Summary of Clean Air Fine Particle Implementation Rule

Proposed in November 2005

EPA Office of Air Quality Planning and Standards

August 17, 2006

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PM2.5 Area Designations and Implementation Schedule

December 2004 PM2.5 area designations

April 2005 Effective date of

PM2.5 designations

November 2005 Implementation rule proposed

Summer 2006 Final PM2.5 implementation rule

December 2007 Regional haze plans due

April 2008 PM2.5 implementation plans due

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8-hour Ozone and PM2.5 Nonattainment Areas

Designated Nonattainment

PM2.5 only*Both 8-hour Ozone and PM2.5*8-hour Ozone Only

* For PM2.5, the designated partial county areas are shown as actual boundaries designated.

OAQPS,AQSSDApril 28, 2005

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PM2.5 Implementation: Overall Approach

• Rule is based on “basic” nonattainment requirements in Clean Air Act (section 172, subpart 1)

• Coordinate planning and strategies to address regional haze and 8-hour ozone issues as well

• For each area, State plan will include measures to attain the PM2.5 standards “as expeditiously as practicable”– Account for significant air quality improvement from regional/national

rules (e.g. CAIR, diesel rules) and State rules on the books– Assess local and in-state contributors to the problem– Adopt reasonable local and in-state measures to attain expeditiously

and to protect public health. Even modest air quality improvements provide PM2.5 benefits in excess of costs.

Ozone & Fine Particle Nonattainment (Apr. 05)

Projected NAs

in 2010 and 2015

after reductions

from CAIR/CAMR/CAVR and

existing CAA

programs

Nonattainment areas for both 8-hour ozone and fine particle pollution

Nonattainment areas for fine particle pollution only

Nonattainment areas for 8-hour ozone pollution only

2010 with CAIR

2015 with CAIRCAIR/CAMR/CAVR and Other Clean Air ActPrograms Will Help Bring Many Eastern Areas into Attainment- However, a numberof areas are projected to not attain through 2010 and 2015

Eastern

108 ozone nonattainment areas with 408 counties

36 PM2.5 nonattainment areas with 195 counties

Projections concerning future levels of air pollution in specific geographic locations were estimated using the best scientific models available. They are estimations, however, and should be characterized as such in any description. Actual results may vary significantly if any of the factors that influence air quality differ from the assumed values used in the projections shown here.

East6 ozone 14 PM2.5

East16 ozone 18 PM2.5

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21 PM2.5 Areas Projected to Not Attain by 2010

• Atlanta, GA• Birmingham, AL• Charleston, WV• Chattanooga, TN-GA-AL• Chicago, IL• Cincinnati, OH-KY-IN• Cleveland, OH• Columbus, OH• Detroit, MI• Huntington-Ashland,

WV-OH-KY

• Indianapolis, IN• Knoxville, TN• Libby, MT • Los Angeles (South Coast), CA• Louisville, KY-IN• Macon, GA• Pittsburgh (Liberty-Clairton), PA• Rome, GA• San Joaquin, CA• St. Louis, MO-IL• Steubenville-Weirton, OH-WV

Total: 121 counties, 51 million population

Very close: New York, Philadelphia, Baltimore, Canton

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PM2.5 Implementation Rule Issues

• Attainment dates• Classifications• PM2.5 precursors• Modeling and attainment demonstration• Reasonably available control technology

(RACT)• Reasonably available control measures (RACM)• Reasonable further progress (RFP)• New source review

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Attainment Dates• State attainment demonstrations and SIP revisions are

due April 2008 – Attainment demonstrations need to provide the supporting

analysis for State adoption of measures that will result in the area attaining the standards “as expeditiously as practicable”

• 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, considering:

• the severity of the nonattainment problem• availability and feasibility of control measures (RACT and RACM)• Modeling demonstration should show why 2010 is not

practicable, and what future date is appropriate• Attainment based on most recent 3 years of data

(e.g. 2007-9 for April 2010 attainment date)

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When Assessing Attainment: Possibility of Two One-Year 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 but the annual

average for the 2009 attainment year is below 15.05, 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, the area can receive a second 1-year extension– Attainment then will be based on 2009-2011

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Classifications

Option 1: No classification system– Keeps it simple under subpart 1.

Option 2: Moderate & serious classifications– Requested comment on criteria for two-tier

system (examples: moderate = 5 yrs or less, serious > 5 yrs.; or based on design value threshold)

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Coverage of PM2.5 Precursors• Atmospheric chemistry leading to 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 SO2 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 do not need to be addressed, unless EPA or the State provides a demonstration that VOC or ammonia is a significant contributor in a particular area.

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Modeling and Attainment Demonstrations

• All nonattainment areas need to submit an attainment plan having appropriate modeling according to PM2.5 modeling guidance – Requested comment on use of EPA modeling

• One-atmosphere modeling recommended (ozone, PM, haze)

• Years to model: coordinate with ozone and regional haze attainment & reasonable progress dates to the extent possible

• Mid-course reviews will be required on a case-by-case basis through SIP approval process– Check progress in 2010 and 2013; if not on track, conduct new

modeling and evaluate new measures

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Reasonably Available Control Technology (RACT)

RACT is the lowest emission limit that a source is capable of meeting with available control technology, considering technological and economic feasibility.

• 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– Also requesting comment on thresholds of 70 and 50 tpy

• Option 2. RACT required for stationary sources only to the extent it is needed for expeditious attainment or to meet RFP.

• Option 3. – Option 2 for areas with attainment dates within 5 years– Option 1 for areas with attainment dates > 5 years

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Control Measures for EGUs

• Proposed determination: in states obtaining all CAIR reductions from EGUs, EGU compliance with CAIR satisfies SO2 RACT and NOx RACT (provided SCR is operated year-round in 2009)

• Rationale: CAIR requires all feasible reductions by 2009/10; highly cost-effective reductions by 2015

• Direct PM2.5 RACT required for all EGUs• RACM section: experience has shown that

consultations between power companies and States may lead to controls on specific plants to address CAIR and local PM2.5 attainment planning needs

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Reasonably Available Control Measures (RACM)

• A RACM demonstration must show that the State has adopted all reasonable measures needed to attain the standard as expeditiously as practicable and to meet RFP.– Reasonable measures are those that are technically

and economically feasible– In determining RACM for an area, the state must

consider the cumulative impact of implementing the available measures and whether such measures taken together would advance the attainment date.

– RACM may vary from area to area– Limited RACM analysis for areas with attainment

dates of April 2010 or earlier

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RACM (cont)

• Preamble includes a list of specific measures that States should consider as part of the RACM analysis. – States would not be required to adopt these

measures, but should use the list as a starting point in the analysis

– States also must analyze additional measures raised in public comment process.

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Example 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.)

* EPA provided grant funding to STAPPA to develop a “PM2.5 Menu of Options” document, published in March 2006.

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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

• If attainment date is no later than 5 years from designations (up to April 2010), RFP would be met by attainment demo

• 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)

• Alternate approach is possible if it would achieve equivalent air quality improvement

• Geographic range of SO2 and NOx emission sources included in RFP plan could extend 200 km beyond nonattainment area boundary

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Contingency Measures

• To be implemented without further action if area fails to attain by its attainment date or fails to meet RFP requirements.

• Need to be measures other than those required for attainment or to meet RFP

• Level of reductions: one year’s worth of reductions needed for attainment in the area

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Condensable PM

• Previous policies: PM is comprised of filterable and condensable emissions. Condensable emissions can be a significant percentage of direct PM2.5 emissions

• Test method 202 has been available for a number of years but not consistently applied. New methods (CTM-039) are under development.

• Some states have required condensables to be addressed in SIPs and NSR permits for some time

• Condensables should be included in RACT applicability and control determinations

• States need to change emission limits in SIPs where reductions in condensable PM are needed for attainment

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Improved Source Monitoring

• Reviewed a 4-part strategy for improving emissions monitoring at sources (described in a Jan. 2005 FR notice)

• Discussed additional reductions that are possible with 1) increased frequency of monitoring (to identify upset conditions sooner), and 2) use of improved monitoring control measures (such as continuous emissions monitors)

• Noted concerns about the widespread use of visual emissions monitoring techniques to determine compliance with PM limits

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PM2.5 Implementation RuleOther Issues

• Technical overview – chemistry, sources, ambient data

• New source review• Transportation Conformity• General conformity• Emission inventories• Tribal issues