Air Toxics Compound Analysis A New NEPA Requirement by djy18697


									Air Toxics Compound Analysis:
  A New NEPA Requirement

               Kevin Black
          Air Quality Specialist
     Federal Highway Administration

            Presented to:
     FHWA Environmental Conference
             Arlington, VA
            June 28, 2006
    Outline of MSAT Presentation
•   Background on Mobile Source Air Toxics
•   MSAT Policy – Interim Guidance
•   MSAT Analysis Methods
•   MSAT Mitigation
•   Conclusion/Questions
Background on Mobile Source Air
       Toxics (MSATs)
      Background on MSATs
• Clean Air Act (CAA) of 1970 originally
  established air quality standards (NAAQS)
  for the criteria pollutants (CAPs)
• Sufficient data from health studies allowed
  establishing these standards
• CAA recognized that these standards
  might need to be revised (and others
  added) and established a process for
  making revisions
Background on MSATs
      Background on MSATs
• During subsequent amendments to CAA
  and periodic standard reviews, revisions
  have been made to the NAAQS
• In the CAA Amendments (CAAA) of 1990,
  Hazardous Air Pollutants were defined and
  regulated by release into atmosphere, but
  this only applied to stationary sources
• CAAA did, however, required EPA to
  evaluate impacts from mobile sources
       Background on MSATs
• EPA conducted the Motor Vehicle Air Toxics
  Study (MVATS) in 1993 to determine the
  emissions from vehicles
• This lead to the Mobile Source Air Toxics Rule in
  March 2001
• The Rule designated 21 compounds emitted by
  vehicles or fuels that were HAPs and referred to
  these as MSATS
• Six were identified as priorities for regulation
          Background on MSATs
Acetaldehyde                              Formaldehyde
Acrolein                                  n-Hexane
Arsenic                                   Lead
Benzene                                   Manganese
1,3-Butadiene                             Mercury
Chromium                                  Methyl Tertiary Butyl Ether
   Chromium III                           Naphthalene
   Chromium VI                            Nickel
Diesel Particulate Matter                 Polycyclic Organic Matter
Diesel Exhaust Organic Gases                 Benzo(a)pyrene
Dioxin/Furans                                Chrysene
   2,3,7,8-Tetrachloro-dibenzo-p-dioxin   Styrene
   2,3,7,8-Tetrachloro-dibenzofurans      Toluene
Ethylbenzene                              Xylene

Primary MSATs in bold font
      Background on MSATs
• In addition, refineries were to maintain
  current standards for the fuel produced
  essentially prohibiting reformulations with
  other toxic compound
• Current regulations for CAPs also
  benefited HAPs:
  - limits on gasoline volatility as determined
  by the Reid Vapor Pressure (RVP)
  - limits on sulfur in diesel fuel
      Background on MSATs
• EPA’s Second Mobile Source Air Toxics Rule
  (February 2006) - Proposed
• Benzene content of gasoline to be limited to an
  annual average of 0.62% by volume beginning
  in 2011
• Exhaust emissions of hydrocarbons from
  passenger vehicles operated in cold
  temperatures phased in between 2010 and 2015
• Passenger Vehicle Standards to be equivalent to
  those existing in California
• Hydrocarbon emission standard for gasoline
  cans in 2009
Background on MSATs
 MSAT Policy – Interim Guidance
• FHWA decided it was important to address
  MSATs in environmental documents
• Several studies pointed to MSATs as a
  significant health problem (MATES, NATA)
• FHWA was sued for not having addressed
  them in some environmental documents
• Some projects had been analyzed for
  MSATs so approaches to conduct
  analyses had been developed
  MSAT Policy – Interim Guidance
• FHWA determined that project sponsors must be
  “encouraged” to analyze MSATs
• Failure to analyze for MSATs could result in the
  sponsor and FHWA being sued
• FHWA developed the MSAT Interim Guidance
• A three tiered approach was established in this
  Guidance which divided projects into groups:
  - projects not requiring analysis
  - projects requiring qualitative analysis
  - projects requiring quantitative analysis
 MSAT Policy – Interim Guidance
• Projects not requiring analysis
  - these projects are projects currently
  exempt under NEPA and conformity rules;
  mostly project types that have been
  determined to have no significant impact
  or one that address safety problems
  - those projects that are CE or result in
  FONZIs after and EA would likely not have
  to do and MSAT analysis
  MSAT Policy – Interim Guidance
• Projects requiring qualitative analysis
  - these projects are projects that the
  sponsor could readily identify as having
  some impact, although likely a smaller
  - most projects will be in this group
  MSAT Policy – Interim Guidance
• Projects requiring quantitative analysis
  - this class of projects will likely be obvious too;
  larger, high profile, often drawing significant
  negative comments from the community
  - these projects may represent only 10 % of
  more but will require a greater analysis effort
  including the development of emission
  - table summarizes analysis criteria and
    MSAT Policy – Interim Guidance
• The Guidance provides criteria to assist
  project sponsors determine the required
  analysis approach
                                         Analysis Method
       Project Criteria
                          No Analysis   Qualitative Analysis   Quantitative Analysis

CE Project                CE Project           -----                   -----

AADT                         -----          < 140, 000              > 140, 000

Diesel Truck %               -----             > 8%                   > 8%

Proximity of Receptors       -----       Within 1000 feet        Within 1000 feet
MSAT Policy – Interim Guidance

Contents of Guidance

Guidance memo
Appendix A: Sample language for exempt projects
Appendix B: Sample language for qualitative analysis
Appendix C: Sample 1502.22 compliance language
Appendix D: Background
       Attachment A: List of MSAT compounds
       Attachment B: FHWA Research Activities
       Attachment C: 40 CFR 1502.22
Appendix E: MSAT mitigation strategies
      MSAT Analysis Methods
• Exempt
• Qualitative
  - descriptive
  - charts and graphs
• Quantitative
  - emission inventory (burden analysis)
  - dispersion analysis
  - toxic weighting factor
  - risk analysis
     MSAT Analysis Methods
• Exempt Projects still must discuss MSATs
• The Guidance for Exempt Projects can be
  found in Appendix A
     MSAT Analysis Methods -
• Descriptive Text (Appendix B)
• Charts and graphs
• !502.22 qualifying statements (Appendix
        MSAT Analysis Methods -
                                                   Vehicle Miles Traveled (VMT) vs.
                                            Mobile Source Air Toxics Emissions, 2000-2020

                         6                                                                                                          Change
                                                                                                   200,000                        (2000-2020)
                         5                                                                                      VMT (Trillions)       +64%

  VMT (trillions/year)

                             DPM+DEOG                                                                           DPM + DEOG             -87%

                         3                                                                                      Benzene                -57%

                                                                                                                Formaldehyde           -65%
                                                                                                                Acetaldehyde          -62%
                                                                                                                1,3-Butadiene         -60%

                         0                                                                         -
                                                                                                                Acrolein              -63%
                         2000             2005      2010         2015               2020

Notes: For on-road mobile sources. Emissions factors w ere generated using MOBILE6.2. MTBE proportion of market for oxygenates is held constant, at
50%. Gasoline RVP and oxygenate content are held constant. VMT: Highway Statistics 2000 , Table VM-2 for 2000, analysis assumes annual grow th
rate of 2.5%. "DPM + DEOG" is based on MOBILE6.2-generated factors for elemental carbon, organic carbon and SO4 from diesel-pow ered vehicles,
w ith the particle size cutoff set at 10.0 microns. 1 short ton = 907,200,000 mg.
     MSAT Analysis Methods -
• Descriptive Text
• Analysis discussion method, and data
• !502.22 qualifying statements (Appendix
                     MSAT Analysis Methods -
Table 1. Emission Projections for Study Site.

                               Baseline                          10 Year Horizon                          20 Year Horizon
                                (2007)                               (2017)                                   (2027)
                EF            Traffic      Loading       EF        Traffic     Loading            EF        Traffic     Loading
                (mg/mi)       Volume       (tons/day)    (mg/mi)   Volume       (tons/day)        (mg/mi)   Volume      (tons/day)

Acetaldehyde    6.36          150,000      0.001         3.18         201,587       0.0006        0.64         270,917      0.0002
Acrolein        0.46          150,000      0.0001        0.23         201,587       0.00005       0.05         270,917      0.00001
Benzene         45.46         150,000      0.007         22.73        201,587       0.005         4.55         270,917      0.0012
1,3-Butadiene   5.09          150,000      0.0008        2.54         201,587       0.0005        0.51         270,917      0.0001
DPM             0.90           15,000      0.00001       0.45          20,159       0.00001       0.09         27,092       0.00003
Formaldehyde    11.55         150,000      0.002         5.78         201,587       0.0012        1.16         270,917      0.0003

Table 1 Notes: This table is only meant to serve as an example. Emission Factors (EF) were calculated using the MOBILE6.2
Emission Factor Model and generic input data. Emission model input data for the specific site should be used to calculate the EF.
This example assumes 150, 000 AADT for the base year. This number will vary according to site and needs to be adjusted for each
site. The loading in this table is expressed in tons/day. Tons are calculated by multiplying the EF X Traffic Volume X (0.000 000
00102 tons/milligram). Since the traffic volume is a daily average, the resulting emission loading is expressed as tons per day. Note
DPM uses a lower traffic volume based on the estimated diesel fleet (in this case 10 % of AADT).
            MSAT Mitigation
• MSAT mitigation will generally only be required
  for those projects which have used quantitative
• Mitigation is discussed in the Guidance
• Some possible strategies
  - restrict idling of vehicles especially diesel
  trucks and buses using no idling ordinances
  - incorporate wider buffers adjacent to project
  - restrict the types of development adjacent to
  project (i.e., no residences, schools, hospitals)
  - evaluate and control emissions from off-road
  equipment such as construction vehicles
• Interim Guidance has been released and is
  effective for all projects which have not
  completed the NEPA process
• All environmental documents processed should
  include an analysis (or statement noting
  exemption) addressing the impacts created by
• It is useful to note the new emphasis on project
  impacts created by both the MSAT Guidance
  and the PM Hotspot Rule released earlier this
  year, table illustrates similarities
                                                   Regulatory Basis                            Comments
                                 MSAT Guidance                    PM Hotspot Rule
Evaluation Criteria
NEPA, Hotspot Rule,       NEPA                              NEPA, Hotspot Rule,
    Conformity                                                  Conformity
AADT Volume               140, 000 – 150, 000 AADT          125, 000 AADT             AADT volumes are
                                                                                         guidelines, decision up
                                                                                         to DOT/Interagency
% Diesel Traffic          8%                                8%                        Based on national defaults
                                                                                           used in MOBILE6
Receptor Susceptibility   Proximity of Receptors            Projects of Air Quality   Decision up to
                                                                 Concern              DOT/Interagency group

Evaluation Method         Qualitative/Quantitative          Qualitative               Quantitative analysis required
                                                                                      for PM Hotspot when future
                                                                                      model validation is completed
Questions ???

          Kevin Black
         Air Quality Specialist



To top