1. PSD Issues in PM2.5 Transition Proposal
WESTAR 2006 Spring Meeting Las Vegas, NV
John Coefield MDEQ

2. ANPR for PM2.5 PSD Transition
Option 1 Reset Baseline and set new trigger dates.
Option 2 Convert PM10 to PM2.5 and keep baseline dates and current status of increment consumption and expansion.
Common Issues

3. Option 1 New Baseline Dates
Option 2 is too problematic.
PM2.5 and PM(2.5-10) are new pollutants.
EPA is allowed to reset and start over.

4. Option 1 Discussion
EPA is requesting comments on where to set the new increments.
Different impacts for areas depending on increment status.

6. Option 1 Discussion (Cont)
For areas that have seen emission reductions and increment expansion, Option 1 will further restrict development.
For areas that have seen emission growth and where increment consumption is limiting development Option 1 will allow more growth.

7. Option 2: Convert PM10 to new NAAQS
Keep PM baselines already established.
Determine PM2.5 and PM(2.5-10) emissions at time of baseline.
Calculate current status of increments and go forward.
Similar to process when PM10 replaced TSP.
EPA is requesting comments on where to set the new increments.

8. Option 2 Discussion Solves inequality issues. Maintains Status Quo.
Provides continued protection to areas already threatened by development.
Determination of PM2.5 emissions at time of baseline may never be defensible.
Prolonged litigation over technical issues may occur.

9. Issues common to both options
Emission estimation for PM2.5 and PM(10-2,5) can be problematic.
Many factors in AP-42 are ratios of PM10 emissions that were ratios of TSP emissions.
EPA is not supporting new emission factor development or committed to keeping AP-42 up to date.

10. Common issues (cont)
Current guidance for PM2.5 (Seitz Memo-1997) uses PM10 procedures as a surrogate for PM2.5.
With the NAAQS at the proposed 24 hour level or lower, Modeled direct PM2.5 emissions will be a problem by themselves and secondary particle formation from precursors can no longer be ignored. (John C.)

11. Common issues (cont)
Draft guidance on modeling and analysis techniques for PM2.5 was issued in 2001
Subsequent legal actions have made some provisions moot.
Still no final document
This guidance appears to preclude the use of CALPUFF in modeling secondary particle formation.

12. Common issues Summary We can’t measure it. We can’t analyze it.
We still have to demonstrate compliance with the NAAQS to issue a defensible permit or resolve a non-attainment designation.
Still looking for a paddle.