Air Quality Update Southwest Ohio Air Quality Agency

Air Quality Update Southwest Ohio Air Quality Agency Cincinnati, Ohio

Introduction �SO 2 NAAQS Update �Ozone NAAQS Update �Air Quality Exceptional Events �PQAO’s �PAMS �Asbestos Program Changes �Area Source MACT Standards

NAAQS Update

2010 SO 2 NAAQS Overview �Standard is 75 ppb based upon a one-hour average (3 year average of the annual 99 th percentile of the 1 -hour daily maximum) �Four Rounds to the Designation Process

SO 2 - Round 1 Designations �Nonattainment for portions of Campbell County, Kentucky and Clermont County, Ohio (Pierce Township) �Based upon monitoring data in Campbell County �Duke Energy Beckjord boilers shut down in 2014 �Subsequent monitoring data demonstrated compliance �Area redesignated to attainment November 21, 2016

SO 2 – Round 2 Designations �Included Clermont County and the Zimmer Power Plant as part of a Consent Decree settlement �Ohio EPA modeling demonstrated compliance with the 1 hour standard �Area designated Attainment/Unclassifiable effective September 12, 2016

SO 2 – Round 3 Designations �August 22, 2017 –U. S. EPA recommendations (Actual > 2000 TPY) �Dynegy Miami Fort Station – Hamilton County: Attainment/Unclassifiable �DPL Stuart and Killen Stations – Adams County: Attainment/Unclassifiable �Operating a SO 2 monitoring network near the General J. M. Gavin and Kyger Creek power plants.

Current SO 2 Design Values

SO 2 NAAQS - Future �Round 4 Designations �Coming in the future �Will be based upon the monitoring data � Five year review – U. S. EPA Policy Assessment recommends maintaining current SO 2 standard �More information see: http: //www. epa. state. oh. us/dapc/SIP/so 2. aspx

2015 Ozone Standard – 70 ppb �June 2017 – U. S. EPA delayed implementation of ozone rules until October 2018 �August 2017 – U. S. EPA withdrew one year extension �October 1, 2017 – Final Designations? ? ? �December 2020 -2021 – State attainment plans due � 2020 – 2033 – Final compliance dates based upon nonattainment classification

Ozone Update - Exceedances 2015 2016 2017 Sycamore 4 8 5 Colerain 3 9 1 Batavia 3 4 2 Lebanon 4 8 1 Middletown 1 7 3 Hamilton 2 7 4 Taft 4 7 4 Exceedances based on 0. 070 ppm

Current Ozone Design Values 2014 -2016 2015 -2017* Butler 0. 072 Clermont 0. 070 Hamilton 0. 072 0. 073 Warren 0. 072 0. 071 *Data through September 30, 2017 Units are parts per million (ppm)

Exceptional Event Demonstration �What is an exceptional event (40 CFR 50. 14)? �May of 2016 Canadian Wildfires impacted Ozone and PM 2. 5 monitors in Cincinnati and Cleveland (May 24 th and 25 th) �Ohio EPA developed draft document which was revised in August 2017

Smoke Plume

Exceptional Event Demonstration

Exceptional Event Demonstrtion

Exceptional Event Demonstration �Once final – document is sent to U. S. EPA for review �For more information see: http: //www. epa. state. oh. us/dapc/sip/misc. aspx

What is a PQAO or Primary Quality Assurance Organization? �“A monitoring organization or a group of monitoring organizations or other organization that is responsible for a set of stations that monitors the same pollutant and for which data quality assessments can be pooled. ” � 40 CFR Part 58 Appendix A 1. 2

What is a PQAO? �Measurement Uncertainty relatively homogeneous as a result of common factors �Operation by common set of field operators according to common procedures �Common Quality Assurance Project Plan or Standard Operating Procedures �Common calibration facilities or standards �Oversight by common quality assurance organization �Oversight by common management organization or laboratory � 40 CFR Part 58 Appendix A 1. 2. 1

What is a PQAO? �January 1, 2015 �Ohio consolidated from 13 to 3 PQAOs � NEPQAO: Cleveland, Lake County, M-TAPCA, Akron, Canton, Ohio EPA-NEDO � CPQAO: Toledo, Ohio EPA-Central and SEDO � SWPQAO: RAPCA, Portsmouth, SWOAQA, Ohio EPA-SWDO � January 1, 2017: Ohio EPA-SWDO closed air program �Benefit(s) �Reduce number of co-located monitors (QA requirement) � Reduce work load � Reduce supplies � Funding �Focus efforts on priority sites

PAMS update �PAMS –Photochemical Air Monitoring Station �Required in recent Ozone Rule at urban NCore sites �Monitoring June – August � Volatile Organic Compounds - hourly � Mixing Height � True NO 2 - hourly � Carbonyls – 3 8 -hour samples daily �June 1, 2019 – required implementation date

Asbestos Program Changes �House Bill 49 (State Budget) is combining the Ohio EPA and Ohio Department of Health (ODH) Asbestos Programs �Ohio EPA rules include: �Notifications �Removal requirements �Disposal requirements �ODH rules include: �Notifications �Licensing of companies and workers �Requirements for training classes

Asbestos Program Changes �No changes will be made to OAC rule 3745 -20 �ODH rules will now be in OAC rule 3745 -22 �Proposed rules issued October 12, 2017 �Program changes will be effective January 1, 2018 �One notification form for both agencies �All notifications will be sent to Ohio EPA – Central Office �Agency inspectors will determine compliance with both rules �Electronic inspection forms

Area Source MACT Standards �Delegation/Enforcement of Standards �Area Source Standards – Ohio EPA has not accepted delegation for most of these standards �Detailed terms will not show up in the permit �Local company recently was issued a Consent Agreement and Final Order with a civil penalty

Area Source MACT Standards � 40 CFR Part 63, Subpart XXXXXX – NESHAP for Nine Metal Fabrication and Finishing Source Categories �One category is Fabricated Metal Products Manufacturing �Requirements for Welding Operations that uses welding rod with: cadmium, chromium, lead, nickel, or manganese �Daily visible emission readings Method 22 �If no visible emissions may go to weekly, monthly, etc.

Area Source MACT Standards �If visible emissions are observed may have to perform Method 9 readings. �Welding operations are normally “De Minimis (OAC rule 3745 -15 -05) or permit exempt �These standards usually require Initial Notifications and Notifications of Compliance Status

U. S. EPA Actions �In 2017, U. S. EPA conducted seven inspections �In 2017, issued two “Request for Information” letters (114 letters) �One focused on Heat Treating Furnaces �Other focused on Coating and Cleanup material emissions

Thank you! Contact info: Anna Kelley & Brad Miller anna. kelley@hamilton-co. org bradley. miller@hamilton-co. org (513) 946 -7777