Impacts of Ozone Nonattainment Designation and Strategies for Compliance
In 1997, the U.S. Environmental Protection Agency (U.S. EPA) revised the National Ambient Air Quality Standards (NAAQS), to include an 8-hour ozone standard. The previous 1-hour ozone standard addressed the effects of exposure to short periods of high concentrations of ground-level ozone. The intent of the new standard is to address exposure to lower ozone levels over longer durations. With the implementation of this new standard, each state was required to submit a list of ozone nonattainment designations for areas within the state. The U.S. EPA reviewed these recommendations and made final attainment designations in April 2004. The implementation of the 8-hour ozone NAAQS resulted in the redesignation of several areas, which previously demonstrated attainment for the 1-hour standard, into nonattainment for the 8-hour standard. This status redesignation has the potential to impact industries located in these areas in various ways. For example, the new ozone nonattainment designations, and each state’s plans to achieve attainment, will need to be incorporated into the State Implementation Plans (SIPs). These SIP changes are expected to translate into new, or revised, Reasonably Available Control Technology requirements. New Source Review (NSR), as well as the requirements of major Nonattainment NSR, will be affected in that industry will be subject to the Lowest Achievable Emission Rate, emission offsets, state-wide compliance determination, and alternatives analysis requirements. The redesignation of attainment status may also result in reductions in Federal Operating Permit (Title V) major source thresholds, leading to additional monitoring, recordkeeping, and reporting. This paper provides a detailed discussion on several changes expected to result from the implementation of the new 8-hour ozone NAAQS and strategies for industries located in new ozone nonattainment areas with regard to complying with new requirements.