Update on the PM2.5 Designations Process and the PM2.5 Implementation Rule Joseph Paisie WESTAR April 8, 2004

2 Purpose Give an update on the PM2.5 designations process Provide a detailed overview of the draft PM2.5 implementation rule

PM2.5 Schedule DateAction Feb. 2004*State designation recommendations due to EPA April 2004Implementation rule to OMB July 2004EPA proposes implementation rule July-Aug 2004 EPA letters to States responding to PM2.5 designation recommendations Dec. 2004*EPA finalizes designations Late Early 2005 EPA finalizes implementation rule * 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.

4 State Recommendations for PM2.5 Designations Recommendations have been received from most States. Expect updates ( data) Additional supporting information is needed for a number of areas.

5 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 – To go live soon

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8 Overview of PM2.5 Implementation Rule Overall approach Attainment dates Classifications PM2.5 precursors RACT RACM RFP Other issues

9 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

10 Attainment Dates State attainment demonstrations and SIP revisions are due within 3 years of designations Assuming designations are finalized in Dec and are effective 60 days later, attainment demonstrations and SIPs would be due in Feb 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 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 ).

11 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”

12 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 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

13 Classifications 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 data, very few counties are not in or adjacent to an MSA  Seeking comment on whether a transport classification is needed

14 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

FOR REFERENCE PURPOSES

16 VOC 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

17 NOx 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

18 Ammonia 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 Precursor Transportation Conformity Proposal*NSR for PM2.5 Draft* PM2.5 Draft Implementation Rule VOC Options: 1) address all VOC; 2) presume that VOC do not need to be addressed, but can be included based on State/EPA finding. Options: 1) address all VOC; 2) presume that VOC do not need to be addressed, but can be included based on State/EPA finding; 3) address only certain VOC NOx Options: 1) include NOx; 2) presume that NOx does not need to be addressed, but can be included based on State/EPA finding. SOx Not required to be addressed due to small % of total emissions, but can be included based on State/EPA finding Included Ammonia Case by case: Not required to be addressed, but can be included based on State/EPA finding ** Applies to interim period. After SIP approval, these programs will address the pollutants addressed in the SIP.

20 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

21 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.

22 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.

23 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.

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

25 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

26 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 or beyond), a second RFP plan is due at the time of SIP submittal (e.g. Feb. 2008)

RFP Plan Design Value Wtd. Avg. Emission Reduction Rate No. of Areas % % % % %4 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

28 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 time period, to be met by December 31, 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 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.

29 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

30 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

31 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