PM2.5 NAAQS
October 26, 2004ARIPPA
trinityconsultants.com
Presented by:Divya HarrisonTrinity Consultants(240) [email protected]
About Trinity Founded in 1974 Core Focus in Air Quality Compliance,
Permitting, Modeling & Expertise in other areas 1,200 projects per year 18 offices, 200 staff ISO 9001:2000 certified Diverse client base, mostly industrial:
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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([email protected])([email protected])Trinity ConsultantsTrinity Consultants5320 Spectrum Drive, Suite C5320 Spectrum Drive, Suite CFrederick, MD 21703Frederick, MD 21703Phone: 240 – 379 – 7490Phone: 240 – 379 – 7490
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