LDEQ to submit to EPA its revised State Plan for Sulfur Dioxide
Comments Due November 26th
See LDEQ's pubic notice below
On June 2, 2010, EPA strengthened the primary National
Ambient Air Quality Standards (NAAQS) for Sulfur Dioxide (SO2).
EPA revised the primary SO2 NAAQS by establishing a new health based 1- hour standard at a level of 75 parts per billion (ppb).
As a result, the EPA designated St. Bernard Parish as nonattainment for the new NAAQS, and the air quality in St Bernard has remained nonattainment since.
Per a recently public noticed DRAFT revised State plan to bring air quality in St Bernard into attainment, the new air dispersion models used by LDEQ resulted in concentrations of SO2 just below the 75 ppb national standard, with the "highest total impact" reported at 74.8 ppb
With such a small margin of safety, attainment status will require strict adherence to federal air permits. The situation may be even more precarious, as this coastal parish is subjected to more frequent and intense weather events that more often result in excess emissions from shutdown, startup, and malfunction events at the major sources.
Additionally, one of the plants, Rain CII Carbon's Chalmette calciner, is often described as the "lion's share" of the sulfur dioxide emissions. Rain's Chalmette calciner has been challenged in recent years to comply with its air permit's requirement to demonstrate compliance through stack testing. Reportedly, the testing probes were prone to melting under the high temperatures at the stack.
The focus of the revisions to the SIP for SO2 heavily rely on the Rain CII calciner's ability to comply with a new air permit in an Administrative Order of Consent (AOC) between LDEQ and Rain CII Carbon LLC - Chalmette. The AOC is located in Appendix D of the DRAFT SIP; it has not yet posted to Rain's EDMS files, nor has it pubic noticed in the local newspaper.
The modeled impact for the SO2 SIP revision is based on Rain's waste heat boiler operated at a 900 pound per hour rate. We are completely dependent on LDEQ and EPA to get this right and to ensure compliance with air permits in our parish. They've had plenty of time since the 2010 Standard was established, and meanwhile, public health in our community has suffered.
PUBLIC NOTICE
The Secretary of Louisiana Department of Environmental Quality (LDEQ) published a public notice in the Louisiana Register that the Office of Environmental Assessment, Air Planning
and Assessment Division, will submit to the Environmental
Protection Agency (EPA) a revision to the Louisiana State
Implementation Plan (SIP) for sulfur dioxide.
and Assessment Division, will submit to the Environmental
Protection Agency (EPA) a revision to the Louisiana State
Implementation Plan (SIP) for sulfur dioxide.
The revision is available for review via LDEQ’s electronic
document management service (EDMS), AI# 174156
document number 14513604 dated 10/18/2024
https://edms.deq.louisiana.gov/app/doc/view?doc=14513604
document management service (EDMS), AI# 174156
document number 14513604 dated 10/18/2024
https://edms.deq.louisiana.gov/app/doc/view?doc=14513604
or at LDEQ Headquarters, 602 North 5th Street in Baton Rouge
The SIP revision will implement standards required by the Clean Air Act for the nonattainment area. All interested persons may submit written comments concerning the revision no later than 4:30 p.m., Tuesday, November 26, 2024, to Arlys Dalton, Office of Environmental Assessment, P.O. Box 4314, Baton Rouge, LA. 70821-4314, or by E-mail at arlys.dalton@la.gov
