PM2.5 NAAQS

October 26, 2004ARIPPA

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Presented by:Divya HarrisonTrinity Consultants(240) 379-7490dharriso@trinityconsultants.com

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PM2.5 NAAQS

What is PM2.5?

“Fine” particulate matter Aerodynamic diameter less than 2.5

µm For perspective, a human hair is

about 70 µm in diameter

PM2.5 Perspective

Human Hair (70 microns)

PM10

PM30 (TSP)

PM2.5

What Are The Sources of PM2.5?

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

SulfatesNitrates

Ammonium

What Are The Sources of PM2.5? (cont.)

* Source: EPA

Why Are We Worried About PM2.5?

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 PM2.5 in July 1997 (effective September 16, 1997) 15 µg/m3 annual average (3-year average

of annual mean, averaged spatially) 65 µg/m3 24-hour average (3-year

average of 98th 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

PM2.5 NAAQS Implementation

After much litigation following promulgation of the PM2.5 NAAQS, EPA is free to implement the standards

States began monitoring PM2.5 levels and speciation shortly after NAAQS promulgation Monitoring data from 1998-2002 is

being used to identify nonattainment areas and strategies

Overall Implementation Timeline (1 of 3)

1998-2002 – 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 PM2.5 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 PM2.5 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 PM2.5 and 40 tpy for precursors (if applicable) STAPPA\ALAPCO proposal is 10 tpy for the PM2.5

significant emission rate

NSR Implications (3 of 4)

Control requirements (BACT/LAER) will likely focus on PM2.5 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 PM10 emissions from a source

Have not always been able to reliably quantify condensable emissions from sources due to variations in the PM10 test methods and emission factors

Condensable emissions are a significant component of PM2.5 emissions

PM2.5 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

PM2.5 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

PM2.5 Measurement Issues (3 of 3)

Sources of potential error Gas-phase homogeneous reactions

between ammonia and HCl or SO2

Dissolution of SO2 and NOx into water Incomplete purging of dissolved SO2

prior to the analyses for condensed material

Other biases?

Other Biases?

Conversion of SO2 and NOx 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 NH3 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 – PM2.5 Policy Modeling related requirements

NJDEP Treatment of NSR permits in pending PM2.5

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 PM2.5 implementation as for 8-hour ozone implementation Because of secondary formation of PM2.5 ,

transport of pollutants will impact attainment with the standards

What is Pennsylvania (et al) Doing? (cont.)

Pushing for greater “regional”approach to addressing PM2.5 transport issues Asserts that some of PM2.5 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

PM2.5 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 HarrisonDivya Harrison(dharriso@trinityconsultants.com)(dharriso@trinityconsultants.com)Trinity ConsultantsTrinity Consultants5320 Spectrum Drive, Suite C5320 Spectrum Drive, Suite CFrederick, MD 21703Frederick, MD 21703Phone: 240 – 379 – 7490Phone: 240 – 379 – 7490