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Update: National Ambient Air Quality Standards Association of California Airports September 15, 2010 Phil DeVita
Overview Typical Air Quality Regulations Revised NAAQS EPA Lead Proposal Moving Forward
Air Quality Regulations Federal Clean Air Act Amendments (CAA) National Environmental Policy Act (NEPA) State California Environmental Quality Act (CEQA) Air Resource Board (ARB) Local Local Air Pollution Districts (35)
Definitions National Ambient Air Quality Standards (NAAQS) – developed by EPA to protect public health (Primary Standards) and welfare (Secondary) Criteria pollutants (NOx, SO2, PM10, PM2.5, CO, Ozone, Lead) Non-attainment Area designated by EPA as not meeting the NAAQS Attainment Area designated by EPA which meets the NAAQS Maintenance Previously designated non-attainment subsequently redesignated to attainment State Implementation Plan Each state is required to draft a state implementation plan (SIP) to further improve the air quality in nonattainment areas and to maintain the air quality in attainment and maintenance areas. The plan outlines the measures that the state will take in order to improve air quality De-minimus Levels Impacts above de-minimus levels are considered significant. Levels are set based on attainment status. Keep impacts below these levels. General Conformity Only apply in non-attainment and maintenance areas. If net emissions below de-minimus levels, and not regionally significant, no further action. Otherwise; Conformity determination conducted using dispersion modeling for NAAQS compliance.
Tightening Ozone EPA proposes tightening the 8-hour Standard effective 8/31/2010 (delayed until October 2010) Reduce the standard from 75 ppb to 60-70 ppb CA Standard 70 ppb Result of New Standard More non-attainment areas Require Agencies to develop a SIP for attainment Precursors such as VOC and NOx will be targeted More projects subject to EPA Conformity Potential for Agencies to require more reductions at airports Reclassification of existing non-attainment areas severity Increase pressure for emission reductions Lower conformity thresholds
Existing Ozone Non-Attainment Regions Source: EPA
Proposed Ozone Non-Attainment Regions Source: EPA
1-Hour Sulfur Dioxide New SO2 standard Effective 6/2/2010 Keep the 3-hour secondary and revoke the 24-hour and annual primary standard New 1-hour standard of (196 ug/m 3 ) more restrictive than CA standard of 655 ug/m 3 New monitors proposed along with modeling for compliance Designations by June 2012
1-Hour NO2 Standard A new short-term standard 100 ppb (188 ug/m 3 ) in addition to annual standard More restrictive than CA (current 1-hour NO2 is at 339 ug/m 3 ) Significant for airports since located near highways and aviation emissions are higher for NO2 Many airports could be located in 1-hour NA, thereby subjecting to General Conformity for NO2 Attainment designations by Jan 2012, conformity reviews by 2013. New Monitors proposed near major roadways or other large stationary sources of NO2
Particulates EPA currently reviewing, update due in 2011 Draft Policy Assessment based on the Integrated Science Assessment recommends stricter PM2.5 standards Annual Standard 10-13 ug/m 3 (15 ug/m 3 ) CA at 12 ug/m 3 24-hour Standard 25-35 ug/m 3 (35 ug/m 3 ) No Ultrafine Particulate standards (i.e. diameter < 0.1 um)
Lead EPA Lowered Standard in January 2009 From 1.5 ug/m3 to 0.15 ug/m 3. Trend in lead emissions down from the 1980s (91%) Lead is still in General Aviation Gas (AvGas) Concern near airports with high piston engine activity Low income/minority populations near airports EPA conducted a follow up study at Santa Monica Airport. Air and Soil emissions. Not a risk assessment. Previous monitoring results below standard but up to 9 times above background New results also below standard especially near the runway
Lead near Airports EPA requires states to locate lead monitors in areas with sources that emit over 1 ton/yr Four new lead monitoring programs at airports: Van Nuys, Phoenix, Teterboro, Centennial
Lead: What is Next EPA ANPR for Endangerment Finding ANPR is the earliest step in the process In response to Friends of the Earth petition EPA agrees to conduct further health and environmental impact studies to understand lead impacts Unknown whether lead emissions from Piston engines contribute to endangerment Endangerment Finding Requires EPA to issue a lead emission standard (i.e. new lead standard for AVGAS EPA would consult with FAA to insure safety and compliance Many issues remain such as drop in, safety, availability Industry concern about how EPA is evaluating emissions near airports: Old fuel usage and LTO, modeling techniques
Moving Forward Airports should track NAAQS changes and attainment designations for their location Know the SIP process for your region including: Obtain SIP emission inventory Understand the budgets Contact DEP agency to learn existing monitoring locations and proposed sites near the airport Have a good understanding of emission inventory at your airport (i.e. modeling) ACRP Project “Quantifying and Monitoring Lead Emissions from Leaded Aviation Gasoline”
Thank You for your time… For more information, please contact: Phil DeVita, CCM firstname.lastname@example.org email@example.com www.hmmh.com
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