2014 - PM2.5 SIP and Regulations: Questions & Answers
Per state statute, DEC is required to respond to questions that it receives at least 10 days before the end of a public comment period. For this regulatory proposal that cutoff was December 9th at 5:00 PM and the comment period has closed. DEC's answers to the written questions it received before December 9th are listed below.
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DEC employees certified in Method 9 use a standard form where they fill in the information such as background and lighting conditions that can affect opacity readings. You can see an example of this form here: (Visible Emissions Field Data Sheet, PDF)
DEC employees are certified in EPA Method 9 to evaluate opacity. While there may be minor variability, these opacity readings are not considered to be “opinion”, rather, this method is used around the country to determine compliance with opacity requirements. DEC does not have the authority to issue tickets/fines. After initially identifying a burner that exceeds opacity limits, DEC would follow up with violators to help them understand the regulations and how they can comply.
The overall goal of the local air quality plan is to bring the entire area into compliance with the ambient air quality standards. The proposed opacity regulations are one component of the plan and we are accepting comments on the approach presented in the regulations and plan. DEC encourages everyone to use good burning practices at all times.
The proposed regulations include a case by case waiver process for residents whose wood or coal heater cannot be operated to meet the opacity limits. The proposal would allow for a waiver if meeting the opacity limits would be unreasonably expensive, technically not feasible, or would otherwise create an unreasonable burden on the owner or operator of the device. See the proposed regulation language for 18 AAC 50.075(d)(2).
If you believe you have observed activities that violate State air quality regulations, you may use the online complaint form accessible via the DEC home page. The complaint information you provide will be used to help DEC staff to investigate the complaint. You may also contact the DEC Air Quality Division offices in Anchorage (269-7577), Fairbanks (451-5173), or Juneau (465-5100) with your air quality concerns.
DEC is responsible for enforcing the state regulations. DEC Division of Air Quality staff already respond to citizen complaints in the FNSB nonattainment area and work with local citizens and businesses to achieve compliance with the existing state regulations, this would continue to be the case for any new final regulations.
In addressing any violations of state air quality regulations, the Department of Environmental Conservation Division of Air Quality will use the compliance and enforcement tools for which it is allowed under state statute. The Division has not been given the authority in statute by the legislature to issue administrative penalties for violations of Alaska environmental laws. This means the Division cannot write "tickets" and must use other tools like written notices of violation, compliance agreements, or in rare cases civil court actions. In most cases, the department finds compliance can be achieved through assisting businesses and individuals in understanding the regulatory requirements and how they can comply.
If a resident is found to be out of compliance with the opacity limits identified for a specific episode, ADEC is responsible for taking actions to enforce the requirement. The Department’s compliance activities are conducted using the tools and authorities provided under the state statutes. The Division of Air Quality does not have statutory authority to issue administrative penalties for violations of Alaska environmental law. This means that ADEC staff cannot simply write “tickets” to individuals that are found to be violating the opacity limits. All compliance and enforcement activities are case specific. ADEC generally initiates compliance activities in response to complaints received that indicate the potential for violations of a state regulation. ADEC staff investigate complaints to verify or corroborate a problem or violation of a state requirement. In most cases, the department finds that compliance can be achieved through assistance to businesses and individuals in understanding the regulatory requirements and how they can comply. In the case of problem burners failing to meet these opacity levels during air quality episodes, it is important to bring a unit into compliance quickly to reduce smoke and assist in bringing levels of PM2.5 into compliance in the local area. As a result, if a resident working with or without the assistance of ADEC does not come into compliance, ADEC staff would request that the resident stop burning for the duration of the air quality episode if they have another heating source available. In the event that compliance assistance is not successful in resolving a recurring smoke concern at a specific residence or business, the department staff may use additional administrative enforcement tools, such as a nuisance abatement order or civil suit, to address the concern.
The Department of Environmental Conservation Division of Air Quality will use the compliance and enforcement tools for which it is allowed under state statute. The Division has not been given the authority in statute by the legislature to issue administrative penalties for violations of Alaska environmental laws. This means the Division must use tools like written notices of violation, compliance agreements, or in rare cases civil court actions. In most cases, the department finds compliance can be achieved through assisting businesses and individuals in understanding the regulatory requirements and how they can comply. Changes to DEC’s enforcement authorities would need to be granted in statute through the legislative process.
The determination that wood smoke is a significant source of PM2.5 comes from testing the filters and then analyzing them by a variety of methods. First, the PM2.5 filters from the air monitors are analyzed to get the speciated components of PM2.5 captured on the filters. This is done by Ion Chromatography for all ions (Cl- , NH4+, NO3-, SO4 2-….), carbon analysis for organic carbon and then XRF (x-ray fluorescence) for the remaining elements (Ti, V, Fe,….etc) and S (Sulfur). Then, all of the speciated components are compared to a ratio of the certain components that make a source profile. Profiles exist for all sources, woodstoves, vehicles, fuel oil from houses, etc., then the profiles are compared to the filter components using the CMB (Chemical Mass Balance) model and the result is a source apportionment in the form of a percentage of sources for certain years and monitoring sites (Appendix III.D.5.8 ). In addition to using a CMB model, we have analyzed C14, levoglucosan, and chemical tracers specific to wood smoke that corroborate what we see in the CMB analyses.
Goldstream Valley has had air monitoring by the Borough’s sniffer vehicle and farther north, Poker Flat has had an IMPROVE monitor (PM2.5 and Speciation) from a Regional Haze Study and is considered a background site (Final Report on the Result from the Poker Flat, Denali National Park and Trapper Creek Castnet Protocol Sites July 1998-2001), but Poker Flat is farther North than Fort Knox. The Borough also operated their RAMS trailer for a short time at a site near the flats below UAF that monitored air coming into the Fairbanks bowl from the Goldstream Valley via the Sheep Creek drainage and that monitor saw generally clean air flowing into the area from the North.
The predominant wind direction is NNE, but during the winter, high PM2.5 concentration events occur under very poor dispersion conditions, which consist of calm, clear days. When the atmosphere is stable, the inversion layer forms and traps particles from rising above that layer and this cause buildup of PM2.5 in the nonattainment area. So while it is possible that emissions from Ft. Knox could reach the Fairbanks area, it is not under the conditions that cause PM2.5 levels above the standard.
That being said, DEC and the Borough did look into the Ft. Knox ammonia source, but during the N/NE wind direction there is almost always clean air coming into Fairbanks and no PM2.5. In addition, nitrate in the form of ammonium nitrate accounts for only 6% of the PM2.5 filter mass. NOx pollution, which forms ammonium nitrate is from all combustion sources (vehicles, home heating, and industrial sources) so even if part of the ammonium nitrate is forming from Ft. Knox, it would be only a small percentage of the 6% mass on the filters especially given the distance and dispersion that would occur when winds from Ft. Knox reach downtown Fairbanks. Generally, high PM2.5 concentrations are during low to no wind episodes and there is no mixing from that far of a distance.
The air quality plan contains information about the sources impacting Fairbanks’ downtown and other areas of the community. As pollution is trapped close to the ground during a winter inversion, pollution from all sources builds up. There is likely some diffuse movement of pollution within the overall area. As you note, wood boilers are not the only source of PM2.5. A variety of other emissions sources also contribute to PM2.5 levels such as wood stoves, vehicles, and power plants. The concentrations observed at the downtown monitoring locations show a slightly different mix of sources than sites that are in local residential neighborhoods. However, there is residential housing in the downtown area and wood smoke is the predominant source at all sites monitored in the nonattainment area. Section 5.8 contains a discussion of differences seen between sites that comes from analyses of the pollutants captured on the air monitoring filters at various local sites.
The GVEA power plant does not run on coal. The coal fired power plant in downtown Fairbanks is Aurora Energy’s Chena Power Plant. Aurora Energy sells power from this plant to GVEA. Aurora Energy, LLC provided ADEC with hourly PM2.5/SO2 emissions data. The SIP includes those emissions in Section 5.06 Emission Inventory Data and Appendix III.D.5.06. DEC monitoring and analytical results found that the majority of PM2.5 pollution is a result of wood burning and not permitted stationary sources, such as the power plants.
DEC has considered the impacts of road dust and emissions from the combustion of heating oil in its emission inventory for the plan. The inventory assumes that road dust emissions from motor vehicles are essentially non-existent during winter episodes in Fairbanks when road surfaces are snow- and ice-covered. Road dust emissions are often comprised of larger, coarse particulate matter (PM10). According to monitoring observations for the highest concentration winter days between 2006 and 2010, the second largest component of PM2.5 is sulfur-containing particles amounting to 18% of the PM2.5 composition. Sulfur is emitted from a variety of sources: primarily from combustion of petroleum based fuels such as heating oil, diesel, and coal.
Sulfur is a component of diesel fuel, heating oil, coal, and other fossil fuels. It is not well understood how gaseous emissions of sulfur form particulate matter in the sub-arctic conditions in Interior Alaska, but sulfur containing particulate matter makes up about 18% of PM2.5 levels. Further discussion on the studies that looked at the components of PM2.5 observed at the air quality monitors in the nonattainment area is available in Section 5.8 of the plan.
House fires do emit large amounts of pollution, but it is important to make efforts to reduce air pollution overall inside the nonattainment area. Because structure fires occur every year, the SIP includes annual and seasonal emissions from structure fires in the emission inventory (Sections 5.6). However, while they are accounted for to some extent in the air quality plan, these are typically short-term, unusual events that may have a significant impact in an unpredictable way within the geographic area. When an unusual, one-time event, like a wildfire or a nearby house fire, affects an air monitor, the data for that event can be flagged as an “exceptional event” by the Borough and State. The EPA reviews those data flags and makes a determination as to whether that data should be excluded from certain regulatory compliance calculations.
The SIP control measures are discussed in Section 5.7 of the plan. They include both mandatory and voluntary measures. The table below shows the proposed mandatory measures for the SIP, which are primarily state regulations. Some of these regulations are already in place and others are proposed and out for public review and comment. There are also two proposed state regulatory contingency measures included in Section 5.10 of the plan. The contingency measures will be triggered (as detailed in the proposed regulations) if the community fails to attain the ambient air quality standard by the 2015 deadline and is re-classified to a "serious" nonattainment status by the Environmental Protection Agency. The table below identifies all of these mandatory measures, their regulatory citation, and their current status (in place, adopted, and proposed):
|Mandatory Measures||Regulatory Citation|
|New wood fired heater emission standards||18 AAC 50.077 (adopted)|
|Visible emission standards||18 AAC 50.075 (in place and proposed)|
|Seasonal requirement to burn dry wood||18 AAC 50.076 (proposed)|
|State outdoor open burning regulations: during advisories and seasonally||18 AAC 50.065 (in place and proposed)|
|State stationary source air permit program||18 AAC 50 Article 3 (in place)|
|FNSB motor vehicle plug-in program||Chapter 8.20 (in place)|
|Commercial wood seller registration program: moisture content disclosure to consumers||18 AAC 50.076 (proposed)|
|Exemption changes to heater emission standards||18 AAC 50.077(b)(7) (proposed)|
A number of the mandatory or regulatory measures are meant to help support and build upon the emission benefits that are coming from various voluntary programs and public education activities in the community. They help to assist and backstop efforts to incentivize upgrades to clean burning wood heaters and to further reinforce the need for best burning practices. For example, emission standards for new wood fired heaters will help to support the benefits coming from the community's voluntary change out program. These new emissions standards will help ensure that cleaner burning devices are being installed overall and that the funds spent on upgrades are not losing some of their benefits to higher emitting devices being installed by local residents outside the change-out program.
The trends in air quality over time are discussed in Section 4 of the air quality plan (also called the State Implementation Plan or "SIP"). The analysis in the SIP includes data from 2008 through 2013. There is variability in the meteorology and pollution levels from year to year and in differing locations within the community. This makes it difficult to demonstrate progress resulting from community actions on a year to year basis. The State Office Building air monitor has been operated the longest and therefore can be analyzed over a longer period than other monitoring sites. The chart below presents the data from the State Office Building air monitor from 2000-2013 that is relevant to showing trends and compliance with respect to the National Ambient Air Quality Standards. Compliance is based on the calculation of a "design value" for individual monitors consistent with the form of the standard. For the 24-hour ambient PM2.5 standard, the design value is calculated from the 3-year average of annual 98th percentile values.
A variety of air monitors and air monitoring sites are operated by the Borough Air Quality Program within the nonattainment area. It should be noted that the air monitoring has shown that the State Office Building site is not the location with the highest concentrations of fine particulate matter in the community. Sites in North Pole and some other neighborhood locations can see higher levels of PM2.5 on a daily basis. The SIP must demonstrate that all areas of the community will come into attainment with the ambient air quality standard.
DEC and the Fairbanks North Star Borough (FNSB) generated estimates of heating devices based on detailed wintertime surveys performed in the nonattainment area. Based on our latest estimates for the air quality plan, the total number of substandard heating units that could be in place by 2019 is 5830. This total includes uncertified wood heaters, unqualified outdoor wood boilers, fireplaces without inserts, and coal heaters. The air quality plan assumes that 4725 of these heating units will be replaced or removed by the end of 2018 through some combination of the change-out program and the natural turnover of heaters by local residents.
The plan does not include any wood heater curtailment in the form of regulatory episode "burn bans" and no emission reduction benefits are claimed for that type of program. However, the Fairbanks North Star Borough's (FNSB) voluntary cessation program is included in the benefit assigned to voluntary measures. The plan does contain wintertime restrictions on outdoor open burning. These do not gain additional benefit in the plan as open burning was controlled by a Borough program in the 2008 baseline period. In this case, the plan shifts the open burning from the previous Borough program to a state implemented program to ensure that emissions from this source do not increase making it more difficult to attain the ambient air quality health standard.
The list of PM2.5 air monitoring sites in Table 5.4-1 includes all the fixed monitoring sites classified as either SLAMS (State and Local Air Monitoring Site, STN (Speciation Trend Network Site), or SPM (Special Purpose Monitoring Site) that have been in operation in the nonattainment area since the EPA designation. There is a footnote in Table 5.4-1 that indicates the shutdown date for the North Pole Elementary School monitoring site. Table 5.5-1 provides a list of the fixed air monitoring sites that are currently in operation within the nonattainment area and constitute the monitoring network today. Because the North Pole Elementary site is no longer in operation it was not included in Table 5.5-1 of existing sites, but was included in the Table 5.4-1 list of SLAMS/STN/SPM PM2.5 air monitoring sites for which data was collected in the nonattainment area.
The North Pole Elementary School site was established in 2009 on school property. The agreement between the FNSB and the school was that the FNSB would operate a temporary site for only a winter season, maybe two. FNSB used their mobile monitoring platform to search for other suitable locations in North Pole. FSNB looked for a site further to the north of the North Pole Elementary School, where some of the mobile monitoring had indicated higher PM2.5 values. In 2012, FNSB located a second instrument trailer at the North Pole Elementary School to establish a correlation between the equipment at the school and the one intended to go to the new site. The North Pole Fire Station site location met the target area, so the trailer was moved and the site was established in March 2012. FNSB operated both North Pole sites simultaneously to establish a correlation between the two locations. In 2013 the North Pole Elementary School site was removed at the request of and to honor the agreement with the school. The shutdown had been scheduled for the end of March which is considered the end of the winter sampling season.
This map was provided to DEC by the FNSB Air Quality program. Any changes or variations on this map would need to come from them.
This is essentially correct. The State Office Building air monitoring site provides long term air monitoring data for the nonattainment area and is the violating monitor that was responsible for the original designation of the nonattainment area. The SIP has a baseline year of 2008. In 2008 the State Office Building site was the primary site within the area. As a result, this site factors prominently in the development of the initial SIP. However, monitoring data from various sites are used in the many different technical analyses and studies that support the SIP.
Since 2008, PM2.5 air monitoring data has been collected in a number of locations throughout the nonattainment area as the FNSB and DEC Air Quality programs have worked to characterize the extent of poor air quality and the variation in air pollution levels within the nonattainment area boundary. Data from the State Office Building site and other available air monitoring sites will be used in future evaluations and calibrations of the air quality model that estimates concentrations across the nonattainment area. In the future, there will be significantly more air monitoring data to use in the on-going air quality planning analyses including the data from air monitors in the North Pole area.
The State Office Building PM2.5 air monitoring site is the original violating monitor that established the nonattainment area and, as a result, there is a long term air monitoring data trend that can be used to compare to the National Ambient Air Quality Standard at that location. However, the air quality plan has to reduce air pollution throughout the entire nonattainment area and must demonstrate through monitoring and modeling how the entire area will come into compliance with the PM2.5 National Ambient Air Quality Standard. The plan includes an analysis of future predicted concentrations at the long term State Office Building monitoring site, but also includes an analysis of predicted air quality concentrations in all the unmonitored areas within the nonattainment area. The demonstration and the unmonitored area analysis is discussed in the modeling and attainment sections of the plan (5.8 and 5.9). Further, in future plans there will be data from additional air monitoring sites that can be used to calculate design values for North Pole and further inform the technical modeling and monitoring analyses for future air quality plan updates.
Wood should be stored where it is off the ground and protected on top from rain and snow. The sides should be left open so the wood can breathe and dry out. Plans for modular wood sheds are available online at EPA’s Burn Wise Site. Additional information on wood storage best practices is available from the Cold Climate Housing Research Center.
Seasoning firewood prior to use can make a big difference in PM2.5 emissions when it is burned and we appreciate your additional ideas related to improving the seasoning of wood in the community. Beginning in October of 2015, the proposed amendment in 50.076(b) requires persons operating wood heaters between October 1st and March 31st in the nonattainment area to only use dry wood, a mix of wet wood with compressed wood logs, or other approved fuels. DEC believes that residents of the nonattainment area will voluntarily comply with the proposed regulation by splitting and drying their wood so that it is seasoned before it is burned or by mixing their unseasoned wet wood with compressed wood logs so that they meet new opacity requirements. These proposed regulations are meant to further encourage residents to season the wood they buy, but also gives residents an option for responsibly burning wood if they are unable to dry wood in time for winter or run out of wood and only have access to wet wood.
DEC has also begun a voluntary program to encourage wood sellers to disclose the moisture content of wood to consumers when they purchase it. This program will help consumers to select wood sellers who will provide them the information about whether their wood needs to be seasoned before it is used. This program is proposed as a contingency measure that would become a requirement if the area fails to come into compliance with the ambient air quality standard by the end of 2015. See proposed regulation 18 AAC 50.076(c).
DEC is committed to promoting a constructive relationship with the wood seller community and is interested in working with wood sellers to develop the details of the moisture disclosure program. Creating a program that benefits both wood sellers and the public is important to ensure that wood sellers actively participate and comply with the regulations. The proposed regulations require DEC to compile a list of approved wood moisture meters. DEC will approve moisture meters that meet certain criteria such as affordability and accuracy. Certified dry wood sellers will be required to provide their customers with moisture disclosure forms that specify the moisture of the wood they sell. A certified dry wood seller who does not comply with the requirements of the program may have their certification revoked.
The proposed regulations contain a contingency measure that would require commercial wood sellers to tell their customers the moisture content of the wood they are receiving. The proposed regulation does not require wood sellers to season wood prior to selling it and it does not require special marking for tracking every piece of wood sold. The moisture content disclosure requirements would likely take effect in 2016, if the nonattainment area fails to come into compliance with the air quality standard. Wood sellers who routinely provide seasoned wood to their customers may choose to become certified dry wood sellers under the wood moisture disclosure program but are not required to do so.
The responsibility to burn dry wood lies on the individuals that use wood for heating. Beginning in October of 2015, the proposed amendment in 50.076(b) requires persons operating wood-fired heating device between October 1st and March 31st in the nonattainment area to only use dry wood, a mix of wet wood with compressed wood logs, or other approved fuels. DEC believes that residents of the nonattainment area will voluntarily comply with the proposed regulation by splitting and drying their wood so that it is seasoned before it is burned or by mixing their unseasoned wet wood with compressed wood logs so that they meet new opacity requirements. These proposed regulations are meant to further encourage residents to season the wood they buy, but also gives residents an option for responsibly burning wood if they are unable to dry wood in time for winter or run out of wood and only have access to wet wood.
Yes. Neither the adopted 2013 regulations nor the proposed 2014 regulations restrict how many heaters or what kinds of heaters can be installed in a home. Once the newly adopted emission standards for wood heaters are in effect, any new wood heaters installed inside the nonattainment area would need to meet those standards. Under the new regulation and plan proposals, both existing and new wood stoves and pellet heaters would need to comply with opacity limits during air quality episodes and only burn approved fuels.
This plan is focused on addressing outdoor air pollution from fine particulate matter (PM2.5) in order to reduce health impacts and to meet the requirements of the federal Clean Air Act. Indoor air pollution can also pose a hazard to health. Numerous studies across the country about the negative health effects of PM2.5 separate those health effects from the effects of exposure to indoor air and control for factors such as this in their data analysis. It is important to note that indoor air comes from the outside and that exposure to outdoor air pollution will occur during the daily activities of many individuals.
The air quality plan for the Fairbanks North Star Borough PM2.5 nonattainment area focuses on programs that will help improve the Borough's air quality while recognizing and balancing the need for local residents to economically heat their homes. One of the primary sources of PM2.5 is wood burning within the community. The emissions from oil burning also play a role, but currently generate much less impact than wood burning activities. As a result, the proposed regulations are focused primarily on reducing emissions from wood and coal heaters. In the past, the Borough considered an incentive program that would help pay for residents to switch from solid fuels back to oil heat on poor air quality days, but this program would not have resulted in permanent emission reductions and would have been expensive to fund each year. As a result, more focus was placed on replacing and encouraging the proper operation of wood and coal heaters.
The State understands that the price of energy is a contributing factor to the air quality issue in the nonattainment area and is already working on projects that address affordable energy. Any requirements that would increase the price of heating oil would be detrimental to improving air quality. High fuel oil prices make heating homes and businesses with more affordable wood and coal more attractive. Unfortunately, fuels such as cordwood, pellets, and coal produce more emissions than oil, gas, or electric heating devices. In response to the energy issue, the State has a variety of programs that help individuals heat their homes and businesses. The Alaska Housing Finance Corporation's Energy Program helps individuals reduce their energy costs through energy efficiency improvements and weatherization. The Low Income Heating Assistance Program helps qualifying individuals pay their home heating costs. The State is also aggressively working on projects to expand the availability of economical natural gas in the nonattainment area, including the Interior Energy Project (LNG trucking) and gas pipeline projects.
The I/M program was developed and implemented to help reduce CO pollution. Motor vehicles were the main contributors to CO in Fairbanks. The amount of PM2.5 contributed by cars is small in comparison to emissions from wood heating. Ways to reduce PM2.5 emissions from vehicles include plugging in block heaters and reducing idle time.
The State of Alaska is striving to meet a December 31st federal deadline with respect to finalizing this air quality plan. The decision was made to release these regulatory proposals for public review in mid-November before the inauguration of Governor Walker. The Department is briefing the new administration on this project. The final package of regulations and the plan must be approved through Governor Walker's administration before they are final and effective. Further, all regulations are reviewed by the state's Department of Law both in the drafting phase and again during finalization of the regulation following public comment to ensure the plan and regulations meet all state legal requirements.
Air quality in the nonattainment area is an important public health issue and the state is required by the Clean Air Act to submit a plan for nonattainment areas. This plan is not tied in any way to ground water protection/control plans. Information on the current status of the North Pole refinery sulfolane pollution clean-up.
An air stagnation alert is a forecast made by the National Weather Service based on meteorological data. Various state and local air quality control programs in Washington and Oregon use this information in their decision making process when calling advisories or burn bans. Alaska's air quality alerts are based on actual air quality data in conjunction with meteorological data.
The newly adopted emissions standards are focused on ensuring clean burning stoves are being installed in the nonattainment area. The current change-out program targets stoves that are not clean burning regardless of their age. New technologies have been developed and woodstove designs have evolved with time to create more efficient and cleaner burning stoves. Requiring newly installed devices to meet the new emissions standards and accelerating the change out of older woodstoves to these cleaner devices are both important components of the state's plan to bring the nonattainment area into attainment. All stoves in the nonattainment area, regardless of age, must meet the opacity standards during an air quality episode.