEBPAGE

In an effort to make public review opportunities more accessible to a broader audience, permits applications for some Tier II and all Tier III projects and an archive of all issued permits are now posted to the DEQ webpage. For the immediate future, web-posting of Tier II applications will be limited to Prevention of Significant Deterioration (PSD) construction projects and Best Available Retrofit Technology (BART) Title V operating permit modifications. PSD construction permits are developed for new major sources (Tier III) and modifications to existing major sources (Tier II or III). Major sources have the most significant individual impact on air quality in Oklahoma and appropriately should receive the greatest opportunities for public review. As the Department continues the process of moving away from paper and more toward electronic media, more documents will be available for public review on the web. This increased availability now includes a full archive of issued permits.

Issued permits previously available through requests to permitting staff and central records are now available on the web. Permits are available as Microsoft Word documents via anonymous ftp. A searchable listing is provided in the ftp directory in .xls and .txt formats. Newly issued permits will be added to this archive at the end of each month.

Links for the permit applications and permit archives can be found on the AQD Permit page under applications and permits for public review.

http://www.deq.state.ok.us/aqdnew/permitting/pubreview.htm


AQD RESPONDS TO NEW EPA LEAD STANDARD

As of October 15, 2008, EPA strengthened the national ambient air quality standards (NAAQS) for lead from 1.5 micrograms per cubic meter (µg/m3) to a much lower 0.15 µg/m3. The revision is the first for lead since the initial standard of 1.5 µg/m3 established in 1978. The new standard is the same for both the primary (health-based) and secondary (welfare-based) standards. Under the new standard EPA is requiring lead to be monitored as “lead in total suspended particulates (TSP)”. Lead will be monitored nationwide in 101 urban areas with populations greater than 500,000. In Oklahoma, this includes only the Tulsa and Oklahoma City areas. Source specific monitoring will also be conducted in areas with sources of lead that emit one ton or more per year. EPA has established a timeline requiring half of the monitors to be operational by January 1, 2010, and the second half of the monitors operational by January 1, 2011. States must classify areas to be designated as attainment, nonattainment, or unclassifiable by October 2009; final designations should be no later than January 2012. States must also submit State Implementation Plans (SIPs) by June 2013.

The revision to the lead NAAQS has resulted from over 6,000 new studies on lead health and environmental effects. The studies have shown evidence of adverse effects of lead at substantially lower levels in the blood than previously thought. Exposures to low levels of lead in childhood have been linked to effects on learning, IQ, memory, and behavior. Therefore children are the most vulnerable to the damaging effects of lead. The main course of lead exposure is from ingestion once lead settles out of the air. After ingestion, lead is quickly absorbed into the bloodstream.

The lead NAAQS revision is estimated to yield health benefits valued between $3.7 and $6.9 billion. This reflects an expected increase in lifetime earnings due to prevention of IQ loss. However, EPA has also estimated the cost of implementing the standard to be approximately $150 million to $2.8 billion.

Recently collected lead values from 3 Tulsa area sites indicate that Oklahoma should be able to meet the new lead NAAQS standard in that area. It remains to be seen whether or not an urban site in the Oklahoma City area or source-oriented sites elsewhere will show similarly low concentrations. The Air Quality Division is planning the installation of a population oriented site in Oklahoma City within the next year. Air Quality staff are also evaluating the need for additional source oriented sites.

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