Date post: | 15-Apr-2017 |
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Environment |
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Topics
Permit and Compliance Improvements – What does this mean for you?
Compliance Strategies for Business – Making things easy
Emerging Air issues including Ozone, Clean Power Plan, etc.
Ohio EPA’s Air Pollution Control Program
5 Regional (District) Offices; 9 Local Air Agencies; Central Office; Field Office
180 Employees across the state plus Local Air Agencies
+72,000 sources at over 14,000 regulated facilities
2,000 Air permits issued annually
+290 Ambient air monitors
We are efficient and lean!
Ohio EPA’s Air Pollution Control Program • District Offices
• Permits, Inspections, • Communication, problem solving
• Central Office • State Implementation Planning • Permit review and issuance • Modeling • Legal and Policy Issues
What drives us? • Consistency - statewide
• Efficiency - permit and compliance programs to
facilitate compliance of regulated community
• Prioritization – recognizing top priorities and focusing our efforts accordingly
Permit Process: Making it Easy • Online application preparation and tracking
• Pre-application meeting to begin process
• Periodic status calls and/or meetings with
specialists
• Review of permit before issuance– No surprises!
• Changes happen – we adapt quickly!
Permit Process: What to Expect • Recommend early pre-meeting
• Review of application within 14 days
• Deadline driven • Highly experienced with PSD & Synthetic Minor
permits
• 85% of new permits written within 90 days in past 2 yrs
Success Story: Oil/Gas Expansion
Worked closely with Oil and Gas industry
Held multiple conference calls with interested parties
Conducted webinars
Guidance:
General Permit developed for well sites
General Permit developed for compressor stations
Developed multiple guidance documents
Information packets and guidance docs to industry
Success Story: Oil/Gas Expansion Since development began, we have issued:
500+ permits for well-site installations
(average issuance – 15 days)
280 permits for mid-stream
(compressor stations, gas clean-up)
40 permits for gas processing for oil/gas expansion
(separation, fractionation, stabilization facilities)
Still expanding!
Available Online Services eBusiness Center
Air Services
Electronic Payments
Other Division Applications
Customer Support Center
Permit Wizard
FAQ
Training
What can you do in Air Services? Create & Submit
Permit Applications
Emissions Reports
Permit Related Reporting
Compliance
Emissions Tests
CEM/CERMS/COMS
Facility Data Updates
Portable Source Relocation
View History & Maintain Data
Permit tracking
View submission history
View correspondence
Designed for Ease of Use Designed to avoid duplicate data entry
Access to facility application and reporting history
Access to Word version of current permits
Ability to copy from previous reports or applications within facility
Compliance and Enforcement Our Goal is Compliance
We strive to be fair, equitable, transparent and timely.
Inspector Rotation
Discuss findings of inspections during the visit.
Minimize surprises and opportunity to address issues quickly. (many times before we leave)
Memorialize how problems should be addressed across the state. (via internal improvements)
Practical Advise Preparing staff for inspections
Obvious stuff (permits, monitoring, recordkeeping, reports, testing, etc.)
Inspections: Ask about inspector’s operational knowledge and tailor conversation. Walk the plant process start to finish
Big Bang Theory vs CSI vs Colombo Human element
Build trust and a relationship
Honesty, integrity, no double-speak, clearly answer questions and find information quickly.
Current Challenges Federal Activity
Ozone
NAAQS
Startup Shutdown Malfunction SIP Call
Interstate Transport
Clean Power Plan
Doing More with Less…
Photo of Republic Steel, Cleveland from
Cleveland State University, Dept. of History, Teaching and Learning Cleveland
Ohio’s Attainment Challenges
The entire state is attainment for nitrogen dioxide,
and carbon monoxide.
Isolated nonattainment areas for SO2, lead and PM
2.5
New Ozone Standard
U.S. EPA adopted ozone standard in 2008 – 0.075
ppm eight-hour average
Cincinnati, Cleveland, Columbus designated
nonattainment
Attainment date - 2014 – Cincinnati and Columbus met
standard – Ohio EPA requested/one year extension for
Cleveland – met standard in 2015
Ozone NAAQS
0
10
20
30
40
50
60
70
80
90
100
110
120
1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013
pp
b
Ohio Average One Year 8-Hour Averages
Average LLS-30 LLS-20
U.S. EPA proposed a range from 0.065 ppm – 0.070
ppm
Ohio EPA filed comments – data supports keeping
standard 0.075 ppm
On October 1, 2015, U.S. EPA adopted a standard
of 0.070 ppm for both primary and secondary
standard
U.S. EPA Revised Ozone Standard
October 1, 2015 U.S. adopts new standards
October 1, 2016 States submit recommendations
for nonattainment areas
October 1, 2017 U.S. EPA finalizes nonattainment
October 1, 2019 Infrastructure SIPs due
October 1, 2020 Attainment date for marginal
nonattainment areas (expect all Ohio
areas to be marginal)
Timeline for Completion – Revised
Ozone Standard (cont’d)
Clean Power Plan aka 111(d)
Carbon emissions from existing coal and natural gas fired electricity generators
U.S. EPA proposes plan that requires 32% reduction in emissions of CO2
111(d) is a stationary source rule
Coal based control technology not practical Parasitic load penalty alone of almost 30%
Only way to reduce emissions is to reduce coal usage
Energy Sector rule More renewable energy sources
Maximize existing natural gas plants
Interim
Step 3
Interim Step 2
Interim Step 1
2030 Goal C
PP
Fin
al R
ule
Init
ial
Sta
te S
ub
mis
sio
n
Fin
al P
lan
Su
bm
issi
on
Clean Energy
Incentive Program
2-year delay
Clean Power Plan Timeline
Key Questions and Challenges
How to analyze Compliance Pathways efficiently?
Mass vs Rate?
Trade-Ready plan?
How do we minimize CPP impact on electricity costs to end users?
How do we assure continued reliable service to the state?
How do we minimize the unpredictability in the marketplace and provide certainty for future investment and development?
Legal Challenges
Methodical analysis
Collaborate very closely with Ohio Public Utilities
Commission
Not an Island (awareness of other states)
Extension request due Sept 2016
Outreach and Engagement Plan
Remain mindful of challenges and not rush to
any decisions.
Ohio’s CPP next steps
Questions or concerns?
Adam Ward
Assistant Chief
Ohio Environmental Protection Agency
Division of Air Pollution Control
w 614.728.3784
c 614.546.9163