|December, 2007, Vol 10, No 4|
Abundant rainfall helped curb the 2007 ozone concentrations in Oklahoma. This was a drastic improvement from the 2006 ozone season which was much hotter and dryer in comparison. There were only four days in 2007 with ozone concentrations which exceeded the standard as compared to 15 days in 2006. Only 5 of the 16 ozone monitoring sites recorded eight-hour average ozone concentrations greater than .084 parts per million in 2007, while 12 of the 16 monitors showed such readings in 2006. No monitoring sites recorded ozone concentrations which exceeded the old one hour standard of .12 parts per million. The three year averages of the 4th high concentrations saw very little change because the 2004 concentrations were comparable to the 2007 concentrations.
The term "particulate matter" (PM) includes both solid particles and liquid droplets found in air. Particles less than 2.5 micrometers in diameter (PM2.5) are referred to as "fine" particles and are believed to pose the largest health risks. Because of their small size (less than one-seventh the average width of a human hair), fine particles can lodge deeply into the lungs. Sources of fine particles include all types of combustion activities (motor vehicles, power plants, wood burning, etc.) and certain industrial processes.
Health studies have shown a significant association between exposure to fine particles and premature mortality. Other important effects include aggravation of respiratory and cardiovascular disease, lung disease, decreased lung function, asthma attacks, and certain cardiovascular problems such as heart attacks and cardiac arrhythmia. Individuals particularly sensitive to fine particle exposure include older adults, people with heart and lung disease, and children.
In 1997, EPA established annual and 24-hour National Ambient Air Quality Standards (NAAQS) for PM2.5 for the first time. In 2006, EPA reviewed the PM2.5 NAAQS. The annual standard remained at 15 µg/m³, while the 24-hour standard was lowered from 65 to 35 µg/m³. EPA plans to designate geographic areas as attaining or not attaining the 2006 24-hour PM2.5 standards by December 18, 2008. States must submit their recommendations for area designations to EPA by December 18, 2007. The map below shows those areas where monitors have reported PM2.5 values above the standard and may be designated as non-attainment areas.
Beginning in 2009, the DEQ will begin collecting PM Coarse data (PMC). Although a new standard has not been promulgated, monitoring will be conducted in order to support continuing research on particle distribution, sources, and health effects.
PM-Coarse (PMC) is the difference measured by subtracting PM2.5 from PM10. Initially this measurement will be achieved using two separate instruments that have been approved separately as PM10 and PM2.5 Federal Reference Methods. Specifically, AQD will begin using sequential PM2.5 samplers for PM2.5 sampling as well as a PM2.5 sampler that has had the particle separator removed for PM10 sampling.
Currently no federally approved continuous methods for PMC are available; however, several vendors are applying for equivalency designation. One of the candidate methods is the 1405DF Filter Dynamic Measurement System (FDMS) using a Tapered Element Oscillating Microbalance (TEOM) to calculate the mass of the filter. This method operates by splitting a portion of the sample stream to measure PM10 and PM2.5 on two separate TEOMs. Another candidate method, the Beta Attenuation Monitor (BAM), operates by collecting particles on a filter tape and subjecting the tape to a stream of β-particles and detecting the difference in β-particle absorption between the clean filter tape and the particle laden filter tape. Size separators appear to be used by both methods and will use simple subtraction to arrive at a PM-Coarse reading.
Nationwide, each state will be required to operate, at a minimum, one PMC site. These will for the most part be located in the larger metropolitan areas to determine population exposure. There will be some sites located in rural areas to determine sources and exposure in less populated areas.
It isn’t known when a new PMC standard will be promulgated, but DEQ Air Quality Division Monitoring Section will be involved in the collection of data to help with the decision-making process for determining the level of any potential new standard. For further information on PMC monitoring please reference the Code of Federal Regulations (CFR) 40 parts 53 and 58.
2008 Emissions Inventory Workshop
The annual workshop will be held on Wednesday, January 16, 2008 at the Metro Tech Spring Lake Campus in Oklahoma City, and again on Wednesday, January 23, 2008 at the OSU-Tulsa campus. As with last year, there will be an 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 2008. Laptop computers will be available to allow hands-on training on Redbud, the DEQ web-based reporting system. 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.
Consideration of Fee Increase, Changes to Excess Emission Requirements Extended to January 2008 AQ Advisory Council Meeting
The Air Quality Advisory Council held its final meeting of the year on October 17, 2007 in Oklahoma City. The agenda for the meeting included hearings on several proposed rules for Chapter 100 of the Oklahoma Administrative Rules, as well as a presentation on Subchapter 19, Control of Emission of Particulate Matter.
Members approved their meeting schedule for the 2008 calendar year as follows:
The Council voted to forward Appendix Q, Incorporation by Reference, to the Environmental Quality Board (EQB) for consideration at its November 15, 2007 meeting. The appendix was updated to include the most recent EPA changes to Title 40, Code of Federal Regulations. The EQB approved Appendix Q at its November meeting, as well as the following rules that were recommended to the Board at previous Air Quality Advisory Council meetings:
The Department proposed a revision to Subchapter 5, Registration, Emission Inventory and Annual Operating Fees, to increase annual operating fees for both minor facilities and for Part 70 sources. Additional income resulting from a fee increase is needed to cover current and anticipated staffing requirements in administering the Department’s programs. The Council voted to hold this rule over to the January Council meeting for further consideration.
Also held over to the January meeting were proposed changes to Subchapter 9, Excess Emission Reporting Requirements. The changes would make the rule consistent with the current interpretation of the EPA guidelines on excess emissions.
The Council voted to table proposed changes to Subchapter 17, Incinerators until further notice, pending final approval of EPA’s reconsideration of the Large Municipal Waste Combustors rule.
Mr. Dawson Lasseter, Engineer Manager with the Air Quality Division, presented the second phase of a summary of Subchapter 19, Control of Emission of Particulate Matter. Recommendations included clarification of existing algorithms and otherwise no change in the rule unless future data identifies a PM problem that can be addressed by altering Subchapter 19.
The next Council meeting will be held in Oklahoma City on Thursday, January 17, 2008.
On January 3, 2007, EPA promulgated changes to the “NESHAP for Oil and Natural Gas Production Facilities,” 40 CFR Part 63, Subpart HH, to include area source requirements. Of particular importance to facilities in Oklahoma is that most triethylene glycol (TEG) dehydration units are now subject to Subpart HH and all such units are subject to a requirement under Subpart HH unless they meet certain exemptions in the rule.
A TEG dehydration unit is exempt from emission reduction requirements if its actual annual average natural gas flow rate is less than 3 Million Standard Cubic Feet per Day (MMSCFD) or if its actual average emissions of benzene are less than 1.0 TPY. Any source meeting either of these criteria is also exempt from any reporting requirements, including initial notification. However, the source must maintain annual records demonstrating that the TEG dehydration unit meets one of the exemptions. Benzene emissions must be either uncontrolled, or with federally enforceable controls in place (in which case an operating permit is required).
TEG dehydration units that are not exempt from emission reduction requirements of the rule are required to have an operating permit. Existing facilities covered by an individual permit will most likely need a permit modification to include conditions to address control requirements under the rule, e.g., operate the dehydrator at a glycol circulation rate that is less than or equal to an “optimum circulation rate.” However, existing facilities operated under the General Permit for Oil & Gas Facilities (GP-OGF) do not need to modify their Authorization, or obtain a new Authorization to address these requirements since they are already incorporated into the General Permit. Owners/operators should obtain any needed permit modifications or coverage under the General Permit as soon as possible.
Compliance dates and control requirements under the rule are based on whether the unit is located within high population density areas, which are defined and referred to in the rule as an “Urban-1 county” and a “Urban Area (UA) plus offset and Urban Cluster (UC) boundary.” TEG dehydration units within a UA plus offset and UC boundary must comply with the same control requirements as a unit located at a major source of Hazardous Air Pollutants (HAP). TEG dehydration units outside of a UA plus offset and UC boundary must be operated at a glycol circulation rate that is less than or equal to an “optimum circulation rate”, which is defined in the rule.
Affected sources constructed or reconstructed before February 6, 1998 located in an Urban-1 county must achieve compliance by January 4, 2010, if located within any UA plus offset and UC boundary, or by January 5, 2009, if not located within any UA plus offset and UC boundary. Affected sources constructed or reconstructed on or after February 6, 1998 located in an Urban-1 county were required to achieve compliance upon startup or by January 3, 2007 whichever was later. Affected sources constructed or reconstructed before July 8, 2005 not located within an Urban-1 county must achieve compliance by January 4, 2010, if located within a UA plus offset and UC boundary, or by January 5, 2009, if not located within a UA plus offset and UC boundary. Affected sources constructed or reconstructed on or after July 8, 2005 not located in an Urban-1 county must achieve compliance upon startup.
Initial notifications must be submitted by January 3, 2008 if startup was prior to January 3, 2007. Otherwise the notification is due 180 days after the source becomes subject to the standard.
Note that although the rule appears to require that the initial notification be submitted to DEQ with a copy to EPA Region VI [per 40 CFR 63.9(b)], the owner or operator need not submit a copy of the initial notification to EPA. Oklahoma has been delegated authority to implement the NESHAP program, thus all notifications need only be submitted to DEQ (70 FR 73595).
If the source is located within a UA plus offset and UC boundary, the owner or operator must also submit the information required in 40 CFR 63.775(c)(2) through (6). If the source is not located within any UA plus offset and UC boundary, the owner or operator must submit the information listed within 40 CFR 63.775(c)(7) with the initial notification.
A “Notification of Compliance Status Report” is also due within 180 days of the compliance date. The rule allows the information required in the “Notification of Compliance Status Report” to be submitted in an operating permit application, an amendment to an operating permit application, or a separate submittal.
Anyone with questions may call (405) 702-4100. Your call will be directed to a member of the permitting staff.
In response to Oklahoma’s new immigration law, the Oklahoma Taxpayer and Citizen Protection Act, which became effective November 1, 2007, the Department of Environmental Quality (DEQ) and the Lead Based Paint (LBP) program of Oklahoma has changed its procedures for obtaining initial or renewal LBP certifications. The Act requires that all state agencies verify “lawful presence” of any natural person over the age of 14 applying for state benefits, including LBP certifications.
As a result of the new immigration law (HB 1804), applicants who are United States citizens must provide a document to DEQ from each of the following three categories:
1. A copy of a valid, unexpired driver’s license or photo-identification card from state of residency; AND
For all non-U.S. citizens, applicants must provide to DEQ an Affidavit Regarding Citizenship signed in the presence of a notary public and documentation demonstrating “lawful presence.” A list of acceptable documents is posted on DEQ’s Web site at www.deq.state.ok.us or applicants can call Richard Hooper at 405-702-4100.
Additionally, DEQ is required to enter all non-U.S. citizens into the Department of Homeland Security’s Systematic Alien Verification for Entitlements (SAVE) program in order to verify eligibility for LBP certifications.
DEQ will notarize Affidavits Regarding Citizenship at no cost at the agency’s Oklahoma City office during normal business hours. Applicants can also have the affidavit notarized at their own expense by any notary public. Applications can be dropped off in person or sent by mail.
When the new National Weather Service (NWS) Center in Norman opened in the fall of 2006 it started a tradition of holding a National Weather Festival. The annual festival was created to demonstrate the capabilities of the new center and to provide weather education for the public.
An estimated 2000 attendees participated in this year’s Weather Festival on October 20, 2007. The Air Quality Division was represented for the first time. Crystal K. Stearns, Melissa Sims, and Margaret Robertson spoke with children, parents and teachers about air quality. Through computerized exercises like smogcity2.com they were able to demonstrate how changes in human and weather activity can affect our air quality. Exercises from airnow.gov and epa.gov helped explain the Air Quality Index (AQI) and its different ratings. A laptop computer played a video about air pollution and the AQI that was created by the National Oceanic and Atmospheric Administration (NOAA) and EPA. Handouts and other educational materials on air quality and the environment were made available to all attendees.
The Weather Festival was a huge success. Many children and adults were reached with the educational exercises and documents presented, and left the National Weather Festival with a greater understanding of air quality and how it is affected by man and nature.
AP-42 EMISSION FACTOR UPDATES
Currently, EPA lists three sections under review: Section 12.2, Coke Production; all of Chapter 15, Ordnance Detonation; and Section 12.5.1, Steel Mini-mills. The comment periods for all three are now closed.
Find more AP-42 information on EPA’s TTN-CHIEF Bulletin Board at http://www.epa.gov/ttn/chief/ap42/index.html.
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