October 6, 2014
On September 12, 2014, EPA released its Policy Assessment for the Review of the Ozone National Ambient Air Quality Standards according to a blog post by Seth Jaffe for Mondaq Law and Environment news. In its assessment EPA staff concluded:
“That it is appropriate in this review to consider a revised primary O3 standard level within the range of 70 ppb to 60 ppb. A standard set within this range would result in important improvements in public protection, compared to the current standard, and could reasonably be judged to provide an appropriate degree of public health protection.”
As EPA staff noted, the Clean Air Science Advisory Committee (CASAC) made the same recommendation. “I therefore think it’s game over for the current standard,” Jaffe says. “Whatever the politics surrounding the ozone NAAQS, I just don’t think that a decision by EPA to retain the current standard would survive judicial review.”
The real question, then, is how low EPA will actually go. Both CASAC and staff hedged their bets by recommending a range of 70 ppb to 60 ppb. Basically, a standard of 70 ppb would appear to provide a “margin of safety” for all impacts other than “the lowest exposure concentration demonstrated to result in lung function decrements and pulmonary inflammation (i.e., 60 ppb).”
“It’s worth noting that, if EPA Administrator, Gina McCarthy, wants to use lung function decrements as the basis for the NAAQS, even 60 ppb may not be enough, because it provides no margin of safety. Thus, if I were forced to bet, I’d predict a new NAAQS at 70 ppb. I don’t think it will save EPA from criticism on the right, but it’s a reasonable balancing act,” says Jaffe. EPA’s current NAAQS is 75 pbb.
What this means to you
A lowering of the NAAQS standard for ground level ozone means most states will have to revise their state implementation plans (SIPs) for stricter limits for oxides of nitrogen (NOX) and volatile organic compounds (VOCs) the primary components of ozone when mixed with sunlight. Stricter limits would likely be phased in over an agreed upon time period.
MIRATECH can help
Contact MIRATECH to learn more about controlling NOx and VOC emissions for your operation.