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May 23, 20061
PM 2.5 Implementation, Proposed Revisions and Haze
PM 2.5 Implementation, Proposed Revisions and Haze
Air Quality Issues WorkshopAllegheny Mountain Section of the Air &
Waste Management AssociationMay 23, 2006
Scott R. Dismukes, Esq.Eckert Seamans Cherin & Mellott
600 Grant Street, 44th FloorPittsburgh, PA 15219
(412) [email protected]
May 23, 20062
PM 2.5 ImplementationPM 2.5 Implementation
PM 2.5PM 2.5 Proposed RevisionsPM 10-2.5 Proposed Inhalable
Coarse Particles (“Thoracic Standard”)
Haze
May 23, 20063
May 23, 20064
NAAQS ImplementationNAAQS Implementation
The Clean Air Act requires EPA to set two types of national ambient air quality standards (NAAQS) for ‘criteria’ air pollutants. Primary standards to protect public health with
an adequate margin of safety Secondary standards to protect public welfare
and the environment (visibility, wildlife, crops, vegetation, national monuments and buildings)
The law requires EPA to review the scientific information and the standards for each pollutant every five years.
Cont’d.
May 23, 20065
NAAQS Implementation, cont’d.NAAQS Implementation, cont’d.
Review NAAQS every 5 years Revise NAAQS Standard
PM2.5, Ozone, Haze Modeling and attainment demonstrations Nonattainment designations (5 years to attainment) Develop Federal Implementation Rule State SIP due (within 3 years of designation)
RACT RACM RFP Revised NSR “Part D”
Attainment demonstration (within 5 years of designation)
May 23, 20066
PM2.5 Designationand Implementation Schedule
PM2.5 Designationand Implementation Schedule
July 18, 1997 PM NAAQS Revised December 17, 2004: EPA issued final PM2.5
designations (based on 2001-3 data) April 5, 2005: Effective date of PM2.5 designations November 1, 2005: Propose implementation rule Summer/Fall 2006: Finalize implementation rule December 2007: Regional haze implementation
plans due April 2008: PM2.5 implementation plans due April 2010: AQCR’s PM2.5 attainment date
May 23, 20067
PM2.5 Nonattainment AreasPM2.5 Nonattainment Areas
1) Atlanta, GA2) Baltimore, MD3) Birmingham, AL4) Canton, OH5) Charleston, WV6) Chattanooga, TN-GA-AL7) Chicago, IL-IN-WI8) Cincinnati, OH-KY-IN9) Cleveland, OH10) Columbus, OH11) Dayton, OH12) Detroit, MI13) Evansville, IN-KY14) Greensboro, NC
15) Hagerstown-Martinsburg,MD-WV
16) Harrisburg, PA17) Hickory, NC18) Huntington-Ashland, OH-
WV-KY19) Indianapolis, IN20) Johnstown, PA21) Knoxville, TN22) Lancaster, PA23) Libby, MT24) Louisville, KY-IN25) Macon, GA26) New York, NY-NJ-CT27) Parkersburg, WV-OH
28) Philadelphia, PA-NJ-DE
29) Pittsburgh, PA30) Pittsburgh/ Liberty-
Clairton, PA31) Reading, PA32) Rome, GA33) San Joaquin Valley,
CA34) South Coast, CA35) St. Louis, MO-IL36) Steubenville, OH-WV37) Washington, DC-MD-
VA38) Wheeling, WV-OH39) York, PA
Unclassifiable Greenville, SC
May 23, 20068
PM2.5 Implementation Rule Issues PM2.5 Implementation Rule Issues
Attainment dates Classifications PM2.5 precursors (? NOx, SO2, VOC…) Modeling and attainment demonstration Reasonably available control technology
(RACT) Reasonably available control measures
(RACM) Reasonable further progress (RFP) New source review
May 23, 20069
Attainment Dates Attainment Dates State attainment demonstrations and SIP
revisions are due April 2008 Under CAA, attainment date is no later than five
years from date of designation (e.g. Apr. 2010) Extensions of 1-5 years are possible
Attainment determination would be based on most recent 3 calendar years (e.g. 2007-2009 for Apr. 2010 attainment date).
State must provide thorough analysis of feasible RACM and RACT in the nonattainment area.
May 23, 200610
Attainment Date ExtensionAttainment Date Extension
At time of SIP submittal State must provide thorough analysis of
feasible RACM and RACT in the nonattainment areaBased on this analysis, the State can propose
an attainment date extension and EPA can grant such an extension, taking into consideration:
The severity of the nonattainment problem The availability and feasibility of control measures
The extension can be up to five years beyond April 2010
May 23, 200611
Attainment Date Extension, cont’d.Attainment Date Extension, cont’d.
For an extension, the State must include a modeling demonstration which:Shows that attainment by April 2010
is not practicable, considering the severity of the problem and availability and feasibility of controls
Supports what future date is an appropriate attainment date
May 23, 200612
Possibility of Attainment Extensions
Possibility of Attainment Extensions
Example Attainment date for an area is April 2010, to
be based on 2007-2009 data If 2007 and 2008 are over 15.05 µg/m3 but
the annual average for the 2009 attainment year is below 15.05 µg/m3, the area can receive a 1-year extension Attainment then will be based on 2008-2010
If the average of 2009 and 2010 is below 15.05 µg/m3, the area can receive a second 1-year extension Attainment then will be based on 2009-2011
May 23, 200613
Coverage of PM2.5 PrecursorsCoverage of PM2.5 Precursors Atmospheric chemistry for PM2.5 formation is
complex Proposed approach for PM2.5 implementation
and new source review PM2.5 direct emissions (includes organic carbon,
elemental carbon, and crustal material) and S02 must be addressed
NOx must be addressed in all areas, unless the State and EPA provide a demonstration finding that NOx is not a significant contributor in a specific area.
VOC and ammonia would not be addressed, unless EPA or the State provides a demonstration that VOC or ammonia is a significant contributor in a particular area.
May 23, 200614
Reasonably Available ControlTechnology (RACT)
Reasonably Available ControlTechnology (RACT)
RACT is the lowest emission limit that a source is capable of meeting with available control technology, considering technological and economic feasibility.
So, SIP Option 1. RACT required for all stationary sources with the potential to emit (PTE) more than 100 tpy of direct PM2.5 or any precursor EPA requesting comment on thresholds of 70 and 50 tpy
SIP Option 2. RACT required for stationary sources only to the extent it is needed for expeditious attainment or to meet RFP.
SIP Option 3. Option 2 for areas with attainment dates within 5 years Option 1 for areas with attainment dates > 5 years
May 23, 200615
RACTRACT
RACT measures must be implemented by no later than the beginning of the calendar year preceding the attainment date.(Example: If attainment date is April 2010, any necessary RACT measures would need to be implemented by no later than January 2009.)
May 23, 200616
RACT, cont’d.RACT, cont’d.
Previous RACT determinations:May be acceptable for purposes of PM2.5, if State certifies and supports that previous RACT determinations represent appropriate level of control.
EPA may revise control techniques guidelines or alternative control technology documents for selected categories with multipollutant impacts (e.g.: revise presumptive baseline)
May 23, 200617
Reasonably Available ControlMeasures (RACM)
Reasonably Available ControlMeasures (RACM)
A RACM demonstration must show that the State has adopted all reasonable measures needed to attain the standard as expeditiously as practicable and meet RFP. Demonstrate that no additional measures are
available that would advance the attainment date. Preamble includes a list of specific measures
that States should consider as part of the RACM analysis. States should assess whether implementing such
measures are technically and economically feasible States also must analyze additional measures
raised in public comment process.
May 23, 200618
Example Control MeasuresExample Control Measures Diesel retrofits (trucks, school
buses, stationary engines) Diesel idling (trucks, trains,
port equipment, etc.) Programs to reduce emissions
from poorly maintained vehicles
New or improved direct PM and precursor controls on stationary sources
Year-round operation of seasonal stationary source NOx controls
Increase use of alternative fuel, hybrid vehicles
Buy-back programs for small engines (boats, vehicles, equipment)
Year-round measures to reduce VMT (Commuter Choice, carpooling incentives, etc.)
Open burning laws and better enforcement
Programs to reduced emissions from residential wood combustion and back yard barrel burning
Smoke management plans Reducing emissions of
volatile aromatic compounds (surface coatings, gasoline, solvents, etc.)
May 23, 200619
Reasonable Further Progress (RFP)Reasonable Further Progress (RFP) RFP: annual incremental reductions in
emissions for purpose of ensuring timely attainment
Baseline emission inventory year is 2002 RFP plan due with attainment demonstration in
2008 For areas with an attainment date extension, the
State would establish emission reduction milestones showing generally linear progress from 2002 to January 1, 2010 and January 1, 2013 (if necessary)
Areas demonstrating attainment by 2010 will be “deemed” to meet RFP.
May 23, 200620
New Source ReviewProposed Revisions for PM2.5
New Source ReviewProposed Revisions for PM2.5
Requirements Significant emissions rate for PM2.5 — 10 tpy Precursors
SO2 always "in" as a precursor; NOx presumed "in" unless State demonstrates
that NOx is a significant contributor to PM2.5 or part of the transport problem
VOC and ammonia presumed "out" unless State demonstrates otherwise. Ammonia is not a precursor in PM2.5 attainment areas.
PM 2.5: Major source threshold 100 tpy; offset ratio 1:1
May 23, 200621
New Source ReviewProposed Revisions for PM2.5 (cont.)
New Source ReviewProposed Revisions for PM2.5 (cont.)Current program until PM2.5 rule is promulgated Interim guidance memo for both attainment and
nonattainment areas Use PM10 as a surrogate for PM2.5NSR Provisions during SIP development period (from final rule until State implementation plans are
approved) PSD program
Continue implementing guidance using PM10 as surrogate(include condensables and PM 2.5 modeling analysis); or
Update guidance to reflect the PM2.5 rule provisions or revise 40 CFR part 51 appendix S to point to PM 2.5 provisions in 40CFR 52.21; or
States can request delegation of only the federal PM2.5 program Nonattainment program
Use 40 CFR part 51 appendix S.
May 23, 200622
Proposed Revisions for PM2.5 and PM10
Proposed Revisions for PM2.5 and PM10
On December 20, 2005 the EPA proposed revisions to the National Ambient Air Quality Standards (NAAQS) for particulate matter.
The proposed revisions address two categories of particles:fine particles (PM2.5), which are 2.5
micrometers in diameter and smaller; andinhalable coarse particles (PM10-2.5), which are
smaller than 10 micrometers in diameter but larger than PM2.5 (Thoracic Standard)
May 23, 200623
Schedule for Revised PM NAAQS Review
Schedule for Revised PM NAAQS Review
Rulemaking on PM NAAQS:Proposal signed on December 20,
2005Public comment period: 90 days
Comment Period Extended to July 10, 2006
Public HearingsFinal Rule to be signed by September
27, 2006
May 23, 200624
What are EPA’s Current PM Standards?
What are EPA’s Current PM Standards?
PM2.5 Annual standard set at 15 µg/m3
Annual arithmetic mean, averaged over 3 years 24 hr standard set at 65 µg/m3
Annual 98th percentile, averaged over 3 years • PM10
50 µg/m3
annual average 150 µg/m3
24-hr average (99th percentile) Under the Proposal, EPA would revise the PM2.5 24-
hour standard from the current level of 65 µg/m3 to 35 µg/m3.
EPA is proposing to retain the current PM2.5 annual standard at 15µg/m3
May 23, 200625
Inhalable Coarse PM –Moving from PM10 to PM10-2.5
Inhalable Coarse PM –Moving from PM10 to PM10-2.5
EPA’s current standards for coarse particles (PM10) were set in 1987. a 24-hour standard of 150 µg/m3, and an annual standard
of 50 µg/m3 -- apply to particles 10 micrometers in diameter and smaller.
The proposed revisions would change the definition to apply to particles between 10 and 2.5 micrometers in diameter also known as PM10-2.5 .
The proposed new PM10-2.5 standard would be a 24-hour standard, at 70 µg/m3.
EPA is not proposing an annual standard for PM10-2.5.
May 23, 200626
Revoking the Current PM10 Standard
Revoking the Current PM10 Standard
EPA is proposing to revoke the current 24-hour PM10 standards, except in areas that have both
1) violating monitors; and2) a population of 100,000 or
more. The Agency is proposing to
immediately revoke the current annual PM10 standards in all areas.
May 23, 200627
Timeline if PM2.5 NAAQS Are Revised
Timeline if PM2.5 NAAQS Are Revised
Milestone 1997 PM2.5 Primary NAAQS
2006 PM2.5 Primary NAAQS
Promulgation of Standard
July 1997 Nov. 2006
State Recommendations to EPA
Feb. 2004(based on 2001-2003 monitoring data)
Nov. 2007(based on 2004-2006 monitoring data)
Final Designations Signature
Dec. 2004 Nov. 2009
Effective Date of Designations
April 2005 April 2010
SIPs Due April 2008 April 2013
Attainment Date April 2012 (based on 2007-2009 monitoring data)
April 2015 (based on 2012-2104 monitoring data)
Attainment Date with Extension
Up to April 2015 April 2020
May 23, 200628
Timeline if PM10-2.5 Standard Is Finalized
Timeline if PM10-2.5 Standard Is Finalized
Milestone 2006 PM10-2.5 NAAQS
Effective Date of Standard Nov. 2006
State Recommendations to EPA
July 2012 (based on 2009-2011 monitoring data)
Final Designations May 2013
Effective Date of Designations
July 2013
SIPs are Due July 2016
Attainment Date July 2018 (based on 2015-2017 monitoring data)
Attainment Date with Extension
Up to July 2023
May 23, 200629
What is Regional Haze?What is Regional Haze? Visibility impairment not directly attributable to
one or a few individual emission sources Cumulative impact of general atmospheric
pollutant loading Required under CAA (§169A)
“Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory class I Federal areas which impairment results from manmade air pollution.”
40CFR §51 “calls for States to establish goals and emission
reduction strategies for improving visibility in all 156 mandatory Class I national parks and wilderness areas.”
May 23, 200630
Regional HazeRegional Haze
MeasurementsVisual range and light extinction over
distance are two measures of visibility impairment. For regulatory purposes, EPA uses the “deciview.” A deciview is an increment of visibility change that is just perceptible to the human eye.
Deciviews are calculated from measured or modeled concentrations of individual pollutants based on their unique light extinction properties, adjusted for relative humidity.
May 23, 200631
General Requirements forState Regional Haze Programs
General Requirements forState Regional Haze Programs
For each mandatory class I Federal area:Determine baseline visibility conditionsEstablish “rate of progress” goalsIdentify and address all “BART” eligible”
sourcesDevelop emission control program if neededSubmit approvable State Implementation Plan
and supporting technical demonstration to EPA
SIP required every 10 yearsAchieve natural conditions by 2064
May 23, 200632
State Responsibilities UnderRegional Haze Rule
State Responsibilities UnderRegional Haze Rule
Establish baseline and set goal for improving visibility on 20% haziest days, while protecting visibility on 20% clearest days, in each of its Class I areas. Goal is to reach “natural conditions” in each area by 2064.
Develop long-term strategies for reducing emissions that contribute to regional haze in any Class I area. First SIP submittal must show “reasonable progress” towards visibility goals by 2018.
Develop process for determining BART control levels (or otherwise exempting sources) on a case-by-case basis. First SIP submittal must include control requirements and compliance schedules for BART.
May 23, 200633
4 Core Requirements of SIP4 Core Requirements of SIP
1. Calculate Baseline & Natural Visibility Conditions
2. Reasonable Progress Goals3. BART (Best Available Retrofit
Technology)4. Long-term Strategy (includes
control measures needed to achieve goals)
May 23, 200634
Definition of BART-Eligible SourceDefinition of BART-Eligible Source A BART-eligible source is the set of all
emissions units at a facility that: Fall into one of 26 prescribed source categories; Source built/reconstructed between 1962 and 1977;
and Collectively have the potential to emit 250 tons per
year of any visibility-impairing pollutant: (NOx, SOx, PM10, VOC)
A “BART-eligible source” is not “subject to BART” unless it reasonably causes or contributes to visibility impairment. A state may determine that all (or none) of its BART-eligible sources cause or contribute, or it may provide for exemptions.
May 23, 200635
What is BART?What is BART?
Basic StepsBART eligibility determination
Meets date, type and potential emission criteriaSubject to BART determination
Fails state exemption test (“reasonably anticipated”)
Engineering Analysis BART emission control requirement Resulting visibility impact assessment
Compliance options
May 23, 200636
Determine Whether Facility Causes/Contributes to Visibility Impairment
in Class I Area:3 Options
Determine Whether Facility Causes/Contributes to Visibility Impairment
in Class I Area:3 Options
1. Perform individual source exemption analysis: Use CALPUFF or
other EPAapproved model
Compare to natural background
“Cause” = impact > 1.0 deciview
“Contribute” = impact > 0.5 deciview (or lower)
2. Exempt sources with common characteristics.
3. Consider all BACT eligible sources subject based on statewide analysis or demonstrated sources are subject based on modeling
May 23, 200637
Conduct A BART Determinationfor Facilities Subject to BART
Conduct A BART Determinationfor Facilities Subject to BART
Facility will conduct a BART determination used by the State to establish emission limits in permits.
Analysis considers 5 factors:1. Available technology2. Costs of compliance3. Energy and non-air environmental
impacts4. Remaining useful life of plant5. Visibility improvement reasonably
expected from the control technology.
May 23, 200638
Consideration of MACT and BACT Limits
Consideration of MACT and BACT Limits
Default: Maximum Achievable Control Technology Standards represent BART for PM and VOC
Recent BACT determinations may also be “BART,” case-by-case
Controls installed for other reasons may be BART, case-by-case
Query: What is same or similar source?
May 23, 200639
Other ItemsOther Items
Order for evaluating control optionsLike BACT determinations, top-down
Determining weight of 5 factorsCase-by-case
Averaging emissionsYes, across BART-eligible units
May 23, 200640
The Future of BARTThe Future of BART
By December 2007…All BART eligible sources identifiedAll “appropriate” BART control determined
Factored into overall Regional Haze progress goals
Modeling demonstration Potential BART market trading system
By 2013 sources must either: Install BART controls, retire unit(s), or
participate in a BART emissions trading program
