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ANPR: Transition to New or Revised PM NAAQS. WESTAR Business Meeting March 2006. What issues are discussed in the ANPR?. Proposed options for transitioning from 1997 PM 2.5 NAAQS to any new 2006 PM 2.5 NAAQS Timelines for implementation of any new 2006 PM 2.5 NAAQS

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anpr transition to new or revised pm naaqs

ANPR: Transition to New or Revised PM NAAQS

WESTAR Business Meeting

March 2006

what issues are discussed in the anpr
What issues are discussed in the ANPR?
  • Proposed options for transitioning from 1997 PM2.5 NAAQS to any new 2006 PM2.5 NAAQS
  • Timelines for implementation of any new 2006 PM2.5 NAAQS
  • Timelines for implementation of any new PM10-2.5 NAAQS
  • Transition from the PM10 standards to any new PM10-2.5 NAAQS
  • What emission inventory requirements should apply to PM2.5 and PM10-2.5 NAAQS
  • Next steps
transition from 1997 to 2006 pm 2 5 naaqs
Transition from 1997 to 2006 PM2.5 NAAQS
  • Option 1:
    • Proposed change to annual PM2.5 standard is minimal
      • Not significant enough to require new designations
    • Propose to not revoke the annual PM2.5 standard
    • Propose to revoke the 1997 24-hr PM2.5 standard one year after designations under any new 24-hr PM2.5 standard
    • SIPs for annual PM2.5 standard would stay in place until areas redesignated attainment
transition from 1997 to 2006 pm 2 5 naaqs4
Transition from 1997 to 2006 PM2.5 NAAQS
  • Option 2:
    • Revoke annual and 24-hr PM2.5 standard 1 year after designations under any new PM2.5 standards
    • Develop and implement “anti-backsliding” rule
      • Which planning control requirements remain?
      • NSR program
      • Conformity programs
timeline for new pm 10 2 5 standard
Timeline for New PM10-2.5 Standard*

*Schedule based on monitor deployment in 2009

transition from the pm 10 standards to any new pm 10 2 5 naaqs proposed in pm naaqs
Transition from the PM10 standards to any new PM10-2.5 NAAQS – Proposed in PM NAAQS
  • Proposal for revoking PM10 Standards upon promulgation of 2006 PM10-2.5 NAAQS:
    • Revoke annual PM10 standard everywhere
    • Revoke 24-hr PM10 standard everywhere except
      • Where violating monitor and urbanized area with population greater than 100K
  • Taking comment on retaining 24-hr PM10 standard in non-urbanized areas with ambient mix of PM from traffic, industrial and construction sources and one violating monitor
transition from the pm 10 standards to any new pm 10 2 5 naaqs proposed in anpr
Transition from the PM10 standards to any new PM10-2.5 NAAQS – Proposed in ANPR
  • Revoking 24-hrPM10 standard one year after designations under PM10-2.5 standards
  • Anti-backsliding rule would be needed:
    • Control Measures – to be retained based on PM10 classification – moderate or serious
    • Maintenance for areas that come into attainment w/ PM10 prior to revocation?
    • Transportation conformity – to be addressed in separate rulemaking
    • General conformity – to be addressed in separate rulemaking
    • New Source Review – following slides
transition from the pm 10 standards to any new pm 10 2 5 naaqs nsr issues
Transition from the PM10 standards to any new PM10-2.5 NAAQS: NSR Issues
  • Does PM10 continue to be aregulated NSR pollutant for PSD where 24-hr PM10 isrevoked?
    • Option 1: PM10 continues to be regulated NSR pollutant since retained in some areas; PSD continues to apply – but only BACT since non-criteria pollutant
    • Option 2: interpret definition to be area-specific, so PM10 no longer regulated NSR pollutant and none of the PSD requirements would apply
  • Does the CAA require continued obligation for some form of PM increment?
    • Option 1: Conclude § 166(f) and § 163 requirements no longer applicable and develop new increments for PM2.5 and PM10-2.5 establishing new baseline and trigger dates
    • Option 2: Substitute PM10 increments with two new increments PM2.5 and PM10-2.5 – retain existing baseline and dates
transition from the pm 10 standards to any new pm 10 2 5 naaqs nsr issues cont d
Transition from the PM10 standards to any new PM10-2.5 NAAQS: NSR Issues cont’d
  • How should permitting authorities implement the PM2.5 program upon revocation of PM10?
    • Option 1: Continue to use PM10 as surrogate – but compare PM10 emissions concentrations with the PM2.5 NAAQS - conservative
    • Option 2: Continue to apply existing surrogate policy for implementing the PM2.5 program – compare PM10 emissions with former PM10 NAAQS
  • How to implement PSD program for PM10-2.5 upon the effective date of promulgation for PM10-2.5?
    • Option 1: Use PM10 as a surrogate – compare PM10 emissions concentrations with the PM10-2.5 NAAQS - conservative
    • Option 2: Compare PM10 analysis to former PM10 NAAQS and use compliance with this as surrogate for compliance with new PM10-2.5 NAAQS for a temporary period
    • Option 3: Use compliance with BACT for PM10-2.5 as a surrogate for the PM10-2.5 compliance demonstration
pm 10 2 5 naaqs nsr issue
PM10-2.5 NAAQS : NSR Issue
  • How should ambient PM10-2.5 dominated by rural windblown dust and soils, and generated by agricultural and mining sources be treated in the NSR program for the proposed PM10-2.5 standard?
    • Definition of proposed PM10-2.5 standard suggests that NSR applicability test would exclude these sources from consideration. How do we implement the NSR program if a NAAQS with these characteristics is promulgated?
applicable emission inventory requirements for pm 2 5 and pm 10 2 5 naaqs
Applicable emission inventory requirements for PM2.5 and PM10-2.5 NAAQS
  • EPA’s emission inventory program is specified in the Consolidated Emissions Reporting Rule, the Air Emissions Reporting Requirements, and guidance
    • Are the data elements specified in the CERR and AERR sufficient to develop adequate SIPS for PM2.5 and PM10-2.5?
    • Fugitive emissions are significant contributors to PM10-2.5
      • Should EPA require/develop more precise methods for estimating these emissions
    • Should EPA require any additional emission inventory data elements or temporal allocation techniques to estimate more accurately daily emissions and their variability?
    • Other inventory issues which need to be defined?
next steps
Next Steps
  • ANPR published in FR on Feb 9 (71 FR 6718) w/ 60 day comment period ending April 10, 2006
  • Evaluate comments and develop proposal sometime after NAAQS are finalized in September 2006