In November, the EPA proposed strengthening the National Ambient Air Quality Standards (NAAQS) for ground-level ozone. More commonly referred to as smog, ozone is a pollutant that forms on warm, sunny days and should not be confused with ozone in the upper atmosphere. Unlike other pollutants, ozone is not directly emitted by any one source; rather it is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight.
Often invisible but harmful, ozone pollution threatens the health and well-being of all living creatures. Breathing ozone can trigger a variety of health problems, particularly for children, the elderly and people of all ages who have asthma. Ground level ozone can also have harmful effects on sensitive vegetation and ecosystems.
Currently, the EPA requires states to maintain ozone levels to concentrations at or below 0.75 parts per billion (ppb). At present, 227 counties throughout the country are considered in nonattainment of the existing ozone requirement. Under the proposed rule, this number would increase significantly. If reduced to 0.70 ppb, 358 counties would be out of compliance. If lowered to 0.65 ppb, that number jumps to 558 counties, which would now be in violation of the standard.
States and counties no longer meeting the prescribed ozone levels would be required to develop plans ensuring reasonable progress is being made toward attaining the new standards. Known as state implementation plans (SIPs), these enforceable documents explain how states will achieve and maintain the required air quality standard through the use of control strategies. The control strategy approach will vary by state and region but will provide an outline or set of actions that may be taken to meet the standard, such as identifying industries that will be required to install certain types of control equipment and technology.
Targeted sources may include:
- Point sources (e.g., refineries, chemical plants, terminals, industrial facilities).
- Area sources (e.g., auto body shops, dry cleaners).
- Mobile sources (e.g., construction equipment, automobiles).
- Biogenic sources (e.g., trees and plants).
So what does this translate to in terms of practical effect on the industry? In areas where ozone attainment is now an issue, states will need to look to new sources of VOC and NOx in order to reduce ozone to acceptable levels. With many of the larger emitters already accounted for and control measures in place, environmental regulators will increasingly look to smaller sources and operations in an attempt to reduce emissions to target levels. Areas with existing ozone issues can be looked at as providing a forecast for possible air district emissions targets. Texas, California and New Jersey have targeted a variety of smaller source VOC and NOx emissions through past regulations; placing restrictions on activities such as tank degassing, turnaround events, vacuum truck control and other emissions sources.
EPA will take comment on the proposal for 90 days after it is published in the Federal Register and will hold three public hearings addressing comments and concerns. The agency will then issue a final decision by Oct. 1. Once enacted, states will begin to design and deliberate, through an open process, their plans to improve air quality. Finalized rules will then follow with states attempting to meet the new ozone standard within required deadlines.
For more information, visit www.gem-mobile.com or call (281) 471-0107.
