1. 2018 State Implementation Plan For the Annual PM2.5 Standard
Imperial County APCD
2018 State Implementation Plan
For the Annual PM2.5 Standard

2. NAAQS – National Ambient Air Quality Standards
Background
CAA – Clean Air Act
First passed in 1963, updated in 1970 to establish NAAQS
NAAQS – National Ambient Air Quality Standards
Establishes concentration limits for certain pollutants in the ambient air, including particulate matter (24-hour and annual)
PM2.5 Annual NAAQS: 12.0 μg/m3 (3-year avg.)
PM hour NAAQS: 35.0 μg/m3 (3-year avg. of 98th percentile)
Imperial County designated as Moderate nonattainment of the annual PM2.5 NAAQS in 2015 and required to submit a SIP
Primary = provide public health protection
Secondary = provide public welfare protection (against decreased visibility, damage to animals/vegetation/buildings)
Both are annual means averaged over 3 years.

3. Sources of particulate matter in the atmosphere
Background – PM2.5
Sources of particulate matter in the atmosphere
Primary: Emitted directly by agricultural and industrial activities, construction/demolition, windblown dust, etc.
Secondary: Forms from precursor emissions, many of which are combustion byproducts such as NOX, SOX, and VOCs
Human health effects of PM2.5 exposure
Small particle size allows PM2.5 to penetrate deeply into the body, contributing to:
Respiratory effects like asthma, lung disease, and decreased lung function
Cardiovascular complications such as heart attacks and arrhythmia
Conclusion of the slide/transition into next one: Imperial needed to prepare this SIP to address the sources of PM2.5 that can be controlled in order to decrease atmospheric levels to below the NAAQS and reduce PM2.5’s impact on these health issues.

4. Background – Components of the SIP
Moderate Area Requirements:
Comprehensive emission inventories
An attainment demonstration
A reasonably available control measure (RACM) assessment
A reasonably available control technology (RACT) assessment
Demonstration of reasonable further progress (RFP)
Quantitative milestones schedule
Contingency measures
Other clean air act requirements (e.g. Transportation Conformity)

5. Nonattainment Area
Perhaps transition to next slides by mentioning that the Calexico-Ethel station is only a few miles from the border with Mexico and is effectively in the greater metropolitan area of the large city of Mexicali.
Mexico

6. Overview of existing air quality Annual PM2.5 Design Value
Design value definition for PM2.5:
Perhaps remark that the overall trend for the county has been a decrease in PM2.5 but that Calexico has remained above the standard for reasons that will be discussed later.

7. Overview of existing air quality 24-hour PM2.5 Design Value
The situation is similar for the 24-hour design value.
DV definition: the fourth highest daily measurement averaged over three years.

8. Emission Inventory – Example: Baseline (2012)
Source Category
PM2.5 (tons/day)
% Total
NH3 (tons/day)
NOX (tons/day)
SOX (tons/day)
VOC (tons/day)
Stationary Sources
Fuel Combustion
0.13
1.08%
0.00
0.00%
1.52
10.71%
1.74%
0.05
0.44%
Waste Disposal
1.19
5.13%
Cleaning and Surface Coatings
0.41
3.44%
Petroleum Production and Marketing
0.50
4.17%
Industrial Processes
3.37%
0.02
0.15%
0.01%
Total Stationary Sources
0.55
4.45%
1.54
10.85%
0.96
8.06%
Areawide Sources
Solvent Evaporation
12.87
55.37%
3.01
25.35%
Farming Operations
0.91
7.36%
8.68
37.34%
1.48
12.47%
Unpaved Road Dust
4.76
38.73%
Fugitive Windblown Dust
3.69
30.00%
Managed Burning and Disposal
0.82
6.70%
0.54%
0.29
2.05%
18.11%
0.60
5.04%
Other Processes
0.40
3.21%
0.26
1.13%
0.08
0.56%
0.74%
0.04
0.36%
Total Areawide Sources
10.58
86.01%
21.94
94.37%
0.37
2.62%
18.86%
5.14
43.22%
Mobile Sources
On-Road Vehicles
0.19
1.55%
0.11
0.49%
5.31
37.38%
5.85%
1.77
14.86%
Off-Road Vehicles
0.98
7.99%
6.98
49.15%
0.21
73.56%
4.03
33.86%
Total Mobile Sources
1.17
9.54%
0.12
0.50%
12.28
86.53%
0.22
79.40%
5.79
48.71%
Total for Imperial County
12.30
100%
23.24
14.19
0.28
11.89
Don’t need to explain in detail but just an example for the public of what an emission inventory looks like. Can point out that the major sources of direct PM2.5 are shown in blue (will help lead into our slides on the controls analysis)

9. Emission Inventory, Baseline year (2012)

10. Emission Inventory, Attainment year (2021)

11. Emission Inventory – Precursor Demonstration
CARB conducted an analysis to determine the effect that precursors have on ambient PM2.5 levels
The modelling results indicated that none of the four common PM2.5 precursors (NOX, SOX, NH3, and VOCs) significantly contribute to PM2.5 levels in the nonattainment area
Conclusion: Imperial not required to consider precursors in the control measures analysis and other SIP requirements beyond the emission inventory

12. Attainment Demonstration – Section 179(B) (CARB)

13. Control Strategy– Analysis of Current Controls
The CAA requires implementation of all “reasonably available” controls as needed for expeditious attainment of the NAAQS
The District analyzed the current measures controlling each source of PM2.5 in the emission inventory and found that:
All of the top stationary sources were evaluated for RACT requirements
All mobile sources are controlled by RACM
Some area sources such as agricultural burning, windblown dust, and road dust are controlled by RACM, but others like residential wood burning are not
Can explain the difference between RACM and RACT and the role technology plays in controlling stationary sources.
Can potentially explain that part of this analysis was to compare the relevant rules with similar rules in other air districts in order to determine if Imperial’s are as stringent.

14. Control Strategy– Newly Proposed Controls
To control residential wood burning to RACM standards, the District is proposing a rule that would require new residential wood burning devices to comply with NSPS requirements
Additionally, several Additional Reasonable Measures (ARM) have been proposed that involve:
Curtailment of residential wood burning in Calexico when PM2.5 levels are forecasted to be elevated at the Calexico monitor
NOX emission limits for boilers, steam generators, process heaters, and residential water heaters
Management practices to limit NH3 emissions from biosolids, animal manure, and poultry litter composting
Potentially explain that:
NSPS = New Source Performance Standards, a program created by EPA to set limits for certain pollutants based on the type of technology.
ARM = Additional Reasonable Measures which means they satisfy RACM requirements but cannot be implemented within 4 years of designation as nonattainment.
Even though precursors don’t significantly impact PM2.5 levels, these ARM are still anticipated to have a beneficial effect on public health and welfare.

15. Control Strategy– Contingency Measures
In the event that the District fails to meet the requirements of RFP and the quantitative milestones, the following proposed contingency measures will be implemented automatically:
An expansion of the applicability of Rule 804 to control more parcels of open areas in rural parts of the county
A lower threshold of the PM2.5 levels required to trigger curtailment of wood burning
These measures are required to be equivalent to one year’s worth of the emission reductions between the baseline year (2012) and attainment year (2021) assuming consistent annual decreases in emissions.
Details:

16. border strategic concepts
Mexicali/Imperial Air Quality Task Force (AQTF)
Web-based air quality and health information center
Includes mobile air quality alert application
AQI advertisement – billboards and media (TV and radio)
Mexicali and Imperial County Educational Media Campaign
Vehicle idling emissions study (Calexico ports of entry)
Diesel truck inspection program
Mexicali monitoring study
Mexico emission inventory improvements (contract starting soon)
Program to improve air quality in Mexicali by Mexican government

17. Next Steps
Presentation of SIP to Imperial County Board of Supervisors with District recommendation for adoption
RACM/ARM rulemaking process
Presentation of SIP to CARB for adoption
Submittal to USEPA for final review

18. Additional questions can be directed to: ICAPCD
Questions/Comments?
Additional questions can be directed to: ICAPCD
Reyes Romero, Assistant APCO
(442)
Monica Soucier, Division Manager
(442)