NATURAL GAS VEHICLE WORKSHOP
The Department of Environmental Quality is co-hosting a comprehensive one-day workshop on Wednesday, April 1, 2009, for public and private fleet operators and clean-air/clean-transportation policymakers. This workshop will provide a review of the economic, environmental, and national energy security market drivers that are prompting the move to compressed natural gas (CNG)- and liquefied natural gas (LNG)- powered vehicles. Featured presenter is Stephe Yborra, Director of Market Analysis, Education and Communications for the Clean Vehicle Education Foundation. The workshop will be held at the Reed Conference Center at the Sheraton Midwest City, 5750 Will Rogers Rd., Midwest City, OK. For more information or to register online, please visit http://cleanvehicle.org/workshop/OKC.html.
The event is also co-hosted by the Office of the Secretary of the Environment, The Office of the Secretary of Energy, The Oklahoma Department of Commerce, the Department of Central Services, INCOG, ACOG, Tulsa Clean Cities, and the Clean Vehicle Education Foundation.
AIR QUALITY ADVISORY COUNCIL PASSES RULES
AMENDING EXCESS EMISSIONS
AND NITROGEN OXIDES EMISSIONS REQUIREMENTS
The Air Quality Advisory Council held its first meeting of 2009 in Oklahoma City on January 21. The agenda included hearings on two proposed rules for Chapter 100 of the Oklahoma Administrative Rules, as well as two presentations by DEQ officials.
Council members voted to elect Laura Lodes as Chair for 2009, and Jerry Purkaple as Vice Chair. Ms. Lodes represents engineering interests, and Mr. Purkaple represents the petroleum industry.
After considering the proposal at several Council meetings over the past 2 years, members voted to recommend the proposed modifications to Subchapter 9, Excess Emission Reporting Requirements, to the Environmental Quality Board at its February 2009 meeting. More information is available in this issue in the article "Changes to Excess Emissions Reporting Requirements".
Proposed changes to Subchapter 33, Control of Emissions of Nitrogen Oxides, were recommended to the Environmental Quality Board and passed at the February 27 meeting. The changes clarify what types of fuels are covered by the rule, address emission standards for fuel-burning equipment that uses more than one type of fuel and address equipment with technological limitations.
A presentation on mercury in fish was given by Jay Wright of the DEQ's Customer Services Division. Mr. Wright reported that 16 of 35 lakes surveyed contained fish with mercury concentrations above 0.5 mg/kg, Oklahoma’s fish consumption advisory threshold. Eddie Terrill, Air Quality Division Director, noted that this is an important issue for the Department. Over the last three years, the Council and DEQ staff worked on the development of a state rule to regulate mercury from Oklahoma’s coal-fired power plants, but progress has been slowed by the U.S. Court of Appeals vacatur of the Clean Air Mercury Rule. Mr. Terrill affirmed that the Department has not and will not let the issue drop.
Phillip Fielder, Engineering Manager with DEQ's Air Quality Division (AQD), gave a brief presentation on the status of Boiler and Area Source Maximum Achievable Control Technology (MACT). The information presented indicated that the AQD is in the final stages of developing an Area Source MACT General Permit. Also, AQD is currently waiting on EPA guidance to address the issues related to the vacated Boiler MACT standard and is therefore requesting sources to not submit a 112(j) Part I application at this time.
The next Council meeting will be held in at the Tulsa Campus of Oklahoma State University on Wednesday, April 15, 2009.
AP-42 EMISSION FACTOR UPDATES
Currently, EPA lists three chapters under review. Comments on Chapter 2, Section 4: Municipal Solid Waste Landfills, are due by May 5, 2009. The comment period on Chapter 4, Section 12: Manufacture of Rubber Products, closed on February 2, 2009. Chapter 15: Ordance Detonation, has been reopened with comments due by February 20, 2009. 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.
AQD Updates General Permit for Minor Source Oil & Gas Facilities
The Air Quality Division (AQD) recently updated the Minor Source General Permit for Oil and Gas Facilities (GP-OGF), primarily to accommodate recent changes to Federal National Emission Standards for Hazardous Air Pollutants (NESHAPs) under 40 CFR Part 63 and New Source Performance Standards (NSPS) under 40 CFR Part 60. The revised general permit, with an effective date of 12/18/2008, also includes some changes to the organization and wording of specific conditions.
The GP-OGF is for facilities involved in the production, gathering, processing, storage, or transportation of crude oil, refined petroleum products, natural gas, and natural gas liquids (NGL), including condensate. It authorizes construction and operation of oil and gas facilities with potential emissions below the major source thresholds, and are therefore considered both “true minors” (less than 100 tons/year (TPY) of any regulated pollutant in an attainment area) and “area sources” of hazardous air pollutants or HAPs (less than 10 TPY of any individual HAP and less than 25 TPY of total HAPs). Facilities that maintain their emissions below the major source threshold by using operational limitations and/or add-on controls also qualify under the GP, provided the Notice Of Intent (NOI) specifies any necessary specific conditions to be included in Authorization.
The permit revision adds provisions for NSPS Subpart JJJJ for spark ignition reciprocating internal combustion engines (RICE), NESHAP Subpart ZZZZ amendments for RICE at area sources, and NESHAP Subpart BBBBBB for area source gasoline distribution facilities. These recent changes in the federal standards, particularly those to NSPS Subpart JJJJ, significantly expand the number of oil and gas facilities that are required to obtain an AQ permit. The GP-OGF has been serving as a “bridge” to handle these additional facilities until Air Quality issues the General Permit for Area Source NESHAP and Small NSPS Facilities (scheduled to go to public notice this spring), or addresses Subpart JJJJ with a permit-by-rule or other rule change.
Existing facilities may continue to operate under the old GP-OGF or switch to the new GP. However, the old version is no longer available to new or certain modified facilities. Those oil and gas facilities that replace or add equipment or processes that are subject to the amended federal standards must apply under the new general permit. Note that these recent regulatory changes apply to affected facilities regardless of whether they are covered by an individual permit or either version of the GP. An updated fact sheet and general permit application forms (NOIs) are available on DEQ’s web site at www.deq.state.ok.us, along with copies of the Minor Source General Permit for Oil and Gas Facilities and accompanying explanatory memo.
General permits provide flexibility for qualified minor facilities while allowing DEQ to maximize use of available resources. A general discussion of air quality individual and general permits is included in an article titled “AQD Reissues General Permit for Minor Source Rock Crushers” in the August 2007 edition of AQ Update, available on DEQ’s web site. Additional information on other general permits issued by AQD can be found on DEQ’s web site, as well.
2009 EMISSIONS INVENTORY WORKSHOPS
A total of 209 industry representatives and consultants attended emissions inventory workshops in Oklahoma City on January 22 and in Tulsa on January 29. The morning sessions provided an introduction to the DEQ emissions inventory reporting web application, the basics of emissions inventories and Redbud. The afternoon session included more in-depth discussions and additional material.
The Emissions Inventory Section staff provided PowerPoint presentations and live Redbud demonstrations which were followed by question-and-answer sessions. Laptop computers were made available to anyone who wished to practice entering information online. A Wi-Fi signal was available to those who brought their own laptop computer and wished to access Redbud and edit data for either their own company or for a “Testco” practice facility.
This year, the following additional topics were discussed:
EPA’s drive to produce more accurate inventories, during a shortened timeframe
The critical importance of the 2008 National Emissions Inventory (NEI) – the data for which is now being reported by industry
The new federal Air Emissions Reporting Rule (AERR) which reduces the amount of time DEQ has to review and check data before it is reported to EPA
Potential Ozone Nonattainment Status in Oklahoma Cities and its implications for emissions inventories
Plans for increased Quality Control checking on each emissions inventory
Update on the upcoming federal Cross Media Electronic Reporting Rule (CROMERR) which will mean more stringent requirements for electronic signatures for the next reporting year
Feedback forms returned at the conclusion of each session reflected a very positive reception. Several requests and suggestions will be implemented as resources allow.
There were several questions asked at each workshop which will be incorporated into the Frequently Asked Questions (FAQ) section of the Emissions Inventory website at http://www.deq.state.ok.us/AQDnew/emissions/EI_FAQs.htm. The workshop agenda and Microsoft PowerPoint presentations are available at http://www.deq.state.ok.us/AQDnew/emissions/2009WorkshopAgenda.html.
Changes to Excess Emissions Reporting Requirements
On January 21, 2009, the Air Quality Advisory Council (“Council”) voted in favor of modifying ODEQ’s excess emissions rule set forth in OAC 252:100-9. The proposed rule may be found at http://www.deq.state.ok.us/mainlinks/EQBmtg.htm. The version of the rule approved by the Council results in the following significant changes to the current excess emissions rule:
Affirmative Defenses Established -The proposed version of the rule establishes affirmative defenses that may relieve industry of monetary penalties associated with excess emissions during periods of startup, shutdown, or malfunction. These affirmative defenses may be asserted by a facility at any time. The affirmative defenses established by this rule for startup and shutdown activities do not apply to facilities with permits that already take into account emissions from startup and shutdown activities.
Reduction in Immediate Notice Reporting Requirements – The proposed version of the rule reduces the amount of immediate notice reporting required by industry by providing exceptions to the immediate notice requirements for certain (low quantity) excess emissions that are not likely to pose a significant threat to human health or the environment. The exceptions to the immediate notice requirements also extend to all emissions that are the result of startup or shutdown activities.
Additional Time to Submit Written Reports – The proposed version of the rule triples the amount of time facilities have to submit written reports for excess emissions to the ODEQ. The current rule allows a facility ten (10) days to submit a written report and the proposed rule approved by the Council allows up to thirty (30) days for the written report to be submitted to ODEQ.
The proposed version of the rule potentially decreases the reporting burden on industry by providing a mechanism by which duplicative reporting may be avoided.
Maintenance Activities – The approved rule does not contain an affirmative defense for excess emissions related to maintenance activities. Maintenance activities are typically activities for which emissions may be anticipated and planned; as such, the emissions related to maintenance activities should be accounted for in a facility’s air quality permit. Recognizing that many air quality permits do not currently account for emissions resulting from maintenance activities, the agency intends to provide a six month grace period (beginning after the effective date of the pending rule change) for those facilities to submit applications for permit modifications that account for maintenance emissions.
Effective Date of New Requirements - Pending approval by the Environmental Quality Board, the Legislature, and the Governor, the amendments approved by the Council will go into effect on July 1, 2009. Additional information regarding implementation of this rule will be available on the DEQ website.
SMOKE SCHOOL-SPRING 2009
Visible Emissions Evaluation training is being offered through CenSARA. Training will occur in Oklahoma City on March 24, 25, 26 and Tulsa on April 21, 22, 23. Field certifications and a classroom lecture will be offered at both locations. Applicants who have not attended smoke school previously are required to attend the classroom lecture. Lecture attendance is encouraged for all applicants who have not attended a lecture in the past year. These courses will meet EPA Method 9 and Method 22 training requirements. Individuals qualifying at the field certification will be certified to make visible emission readings.
Maps and registration information for both locations are available at the CenSARA website: http://www.censara.org/training.asp#.
Questions may also be directed to Lyndee Songer at 405-702-4106.