Final Clean Air Fine Particle Implementation Rulefor the 1997 PM2.5 Standards

Rich Damberg

EPA Office of Air Quality Planning and Standards

June 20, 2007

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Particulate Matter: What is It?

A complex mixture of extremely small particles and liquid droplets

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PM Components: Fine and CoarseInhalable Coarse ParticlesCrushing, grinding, dustResuspended dusts (soil, street dust)Coal/oil fly ashAluminum, silica,iron-oxidesTire and brake wearInhalable biological Materials (e.g., from soils, plant fragments)Sources:Resuspension of dust tracked onto roadsSuspension from disturbed soil (farms,

mines, unpaved roads)Construction/demolitionIndustrial fugitivesBiological sourcesExposure/Lifetime:Coarse fraction (2.5-10) lifetime of hours to

days, distribution up to 100s km

Fine ParticlesCombustion, gases to particlesSulfates/acidsNitrateAmmoniumOrganicsCarbonMetalsWater

Sources:Coal, oil, gasoline, diesel, wood

combustionTransformation of SOx, NOx, organic

gases including biogenicsHigh temperature industrial processes (smelters, steel mills)Forest fires

Exposure/Lifetime:Lifetime days to weeks, regional

distribution over urban scale to 1000s of km

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Public Health Risks Are Significant

Particles are linked to:• Premature death from heart and lung disease

• Aggravation of heart and lung diseases– Hospital admissions – Doctor and ER visits – Medication use– School and work absences

• And possibly to– Lung cancer deaths– Infant mortality– Developmental problems, such as low birth weight,

in children

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Some Groups Are More at Risk

• People with heart or lung disease– Conditions make them

vulnerable

• Older adults – Greater prevalence of heart

and lung disease

• Children– More likely to be active

– Breathe more air per pound

– Bodies still developing

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EPA’s PM2.5 Standards: Old and New

1997 Standards 2006 Standards

Annual 24-hour Annual 24-hour

PM2.5

(Fine Particles)

15 µg/m3

Annual arithmetic mean, averaged over 3 years

65 µg/m3

24- hour average, 98th percentile, averaged over 3 years

15 µg/m3

Annual arithmetic mean, averaged over 3 years

35 µg/m3

24- hour average, 98th percentile, averaged over 3 years

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Significance of State Plans to Attain the 1997 PM2.5 Standards

• Among the criteria pollutants, PM2.5 poses the greatest health risks.

• Local and in-state sources are responsible for a significant portion of the PM2.5 problem and health risk– These sources are the focus of PM2.5 SIPs.

• CAA requires these SIPs to demonstrate attainment as expeditiously as practicable to protect public health

• PM2.5 implementation rule describes the steps for determining required controls and the date that is as expeditious as practicable

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Timeline for PM2.5 NAAQS ImplementationApril 2005 39 areas designated for 1997 standards

Dec. 2006 2006 revised PM NAAQS

Dec. 2007 States recommend designations for 2006 revised PM2.5 standards

April 2008 PM2.5 State plans due for 1997 standards

2008-9 Final designations for 2006 PM2.5 standards

(effective date 60-90 days later; 2009-10)

Apr 2010-15 Attainment date for areas designated in 2005 for 1997 standards

April 2012-13 PM2.5 State plans due for 2006 standards

April 2014-20 Attainment date for areas designated

in 2009-10

Currently Designated PM2.5 Nonattainment Areas - 1997 StandardsViolated annual and/or 24-hour PM2.5 standards with designated data (2001-2003*)

LegendNonattainment areas violating: Number of Areas both annual (15 µg/m3) and 24-hour (65 µg/m3) standards 2 ONLY the 24-hour standard (65 µg/m3) 0 ONLY the annual standard (15 µg/m3) 37

Total PM2.5 Nonattainment Areas 39

* 2002-2004 data were considered in the designation process but all nonattainment designations were based on 2001-2003 data

Areas/Sites Violating 24-Hour PM2.5 NAAQS – 2003-2005

Current nonattainment area violates new 24-hr NAAQS [32 areas]

Current nonattainment area meets new 24-hr NAAQS [7 areas]

• Sites not in a current nonattainment area violate the new 24-hr NAAQS (59 sites)

• 59 sites are violating the new 24-hr standard and are NOTlocated in an existing nonattainment area. • They are located in 38 different areas (34 in metro areas, 4 not in a metro area).

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Keep in Mind During State Planning for the Fine Particle Standards

• Current planning is focused on annual standard• If area also violates 2006 24-hour standard,

consider measures on key source categories that contribute to high 24-hour concentrations

• If other areas in the state were designated attainment in 2005 but are now violating, take steps to achieve clean air in these areas

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Approaches to Address “Violating Attainment Areas”

• Informal discussion with States and sources• Letter to State • Enforcement action by State • Voluntary measures plus MOA agreement as

“backstop”– Stakeholders agree on voluntary measures– Enforcement as “backstop”

• SIP call • Designation to nonattainment• A combination of the above

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Elements of the PM2.5 Implementation Rule

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Pollutants to Address in Attainment Plans• Direct PM2.5 and SO2: must be evaluated for control measures

in each area• NOx: Sources of NOx must be evaluated for control measures in

each area, unless the State and EPA provide a technical demonstration showing that NOx emissions from sources in the State do not significantly contribute to PM2.5 concentrations in a specific area

• VOC: Sources of VOC are not required to be evaluated for control measures in each area, unless the State or EPA provide a technical demonstration showing that VOC emissions from sources in the State significantly contribute to PM2.5 concentrations in a specific area

• Ammonia: Sources of ammonia are not required to be evaluated for control measures in each area, unless the State or EPA provide a technical demonstration showing that ammonia emissions from sources in the State significantly contribute to PM2.5 concentrations in a specific area

• Rule provides basic guidance on potential analyses for technical demonstration; weight of evidence approach.

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SIP Due Dates and Attainment Dates• SIP revisions are due April 2008

– Account for significant air quality improvement from regional/national rules (e.g. CAIR, diesel rules) and State rules on the books

– Evaluate controls for local and in-state contributors to the problem

– Adopt reasonably available measures to attain “as expeditiously as practicable” as required by the Clean Air Act (CAA)

– Include enforceable emissions limitations and source testing & monitoring procedures as required by the 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 air pollution control measures

• Areas evaluated based on most recent 3 years of monitoring data (e.g. 2007-9 for April 2010 attainment date)

• No classification system

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Reasonably Available Control Technology (RACT) /Reasonably Available Control Measures (RACM)

• For nonattainment areas, States need to adopt all reasonably available control measures (including RACT) needed to attain the standards as expeditiously as practicable and meet Rate of Further Progress requirements– Collective analysis; demonstrate that no reasonably available additional

measures would advance the attainment date by at least 1 year• Guidance in rule

– Identify technically and economically feasible measures– Conduct air quality modeling– Select RACT/RACM

• Area-specific flexibility– No tonnage threshold; evaluate smaller sources for areas with more

severe problem– Limited analysis without modeling if have projected design value of 14.5

ug/m3 of PM2.5 by 2007-2009• Preamble includes list of specific measures that States should

consider as a starting point for RACT/RACM assessment

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RACT/RACM for Sulfur Dioxide and Nitrogen Oxides from Electric Generating Units (EGUs)

• Presumption– SO2: If State meets the Clean Air Interstate Rule (CAIR) SO2

cap through EGU reductions only, then the State may presume that its nonattainment area EGUs meet RACT and RACM

– NOx: If State meets CAIR NOx cap through EGU reductions only, then the State may presume that its nonattainment area EGUs meet RACT and RACM (provided NOx sources with SCR operate it year-round)

• A State may impose additional requirements on a specific plant if the State determines it is a reasonable means to attain expeditiously– However, several factors should be considered re: potential

disbenefits of beyond-CAIR controls– Addressed case-by-case through SIP development process

• Direct PM2.5 RACT/RACM required for all EGUs

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Reasonable Further Progress (RFP)• RFP: annual incremental reductions in emissions for purpose of

ensuring timely attainment• RFP plan due with attainment demonstration in 2008

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

• For areas with an attainment date extension, the State must establish emission reduction milestones showing “generally linear” progress from 2002 through the 2009 emissions year and, if appropriate, the 2012 emissions year

• 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 up to 200 km beyond nonattainment area boundary.

• Mid-course review in 2011 for area with 2014 or 2015 attainment date

• Adopt new strategies as necessary

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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 Particulate Matter• PM is comprised of filterable and condensable emissions.

Condensable emissions are a significant percentage of direct PM2.5 emissions from some sources.

• Emission inventories have been required to include condensable PM for a number of years

• Test methods for condensable PM are available but concerns remain about data uncertainties and ability to develop enforceable emission limits for many sources in a short period of time.

• For sources included in PM2.5 attainment plans, emissions limits including condensable PM are required after January 2011. – EPA encourages States that already have required emissions testing

and established emission limits for condensable PM to continue• Transition period activities

– EPA to update Method 201A & 202 for use by States during and following transition

– Stakeholder groups to conduct testing with updated Method 201A & 202 to update emissions factors

– EPA to work with ASTM to finalize dilution-based test method– States to enhance databases to support regulations

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Other Issues

• Improved source monitoring

• Transportation conformity

• General conformity

• Emission inventories

• Enforcement and compliance

• NSR addressed in a separate rulemaking