Presentation to Industry

Action Plan for Summer 2004

April 1, 2004

maurice.oubre@la.gov

225/219-3434

2

Overview

• Current Status of Baton Rouge Area• Re-classification to Severe• Chapter 22 NOx Rule• HRVOC Workgroup• HRVOC Survey• Action Plan for Summer 2004

3

Current Status of BR Area

• 1-Hr Standard No more than 3 exceedances in 3 years at

any monitor (10 monitors in BRNA) Exceedance =/>125ppb (truncated) Capitol and LSU were out for 01-03 and

already have 4 hits for current 02-04 period See Table

4

1-Hr Ozone StatusMonitor 2002 2003 2004 02-04 03-05Baker 1 1 2 2

Capitol 2 2 4 2

LSU 1 3 4 3Pride

Port Allen 1 2 3 2

B Plaquemine 1 1 2 1

Carville 2 2 2

Grosse Tete

Dutchtown

F Settlement

Total 5 11 1 17 12

5

Current Status of BR Area

• 8-Hr Standard 4th highest value each year is averaged over

a 3 year period Exceedance =/> 85ppb (truncated) LSU monitor was out for 2001-03 See Table

6

8-Hr Ozone Status

Monitor (ppb)2002

(4th Hi)2003

(4th Hi) 01-032004

(4th Hi2004

(trigger)Baker 83 88 84 60 84Capitol 79 82 80 54 94

LSU 78 100 86 59 77Pride 75 80 77 60 100

Port Allen 80 89 84 61 86B Plaquemine 73 81 77 59 101

Carville 75 89 84 58 91

Grosse Tete 74 81 78 61 100

Dutchtown 75 77 75 58 103

F Settlement 75 82 77 59 98

Monitors Out 1 to 3/21

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1-Hr Summary

• LSU monitor already has 3 hits for 2005• Capitol, Port Allen, and Carville have 2

Exceedances in 2004 and 2005 (especially at LSU) are crucial or the area will be out of attainment in 2005 – the Clean Air Act attainment year.

8

Re-Classification to Severe

• BR was originally classified serious with an attainment date of 1999.

• Modeling showed that the area was being affected by ozone transport from Houston.

• Under EPA guidance, an extension to 2005 was granted based on transport.

• Under pressure EPA pulled the approval and the area was bumped-up to severe with a 2005 attainment date. (June 23, 2003)

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Consequences of Bump-Up

• Definition of major source reduced from 50 tpy to 25 tpy for both NOx and VOC (revise Chapters 21 and 22)

• Offset requirements increase to 1.3 with LAER and 1.5 to avoid LAER (Lowest Achievable Emission rate)

• Reformulated Gasoline (RFG)• Section 185 fees for failure-to-attain by2005

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Section 185 Fees (rule in comment period until 4/2)

• Fees start in 2007 (for 2006) and continue until the area is in attainment

• Exemptions: (EPA opposed, no exemptions) if equipped with minimum 95% control; or if equipped with BACT• Baseline is the average of annual emissions

of VOC and NOx from non-exempt sources for the most representative 3 years between 1998 and 2002. (EPA opposed, must be 2005)

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Section 185 Fees (continued)

Fee = [A-(80% x B)] x C A = Total actual VOC and NOX emissions

in previous year from non-exempt sources B = Baseline amount (tons) C = $5,000 per ton adjusted by CPI to

subject year (approximately $8,000)

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Chapter 22 NOx Rule

• Promulgated March 2002• Applicable in 9 parishes during ozone season• Establishes emission factors for boilers, heaters,

furnaces, turbines and engines• Sources must be in compliance by 5/1/05• Average point NOx reduction is 30%• Model shows attainment in 2005

Revision for severe classification by June 23

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HRVOC Workgroup

• 1-hour ozone design value has dropped from around 170 ppb in the early 90s to the low 130s ppb today

• VOC and NOx have been dropping steadily since the early 90s

• See VOC and NOx graphs

14

Point Source VOC Emissions TrendBaton Rouge Nonattainment Area (1990-2002)

TON

S PE

R Y

EAR

5000

10000

15000

20000

25000

30000

35000

40000

45000

90 93 94 95 96 98 99 00 01 02

YEAR Data Source: DEQ

97

15

0

10000

20000

30000

40000

50000

60000

70000

80000

90 93 94 95 96 97 98 99 00 01 02

YEAR

TON

S PE

R Y

EAR

Point Source NOx Emissions Trend Baton Rouge Nonattainment Area (1990-2002)

Data Source: DEQ

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HRVOC Workgroup (continued)

• Continuing to have exceedances (11 in 03)• Plot shows rapid ozone formation events

(greater than 40ppb/hr rise) - see graph• Similar spikes in Houston, Texas 2000 Air

Study implicated HRVOC – 1,3-butadiene, acetaldehyde, butenes, ethylene, propylene, toluene and xylenes

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Sept 11, 2002 Ozone

020406080

100120140160180

Hour

O3

ppbv

Capitol Baker LSU Port Allen Carville Bayou Plaquemine Pride

CapitolLSU

P Allen

B Plaquemine

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HRVOC Workgroup (continued)

• Workgroup (DEQ, Industry, Environmentalists) formed to evaluate role of HRVOC.

• Recommendations: Add NOx at Dutchtown, Met at LSU and Carville Add continuous VOC at LSU, Capitol, Carville Add VOC canister every 6th day at others Record 5 minute data in addition to 1 hour average Develop database for past and future data, perform

statistical analyses

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Site NOx O3 MetVOC

3-hr (daily)

3-hr (3-days)

24-hr(6-days)

Trigger (1 ppm of TNMHC)

(3)Capitol *  

LSU * *   * *

Bayou Plaquemine    

Port Allen     *

Pride    

Dutchtown *     *  

Baker      

Carville * *     *

Grosse Tette        

French Settlement        

           

           

Southern          

South Scotlandville           *

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HRVOC Survey

• Purpose was to identify sources of HRVOC (TEDI-toxics, EIS-total VOC, TRI-facility)

• Sent to 148 facilities in BR area• 62 met criteria of >1,000 lbs/yr HRVOC

emissions and submitted information• Results: See graphs

21

HRVOC Emissions by Chemical

1,3-butadiene2.2%

ethylene44.8%

toluene24.9%

propylene12.5%

butenes6.4%

acetaldehyde2.8%xylene

6.4%

Total = 3,500,000 lbs

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HRVOC Emissions by Emission Type

non-routine1.26% other

0.10%

loading/unloading0.97%

start-up/shutdown3.25%

accidental9.33% routine

52.45%

fugitives32.63%

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Breakdown of Routine Category

analyzer6%

wastewater2% Cooling Tower

2%

miscellaneous6%

Flare8%

Tank/Silo29%

process vents47%

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HRVOC Emissions by Estimation Method

other1.4%

measured8.7%

engineering estimate

9.5%

calculated6.2%

educated guess2.9%

factors35.5%

material balance21.2%

estimated13.9%

modeled0.6%

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Action Plan for Summer 2004

• Review Environmental Management System Are all emissions being accounted for? Can emissions be lowered by reducing at

source, recycling, recovery or treatment? Are measured values being used, where

available, to estimate the quantity of emissions? Are the latest and best factors and estimation

methodologies being used?

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Action Plan for Summer 2004 (continued)

• Fugitives – before Summer - consider remote imaging to survey regulated and non-regulated components where HRVOC could leak, make extraordinary attempts to fix tagged leakers

• Flares – always operate within design, delay discretionary flaring to evening

• Cooling Towers – check inlets weekly for HRVOC, fix leaks as soon as possible

• Wastewater – reduce HRVOC wherever possible

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Action Plan for Summer 2004 (continued)

• Analyzer Vents – route to flare or minimize• Shutdowns – do early or postpone until after

ozone season• Maintenance/Equipment Opening – delay

until evening, refueling in late evening• Seasonal Activities – delay painting until later

in year, do grass cutting in evenings, etc.

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Summary

• Ozone exceedances in downtown BR in 2004/05 will put the area out of attainment.

• If this happens, emission fees will kick-in.• Facilities are asked to develop action plans

to reduce emissions, especially HRVOC, but also, other VOC and NOx.

29

Fugitive Monitoring

• EPA is preparing an alternate to Method 21 that will allow Remote Imaging by end 04.

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