Ohio EPA, Air Pollution Control Updates

Topics

Permit and Compliance Improvements – What does this mean for you?

Compliance Strategies for Business – Making things easy

Emerging Air issues including Ozone, Clean Power Plan, etc.

Ohio EPA’s Air Pollution Control Program

5 Regional (District) Offices; 9 Local Air Agencies; Central Office; Field Office

180 Employees across the state plus Local Air Agencies

+72,000 sources at over 14,000 regulated facilities

2,000 Air permits issued annually

+290 Ambient air monitors

We are efficient and lean!

Ohio Air Pollution Control Offices

Ohio EPA’s Air Pollution Control Program • District Offices

• Permits, Inspections, • Communication, problem solving

• Central Office • State Implementation Planning • Permit review and issuance • Modeling • Legal and Policy Issues

What drives us? • Consistency - statewide

• Efficiency - permit and compliance programs to

facilitate compliance of regulated community

• Prioritization – recognizing top priorities and focusing our efforts accordingly

Permit Process: Making it Easy • Online application preparation and tracking

• Pre-application meeting to begin process

• Periodic status calls and/or meetings with

specialists

• Review of permit before issuance– No surprises!

• Changes happen – we adapt quickly!

Permit Process: What to Expect • Recommend early pre-meeting

• Review of application within 14 days

• Deadline driven • Highly experienced with PSD & Synthetic Minor

permits

• 85% of new permits written within 90 days in past 2 yrs

Success Story: Oil/Gas Expansion

Worked closely with Oil and Gas industry

Held multiple conference calls with interested parties

Conducted webinars

Guidance:

General Permit developed for well sites

General Permit developed for compressor stations

Developed multiple guidance documents

Information packets and guidance docs to industry

Success Story: Oil/Gas Expansion Since development began, we have issued:

500+ permits for well-site installations

(average issuance – 15 days)

280 permits for mid-stream

(compressor stations, gas clean-up)

40 permits for gas processing for oil/gas expansion

(separation, fractionation, stabilization facilities)

Still expanding!

Available Online Services eBusiness Center

Air Services

Electronic Payments

Other Division Applications

Customer Support Center

Permit Wizard

FAQ

Training

What can you do in Air Services? Create & Submit

Permit Applications

Emissions Reports

Permit Related Reporting

Compliance

Emissions Tests

CEM/CERMS/COMS

Facility Data Updates

Portable Source Relocation

View History & Maintain Data

Permit tracking

View submission history

View correspondence

Designed for Ease of Use Designed to avoid duplicate data entry

Access to facility application and reporting history

Access to Word version of current permits

Ability to copy from previous reports or applications within facility

Compliance and Enforcement Our Goal is Compliance

We strive to be fair, equitable, transparent and timely.

Inspector Rotation

Discuss findings of inspections during the visit.

Minimize surprises and opportunity to address issues quickly. (many times before we leave)

Memorialize how problems should be addressed across the state. (via internal improvements)

Practical Advise Preparing staff for inspections

Obvious stuff (permits, monitoring, recordkeeping, reports, testing, etc.)

Inspections: Ask about inspector’s operational knowledge and tailor conversation. Walk the plant process start to finish

Big Bang Theory vs CSI vs Colombo Human element

Build trust and a relationship

Honesty, integrity, no double-speak, clearly answer questions and find information quickly.

Current Challenges Federal Activity

Ozone

NAAQS

Startup Shutdown Malfunction SIP Call

Interstate Transport

Clean Power Plan

Doing More with Less…

Photo of Republic Steel, Cleveland from

Cleveland State University, Dept. of History, Teaching and Learning Cleveland

Ohio’s Attainment Challenges

The entire state is attainment for nitrogen dioxide,

and carbon monoxide.

Isolated nonattainment areas for SO2, lead and PM

2.5

New Ozone Standard

U.S. EPA adopted ozone standard in 2008 – 0.075

ppm eight-hour average

Cincinnati, Cleveland, Columbus designated

nonattainment

Attainment date - 2014 – Cincinnati and Columbus met

standard – Ohio EPA requested/one year extension for

Cleveland – met standard in 2015

Ozone NAAQS

0

10

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40

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100

110

120

1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013

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Ohio Average One Year 8-Hour Averages

Average LLS-30 LLS-20

U.S. EPA proposed a range from 0.065 ppm – 0.070

ppm

Ohio EPA filed comments – data supports keeping

standard 0.075 ppm

On October 1, 2015, U.S. EPA adopted a standard

of 0.070 ppm for both primary and secondary

standard

U.S. EPA Revised Ozone Standard

October 1, 2015 U.S. adopts new standards

October 1, 2016 States submit recommendations

for nonattainment areas

October 1, 2017 U.S. EPA finalizes nonattainment

October 1, 2019 Infrastructure SIPs due

October 1, 2020 Attainment date for marginal

nonattainment areas (expect all Ohio

areas to be marginal)

Timeline for Completion – Revised

Ozone Standard (cont’d)

Clean Power Plan aka 111(d)

Carbon emissions from existing coal and natural gas fired electricity generators

U.S. EPA proposes plan that requires 32% reduction in emissions of CO2

111(d) is a stationary source rule

Coal based control technology not practical Parasitic load penalty alone of almost 30%

Only way to reduce emissions is to reduce coal usage

Energy Sector rule More renewable energy sources

Maximize existing natural gas plants

Interim

Step 3

Interim Step 2

Interim Step 1

2030 Goal C

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Clean Energy

Incentive Program

2-year delay

Clean Power Plan Timeline

Key Questions and Challenges

How to analyze Compliance Pathways efficiently?

Mass vs Rate?

Trade-Ready plan?

How do we minimize CPP impact on electricity costs to end users?

How do we assure continued reliable service to the state?

How do we minimize the unpredictability in the marketplace and provide certainty for future investment and development?

Legal Challenges

Methodical analysis

Collaborate very closely with Ohio Public Utilities

Commission

Not an Island (awareness of other states)

Extension request due Sept 2016

Outreach and Engagement Plan

Remain mindful of challenges and not rush to

any decisions.

Ohio’s CPP next steps

Questions or concerns?

Adam Ward

Assistant Chief

Ohio Environmental Protection Agency

Division of Air Pollution Control

w 614.728.3784

c 614.546.9163

adam.ward@epa.ohio.gov