How will Current Regulations be Revised to Improve Air Quality? Randy Wood October 21, 2003

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How will Current Regulations be Revised to
Improve Air Quality?Randy Wood October 21, 2003

• Texas Commission on Environmental Quality

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December 2000 Revision

• On December 6, 2000 the TCEQ adopted a 1-hour
  ozone SIP revision for the 8-county area
• Total reduction of NOx emissions of more than 750
  tons per day were necessary to demonstrate
  attainment in the area
• Houston has until 2007 to attain the 1-hour ozone
  standard

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Houston/Galveston Emissions(tons per day)
1052 tons
(2007 Future Case)
Attainment
289 tons
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Control Strategies Adopted

• 90 reduction in point source NOx
• Required an overall 90 reduction in power plant,
  refineries, and chemical plants - including
  grandfathered sources
• Emissions banking and trading
• Provides flexibility in meeting the 90
  requirement

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Control Strategies cont.

• Speed limit reduction
• Reduced all speed limits 60 mph and higher to 55
  mph
• Airport GSE
• Agreements reached to get equivalent reductions
  at area airports
• California Large Spark Off-Highway Equipment

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Control Strategies cont.

• Lawn and Garden Equipment Use Restrictions
• 6 a.m. noon ban during ozone season
• VOC RACT
• various controls for some bakeries, printers and
  chemical batch processes.
• Vehicle Idling Restriction

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Control Strategies cont.

• Inspection and Maintenance
• Cleaner Diesel Fuel
• Construction Equipment Operation Restrictions
• Accelerated Purchase requirement for federal Tier
  2/3 equipment

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Control Strategies cont.

• Transportation Control Measures
• Signal timing, bicycle/pedestrian projects, HOV
  lanes, etc.
• Voluntary Projects
• Various voluntary projects such as bus fare
  promotions, alternative fuel programs, an ozone
  action days.

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Lawsuit

• January 2001 BCCA-AG sues the TCEQ over the 90
  requirement
• Results of TXAQS 2000 gives a directional
  indication that HRVOCs contribute to ozone
  formation in the HGA area

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September 2001 Revision

• Incorporated revisions to the cleaner diesel fuel
  rules, point source NOx rules, and emissions
  banking and trading program
• The December 2000 and September 2001 revisions
  were approved by EPA October 15, 2001

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December 2002 Revision

• TCEQ adopted HRVOC rules in exchange for 80 NOx
  reduction (as opposed to 90) requirements as a
  result of settlement w/ BCCA-AG
• Rules were for four source categories
• Flares, vents, cooling towers, and fugitives

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March 2003 Proposal

• HRVOC rules are reopened for technical clean-up
• Scheduled for adoption October 22
• Rules correct inconsistencies and replace
  ambiguous language that may otherwise result in
  unduly burdensome requirements for which
  compliance dates are imminent

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What is the Goal?

• Submit approvable SIPs to EPA to prevent federal
  intervention
• Submit a 1-hr/8-hr SIP to EPA in Oct. 2004

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Why Dont We Have the Answers Today?

• The photochemical modeling process has not been
  completed
• CAA requires photochemical grid modeling

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The Modeling Process
Three Models Combined

• Meteorological Model

• Temperature and sunlight affect reaction rates
• and mixing layer height

• Emissions Model

• Emissions from cars, planes, construction
• equipment, factories, power plants

Photochemical
Model

• Chemical Model

• Chemistry changes during day and night

• 33 chemical groups, more than 80 reactions

• Complex System of differential equations

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The Modeling Process
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Emissions Inventory

• Where no data exists, we must build estimates
• Uncertainty regarding the VOC emissions inventory
• Incorporating real world air monitoring data in
  the current emissions inventory

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Modeling Goals

• Purpose of model is to compare effectiveness of
  various control strategies
• Determine what controls are most effective

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The Modeling Process

• Process is not static
• Stakeholder input necessary
• The typical SIP development process takes 3 years
• EPA requires periodic update of SIPs

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Why Dont We Have the Answers Today?

• The modeling must be defendable
• The process can be completed quickly, but the
  results wont be defendable
• Important to replicate what is really happening
  in the atmosphere

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Texas Air Quality Study 2000

• VOCs from industry are primarily responsible for
  high ozone in Houston.
• VOC emissions are substantially under-reported by
  industry.
• VOC concentrations in Houston are very different
  from other cities
• Ozone is produced faster and yields more in
  Houston than in other cities

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Complete the Modeling

• TexAQS did not answer all questions
• Should VOCs or NOx be controlled to reach
  attainment?
• What combination of NOx and VOC reductions will
  attain the standard?
• How much VOCs are actually being emitted from
  industry (80 plants) in Houston?
• Which VOCs are the most effective to control?

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What Are We Going to Do to Achieve the Goal?

• Complete development of photochemical model w/
  control strategies
• Develop control strategies/rules to achieve the
  necessary emission reductions
• Not all control strategies are rules

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Rule Development

• Dependant on photochemical modeling results
• Requires extensive research
• Searching inventories for sources
• Investigating accuracy of inventories
• Evaluating new technologies
• Calling vendors

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Rule Development

• Research literature and other states
  requirements
• Stakeholder input (with advisory group
  restrictions), public comment period and policy
  decisions necessary

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Control Strategy Obstacles

• Federal Pre-empted from regulating source
• Ex Locomotives, ocean going vessels, diesel
  engines
• Texas Legislature removed TCEQs regulatory
  authority
• Ex Fuels, Speed Limit, Construction Equipment
  Related Rules

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Control Strategies Obstacles

• Available technology and verification/certificatio
  n of technology
• There are a limited number of EPA verified or
  CARB certified technologies
• EPAs verification process is costly and timely

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Efforts to Overcome Obstacles

• TCET funded to test technologies for verification
  purposes
• TCEQ has urged EPA to expedite its verification
  process
• TCEQ in partnership w/ CARB and NY have pressured
  EPA to improve verification process and implement
  cleaner engine/fuel standards