Commenter:
Hon. David Snyder, Metropolitan Washington Air Quality Committee (MWAQC)
Comment on Virginia Opacity Standard
Metropolitan Washington Air Quality Committee
Suite 300, 777 North Capitol Street, N.E. Washington , D.C. 20002-4239202-962-3358Fax: 202-962-3203
October 15, 2008
Richard D. Langford, Chair
Virginia State Air Pollution Control Board
c/o Virginia Department of Environmental Quality
P.O. Box 1105
Richmond, Virginia 23218
Dear Chair Langford,
I am writing on behalf of the Metropolitan Washington Air Quality Committee (MWAQC) regarding Virginia’s opacity regulations, Section 9 VAC 5-40-80 and 9 VAC 5-50-80 (Standard for Visible Emissions). MWAQC urges the Board to lower the opacity standard for new and existing facilities from 20% to 10%. The lower standard is consistent with standards in Maryland and the District of Columbia.
MWAQC is certified by the governors of Maryland and Virginia and the mayor of the District of Columbia to develop regional air pollution control strategies for the Washington, DC-MD-VA region. Virginia jurisdictions represented on MWAQC include Arlington, Fairfax, Loudoun, and Prince William counties and the Cities of Falls Church, Manassas, Alexandria, and Fairfax. The Metropolitan Washington Air Quality Committee (MWAQC) was created to ensure a regional approach to improving air quality which, in this case, means adopting consistent opacity standards.
Opacity measures the amount of visible light that is blocked by exhaust smoke. Opacity gives an indication of the concentration of particles leaving a smokestack. The more particles which are passed through a stack, the more light will be blocked, and, as a result, a higher opacity percentage is achieved. Therefore, opacity is closely linked to particles including the fine particles in the smoke.
The region is designated as a nonattainment area for the 1997 annual PM2.5 NAAQS. MWAQC is concerned that the opacity standards for new and existing facilities in Virginia are set at a level that is too high to be sufficiently protective of human health. Therefore, it is important that this issue be dealt with urgently.
Opacity measurements provide frequent, low cost information on the effectiveness of a source's fine particle emission control. For sources other than stacks, opacity limit is the only limit that can be established, tested, and enforced. Therefore, the tightening of Virginia’s existing opacity standard from 20% to 10% will provide a cheaper and efficient way of controlling particulate emissions in the region. This will go a long way in ensuring that the Washington region’s fine particle levels stay below the fine particle standard.
We strongly urge the State Air Pollution Control Board to lower the opacity standard for new and existing facilities from 20% to 10%. MWAQC believes that such action by the Board will help improve air quality in the metropolitan Washington D.C. area. A 10% standard is more healthful, more efficient in achieving lower emissions, and regionally consistent.
I am writing as an individual, environmental professional who has worked in the field of air quality in Virginia for 12+ years regarding the recent petition from the MWAQC to lower the opacity standard for new and existing facilities in Virginia from 20% to 10%. With respect to existing stationary sources in Virginia, I believe that the visible emission standard found in 9 VAC 5-40-80 should not be lowered from 20% to 10%. The issues that I would like to submit for consideration to the SAPCB are as follows:
Is there any scientific evidence or are there any health studies available that show that a 20% opacity limit is too high to be sufficiently protective of human health? I think that this type of evidence should be the basis for a regulatory change of this nature rather than out of concern or just because other states have set a lower opacity standard.
Is there any scientific evidence or air quality studies available that show that lowering the Virginia Opacity Standard from 20% to 10% opacity will result in a significant improvement in air quality. I think that this type of evidence should be the basis for a regulatory change of this nature rather than out of concern or just because other states have set a lower opacity standard.
Won't there be upcoming PM2.5 regulations that will address the issue of fine particulate emissions. If so, then no reason to also lower the opacity standard.
I urge the SAPCB to consider the financial burden that Virginia industry may have to bear to meet stricter opacity regulations. Many existing sources in Virginia have permitted opacity limits above 10% and would likely have to install additional air pollution control equipment to meet a 10% opacity standard. An analysis of the financial burden should be considered.
If the SAPCB does pursue a regulatory change to lower the Virginia opacity standard for existing sources from 20% to 10% , I suggest that there be some sort of "grandfathering clause" for existing sources that have permitted opacity limits above 10%. For example, an older diesel emergency generator or diesel fire pump engine (with permitted 20% opacity limit) would likely not be able to meet a 10% opacity limit and would either have to be replaced with a brand new diesel engine or retrofited with some type of particulate filter. Again, financial burden that should be analyzed before changing opacity standard.
Thank you for allowing me to submit comments on the petition. Respectfully, James McGrath
