|May, 2008, Vol 11, No 2|
Ozone Standard The new standards for ground-level ozone announced this spring by the Environmental Protection Agency (EPA) are expected to impact air quality programs in Oklahoma. The primary ground-level ozone standard was tightened from 80 parts per billion to 75 parts per billion (0.08 parts per million to 0.075 parts per million). More than 1,700 new and expanded studies conducted since the 1997 standard was established formed the basis for establishing the new standards.
The primary standard is set at a level with an ample margin of safety to protect public health, including the health of "sensitive" populations such as asthmatics, children, and the elderly. The secondary standard, which was set at the same level as the primary standard, was established to protect public welfare, including protection against visibility impairment, damage to animals, crops, vegetation, and buildings.
Why the information is important to you Ground-level ozone is formed through a combination of nitrogen oxides (NOx) and volatile organic compounds (VOCs) in the presence of sunlight. In the earth's lower atmosphere, ground-level ozone is considered harmful. Motor vehicle exhaust and industrial emissions, gasoline vapors, and chemical solvents as well as natural sources emit NOx and VOCs that help form ozone. Ground-level ozone is the primary ingredient of smog. Sunlight and hot weather cause ground-level ozone to form in higher concentrations in the air.
Ozone can harm people's lungs, and of particular concern are individuals with asthma or other lung diseases, as well as those who spend a lot of time outside, such as children. Ozone exposure can aggravate asthma, resulting in increased medication use and emergency room visits, and it can increase susceptibility to respiratory infections. Recent research has shown that repeated episodes of ozone-induced inflammation may cause permanent changes in the lungs, leading to long-term health effects and a lower quality of life.
All areas in Oklahoma are currently attaining the 1997 eight-hour ozone standard, but monitoring by the Oklahoma Department of Environmental Quality (DEQ) has shown that both rural and urban areas in Oklahoma will likely violate the new 75 parts per billion health-related standard. The state currently has 17 ozone monitoring sites. In addition, ozone data is collected at five sites operated by tribal environmental authorities.
Health Advisories The Air Quality Division of the DEQ operates a statewide email communication system that advises Oklahomans when air pollution in the state reaches unhealthy levels. In addition, statewide ozone watches forecast events when weather conditions are conducive to the production of ozone. The health advisories and ozone watches are issued as a service to Oklahomans so that they can make informed decisions regarding their daily activities to avoid or reduce exposure to air pollution. Oklahomans can now sign up at http://www.deq.state.ok.us/aqdnew/AdvisorySignUp.htm to receive these alerts which are issued for particular counties where real-time data from DEQ's automatic monitors indicates a current air quality problem.
Air Quality Index Another tool, the Air Quality Index (AQI), is a national daily report for all major metropolitan areas. The DEQ prepares the AQI for the Lawton, Oklahoma City and Tulsa metropolitan areas. This information can be accessed on the DEQ website at http://www.deq.state.ok.us/aqdnew/AQIndex/AQI.htm (a box on the right side of the screen allows the user to select the city of interest). While the AQI provides the previous day's monitored concentrations, the report also contains predicted levels for the next day. This is important when pollutants are expected to reach unhealthy levels because it gives people time to take precautions. The AQI changes resulting from the new ozone standard are identified in the chart.
Oklahoma's recommendation for classification of areas as attainment, non-attainment or unclassifiable will be based on monitoring data for 2006-2008, and is to be submitted to EPA by March 12, 2009. The EPA plans to make final designations by March 2010.
AP-42 EMISSION FACTOR UPDATES
Currently, EPA lists only one chapter under review: Chapter 15, Ordnance Detonation. Sub-sections 15.1, 15.2, 15.9, and 15.10 were updated or added. The comment period closes June 16, 2008.
The Air Quality Advisory Council held its April 2008 meeting at the OSU Campus in Tulsa. The agenda for the meeting included hearings on two proposed rules for Chapter 100 of the Oklahoma Administrative Rules. In addition, the Council heard comments from the public regarding the dangers of mercury in the environment.
The Council voted to recommend the following two rules be forwarded to the Environmental Quality Board for consideration at its August 19 meeting:
The Council heard comments from the public regarding the issue of mercury. On February 8, 2008, the United States Court of Appeals for the District of Columbia vacated the Clean Air Mercury Rule (CAMR), thus rendering the Air Quality Division’s proposed mercury rule unenforceable. The Department may propose a new state rule on mercury at a later date. A rule may be necessary to preserve the mercury monitoring requirements imposed by CAMR which are contained in Subpart I of Part 75 in Title 40 of the Code of Federal Regulations.
The next Council meeting will be held in Ponca City on Wednesday, July 16, 2008.
On May 1, 2008 EPA proposed to strengthen the NAAQS (National Ambient Air Quality Standard) for lead. The proposal includes revising the lead primary standard of 1.5 µg/m³ to within the range of 0.10-0.30µg/m³, measured as total suspended particulates. However, EPA will be taking comments on alternative levels up to 0.50 µg/m³ and lower than 0.10 µg/m³. EPA also intends to set the secondary standard identical to the primary standard. Since the initial lead standard of 1.5 µg/m³ in 1978, over 6,000 studies of lead on public health and welfare have been published. The results of these studies show adverse effects on health and welfare at much lower levels of lead than previously thought.
EPA also plans to extend the revision to improve the existing lead monitoring network. Monitoring considerations include requiring monitors to be placed near large lead emission sources, such as smelters, metallurgic operations, and airports. EPA proposes to have monitors positioned in urban areas with populations greater than 1 million to access information on the general population exposure to lead in the air. Along with monitoring, EPA proposes to revise the air quality statistics of determining compliance of the standard with two options: the current form of using maximum quarterly averages from 3 years of data; or changing to the second highest monthly average using 3 years of data.
Two public hearings are set on June 12, 2008 in Baltimore and St. Louis for the discussion of the new lead NAAQS. EPA plans to issue the final lead standards by September 2008. State recommendations for designation should be submitted to EPA by September 2009, and final designations from EPA should be submitted no later than September 2011. State Implementation Plans should be submitted before 2013, and the states should meet the standards by no later than Fall of 2016. Monitoring deadlines include all new lead monitors to be operational by January 1, 2010: if a large number of monitors are needed then only half are required to be operational by 2010, the other half must be operational by January 1, 2011.
DEQ has already begun the process of considering potential locations for placement of newly required lead monitoring sites. Unless the final rule changes significantly from what is in the proposal, it is likely that there will be 2-5 sites installed statewide.
DEQ discontinued lead monitoring following the reduction of lead monitoring requirements in the 1999 final rule of Air Quality Ambient Surveillance for Lead. At that time lead concentrations had diminished in Oklahoma to well below the 1.5 microgram standard. In most cases, lead concentrations were rarely detectable by available analysis methods.
New Lead Renovation, Repair and Painting Program Rule
While EPA has a well-established program regulating activities that deal directly with Lead-Based paint, the issues dealing with incidental contact with Lead-Based paint from activities such as remodeling or painting were never adequately addressed. After many years of testing and research EPA concluded that renovation, repair and painting in housing and child-occupied facilities containing Lead-Based Paint may generate hazardous levels of lead dust; this conclusion lead to the promulgation of EPA’s 40 CFR 745 Lead: Renovation, Repair and Painting Program Rule which will become effective June 23, 2008. The new rule addresses certification and training requirements for firms and workers in all housing built before 1978. Supplemental rules dealing with fees, lead testing devices and training curricula will be released over the next few months.
In Oklahoma, the DEQ Air Quality Division has delegation from EPA for the Lead-Based Paint program. We are currently reviewing the new rule and monitoring the up-coming supplemental rules; a decision on whether to ask for delegation of the new program will be made after all the rules are promulgated and the information is collected and analyzed.
Facilities subject to Title V permitting are required to submit various reports throughout the year, including Annual Compliance Certifications (“ACCs”) and Semi-annual Monitoring and Deviation Reports (“SARs”). These reports can be the cause of confusion for facilities, partly due to the similarities of the reports, and also due to the records required to be submitted with each report. Each report must be submitted with the proper form from the DEQ website, www.deq.state.ok.us.
ACCs are required to be submitted thirty days after the issuance date of the original Title V permit. Each permit issued by the Department has Specific and Standard Conditions. The requirment to submit an ACC is found in Standard Condition IV.A. In some permits, the Specific Conditions also contain a requirement to submit the ACC and will further specify what records need to be included with the submittal.
SARs are due twice each year, thirty days after each six-month period following the issuance of the original Title V permit. The requirement to submit an SAR is found in Standard Condition III.C and specifies a “report of the results of any required monitoring.” Monitoring is defined in the Oklahoma Administrative Code (“OAC”) 252-100-43 as follows:
This means that any required recordkeeping or routine monitoring conducted at the facility must be submitted with each SAR in order to demonstrate compliance with limits established in the Title V permit. Records required for submittal will vary from facility to facility, based on permit conditions. These records may be summarized, as long as compliance with limits can be determined. The information should be sufficient for the Department to determine compliance with all conditions of the Title V permit. Any reports that have been previously submitted to the Department may be incorporated into the SAR by reference.
For more information about reporting requirements, please contact Becky Whitecotton at 405-702-4100.
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