UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: November 12, 2015

SUBJECT: Technical Support Document for the District of Columbia State Implementation

Plan for the Interstate Pollution Transport Requirements for the 2010 Nitrogen Dioxide National Ambient Air Quality Standards

FROM: Emlyn Velez

- Rosa, Environmental Engineer \ s \

Office of Air Program Planning

TO: File for Docket ID Numb er EPA

- R03

- OAR

- 2015

- 0750

THRU: Cristina Fernandez, Associate Director \ s \

Office of Air Program Planning

A. INTRODUCTION

The Environmental Protection Agency (EPA) is taking action on a revision to the District of Columbia State Implementation Plan (SIP) submitted by t he District Dep ar t ment of Energy and

Environment ( D DO E E) to satisfy the interstate pollution transport requirements under section 110(a)(2)(D)(i)(I) for the 2010 nitrogen dioxide (NO 2 ) national ambient air quality standards (NAAQS or standards).

B. BACKGROUND

On February 9, 2010 (75 FR 6474), EPA established a new 1

- hour primary NAAQS for NO 2 at a level of 100 parts per billion (ppb), based on a 3

- year average of the 98 th percentile of the yearly

distribution of 1

- hour daily maximum concentrations. See 40 CFR 50.11. NO 2 is a subset, and often considered an indicator, of the broader pollutant nitrogen oxides (NOx).

Whenever new or revised NAAQS are promulgated, the CAA r equires states to submit a plan for the implementation, maintenance, and enforcement of such NAAQS. The plan is required to address basic program elements, including, but not limited to, regulatory structure, monitoring, modeling, legal authority, and ade quate resources necessary to assure attainment and maintenance of the standards. These elements are referred to as infrastructure requirements. Infrastructure SIP revisions should provide for the “implementation, maintenance, and

enforcement” of such NAA QS. The statute directly imposes on states the duty to make these SIP submissions, and the requirement to make the submissions is not conditioned upon EPA’s taking any action other than promulgating a new or revised NAAQS. Section 110(a)(2) includes a li st of specific elements that “[e]ach such plan” submission must address.2

One of the infrastructure requirements, section 110(a)(2)(D)(i)(I) of the CAA, or the “good neighbor” provision, requires states to address interstate transport of air pollution th at affects downwind states’ ability to attain and maintain the NAAQS. Specifically, s ection

1 10(a)(2)(D)(i)(I) requires state SIPs to address any emissions activity in one state that

contributes significantly to nonattainment, or interferes with maintenan ce, of the NAAQS in any downwind state. EPA sometimes refers to these requirements as prong 1 (significant contribution to nonattainment) and prong 2 (interference with maintenance), or conjointly , the interstate pollution transport requirements.

C. SUMMARY OF STATE SUBMITTAL

On June 6, 2014, t he District submitted

, through D D OEE

, a revision to its SIP to satisfy the

infrastructure requirements of section 110(a)(2 ) of the CAA for the 20 10 NO 2 NAAQS . T he

District’s infrastructure SIP revision addressed the applicable infrastruct ure requirements for the

20 10 NO 2 NAAQS , including s ection 110(a)(2) (D)(i)(I ) of the CAA. I n its transport submittal, the District concludes that it does not contribute to nonattainment in, or interference with

maintena nce by, any other state with respect to the 20 10 NO 2 NAAQS, based on emissions and air quality data. Further discussion of the District’s justification provided in each submittal as well as EPA’s rationale for proposing approval of this SIP revision as me eting s ection 110(a)(2) (D)(i)(I ) of the CAA for the 20 10 NO 2 NAAQS is provided below.

D. EVALUATION OF STATE SUBMITTAL

NO 2 is one component of NOx and is generally used as an indicator for the larger group of NOx.

The District evaluated actual emission s inventories for the District and concluded that there are currently no large stationary sources that can contribute significant NO x emissions to nearby states. EPA confirms that the District’s stationary point sources correspond to 7 percent of the

tota l NOx emissions in 2011, while the nonpoint sources correspond to 17 percent. See Table 1

below based for 2011 NEI data (version 2)

.

Table 1

. 2011 Actual Emission from the District by Source Category

Source Category Annual Emissions

(tons per year)

Point 692.33

Area 1621.35

Onroad 4739.47

Nonroad 2364.45

Total 9417.60

As indicated in the June 6, 2014 submittal, there are currently no electric generating units ( EGUs ) in the District. The District’s last remaining EGU, Benning Road Generating, was decommissioned in 2012, in part to meet other SIP requirements. See 77 FR 5191 (February 2, 2012) (approving the District’s Regional Haze SIP revision). Additionally, the District indicates3

that its two largest stationary sou rces of NOx , the U.S. General Services Administration’s Central Heating and Refrigeration Plant (GSA) and the U.S. Capital Power Plant (CPP), are subject to Federally

- enforceable emissions limits that have already resulted in significant

emissions reductio ns of NOx. The CPP is subject to NOx emissions for the two coal

- fired

boilers of 0.43 pounds per million British thermal units (lb/MMBtu) with slightly more stringent limits during the ozone season, 1 in addition to a recent plant

- wide annual limit (PAL) o f 248.1 tons per year (tpy), effective since January 2013. 2 EPA also notes that CPP has plans to construct combustion turbines to burn natural gas which will replace the coal

- fired boilers and have significantly tighter NOx emission limits. 3

The GSA is subject to a Federally

- enforceable PAL of NOx emissions of 268 tpy. 4 In addition,

the GSA has the only non

- EGU s in the District that are subject to EPA’s NOx SIP Call 5 , which imposed NOx reduction requirements on large boilers and turbines over 250 milli on British thermal units per hour (MMBTU/hr) as well as imposing requirements on EGUs. Th us, to meet the NOx SIP Call requirements, as of May 2015, th e GSA’s largest t hree emission units (i.e., over 250 MMBtu/hr) are subject to a combined stringent NOx emission limit of 25 tons per

ozone season. 6 The District explains in its SIP submittal that GSA does not have any other sufficiently large emissions units that could be controlled to significantly reduce NOx emissions

. T he District affirms that all other major stationary sources in the District have emitted less than 30 tons per year of NOx since 2008.

On February 17, 2012 (77 FR 9532) , EPA published its final designations for the 2010 NO 2 NAAQS, based upon 2008

- 20 10 design values . In this rulemaking, EPA determined that no area

in the count r y was violating the standard , designating all the areas of the country as

unclassifiable/attainment . The 2008

- 2010 design values reflect conditions at the time throughout

the country well below the 2010 NO 2 NAAQS , including the District and nearby states.

Currently available air quality monitoring data confirms that NO 2 levels continue to be well

below the 2010 NO 2 NAAQS in the District and in a ny areas surrounding or bordering the

District. The District’s June 6, 2014 submittal included historical NO 2 air quality monitoring data for the District, as well as recent air quality monitoring data for the states surrounding or bordering the District within a 50 kilometer radius

, the standard distance for modeling analysis in

EPA’s Guideline on Air Quality Models (Appendix W to 40 CFR Part 51)

. Acc o r dingly, the District provided NO 2 air quality data f rom certain monitors in Maryland and Virginia which are located within the 50 kil ometer radius from the District

, during 2008

- 2010, 2009

- 2011 and 2010

- 2012 , as presented in Table 2 below

. See also attached the Air Quality System (AQS) reports (AMP480) with NO 2 monitoring data reported by the states. Base d on the air quality data provided

, EPA confirms that NO 2 air quality data for the District and for the surrounding states within the 50 kilometer radius from the District results in design values well below the 2010 NO 2

1 See District’s Title V Permit Number 033, issued on April 14, 2000 and presently in effect

. 2 See the EPA

- approved permit EPA

- R3

- PAL

- 001, effective on January 23, 2013

. 3 See District’s pre

- construction permits 6663

- C and 6664

- C, effective on June 6, 2013

. 4 See District’s Title V Permit Number 032, issued on July 28, 2000 and presently in effect.

5 63 FR 57371 (October 27, 1998)

6 This limit is required under 20 DCMR chapter 10, as amended by the District in May 2015. On June 26, 2015

, the

District submitted to EPA the se amendments to 20 DCMR chapter 10 as a SIP revision

, to address specific NOx SI P Call requirements.4

NAAQS, with the highest valid value being only 52 ppb (in Baltimore City, Marylan d )

.

Table 2

. 1

- Hour NO 2 Design Values for the District, Maryland, and Virginia

State County Site 1

- Hour Design Values (ppb) a

2008

- 2010 2009

-

2011 2010

-

2012 2011

-

2013 2012

-

2014

DC District of Columbia 110010025 52

- - - - DC District of Columbia 110010041 61 59 55 51

- DC District of Columbia 110010043 59 57 53 50 48

MD Baltimore 240053001 52 50 48 44 44

MD Baltimore city 245100040 57 58 57 52 52

VA Arlington 510130020 50 49 47

- - VA Charles City 510360002 57 55 52 47 43

VA Henrico 510870014

- 41 41 39

- VA Loudoun 511071005 40 41 39 37

- VA Prince William 511530009 30 28 28 28 28

VA Richmond city 517600024 54 52 51

- - VA Roanoke 511611004 38 39 39 36 37

a Only valid design values are evaluated.

The District affirms that improvements in air quality have been in part due to existing SIP

approved control measures for NOx emissions. The District’s SIP presently includes requirements for emissions limits on NOx including, but not limited to: 20 DCMR sections 80 2,

804 and 805 and 20 DCMR c h apter 10 for stationary sources. In addition, all major stationary

sources of NO 2 are subject to th e Federal requirements for prevention of significant deterioration (PSD) 7 and the SIP

- approved requirements of NSR in 20 DCMR section 204, 8 both which provide preconstruction review and permitting requirements in attainment and nonattainment

areas. Further, as noted by the District and recognized by EPA, due to previous ozone designations, the District’s NSR program continues to apply to its major stationary sources of NOx with potential emissions of 25 tons per year, a much more rigorous threshold t han currently applicable for major sources of NO 2 under the PSD program. 9 Additionally, the SIP

- approved regulation of 20 DCMR section 209 contains the District’s minor NSR program, which regulates

“minor” new or modified stationary sources ( with potentia l emissions exceeding certain lower

thresholds ) regardless of attainment status with respect the NAAQS. The District’s minor NSR

program es tablish es permitting requirements for sources of NOx emissions with a level of

control consistent with state

- of

- the

- art technology. Altogether, t hese permitting requirements help ensure that no new or modified NO 2 sources in the District will cause or contribute to

nonattainment for the 2010 NO 2 NAAQS. EPA finds the District’s SIP provisions are adequate

7 T he District is subject to a Federal Implementation Plan (FIP) containing the Federal PSD provisions in 40 CFR 52.21, as i ncorporated by reference in th e District SIP in 40 CFR 52.499. See August 7, 1980 (45 FR 52676, at 52741) ; March 10, 2003 (68 FR 11316, at 11322) ; and December 24, 2003 (68 FR 74483, at 74488).

8 Since the District is part of the Washington, DC, MD, VA nonattainment are a for the 2008 8

- hour ozone NAAQS and previous ozone standards , NO 2 as a subset of NOx is regulated under the NSR program , as precursor of ozone.

NO 2 is also regulated under the PSD program, as the District is designated as unclassifiable/attainment under the

2010 NO 2 NAAQS.

9 See 20 DCMR 204 ( 69 FR 77647 ; December 28, 2 004) and 20 DCMR chapter 1, section 199 ( 78 FR 24922 ; April 29, 2013)

. Se e also 40 CR 52.21(b)(1)(i).5

to prevent it s NOx emission sources to interfere with maintenance

, or contribute significantly to

nonattainment

, in another state with respect to the 2010 NO 2 NAAQS.

Based on and EPA’s review of air quality monitoring data and emission data, EPA does not expect NOx emissions in the District to increase significantly. EPA therefore does not expect monitors identified in Table 2 above, which all currently have design values well below the 2010

NO 2 NAAQS, to have difficulty maintaining attainment of the NAAQS. EPA con cludes the

District’s emission sources

, which are subject to the SIP

- approved provisions identified above, are not significantly contributing to nonattainment in another state with respect to the 2010 NO 2 NAAQS and are not likely to interfere with maintena nce of the 2010 NO 2 NAAQS in another

state.

E. EPA’s CONCLUSION

For all the reasons provided above , EPA is proposing to determine that the District’s SIP includes adequate provisions to ensure that NOx emissions sources within the District will not sig nificantly contribute to nonattainment or interfere with maintenance in another state with respect to the 2010 NO 2 NAAQS. Based upon EPA’s review of th e air quality data and the District’s submittal, EPA propos es that the District has met its obligations pursuant to 110(a)(2)(D)(i)(I) with respect to the 2010 NO 2 NAAQS

.

Attachments:

Attachment A

- 1: EPA AQS Design Value Report ( AMP480) dated November 5, 2015 for the District, Maryland, and Virginia.

Attachment A

- 2: EPA AQS Design Value Report ( AMP480) dated November 5, 2015 for Virginia.