david brymer and betsy peticolas texas commission …awma-gcc.org/docs/ace2017brymer.pdf · david...
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David Brymer and Betsy Peticolas
Texas Commission on Environmental Quality
Office of Air
February 16, 2017
1-hr. ozone standard (0.12 ppm) ◦ Measuring attainment since 2013
◦ Redesignation substitute approved in Oct. 2015
1997 8-hr ozone standard (0.08 ppm) ◦ Measuring attainment since 2014
◦ Redesignation substitute approved by EPA Nov. 2016 (effective date Dec. 2016)
2008 8-hr ozone standard (0.075 ppm) ◦ Mot measuring attainment
◦ Bump up from marginal to moderate on Dec. 14, 2016
◦ Attainment demonstration and Reasonable Further Progress SIP revision approved Dec. 15, 2016 and submitted before the end of 2016
2015 8-hr ozone standard (0.070 ppm)
• On October 1, 2015, the EPA lowered the National Ambient Air Quality Standard (NAAQS) for ground-level ozone to 70 parts per billion (ppb).
• Based on preliminary air monitoring data for 2015, the Dallas-Fort Worth, Houston-Galveston-Brazoria, San Antonio, and El Paso areas are measuring levels above the 2015 ozone standard. ◦ State recommendations based on the 2015 Design Value ◦ Final EPA designation expected to be based on the 2016
Design Value
Area
Certified 2015 Ozone
Design Values (parts per
billion)
Preliminary 2016 Ozone
Design Values as of Oct.
31, 2016 (parts per billion)
DFW 83 80
HGB 80 79
San Antonio 78 73
El Paso 71 71
Hood County 73 69
Beaumont-Port
Arthur 68 68
Killeen-Temple-
Fort Hood 69 67
Austin 68 66
Tyler-Longview-
Marshall 68 66
Waco 67 63
Victoria 64 63
Corpus Christi 65 65
Big Bend 64 59
Lower Rio Grande
Valley 59 57
Mission-Edinberg-
Mercedes 56 55
Laredo 59 54
CSA/CBSA County
2016 8Hr
Ozone DV
(ppb)
Dallas—Fort Worth Denton 80
Houston—The Woodlands Harris 79
Houston—The Woodlands Galveston 76
Houston—The Woodlands Brazoria 75
Dallas—Fort Worth Tarrant 75
Dallas—Fort Worth Collin 74
San Antonio—New Braunfels Bexar 73
Dallas—Fort Worth Parker 73
Dallas—Fort Worth Dallas 72
Dallas—Fort Worth Johnson 72
Houston—The Woodlands Montgomery 72
El Paso—Las Cruces El Paso 71
Dallas—Fort Worth Hood 69
Beaumont—Port Arthur Jefferson 68
Killeen-Temple Bell 67
Longview-Marshall Gregg 66
Dallas—Fort Worth Rockwall 66
Austin—Round Rock Travis 66
Amarillo-Borger Randall 65
Tyler-Jacksonville Smith 65
Victoria—Port Lavaca Victoria 65
Corpus Christi—Kingsville—Alice Nueces 64
Beaumont—Port Arthur Orange 64
Dallas—Fort Worth Ellis 63
Waco McLennan 63
Longview-Marshall Harrison 62
Dallas—Fort Worth Kaufman 61
Dallas—Fort Worth Navarro 61
No CSA Polk 61
Dallas—Fort Worth Hunt 60
No CSA Brewster 59
Brownsville-Harlingen-
Raymondville Cameron 57
McAllen-Edinburg Hidalgo 55
Laredo Webb 54 **The Brewster County, Randall County, and Polk County monitors are part of the Clean Air Status and Trends Network (CASTNET) of monitors and report data directly to the EPA.
*2016 design values are calculated as of 12/9/2016 and subject to change
0.070 parts per million (ppm)
Marginal 0.071 up to 0.081 ppm
Moderate 0.081 up to 0.093 ppm
Serious 0.093 up to 0.105 ppm
Severe – 15 0.105 up to 0.111 ppm
Severe – 17 0.111 up to 0.163 ppm
Extreme 0.163 ppm or more
October 2016 State designation recommendations June 2017 EPA publishes public notice of its proposed designations October 2017 EPA to finalize designations and classifications; EPA to finalize implementation rule December 2017 Expected effective date of designations December 2019 Emissions Inventory SIP revisions due for all nonattainment areas December 2020 Attainment deadline for marginal nonattainment areas
Address implementation issues for area and
mobile source emission reduction credit
generation
◦ Surplus
◦ Real
◦ Quantifiable
◦ Permanent
◦ Enforceable
• Proposal:
• Commissioner’s Agenda March 8, 2017
• Copies of the proposed rule available at http://www.tceq.texas.gov/rules/propose_adopt.html
• Public hearings:
• Houston: April 18, 2017
• Arlington: April 19, 2017
• Austin: April 20, 2017
• Comments due by 5:00pm April 24, 2017
• Adoption: August 2017
• Additional Meetings on Rule Implementation
◦ Houston: February 28, 2017, 1:00pm at the Houston-
Galveston Area Council, Conference Room B, 3555 Timmons Ln #120, Houston, TX 77027;
◦ Dallas-Fort Worth: March 1, 2017, 10:00am, at the
North Central Texas Council of Governments, The Fred Keithley Conference Room, 616 Six Flags Drive, Arlington, TX 76011; and
◦ Austin: March 2, 2017, 1:30pm at the TCEQ
Headquarters, Building F, Room 2210, 12100 Park 35 Circle, Austin, TX 78753.
• Non-residential area sources
• Sources with approved/approvable emissions estimation
methods
• Fleet vehicles
• Mobile sources primarily operated in a nonattainment area
• Sources that operated in SIP emissions year
• Sources with >0.1 ton credit after all adjustments
• Sources with real reductions, not activity shifting
• Mobile sources made permanently inoperable or moved
out of North America
Inelastic area source shutdowns will not be credited.
Reduce SIP emissions available for credit by: ◦ 25% for area and non-road mobile source categories
◦ 15% for on-road mobile source category
◦ Draft strategy discussed reductions of:
20% to 30% for area and non-road mobile
5% to 15% for on-road mobile
As area and mobile emissions estimation uncertainties diminish, commission may determine that a greater proportion of SIP emissions could be creditable without risking: ◦ noncompliance with requirement to be surplus to SIP;
and
◦ having a negative impact on the relevant air shed.
Reduce credits for shutdown by 15%. Draft strategy: 20%
Reduce credits based on emissions estimation data.
◦ No adjustment for records required for same facility type at
a point source.
◦ Reduce 15% for alternative methods.
◦ Draft strategy discussed:
Source-specific continuous monitoring: 0% to 10%;
Source-specific non-continuous monitoring: 5% to 15%; and
Alternative methods: 10% to 20%.
Total combined adjustment of no more than 20% Draft strategy: 20% to 30%
Determine historical adjusted emissions from two of five years before reduction. ◦ Can “look back” six to ten years when detailed
operational records are available.
◦ Draft strategy only allowed five year look back.
Mobile SIP and historical adjusted emissions set based on actual emissions in nonattainment area.
Mobile credits set based on remaining useful life, annualized over 25 years. ◦ SIP fleet turnover assumptions
EPA-approved/approvable protocols are required for emissions estimation.
Generator must comply with required conditions. ◦ Monitoring, testing, recordkeeping
◦ Specified in Emissions Banking and Trading Emission Reduction Certification Form (Form EBT-CERT)
EBT-CERT may contain special conditions including, but not limited to: ◦ Vehicle Replacements
Moved out of North America
Proof the vehicle is permanently inoperable and certified or duplicate Texas Nonrepairable Vehicle Title
◦ Vehicle Repower
Proof the engine is permanently inoperable
Moved out of North America
Credit applications must be submitted no more than two
years after the facility's emissions reduction date. ◦ Lack of clarity created by “implementation of the emission
reduction strategy” created implementation issues.
Proposed language is intended to clarify expectations.
For example, at an oil and gas site: ◦ Compressors, dehydrators, and sweeteners, tanks, and fugitives
could have different emission reduction, application, and credit
expiration dates.
◦ Each facility's emissions reduction date would set that facility's
credit application deadline and expiration date.
◦ Well plugging could be completed after the application deadline,
but must be completed prior to credit certification.
Oil and Gas
If: ◦ the application is for a complete shutdown of an oil and
gas production site;
◦ well plugging is completed within one year of final production being reported to the Railroad Commission of Texas (RRC), and
◦ the well is plugged in accordance with RRC requirements,
then: ◦ the application may be submitted no more than two
years after the site's production well is plugged (as opposed to each facility’s emission reduction date); and
◦ credits certified under this exception will be available for 72 months from the date well plugging is completed.
• Exceptions to standard credit application deadline and life for area and mobile sources • For emission reductions that occurred between June 1, 2013
and January 1, 2015
• application deadline December 31, 2017
• For emissions reductions that occurred between January 1, 2015 and January 1, 2017
• application deadline three years after emissions reduction
• Exceptions expire January 1, 2020
• Extend credit life to 72 months for:
• emission reductions eligible for application deadline exceptions; and
• emission reductions occurring before and included on an application submitted, but not acted on, before January 1, 2017.
New major sources, major modifications of
existing major sources, and minor sources with a
project that is major by itself
Nonattainment classification determines major
source thresholds and pollutant offsets
If two separate classifications apply, the most
stringent is used for air permitting
Nonattainment NSR
Requires LAER ◦ The most stringent emission limitation either
Contained in the SIP or TCEQ rule or
Achieved in practice by such class or source category
Emissions offsets ◦ Actual emission reductions of the pollutant that is
increasing
◦ Air Quality Division, Banking and Trading Programs
teams administers offsets
Public notice and opportunity for contested case
hearing
Nonattainment NSR
Ozone Thresholds
Marginal
100 tpy
40 tpy
Moderate
100 tpy
40 tpy
Serious
50 tpy
25 tpy
Severe
25 tpy
25 tpy
Houston Galveston Brazoria
HGB moderate for ozone (2008) standard
New major source =100 tpy of NOx or VOC
Major modification = 40 tpy of NOx or VOC
Offset ratio = 1.15 to 1
Changes to NNSR Permits
If an NNSR application is pending and the source no
longer meets the applicability criteria for NNSR, the
applicant may void that application.
If a site no longer meets the applicability criteria for
NNSR after a redesignation to attainment and the source
has not commenced construction, the applicant can void
the NA permit and be authorized only under a minor
NSR authorization
If the source has commenced construction the source
must continue to comply with its NNSR permit
Air Quality Division (512) 239-1725
Air Permits Division (512) 239-1250