PM 2.5 NAAQS October 26, 2004 ARIPPA trinityconsultants.com Presented by: Divya Harrison Trinity Consultants (240)

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PM 2.5 NAAQS

What is PM 2.5 ?  “Fine” particulate matter  Aerodynamic diameter less than 2.5 µm  For perspective, a human hair is about 70 µm in diameter

PM2.5 Perspective

What Are The Sources of PM 2.5 ?  Carbonaceous  Combustion activities  Inorganic  Dust  Secondary Formation  Condensation of gases  Atmospheric reactions  Primarily from nitrates and sulfates

Cars, trucks, heavy equipment, wild fires, waste burning, and biogenics (VOCs, direct PM) Power Generation (SO2) Dust from road and construction Cars, trucks, and power generation (NOx) Fertilizers and Animal Feed Operations (in combination with NOx/SOx sources) Carbon Crustal Sulfates Nitrates Ammonium What Are The Sources of PM 2.5 ? (cont.) * Source: EPA

Why Are We Worried About PM 2.5 ?  Fine particles are believed to pose the greatest risk to human health  Respiratory disease  Cardiovascular disease  Fine particles also contribute to regional haze issues

NAAQS Background (1 of 4)  The Clean Air Act identifies six common air pollutants that can injure health, harm the environment, and cause property damage  “Criteria” pollutants  Particulate matter (PM) is a criteria pollutant

NAAQS Background (2 of 4)  EPA is tasked with developing National Ambient Air Quality Standards (NAAQS) for criteria pollutants  Primary NAAQS – set at levels “allowing an adequate margin of safety…requisite to protect the public health.” (based on most sensitive individuals)  Secondary NAAQS – set at levels adequate to protect “human welfare,” where welfare is defined in terms of vegetation, soil, and visibility

NAAQS Background (3 of 4)  EPA established new NAAQS for PM 2.5 in July 1997 (effective September 16, 1997)  15 µg/m 3 annual average (3-year average of annual mean, averaged spatially)  65 µg/m 3 24-hour average (3-year average of 98 th percentile at each monitor)  Primary and secondary standards are equal

NAAQS Background (4 of 4)  Areas that don’t meet the NAAQS are designated as nonattainment areas  Designation is pollutant-specific  Subject to more stringent requirements  Additional controls  Emissions offsets  Fees

PM 2.5 NAAQS Implementation  After much litigation following promulgation of the PM 2.5 NAAQS, EPA is free to implement the standards  States began monitoring PM 2.5 levels and speciation shortly after NAAQS promulgation  Monitoring data from is being used to identify nonattainment areas and strategies

Overall Implementation Timeline (1 of 3)  – Collect monitoring data  February 15, 2004 – Deadline for states to submit proposed designations  June 28-29, 2004 – EPA issued letters to states outlining EPA’s intended designations

Overall Implementation Timeline (2 of 3)  September 1, 2004 – Deadline for states to submit comments on EPA’s intended designations  November 2004 (Anticipated) – EPA to propose PM 2.5 NA implementation guidance  November 2004 (Anticipated) – EPA issues final designations

Overall Implementation Timeline (3 of 3)  February 2005 (Anticipated) – Effective date of designations  May/June 2005 – EPA finalizes implementation rule  February 2008 – Deadline for states to update SIPs to incorporate NA provisions (3 years from effective date)  February 2010 – Attainment with standards required for most NA areas (5 years from effective date - dependent upon classification)

Comparison of Proposed NA Areas

Comparison of Proposed NA Areas (cont.)  State proposals generally included only counties with monitored values greater than the NAAQS  EPA intended designations included additional counties based on potential contribution to monitored NA  Large emissions sources  High growth rate  High population and commuting levels

NSR Implications (1 of 4)  EPA will be requesting public comment on the proposed implementation methodologies  Part of proposed implementation rule to be published  Originally scheduled for early fall  Latest indications are that rule will not be proposed until after the election in November  EPA has been fairly tight-lipped about what will be proposed in the implementation rule  States are waiting (and getting frustrated)

NSR Implications (2 of 4)  EPA will likely propose that PM 2.5 be regulated like other criteria pollutants  100/250 tpy major source PSD threshold  EPA wrestling with the proposed significant emissions change level  Proposal anticipated to be between 5-15 tpy for PM 2.5 and 40 tpy for precursors (if applicable)  STAPPA\ALAPCO proposal is 10 tpy for the PM 2.5 significant emission rate

NSR Implications (3 of 4)  Control requirements (BACT/LAER) will likely focus on PM 2.5 precursors  Nitrates  Sulfates  VOC  Ammonia

NSR Implications (4 of 4)  EPA anticipates giving states the authority to decide which precursors to regulate  States will also likely have full control in deciding the specific requirements for regulated precursors  RACT/BACT/LAER will be very case-by- case

Condensable Emissions  States require to consider condensable emissions in evaluating PM 10 emissions from a source  Have not always been able to reliably quantify condensable emissions from sources due to variations in the PM 10 test methods and emission factors  Condensable emissions are a significant component of PM 2.5 emissions

PM 2.5 Measurement Issues (1 of 3)  EPA Method 202 is reference method for condensable PM measurement  Accuracy and representativeness problems  Potentially significant positive and negative biases

PM 2.5 Measurement Issues (2 of 3)  Method 202 uses water-filled impingers to cool the sample gas and to collect particulate matter  Exposure of the gas stream to a turbulent mixture of water droplets creates the opportunity for efficient mass-transfer operations and chemical reactions that do not occur during normal plume dispersion

PM 2.5 Measurement Issues (3 of 3)  Sources of potential error  Gas-phase homogeneous reactions between ammonia and HCl or SO 2  Dissolution of SO 2 and NO x into water  Incomplete purging of dissolved SO 2 prior to the analyses for condensed material  Other biases?

Other Biases?  Conversion of SO 2 and NO x occurs in Method 5 or Method 201A (front half of sampling train)  Can create vapor phase sulfuric acid and nitric acid that would not normally be formed in the vapor plume  Collected in Method 202 (back half of sampling train) as condensable PM

Measurement Alternatives?  Corrections for Method 202  Compensate for homogeneous reaction biases related to NH 3 and HCl (EPA Method 202)  Compensate for sulfate formation (SCAMD)  Dilution technique for Condensable PM  Uses a stack dilution sample system  Filtered air and mixing chamber for cooling and condensation  EPA’s replacement to Method 202?  Current being trialed as EPA Conditional Method 039

State PM2.5 Initiatives  NYSDEC – PM 2.5 Policy  Modeling related requirements  NJDEP  Treatment of NSR permits in pending PM 2.5 NA areas as NA NSR permit actions  Lots of Planning Concepts, but general frustration on lack guidance from EPA

What is Pennsylvania (et al) Doing?  Awaiting further guidance (implementation rule) from EPA before moving forward  Final designations will also have a big impact  Anticipating a similar approach for PM 2.5 implementation as for 8-hour ozone implementation  Because of secondary formation of PM 2.5, transport of pollutants will impact attainment with the standards

What is Pennsylvania (et al) Doing? (cont.)  Pushing for greater “regional”approach to addressing PM 2.5 transport issues  Asserts that some of PM 2.5 problem is due to transport from outside the state  Also asserts that PA sources shouldn’t entirely pay the price if the problem is caused by external sources

PM 2.5 Wrap-Up  NA requirements may be coming to an area near you  Be prepared for additional controls and more stringent requirements  Be careful of Method 202 as measurement technique for fine PM  Stay tuned – there are still many questions to be answered in the next few months

Thank you for coming… Questions?

Divya Harrison Trinity Consultants 5320 Spectrum Drive, Suite C Frederick, MD Phone: 240 – 379 – 7490