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Massachusetts SIP Steering Committee: June 1, 2007, Meeting Summary    

In Attendance:

Anne Arnold, EPA Region 1
Richard Burkhart, EPA Region 1
Paula Hamel, Dominion
John LeFebvre, Polaroid
John Quinn, Mass Petroleum Council
Rich Rothstein, Km Chng Environmental
Carrie Russell, Conservation Law Foundation
Carl Spector, City of Boston

Mass DEP Staff:

Eileen Hiney
Glenn Keith
Barbara Kwetz
Steve Dennis
Richard Fields
Azin Kavian
Ken Santlal

Please note that all materials distributed or presented at the June 1, 2007 meeting are available at http://www.mass.gov/dep/public/committee/daqcpu11.htm.

Update on Regional Haze Control Strategies  (Barbara Kwetz - Presentation and Handout)

Barbara Kwetz reviewed the requirements of EPA's Regional Haze Rule and discussed the ongoing MANE-VU process to address visibility impairment in Class 1 federal areas, of which there are 7 in the MANE-VU region. "Reasonable Progress Goals" must be set for each Class 1 area, with 2018 being the first milestone year. Goals are set by the states with Class 1 areas (does not include MA) in consultation with those states that contribute to visibility impairment and with Federal Land Managers.

MANE-VU has developed a Reasonable Progress Goals Project Summary, which was distributed. The pollutant of primary concern in MANE-VU is Sulfates (SO2), with Organic Carbon as the second largest contributor. Approximately 70% of the SO2 emissions in the 2002 MANE-VU emission inventory come from 34 electric generating units; some of these are within the MANE-VU states and others are outside of the region. There are also impacts from wood smoke from within the MANE-VU region and Canada.

MANE-VU has identified potential control measures and will develop a "Four Factor Analysis" per EPA guidance for each control measure as applied to each source category. The Four Factor Analysis looks at costs and time needed for compliance, the energy and non-air quality environmental impacts of compliance and the remaining useful life of any existing source. The analysis will provide additional information for MANE-VU states to consider in setting Reasonable Further Progress Goals for each Class 1 area. The next steps will be to review modeling results, continue consultation within MANE-VU and with other Regional Planning Organizations, and obtain input from stakeholders. 

SIP Requirements Update

MassDEP must address multiple SIP requirements in the next few months. Eileen Hiney reviewed the status of the RACT, Transport and Reasonable Further Progress SIPs. (Presentation)

Steve Dennis reviewed the Attainment Demonstration for the 8-Hour Ozone Attainment SIP.  (Presentation)

  • RACT SIP: MassDEP had conducted the required review of all RACT regulations to determine if what it adopted as 1-hour RACT still can be considered RACT for 8-hour purposes. With the exception of solvent cleaning, asphalt paving, and Stage II pressure vacuum vent caps on certain systems, MassDEP has concluded that existing VOC RACT satisfies 8-Hour RACT requirements. For NOx RACT, it expects to conclude that 1-Hour RACT meets 8-Hour RACT for all source categories, including industrial, commercial and institutional (ICI) boilers.

  • Transport SIP: Within three years after a new National Ambient Air Quality Standard is issued, the Clean Air Act requires that, in addition to adopting a SIP that demonstrates its own attainment, a state must submit a SIP that address the transport of emissions generated within its borders to downwind states. Following the promulgation of ozone and PM2.5 standards in 1997, EPA did not complete the nonattainment designations until June 2004 for ozone, and April 2005 for PM2.5. Therefore, states were not able to submit SIPs within 3 years. EPA has set a submittal date of May 25, 2007 for states to submit the required "transport" SIPs.

    In CAIR, EPA concluded that emissions from Massachusetts contribute to ozone nonattainment in CT and RI, but do not contribute to PM 2.5 nonattainment anywhere. MassDEP’s Transport SIP will conclude that with the adoption of Mass CAIR and the other VOC control measures that will be part of its attainment SIP, it has addressed its contribution to nonattainment. 

  • Resonable Further Progress SIP: To meet 8-hour ozone standard requirements related to Reasonable Further Progress (RFP), moderate nonattainment areas must demonstrate that by the end of 2008, the area will reduce emissions of VOCs, NOx, or a combination thereof, by at least 15% from 2002 levels. MassDEP has completed preliminary RFP calculations and expects to be able to demonstrate that, in both EMA and WMA, emissions will be reduced by a significantly greater percentage than the required 15%. 

  • Attainment Demonstration SIP: With the latest update to the regional emissions inventory that is being used in the Ozone Transport Commission's attainment demonstration modeling, Massachusetts is modeling attainment. The Lynn and Milton monitors in Eastern MA are showing the highest modeled ozone values in MA in 2009 of .082 ppb, but these are below the .084 ppb that is considered modeled attainment. 

Regulatory Update (Eileen Hiney - Handout)

  • Mass Clean Air Interstate Rule (CAIR) Implementation: MassDEP submitted its CAIR SIP and Mass CAIR rule to EPA on March 30. The rule was published in the MA Register and became effective on May 4, 2007. MassDEP has begun implementing the rule, including drafting a CAIR permit application for sources in the Mass CAIR program. 

  • Architectural and Industrial Maintenance (AIM) Coatings and Consumer Products: MassDEP held public hearings in February and March on proposed amendments to its existing regulations restricting the VOC content of AIM coatings and consumer products. The final rules, which will have a January 1, 2009 effective date, should be issued within the next few months.

  • Solvent Metal Degreasing: MassDEP intends to propose an amendment to its existing regulation for this category (310 CMR 7.18(8)) to include a vapor pressure limit on solvents used in cold cleaning, consistent with a 2001 OTC Model Rule. This will address RACT requirements for this category under the 8-hour ozone standard. The proposed amendment should be issued for public comment in the next few months and will have a proposed effective date of January 1, 2009. 

  • Adhesives and Sealants: The OTC recommended that states adopt new controls on adhesives and sealants used by industrial sources as part of its 8-hour ozone control measures review; industry has not objected to the proposal.  The OTC is drafting a model rule for states to consider.  MassDEP intends to propose a new regulation based on the OTC model rule by the end of 2007.

  • Asphalt Paving: Cutback asphalt typically contains from 25 to 45 percent by volume of petroleum distillates. Emulsified asphalt is a lower emitting alternative that uses an emulsifying agent, such as soap. Some emulsified asphalts may contain virtually no VOCs; others may contain up to 12% VOC by volume. MassDEP regulation 310 CMR 7.18(9) bans the use of cutback asphalt during the ozone season, but with a number of exceptions. It does not address emulsified asphalt.

    The OTC identified asphalt paving as a category for additional VOC reductions and developed a model rule that prohibits the use of cutback asphalt during the ozone season and limits the VOC content of emulsified asphalt. MassDEP intends to adopt the OTC model rule to the extent feasible in Massachusetts, after receiving input from stakeholders.

  • Portable Fuel Containers: MassDEP intended to adopt the OTC Model Rule for PFCs (gas cans). However, in February 2007, EPA finalized a national rule that will be effective January 1, 2009 and achieve the same level of emission reductions. MassDEP, therefore, will not propose a state rule.  

Ozone NAAQS Review  (Rich Burkhart – Presentation)

EPA is required to review the NAAQS every five years; a review of the ozone NAAQS is underway.  Final Staff Paper Analyses were issued on January 31, 2007 and a proposal is to be signed by June 20, 2007.  A final rule will be signed by March 12, 2008 pursuant to a consent decree.

Since that last ozone NAAQS review was completed, a considerable amount of new health data has been accumulated that supports a standard lower than the current 8-hour standard. The EPA Staff paper discusses possible ranges for a new primary standard to protect public health and a secondary standard to protect against environmental impacts on vegetation and ecosystems.

Next Meeting: September 6, 2007

 

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