The Richmond area has not met all requirements of part D of Title I of the CAA
pertaining to moderate nonattainment areas under section 182(b)(2)(A), which
states, "(2) Reasonably available control technology.- The State shall submit a
revision to the applicable implementation plan to include provisions to require the
implementation of reasonably available control technology under section 172(c)(1)
with respect to each of the following: (A) Each category of VOC sources in the
area covered by a CTG document issued by the Administrator between the date of
the enactment of the Clean Air Act Amendments of 1990 and the date of
attainment."
The Richmond area was classified under the one hour ozone standard as
moderate nonattainment. A redesignation request to attainment of the one hour
ozone standard and a maintenance plan were submitted to EPA July 26, 1996;
and EPA issued a final approval on November 17, 1997. However, implementation
of provisions for the following CTG categories were not completed:
a) reactor processes and distillation operations in the synthetic organic chemical
manufacturing industry (notice of issuance of the CTG was published on November
15, 1993 (58 FR 60197));
b) wood furniture manufacturing operations (notice of issuance of the CTG was
published on May 20, 1996 (61 FR 25223)); and
c) shipbuilding and ship repair surface coating (notice of issuance of the CTG was
published on August 27, 1996 (61 FR 44050)).
As stated in the 4/12/07 Federal Register, "On October 18, 2000, EPA reinstated
the 1 hour ozone NAAQS in the Richmond area and notified Virginia that it was
required to implement the contingency measures contained in the SIP approved
maintenance plan to address the violations that occurred in 1998 and 1999. See
65 FR 45182, July 20, 2000." In addition to the violations of the 1-hour ozone
NAAQS that are identified in the 4/12/07 Federal Register for the years 1998 and
1999, there are violations of the 1-hour ozone NAAQS for the years 2000, 2001,
2002, 2003, and 2004. It isn't clear from the SIP record whether any of the
contingency measures contained in the SIP-approved maintenance plan were ever
implemented..
The Richmond area was initially classified under the eight hour ozone standard as
moderate nonattainment. The implementation of provisions for the following CTG
categories were not completed:
a) reactor processes and distillation operations in the synthetic organic chemical
manufacturing industry, wood furniture manufacturing operations, and shipbuilding
and ship repair surface coating (see previous descriptions);
b) coating operations at aerospace manufacturing and rework operations (notice of
issuance of the CTG was published March 27, 1998 (63 FR 15005)); and
c) lithographic printing materials, letterpress printing materials, flexible packaging
printing materials, flat wood paneling coatings, and industrial cleaning solvents
(notice of issuance of the CTGs was published on October 5, 2006 (71 FR 58745)).
Also, EPA should be aware that the monitor in Henrico County measured the
following during 2005 and 2006:
a) 7 exceedances of the 8 hour ozone standard (3 in 2005 and 4 in 2006); and
b) relatively high annual results for the fourth highest 8 hour average values (0.084
ppm in 2005 and 0.086 ppm in 2006).
If there are 4 exceedances of the eight hour ozone standard in 2007 at the
monitor in Henrico County, that monitor will have a three year average of the fourth
highest eight hour average values that is equal to or greater than 0.085 ppm, which
would indicate a violation of the eight hour ozone standard.. EPA should either
delay final approval of the redesignation request until the end of the 2007 ozone
season to determine if this monitor shows a violation of the eight hour ozone
standard or conduct an evaluation on whether this monitor is projected to have no
more than three exceedances during 2007.
Comment on FR Doc # E7-07018
This is comment on Proposed Rule
Approval and Promulgation of Air Quality Implementation Plans; Virginia; Redesignation of the Richmond-Petersburg 8-Hour Ozone Nonattainment Area To Attainment and Approval of the Associated Maintenance Plan and 2002 Base-Year Inventory
View Comment
Related Comments
Public Submission Posted: 05/11/2007 ID: EPA-R03-OAR-2006-0917-0009
May 14,2007 11:59 PM ET