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CLEAN AIR MATTERS

Winter 2001 Edition

In this issue:

Diesel Solutions project will reduce toxic diesel pollution
Join the Clean Air Network, be an Air Watcher
Program for wood-smoke complaints changing
How do we know when to call a burn ban?
Agency launching gasoline-vapor initiative
Survey confirms successful Kitsap County outdoor burn ban campaign
Course on stack testing coming in March
New approach to pre-construction permitting reduces paperwork for many businesses
Dry cleaner fees drop 67 percent

Diesel Solutions project will reduce toxic diesel pollution

In July, the Puget Sound Clean Air Agency launched Diesel Solutions — an innovative voluntary program to make diesel vehicles in this region up to 90 percent cleaner. Its aim is to bring ultra-low-sulfur diesel fuel and cleaner diesel vehicles to western Washington five years ahead of federal regulations requiring such a change. We developed Diesel Solutions with a consortium of public and private partners.

The first full project starts this month: Durham School Services will be installing diesel-engine emission-reduction equipment, called retrofit devices, on 20 Everett School District school buses. The retrofitted buses will use ultra-low-sulfur diesel fuel. A $100,000 grant from the U.S. Envi-ronmental Protection Agency (EPA) is funding the contract awarded to CleanAIR Systems to select and pur-chase the retrofit devices and conduct training.

Diesel exhaust is a serious health issue. For example, national studies have shown that diesel exhaust can create as much as 70 percent of the cancer risk from breathing outside air. “Diesel Solutions gives us a program that directly addresses that issue. We have a rare opportunity to reduce emissions of fine particles and toxics and also improve visibility in one program,” said Dennis McLerran, agency executive director.

Public, private partners are critical to program success

Because this is a voluntary program, participation by other public and private entities is critical to the success of Diesel Solutions. Key partnerships include the following: City of Seattle is using ultra-low-sulfur diesel fuel and plans to install diesel-engine retrofit devices on its entire fleet; King County Metro is using ultra-low-sulfur diesel fuel at one bus base, plans to expand fuel use to all bases and is installing retrofit devices on all its buses over the next two years; and Boeing is retrofitting 70 vehicles and plans to convert entirely to ultra-low-sulfur diesel fuel.

The Port of Seattle, Sound Transit and the state Department of Transportation have projects under way or in the planning stages. In addition, Pacific Rim Enterprise Center is planning to retrofit 5 to 15 Emerald City Disposal Company vehicles.

Low-pollution fuel available five years ahead of schedule

Phillips Petroleum (Union 76) is supplying ultra-low-sulfur diesel fuel five years prior to 2006, when the U.S. EPA is requiring it to be the only on-road diesel fuel available nationally. Availability of the fuel makes it possible to use particulate traps, which are the most effective retrofit devices.

Particulate traps reduce fine-particle, hydrocarbon and toxic emissions by more than 90 percent. Other retrofit devices such as oxidation catalysts can reduce emissions by up to 50 percent when combined with the new fuel.

Ultra-low-sulfur fuel initially will be priced at eight cents per gallon more than conventional fuel at the refinery. Transportation costs add slightly more to that amount. We are working on ways to reduce those additional costs.

Variety of sources contributing to funding for Diesel Solutions

We have raised $1.2 million from the following sources so far:

$400,000 from U.S. EPA
$40,000 from the state Department of Ecology
$100,000 from Clean Air Agency civil penalties
$400,000 from Cummins Engine Company
$300,000 from Detroit Diesel.

The U.S. EPA has committed to contributing an additional $800,000 to $1 million over the next several years to leverage this project. Our other partners, including King County Metro, the City of Seattle and Boeing, are spending millions of dollars on this project as well.

“Our goal for Diesel Solutions is to convert 50 percent of governmental fleets and 30 percent of private fleets in the next five years,” said McLerran. “It would result in a 14 to 25 percent reduction in fine-particle emissions by vehicles in the region, significant health benefits and clearer air.”

Join the Clean Air Network, be an Air Watcher

“Keep it in the Green” is the theme and primary goal of a new program called Air Watch Northwest , and members of the agency’s Clean Air Network are VIPs (Very Important Partners).

Launched May 30, 2001, by the Clean Air Agency and the American Lung Association of Washington, the program helps people understand the relationships between their own actions, the weather and air quality.

Air Watch Northwest uses the U.S. EPA's Air Quality Index, which classifies air quality according to color. Green is good, yellow is moderate and orange is unhealthy for health-sensitive individuals. The program combines weather forecasts and monitoring data to predict air quality and provide public warnings of increases in pollution levels.

“Last year, more than 30 percent of the days in our region were either yellow or orange, and that’s not where we want our air quality,” said Dennis McLerran, agency executive director. “We need to work toward obtaining a 100- percent green-day status to protect public health, regional visibility and our quality of life.”

The agency’s Clean Air Network provides advance notice by e-mail to individuals, organizations and businesses when our forecasts indicate that air quality will be deteriorating over the next few days. People can sign up at www.airwatchnorthwest.org. They can also check daily real-time air quality, air-quality forecasts and tips for reducing pollution at that Web site, which gets up to 4,500 hits a day.

An August survey of the Clean Air Network’s 425 members shows that it has a broad reach. One-fifth of the members responded and told us they forward the air-quality messages and calls-to-action to another 65,148 individuals and 2,518 businesses. The network has grown to more than 500 subscribers since the survey.

The Web site also links to the American Lung Association of Washington, a partner in Air Watch Northwest, where health-sensitive individuals and health organi-zations can sign up for the Breathe Easy Network. Through this network, the Lung Association notifies people when air quality is forecasted to be yellow for two consecutive days — so people can plan their activities to protect their health.

Media partners also play important roles in Air Watch Northwest. KING-TV and KIRO radio, the Seattle Post-Intelligencer and The Seattle Times provide air-quality forecasts daily, and KUOW and KPLU radio carry information when air quality deteriorates. In addition to the Puget Sound Clean Air Agency and the American Lung Association of Washington, current Air Watch Northwest partners include the EPA Region 10, state Department of Ecology, University of Washington and Washington State University.

Program for wood-smoke complaints changing

The agency has revised its process for responding to complaints about smoke from fireplaces and wood stoves. As approved by the Board of Directors in October, the new approach adds on-site visits, including weekends, for repeated complaints. It also gives us the option of stronger enforcement actions and fines, and allows us to close cases that cannot be resolved and otherwise might go on for years.

The revised approach incorporates public comment made at board meetings and collaborative discussions among staff, the Advisory Council and the Board of Directors.

Our customer service staff will continue to receive complaints about wood smoke from the public on the agency complaint form. Staff has found that the form reduces erroneous complaints, particularly because people sometimes confuse wood smoke with steam emissions from natural-gas furnaces.

The form encourages people to discuss their concerns with their neighbor, if they haven’t already done so. We’ve found that this approach is a lot more successful in resolving the complaint than agency enforcement action,” said Jim Nolan, compliance director. The form will be revised to improve clarity and add more space to write about the complaint.

We are also enhancing the written materials sent to the neighbor who has been complained about. The materials explain our rules and ask the neighbor to tell us how they are going to address the problem.

The next three steps are new:

If the problem continues, an inspector will make an appointment and meet with the neighbor who has been complained about. The inspector will try to determine if the neighbor misunderstood our information or strongly disagrees with the original complaint, if the complaint is erroneous, and so on.
If our inspectors have evidence the neighbor is violating state wood burning laws, we’ll take enforcement action.
If we don’t have evidence, we will close the case and tell the complainant we are unable to resolve the complaint.

“This new approach to wood-smoke complaints allows us to mediate ongoing grievances in person. It also means that complaints won’t go on for years, because it recognizes we aren’t able to fix every wood-smoke problem in the region. And it frees up inspector resources for other work,” said Nolan.

Q. How do we know when to call a burn ban?

A. It’s part science, part art.

The science: Every day, our staff meteorologists keep an eye on air-quality measurements from the monitoring sites in our four-county jurisdiction. They also study current and predicted weather conditions. When systems that create stagnant air are expected to dominate the Puget Sound region, our staff takes extra care to analyze real-time data from the monitoring sites — checking if the amount of particle pollution is approaching the level set by state statute for issuing a burn ban.

When that “trigger” has been met and the air pollution is forecasted to continue increasing for at least 48 hours, we are empowered to take control actions. We issue a burn ban, which prohibits the use of uncertified wood stoves and fireplaces. It also prohibits all outdoor burning in those counties included in the ban.

The art: Ultimately our team must evaluate an enormous amount of data, analyze numerical predictions and make decisions on how best to apply this information. The team uses this analysis and many years of forecasting experience to decide when to call a burn ban to help prevent air pollution from reaching unhealthy levels. As weather conditions develop that will scour out the pollution from our communities, the team uses the same evaluation process to decide when to lift the burn ban.

Agency launching gasoline-vapor initiative

The Clean Air Agency has embarked on a new initiative to improve gas station compliance with our vapor-control requirements. Gasoline vapors are a significant source of air pollution. However, only 40 percent of 500 high-volume stations had fully functioning vapor-control systems after the second of two intensive education/enforcement campaigns.

To address this issue, we will be working in close partnership with trade associations, station owners and major corporate entities over the next year. We want to better understand the reasons for low compliance rates and design new systemwide approaches to improving compliance.

Vapor-control systems improve air quality

Controlling the release of gasoline vapors has been an important part of our long-range clean air strat-egies. Gasoline vapors are a sig-nificant source of toxic chemicals, such as benzene, and smog-forming compounds (called vola-tile organic compounds, or VOCs).

Vapor-control systems minimize the release of vapors when people pump gasoline and tankers deliver gasoline. However, agency inspectors have found that many gas-station owners and employees fail to make sure their vapor-control systems are working properly.

If compliance with our regulations increased from 40 to 100 percent, the amount of VOCs emitted at gasoline stations would drop by about 29 percent. This would be equivalent to taking 69,000 cars off the region’s roads.

Education, enforcement campaigns not working

The agency has tried several strategies to encourage gas-station owners to comply with our rules. However, compliance has increased from 10 percent to just 40 percent.

In 2000, we focused on an educational approach. We sent letters to all 1,500 station owners letting them know we were coming, describing what we were looking for and urging them to check and repair vapor-control systems before our inspection. We inspected 500 stations that pump the highest volume of gasoline in the region. In spite of being forewarned, 90 percent of those stations had defective systems. We issued warnings describing how to fix the problems.

In spring 2001, we tried a different tack, as recommended by the agency’s CO/Ozone Stakeholders Group. This advisory group, composed of representatives from the petroleum industry, health and environment community, small and large businesses, government and the public, said we needed to put some teeth into the process by issuing penalties.

Agency staff again sent letters urging station owners to make repairs before the inspections and telling them fines would be levied for noncompliance. The results were disappointing. About 60 percent of the owners we inspected received penalties of $1,000 to $8,000 for defective equipment.

Because the agency is more concerned about compliance than penalties, we offered to reduce each fine by 75 percent if the owner agreed to stay in compliance with regulations for two years. Most owners accepted this offer. Agency inspectors will check on compliance next spring.

Other approaches planned

Since both inspection campaigns were time-consuming and yielded poor results, we plan to work closely with trade associations and the petroleum industry to design other programs for increasing industry compliance.

“We are looking for a systemic fix. For example, one possible approach would require gas stations to hire an independent equipment-maintenance expert familiar with vapor-control systems to routinely inspect and fix the systems. With our partners, we’ll also look at other regulatory and programmatic approaches,” said Jim Nolan, compliance director.

Survey confirms successful Kitsap County outdoor burn ban campaign

Awareness of new outdoor-burning restrictions in Kitsap County increased by almost 200 percent after the Clean Air Agency implemented a public-awareness campaign, according to an August 2001 survey by Gilmore Research. The survey compared awareness and behaviors against the findings of a December 1999 survey done before our campaign began. These and other results clearly show that the outdoor-burning campaign was highly successful.

In 1999, less than a third of the survey respondents knew about new legal restrictions on outdoor burning of yard debris scheduled for Jan. 1, 2001. By summer 2001, more than 90 percent knew about the ban, and the number of people who burn yard debris dropped by half.

Partnerships key to outreach campaign

Our communications and inspection staff and a Kitsap-based consultant began a comprehensive outreach campaign in spring 2000. The campaign’s cornerstone was partnerships with county agencies, fire officials, fire educators and other organizations.

The campaign used the theme “Outdoor Burning Is Out! It’s The Law” to tell people about the new law (outdoor burning of yard debris had never been banned in the county except when fire officials called safety bans during dry summer months).

Fire personnel took education lead

“One unique feature of our campaign was that we asked the fire officials and educators, already well-known and respected in their communities, to take the lead in communicating about the impending burn ban. And Kitsap County Solid Waste took the lead to tell people about alternatives to burning,” said Mike Schultz, agency communications specialist. “This really worked well because they all put a lot of time and effort into the project.”

Another unique campaign feature was that the partners — fire educators and fire officials — received a CD-ROM with an array of materials they could customize and a notebook with attractive, ready-to-use materials. They also received large banners to display at fire stations and in their communities. The resource notebooks were so well received that we modified and provided them to fire departments affected by similar outdoor-burning bans in three other counties: King, Pierce and Snohomish.

Other outreach strategies included

transit and newspaper advertising
brochures and maps in all local libraries
a direct-mail piece to all county residents
a new Web site, www.kitsapburnban.org
funding for the Kitsap County Fire Marshal to staff a telephone hotline
cable television public-service announcements funded by Kitsap County Solid Waste.

Course on stack testing coming in March

Representatives from industry, consulting firms, legal firms and other regulatory agencies are invited to A Crash Course in Stack Testing: what you should know so you don’t “crash and burn” during your company’s next stack test.

Sponsored by the Pacific Northwest International Section of the Air and Waste Management Association, the course will be held Wednesday, March 20, 2002, from 8 a.m. to 4:30 p.m. at the Clean Air Agency’s offices.

For more info or to register, visit www.pnwis.org and select “PNWIS Spring Specialty Conference.”

New approach to pre-construction permitting reduces paperwork for many businesses

A new approach to pre-construction permitting is reducing paperwork for many businesses when they build or move their facilities. The new approach also simplifies and clarifies our requirements for pre-construction permits, called Notices of Construction.

Effective Sept. 1, we revised our regulations for several common types of equipment:

First, activities that don’t have a significant effect on air quality no longer have to apply for a pre-construction permit. Some examples are mobile tub grinders that grind stumps, equipment that evaporates wastewater that could be discharged into a sewer and boilers with gaseous fuels (or low-sulfur diesel) rated at less than 10 million British thermal units per hour.
Second, businesses that have portable equipment such as concrete batch plants, asphalt batch plants or rock crushers just have to notify us where they are moving the equipment if they already have a permit. The notification allows agency inspectors to find the equipment for annual inspections.
Third, businesses that are required by our regulations to use the best available air-pollution control technology have to notify us only when they are installing equipment. They no longer have to apply for a pre-construction permit — and agency engineers no longer have to write and issue permits. Examples of these businesses include gas stations installing systems in accordance with California Air Resources Board requirements, dry cleaners using unvented equipment and companies replacing spray booths.

“We eliminated permit requirements that didn’t clearly improve air quality. I expect this new approach will reduce the number of pre-construction permit applications from about 425 per year to about 250 to 300 per year,” said Supervisory Engineer Steve Van Slyke. “It will also allow us to concentrate on pre-construction permits with higher impacts on regional air quality.”

We will continue to require pre-construction permits for larger sources of air pollution and for facilities that can benefit from newer emission-control technology. Our goal is to achieve gradual air-quality improvements as businesses, universities, government agencies and other entities replace old facilities or build new facilities.

Dry cleaner fees drop 67 percent

Nearly all dry cleaners in the region will be paying $100 less in annual registration fees for 2002. We reduced annual fees by 67 percent to $50 for the 498 dry cleaners who operate only unvented machines.

Just eight cleaners still use vented machines – an older technology that emits dramatically more perchloroethylene (perc) to the air. Because the unvented machines control perc so well and are easier to maintain, the agency will no longer be performing scheduled inspections of these businesses.

We have been working closely with the Northwest Dry Cleaners Association and the Korean Dry Cleaners Association for over 15 years to improve equipment and reduce emissions. In the early 1990s, we contracted with these trade associations to provide education to their members about the economic and environmental benefits of unvented, dry-to-dry machines.

The machines saved money through reduced perc usage and made it easy to comply with regulations. The U.S. EPA considers perc to be an environmental carcinogen. Besides protecting air quality, the unvented machines reduce the amount of hazardous waste requiring special handling and disposal. They also virtually eliminate the chemical smell in customers’ dry-cleaned clothes.

We will continue to work with the trade associations to educate their members on the economic benefits of proper machine maintenance.

About the Puget Sound Clean Air Agency

The mission of the Puget Sound Clean Air Agency is to ensure that people in King, Kitsap, Pierce and Snohomish counties have clean, healthy air to breathe. Our job is to provide air quality management services on behalf of cities and counties for their citizens. We do this by adopting and enforcing air quality regulations, sponsoring voluntary initiatives to improve air quality, and educating people and businesses about clean-air choices. To learn more about our work, visit us at www.pscleanair.org.