ozone: violations, nonattainment & our air quality future

Ozone: Violations, NonAttainment

& our Air Quality Future

Peter Bella

Alamo Area Council of Governments

Guadalupe County Workshop / Randolph Metrocom Chamber

October 9, 2012

Key Questions Today

1. What does the ozone violation mean?

2. What actions has San Antonio taken to reduce its

contribution to ozone?

3. Why are all counties in San Antonio – New Braunfels

Metropolitan Statistical Area (MSA) included?

4. What can surrounding counties do to reduce their

ozone contribution?

5. What kinds of sanctions might ensue?

6. What is the role of what we call "transport”?

7. Will the Eagle Ford possibly increase area

ozone?

What is ozone?

• Ozone is an odorless, colorless gas.

• Ground-level ozone can cause:

– shortness of breath

– coughing or wheezing

– headaches nausea

– throat and lung irritation

• Ground-level ozone’s effects are most profound

on children, the elderly, and those with reduced

lung capacity.

What Causes Ozone?

Oxides of Nitrogen (NOx) &

Volatile Organic Compounds (VOC) Note: NOx = NO + NO2 (<= criteria)

Emission Trends for VOC and NOx in

San Antonio / New Braunfels MSA 1996 to 2018

Sa

n A

nto

nio

8-C

ou

nty

MS

A P

op

ula

tio

n

Population Growth in the SA-NB MSA

0.0

1.0

2.0

3.0

4.0

5.0

1970 1980 1990 2000 2010

Po

pu

lati

on

(1

97

0 =

1)

Year

Atascosa

Bandera

Bexar

Comal

Guadalupe

Kendall

Medina

Wilson

Eagle Ford Shale not evident. Courtesy Bill Barker, OEP/CoSA

Texas Water

Development

Board projects

41% growth in the

SA-NB MSA

between 2010-

2040 from

2,142,508 to

3,029,300.

Key Questions Today







ozone contribution?




ozone?

http://www.tceq.state.tx.us/cgi-bin/compliance/monops/select_summary.pl?region13.gif

Regulatory O3 Monitors, AACOG / Bexar Co.:

Camp Bullis C58, Calaveras Lake C59, SA Northwest C23

AACOG-operated Non-regulatory

Ozone monitors: C500 series

CPS Energy Owned and Operated

Ozone monitors: C622, C678

2008 8-hour average Ozone

National Ambient Air Quality Standard

• A community will meet the eight-hour standard when the three-year average of the annual fourth highest daily maximum eight-hour ozone concentration measured at each monitoring site is less than 76 parts per billion (ppb). *

2008 Federal 8-Hour Ozone Standard

* Source: TCEQ's "Compliance with Eight-Hour Ozone Standard" page:

http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl

Violation: the three year average of ozone levels on local monitors was too high.

On August 21, two monitors violated the 2008 ozone standard.

Violation of the 2008 Standard

The “Three-Year Average” needs to be

less than 76 parts per billion (ppb).

Data: http://www.tceq.state.tx.us/cgi-bin/compliance/monops/8hr_attainment.pl

Monitoring Site

Fourth Highest Average

Current

Three-Year

2010 2011

2012 Average

as of

3:12 pm CDT

10/8/2012

Camp Bullis C58 78 75 87 80

Calaveras Lake C59 67 71 70 69

San Antonio Northwest C23 72 79 81 77

Key Questions Today







ozone contribution?




ozone?

Requirements vs. Discretion

Requirements:

• The current 2008 ozone standard is now under review: – May be revised in 2013 according to the five-year review cycle.

• IF the standard revised in 2013, and timeline did not change: – Proposal for a revised standard would be published in 2013

– Final standard promulgated in 2014.

– Nonattainment designations promulgated in 2016 .

• Designations would be made based on 2013-2015 data.

• Next summer: possibly the 1st year in the 3-year average for designations under a more stringent ozone standard.

• Now is a great time to initiate dedicated air quality improvements.

Requirements vs. Discretion

EPA’s Discretion:

• It is within the EPA Administrator’s discretion under the Clean Air Act to notify the Governor of any state that a designation revision should be revised. – “…on the basis of air quality data, planning and control considerations,

or any other air quality-related considerations the Administrator deems appropriate...“

• Now is a great time to initiate dedicated air quality improvements, especially in light of the Ozone Advance program.

What is AIR Committee Doing?

• Ozone Advance – EPA program to provide

assistance to areas interested

in staying in attainment

– Voluntary program for

voluntary progress

– If we are subject to a

nonattainment designation,

AND we have implemented

adequate reduction, EPA

administrator MAY allow time.

What is AIR Committee Doing?

• Ozone Advance

– Outreach to local business and industry

• TERP: Cleaner fuels for cleaner fleets

• Catalogue existing “clean” practices

– June 25, 2013: “Path Forward” letter to EPA

with list of control strategies to put in place

• Eagle Ford Shale (EFS) Emissions

Inventory for Ozone Precursors

– Develop best estimations for activities

– AACOG staff under contract with TCEQ

Strong Commitment to Success and Recognition

June 13, 2007: Hon. Jay Millikin presents recognition award

to Tom Spaits of Capitol Cement for SNCR implementation

Photo:

Forrest

Mims

III

Strong Commitment to Success and Recognition

Key Questions Today







ozone contribution?




ozone?

EPA Default Boundary: MSA*

Metropolitan Statistical

Area Atascosa, Bandera, Bexar, Comal, Guadalupe, Kendall, Medina, and Wilson Counties

See page 3, “Area Designations for the 2008 Revised Ozone National Ambient Air

Quality Standards”:

http://www.epa.gov/groundlevelozone/designations/2008standards/documents/

2008-12/Area_Designations_for_the_2008_Revised_Ozone_NAAQS.pdf

Key Questions Today







ozone contribution?




ozone?

Surrounding Counties

• Alamo Rural Transit – Mass Transit

– Connect work-to-home with mass transit

• TERP: Cleaner fuels for cleaner fleets

• Energy Efficiency / Renewable Energy

– Solar, wind, building code improvements

– Building retrofits / AACOG Weatherization

– SPEER / Energy Systems Lab + Consortium

– Learn from CPS Energy

• Avoid land clearing and agriculture

burns on AQHA days

Key Questions Today







ozone contribution?




ozone?

Key Programs under NA

• Nonattainment New Source Review:

– Seeks industry and business emission reductions

– Allowances are reduced under emissions permits

• Transportation Conformity

– Requires that engineers demonstrate that “added capacity” roadway projects will not add pollution

– One year from the date of a non-attainment designation, federally funded highway and transit projects require demonstration: no increase in emissions due to build-out

RACT/BACT/LAER

• BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas).

• RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas).

• LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas.

Under EPA's "New Source Review" (NSR) program, if a company is

planning to build a new plant or modify an existing plant such that air

pollution emissions will increase by a large amount,

then the company must obtain an NSR permit.

http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

EXTREME

(20 Years)

Clean Fuels and Controls for Boilers

Traffic Controls During Congestion

SEVERE

(15-17 Years)

VMT Growth Offset

Major Source Fees for Failure to Attain

(185 Fees)

SERIOUS

(9 Years)

Enhanced Monitoring and I/M

Modeled Attainment Demonstration

3% per Year VOC Reductions After 6

Years

RFP Milestone Contingency

Measures

Clean Fuels Program

VMT Demonstration

Stage II Gasoline Vapor Recovery

MODERATE

(6 Years)

Basic I/M

RACT & RACM Emissions Reductions

Attainment Demonstration

Contingency Measures

RFP - 15% VOC Reductions within 6

years

MARGINAL

(3 Years)

Emissions Inventory

Emissions Statements

Nonattainment NSR Program & Emissions

Offsets

RACT Fixups

I/M Corrections

10

1.5 : 1

25

1.3 : 1

50

1.2 : 1

100

1.15 : 1

100

1.1 : 1

Courtesy TCEQ

Key Questions Today







ozone contribution?




ozone?

Rural

Sources Cars

Trucks

Locomotives

Small Engines

Vegetation

Major

Combustion

Sources Power

Generation

Cement Industry

Manufacturing

Urban

Sources Cars Trucks

Buses Airports

Industries Construction

Lawn & Garden Equipment

Vegetation

Rural

Background

Ozone Level

Relatively low

Wind Direction

Ozone Increases

Downwind from

Major Combustion

Sources

Ozone Increases

Further Due to

Numerous Urban

Sources

High Ozone

Extends

Downward from

Urban Areas

Courtesy TCEQ

Transport

Image courtesy of the Capital

Area Council of Governments

Key Questions Today







ozone contribution?




ozone?

Superlative Comments

-“Eagle Ford shale will be another Spindletop for Texas.”

-“…and could be the most promising oil play in the nation.”

-“…perhaps largest economic boom in our state’s history.” – Texas RR Commission

-“… one of the nation’s biggest oil and gas fields over next 20 – 30 years.”

-“The 400 mile stretch in south Texas is a major job factory.”

Eagle Ford Shale Play

Horizontal Drilling / Hydraulic Fracturing

Figure from energyindustryphotos.com

"Ozone Impacts of Natural Gas Development in the Haynesville Shale," Environ. Sci. Technol., November 18, 2010 ENVIRON, et. al. http://pubs.acs.org/doi/abs/10.1021/es1021137

Maximum Regional 8-Hour Ozone Impacts in 2012

Maximum impacts extend outside Northeast Texas into

other regions of Texas

Wind directions

relative to Bexar

County on high

ozone days > 70

ppb, 2005-2011 48-hour back trajectories within

250 miles of CAMS 58

13%

25%

24%

26% 8% 2%

1%

2%

Bexar

Medina

Bandera

Kerr Kendall

Comal

Guadalupe

Gonzales

Wilson

Atascosa Frio

McMullen

Live Oak Bee

Karnes

Goliad

Dewitt

Caldwell

Hays

Blanco

Bastrop

Travis Gillespie

La Salle

Well location data, Legend:

http://www.rrc.state.tx.us/eagleford/images/EagleFordShalePlay120211-large.jpg

Wind data analysis: AACOG

Eagle Ford Shale Estimates Draft NOx Emissions in tons per day from 24-county Eagle Ford shale play

EFS Emissions Source 2011

Exploration and Pad Construction 0.6

Drilling 23.9

Hydraulic Fracturing 12.3

Midstream 8.8

Total* Estimated Emissions 45.6

Type of Industry 2008 2013 2018

Electricity Generation 46.5 42.9 42.9

Cement Industry 20.9 25 25

Petroleum Industry 5.7 5.7 5.7

Manufacturing 1.1 1.1 1.4

Military Bases 0.9 0.9 0.9

Other Sources 0.6 0.6 0.6

Total 75.9 76.3 76.6

NOx Emissions in tons per day from Point Sources, 8-County SA-NB MSA

* 2011 estimations for Production

not included.

Production may create up to 25

additional tons of NOx/day in 2011.

2012 emissions will be higher.

For example, midstream sources

are estimated at 39.3 tons of VOC

and 21.0 tons of NOx in 2012.

C23 Back Trajectories on Days with 8-Hour Ozone > 75 ppb and the Location of Eagle

Ford, 2008-2011

NOAA, Feb. 26, 2010. “Realtime Environmental Applications and Display sYstem (READY)”. Available online: http://www.arl.noaa.gov/ready.html. Accessed 01/12/12.

http://www.arl.noaa.gov/ready.html

Questions / Comments

Contact Information:

Peter Bella

Director Natural Resources, AACOG

[email protected]

(210) 362-5249

The Alamo Area

Council of

Governments

• AACOG provides direct

services & planning

supporting communities and

local governments in a 12

county area of south central

Texas

Services to local governments

& citizens (CJ, ART, Aging,

etc.)

Planning forum for multi-

jurisdictional issues (AQ, Eco

Dev., Public Safety, etc.)

http://www.aacog.com/

Anthropogenic NOX Emissions by Source Category, San Antonio / New Braunfels MSA, 1996 to 2018 (tons/day)

Type of Industry Tons/day Percentage

Electricity Generation 42.9 56.2%

Cement Industry 25.0 32.8%

Petroleum Industry* 5.7 7.5%

Manufacturing 1.1 1.4%

Military Bases 0.9 1.2%

Other Sources 0.6 0.8%

Total 76.3 100.0%

NOX Point Source:

2013

NOX Point Source: 2013

* Does not include estimates from Eagle Ford development

Background

* Texas Water Development Board

• AACOG region: Full compliance with CAA (‘70s)

• Significant actions taken in the AACOG region

– Early Action Compact + Cement ind. & Power generation

– Air Improvement Resources

– CoSA’s Mission Verde + CPS Energy’s STEP

– Clean Cities (DOE) + Commute Solutions (TxDOT)

• Now More Than Ever

– Eagle Ford shale (EFS) emissions are not now understood

– 2010 & 2011 Design Values: “On The Cusp” pre-EFS

– Growth > +885,000 in MSA from 2010-2040* pre-EFS

• Doing Nothing ≠ Maintaining Air Quality

Smart Ideas for the Future

• Greater Mobility – Mass Transit

– Lone Star Rail

– Transit Oriented Development

• Greater Urban Densification

– Decade of Downtown / Walkable Communities

• Energy Efficiency / Renewable Energy

– Solar, wind, building code improvements

– Building retrofits

• Better Emissions Inventories

65

70

75

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95 1980

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20

11

De

sig

n V

alu

e (

pp

b)

Year

Northwest C23 North C07 Camp Bullis C58 Calaveras C59 8-Hr O3 Exceedance

C58

75 ppb: Upper limit allowed

2008 8-Hour Ozone Standard

C23

C59

C07 2008 8-Hour Ozone Standard Set

Ozone Trends, San Antonio Region, 1980-2011

65

70

75

80

85

90

95

1980

1981

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20

11

De

sig

n V

alu

e (

pp

b)

Year

Northwest C23 North C07 Camp Bullis C58 Calaveras C59 8-Hr O3 Exceedance

C58

75 ppb: Upper limit allowed

2008 8-Hour Ozone Standard

C23

C59

C07 2004 was the first year that the 8-hour average

ozone standard was active and enforced.

The standard was 85 ppb when it went into effect.

Ozone Trends, San Antonio Region, 1980-2011

Types of Strategies: LOCAL

• Industrial Controls

• Energy Efficiency Projects

• Mobile Source Controls – Fleet controls

– Idling Reduction Programs

– Diesel retrofits

– Commute Solutions

• Outreach – Ozone Awareness Programs

Guy Donaldson, Chief, Air Planning Section, EPA Region 6, “State

Implementation Plans,” http://blueskyways.org/meetings/webinar/june2.html

Air Quality Planning Flow Chart

Is Air Clean?

Gather Air Quality

Data

(Ozone Monitoring)

And Track A.Q. Plan

Progress

Model Impact of

Controls on Air

Quality

Develop

Emission

Control

Measures

Project Future

Emissions

Estimate Current

Emissions

(Build Emissions

Inventory)

Is

Control

Strategy

Adequat

e?

Enforce Rules

and Program

Implement

Rules and

Program

Develop Rules

to Implement

Controls

Attainment &

Maintenance

NO

YES

YES

NO

Develop Base

Case Model

ozone: violations, nonattainment & our air quality future

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