1. Department of Environmental Quality
Update on SO2 Standard Implementation
Air Quality Committee Meeting
July 13, 2016
Donnie Redmond
Department of Environmental Quality

2. Update on Sulfur Dioxide (SO2) Data Requirements Rule (DRR) Implementation
SO2 NAAQS background
Introduction of SO2 DRR
Current status of implementation

4. SO2 Standard Implementation
Round 1: October 4, 2013 – EPA designated areas in the US with violating monitors as nonattainment
None in NC
Round 2: “The down-payment designations”
Court Entered Consent Decree on March 2, 2015
One Facility Impacted in North Carolina
State Recommendation Due September 18, 2015
EPA Sent Letter Generally Concurring with State’s Recommendation on February 16, 2016
Final Response Due to EPA on April 19, 2016
Final Designations Announced by July 2, 2016
… but wait… there’s more…

5. SO2 Standard Implementation
EPA’s final Data Requirements Rule (DRR) – August 2015
All facilities with SO2 emissions > 2000 tons per year must be analyzed
January 15, 2016 – list of facilities due
7 total facilities with emissions over threshold
2 additional facilities below threshold with 3rd party modeling analysis showing potential violations
July 1, 2016 – monitoring or modeling approach due
January 1, 2017 – monitoring sites installed and operational
January 13, 2017 – modeling due to EPA

6. SO2 Standard Implementation
Round 3: December 2017– EPA designates areas based on the modeling analyses submitted
Round 4: December 2020 – EPA designates all remaining areas (using the data collected from the monitoring that started in 2017)

7. SO2 DRR: To Model or to Monitor?
NC DAQ’s letter of January 15, 2016 identified nine facilities to be evaluated
NC DAQ’s letter of July 1, 2016
Five facilities modeled in compliance
Modeling due to EPA Jan 2017
Areas around the facilities will be designated in Dec 2017
Facilities that modeled compliance
Duke Energy Belews Creek
Duke Energy Marshall
Duke Energy Mayo
Duke Energy Allen
Duke Energy Asheville

8. SO2 DRR: To Model or to Monitor?
NC DAQ’s letter of January 15, 2016 identified nine facilities to be evaluated
NC DAQ’s letter of July 1, 2016
Four facilities will go the monitoring path
Monitors must be operating by Jan 1, 2017
monitoring will determine design value
Areas near these facilities will be designated in Dec 2020
Facilities that will undergo monitoring
Duke Energy Roxboro
CPI Southport
Evergreen Packaging Canton Mill
PCS Phosphate

9. SO2 DRR: Monitoring
SO2 DRR monitoring sites are included in the annual Ambient Monitoring Network plan
30-day public comment period
Due to EPA by July 1, 2016
EPA technical staff has visited each new monitoring site
Two sites are already operational (one was an existing site)

10. Factors in determining SO2 monitor location
Modeling
Ranking of maximum values
Ranking of frequency
Combined “index” to rank prospective sites
Much more limited options than typical
Physical characteristics of potential sites
Terrain, tree cover
Access
Power
Long-term availability of the site
Critical: Can we stay for at least three years?

11. SO2 Site Approval Process
EPA on-site visits
Not normally done
Tight timelines, consequences led us to request
Region 4 technical staff obliged
30-day public comment period
Posted on DAQ website; announces
Monitoring Network Plan
Due to EPA by July 1
They typically approve it Sept-Nov

12. PCS Phosphate (Aurora)
Limited siting options because of 2-mile wide Pamlico River downwind of facility and large tracts of land surrounding facility
Propose using existing SO2 monitor at Bayview Ferry, directly across river
Placed relatively high among remaining receptors’ ranking
EPA has previously approved this site, but for other purposes
DAQ’s Washington Regional Office operates this site, and will continue to do so

13. Duke Energy Roxboro Located on CertainTeed property
Monitor is in operation
Duke operates the site, but DAQ will audit, perform daily QA, and ultimately be the party to certify the data
EPA approves (and encourages) such arrangements for this rule

14. CPI Southport
Mostly private property in desired area (based on modeling)
One property owner is agreeable to our conditions
Currently formalizing an agreement and prepping the site
Expect it to be operational by end of July
DAQ’s Wilmington Regional Office will operate
To be submitted as addendum to network plan, with separate 30-day public comment period

15. Evergreen Packaging (Canton)
Monitoring site is on NC DOT property
Currently formalizing agreements for long- term use of property
Expect it to be operational by end of Sept
DAQ’s Asheville Regional Office will operate

16. Questions? Donnie Redmond Ambient Monitoring Section Chief
Department of Environmental Quality