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Update on the PM2.5 Designations Process and the PM2.5 Implementation Rule. Joseph Paisie WESTAR April 8, 2004. Purpose. Give an update on the PM2.5 designations process Provide a detailed overview of the draft PM2.5 implementation rule. PM2.5 Schedule.

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update on the pm2 5 designations process and the pm2 5 implementation rule

Update on the PM2.5 Designations Process and the PM2.5 Implementation Rule

Joseph Paisie


April 8, 2004

  • Give an update on the PM2.5 designations process
  • Provide a detailed overview of the draft PM2.5 implementation rule
pm2 5 schedule
PM2.5 Schedule

*Dates codified in Consolidated Appropriations Bill of FY2004. SIP due dates for PM2.5

and regional haze are 3 years from effective date of PM2.5 designations.

state recommendations for pm2 5 designations
State Recommendations for PM2.5 Designations
  • Recommendations have been received from most States.
  • Expect updates (2001-03 data)
  • Additional supporting information is needed for a number of areas.
state recommendations for pm2 5 designations cont
State Recommendations for PM2.5 Designations (cont.)
  • Summary
    • 116 NA counties
    • 8 partial NA counties
    • 21 counties in OH and MD recommended as NA in “options” under consideration
    • Total population of these 145 counties = 82 million
    • Presumptive metro areas associated with these counties
      • 302 counties with 105 million population
  • Website – www.epa.gov/pmdesignations
    • To go live soon
overview of pm2 5 implementation rule
Overview of PM2.5 Implementation Rule
  • Overall approach
  • Attainment dates
  • Classifications
  • PM2.5 precursors
  • RACT
  • RACM
  • RFP
  • Other issues
pm2 5 implementation overall approach
PM2.5 Implementation: Overall Approach
  • Rule is based on section 172, subpart 1 requirements
  • We strongly encourage early local reductions
    • Mortality & other serious health effects
    • 2002 is inventory base year (No penalty for early reductions)
    • To attain:
    • Reduce emissions under Federal programs (mobile source measures and regional reductions of SO2 and NOx)
    • Federally enforceable State/local measures
attainment dates
Attainment Dates
  • State attainment demonstrations and SIP revisions are due within 3 years of designations
    • Assuming designations are finalized in Dec. 2004 and are effective 60 days later, attainment demonstrations and SIPs would be due in Feb. 2008.
    • Attainment demonstrations need to provide the supporting analysis for adopting a set of measures that will result in the area attaining the standard “as expeditiously as practicable”
    • Modeling and attainment demonstration guidance to be finalized in 2004. Draft recommends finer resolution than 36 km grid.
  • CAA presumption: attainment date is no later than five years from date of designation (e.g. Feb. 2010)
  • Attainment determination would be based on most recent 3 calendar years (e.g. 2007-2009).
attainment date extension
Attainment Date Extension
  • State must provide thorough analysis and review of all feasible RACM and RACT in the nonattainment area
  • Propose an attainment date extension
  • EPA bases decision on
    • severity of the nonattainment problem
    • availability and feasibility of control measures
    • Extension can be UP TO five years beyond the presumptive 5 years, but is not automatically 5 years
    • The proposed date must result in attainment “as expeditiously as practicable”
attainment date extension cont
Attainment Date Extension (cont.)
  • State must include a modeling demonstration
    • Analysis shows that attainment in 2010 is not practicable
    • Analysis demonstrates what future year is an appropriate attainment date

Possibility of Two One-Year Extensions

  • If the annual average for the “attainment year” (e.g. 2009 if attainment date is Feb. 2010) is below 15.05, the area can receive a 1-year extension
  • If the average of 2009 and 2010 is below 15.05, the area can receive a second 1-year extension
  • No classification categories based on design value
  • Proposing “rural transport” classification
    • Criteria
      • Not in or adjacent to a metropolitan area
      • Impacted by overwhelming transport
      • Does not significantly contribute to its own problem
      • Based on 2000-2002 data, very few counties are not in or adjacent to an MSA
        • Seeking comment on whether a transport classification is needed
coverage of pm2 5 precursors
Coverage of PM2.5 Precursors
  • Goal: consistent approach in proposals for transportation conformity, PM2.5 implementation rule, NSR
  • Atmospheric chemistry leading to PM2.5 formation is complex
  • Key issues: coverage of VOC, NOx, and ammonia in each program
  • All reactive VOCs participate indirectly in PM production by forming “free radicals” such as OH.
  • The VOCs which have 7 or more carbon atoms participate directly in PM production.
    • Aromatics (e.g C7~C15, such as toluene and xylene) lead to secondary organic aerosol (SOA) formation (estimated at 20-40% of anthropogenic SOA) when temperatures are high enough.
  • Other heavier VOCs (e.g. C16 and higher) typically condense as primary organic aerosol when emitted to ambient air, and are considered direct PM for purposes of the implementation rule
  • NOx is important in atmospheric chemistry leading to free radicals and particle formation
  • Nitrate replacement will occur when sulfate reductions occur.
  • Nitrate can range from being a small percentage of PM2.5 mass to a very substantial one, depending on the region of the country
  • Proposed approach: ammonia can be addressed provided the State or EPA develops a supporting demonstration
  • Reducing ammonia may or may not lead to fine particle reductions
  • Recent research indicates that a more acidic atmosphere may lead to increased formation of secondary organic aerosol
  • Need to improve our current understanding of ammonia emissions, chemistry, and control strategies.
current approach on pm2 5 precursors by program area
Current Approach* on PM2.5 Precursors by Program Area

** Applies to interim period. After SIP approval, these programs will address the pollutants addressed in the SIP.

reasonably available control technology ract
Reasonably Available Control Technology (RACT)
  • RACT is lowest emission limit that a source is capable of meeting with control technology that is available, considering technological and economic feasibility.
    • In the past, RACT has been an independent requirement that applies to major stationary sources.
    • Subpart 1: no specific categories identified
  • No current plans for EPA to develop CTGs or ACTs.
    • Various existing sources of information
    • STAPPA developing new Menu of Options document for PM2.5 and precursors
reasonably available control technology ract21
Reasonably Available Control Technology (RACT)
  • Option 1. RACT applies to stationary sources with potential to emit (pte) direct PM2.5 or precursor greater than a specific threshold.
    • Suboption 1. Threshold = pte of 100 tpy or more
    • Suboption 2. Threshold = pte of 50 tpy or more
    • Suboption 3. Sliding scale (e.g. 100, 50, 25, etc.) based on design value.
  • Option 2. RACT is required only to the extent it is needed for expeditious attainment or to meet RFP.
    • Any State seeking an attainment date extension must show that it has implemented all RACT in order to meet RFP and provide for expeditious attainment of the standards.
reasonably available control measures racm
Reasonably Available Control Measures (RACM)
  • A RACM demonstration must show that the State has adopted all reasonable measures needed to meet RFP and to attain the standard as expeditiously as practicable.
    • The demonstration should also show that there are no additional measures available that would advance the attainment date or contribute to RFP.
    • 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 cont
RACM (cont)
  • Preamble includes a list of specific measures that States should analyze as part of the RACM analysis.
    • Not required to adopt these measures
    • Provide analysis of technical and economic feasibility
    • Advance the attainment date?
    • Analyze additional measures identified in public comment process.
ract racm potential 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

Smoke management plans

Improved monitoring techniques and more frequent monitoring on sources with control devices

Reducing emissions of volatile aromatic compounds (surface coatings, gasoline, solvents, etc.)

Others ??

RACT & RACM – Potential Measures

** We have provided grant funding to STAPPA to develop a PM2.5 “Menu of Options” document. Target date for completion is late 2004.

regional vs local controls
Regional vs. Local Controls
  • Every area has a regional and a local component to its nonattainment problem
  • Air quality is projected to improve due to reductions from programs on the books (e.g. mobile source rules, NOx SIP call, State programs, etc.)
    • States should take these reductions into account in developing plans to attain “as expeditiously as practicable”
  • EPA are working on programs (e.g. Interstate Air Quality Rule) to address regionally transported SO2 and NOx
  • Analysis of PM2.5 chemical composition monitoring data can help
  • “Urban excess” analyses point to carbon, nitrate, and in some locations sulfate
    • Source apportionment and back trajectory analyses can identify potential contributing source categories
reasonable further progress rfp proposed approach
Reasonable Further Progress (RFP)- proposed approach
  • Baseline emission inventory year is 2002
  • Initial RFP plan due in July 2006 for all areas
  • For an area proposing to have an attainment date 7 years or more after designations (e.g. Feb. 2012 or beyond), a second RFP plan is due at the time of SIP submittal (e.g. Feb. 2008)
2006 rfp plan
2006 RFP Plan
  • Each area has a target weighted average emission reduction rate based on its air quality design value (see table)
  • Consider SO2, PM2.5 primary, and NOx in calculating weighted average emission reduction between 2002 and 2007
  • Take credit for reductions from existing programs
  • Adopt additional measures to meet target rate
  • Weighted average approach based on chemical composition profile from nearby speciation monitor
second rfp plan w attainment demo
Second RFP Plan w/ Attainment Demo
  • Second RFP plan due for areas that demonstrate need for attainment date extension to 7 years from designations
  • Plan sets emissions reduction milestones for 2008-10 time period, to be met by December 31, 2010.
  • Annual emission reduction rates based on overall attainment strategy (e.g. from 2002 base year to proposed attainment year).
  • Example: Attainment demo calls for 30% SO2 and 10% PM2.5 reduction for Feb. 2012 attainment date
    • Linear reduction from 2002 – 2011 means 3% per yr for SO2 and 1% per yr for PM2.5
    • The RFP plan must show air quality improvement equivalent to 9% SO2 and 3% PM2.5 reduction by 2010
    • State may provide alternate combinations of pollutant reductions to achieve same air quality improvement.
modeling and attainment demonstrations
Modeling and Attainment Demonstrations
  • Nonattainment areas submit an attainment plan using PM2.5 modeling guidance
  • Preamble provides overview of modeling guidance
    • Request additional comment, finalize in 2004
    • Describes “relative attainment test,” which estimates future PM2.5 levels
      • Multiply base year ambient concentration for each component by the model-predicted percent change for each component, and summing values
modeling and attainment demonstrations30
Modeling and Attainment Demonstrations
  • Recommends one-atmosphere modeling
  • Coordinate based on attainment years for ozone and PM2.5
    • For example, if an area has a 2008 attainment date for ozone and 2009 for PM2.5, then modeling for 2008 could address both programs
  • Mid-course review requirement
other sections of the preamble
Other Sections of the Preamble
  • Technical overview – chemistry, sources, ambient data
  • New source review - proposed changes for PM2.5
  • Transportation conformity
  • General conformity
  • Contingency measures
  • Innovative program mechanisms
  • Policies for SIP credit
  • PM2.5 source test methods
  • Improved monitoring techniques to reduce emissions
  • Emission inventories
  • Tribal issues