Transcript ANPR: Transition to New or Revised PM NAAQS

ANPR: Transition to New or
Revised PM NAAQS
WESTAR Business Meeting
March 2006
What issues are discussed in the ANPR?
• Proposed options for transitioning from 1997
PM2.5 NAAQS to any new 2006 PM2.5 NAAQS
• Timelines for implementation of any new 2006
PM2.5 NAAQS
• Timelines for implementation of any new PM102.5 NAAQS
• Transition from the PM10 standards to any new
PM10-2.5 NAAQS
• What emission inventory requirements should
apply to PM2.5 and PM10-2.5 NAAQS
• Next steps
Transition from 1997 to 2006 PM2.5 NAAQS
• Option 1:
– Proposed change to annual PM2.5 standard is
minimal
• Not significant enough to require new designations
– Propose to not revoke the annual PM2.5
standard
– Propose to revoke the 1997 24-hr PM2.5
standard one year after designations under
any new 24-hr PM2.5 standard
– SIPs for annual PM2.5 standard would stay in
place until areas redesignated attainment
Transition from 1997 to 2006 PM2.5 NAAQS
• Option 2:
– Revoke annual and 24-hr PM2.5 standard 1
year after designations under any new PM2.5
standards
– Develop and implement “anti-backsliding” rule
• Which planning control requirements remain?
• NSR program
• Conformity programs
Timeline Comparison for PM standards including
proposed 2006 PM2.5 standards
Milestone
1997 PM2.5 Primary
NAAQS
CAIR
2006 PM2.5 Primary NAAQS
Effective date of
Standard
July 1997
March 2005
December 2006
Monitoring Data Used
for State
Recommendations
2001-2003
2004-2006
State
Recommendations to
EPA
Feb. 2004
December 2007
Final Designations
Signature
Dec. 2004
December 2009
Effective Date of
Designations
April 2005
April 2010
SIPs Due
April 2008
Sept. 2006
April 2013
Attainment Date
April 2010 (based
on 2007-2009 data)
Jan. 2009 (Phase I NOx)
Jan. 2010 (Phase I SOx)
Jan. 2015 (Phase 2 - NOx and
SOx)
April 2015 (based on 2012-2104
data)
Attainment Date with
Extension
Up to April 2015
April 2020
Timeline for New PM10-2.5 Standard*
Milestone
2006 PM10-2.5 NAAQS
Effective date of Standard
December 2006
Monitoring Data Used for State
Recommendations
2009-2011
State Recommendations to EPA
July 2012
Final Designations Signature
May 2013
Effective Date of Designations
July 2013
SIPs Due
July 2016
Attainment Date
Up to July 2018 (based on 2015-2017
data)
Attainment Date with Extension
Up to July 2023
*Schedule based on monitor deployment in 2009
Transition from the PM10 standards to any
new PM10-2.5 NAAQS – Proposed in PM
NAAQS
• Proposal for revoking PM10 Standards upon
promulgation of 2006 PM10-2.5 NAAQS:
– Revoke annual PM10 standard everywhere
– Revoke 24-hr PM10 standard everywhere except
• Where violating monitor and urbanized area with population
greater than 100K
• Taking comment on retaining 24-hr PM10
standard in non-urbanized areas with ambient
mix of PM from traffic, industrial and construction
sources and one violating monitor
Transition from the PM10 standards to any
new PM10-2.5 NAAQS – Proposed in ANPR
• Revoking 24-hr PM10 standard one year after
designations under PM10-2.5 standards
• Anti-backsliding rule would be needed:
– Control Measures – to be retained based on PM10
classification – moderate or serious
– Maintenance for areas that come into attainment w/
PM10 prior to revocation?
– Transportation conformity – to be addressed in
separate rulemaking
– General conformity – to be addressed in separate
rulemaking
– New Source Review – following slides
Transition from the PM10 standards to any new
PM10-2.5 NAAQS: NSR Issues
• Does PM10 continue to be a regulated NSR pollutant for
PSD where 24-hr PM10 is revoked?
– Option 1: PM10 continues to be regulated NSR pollutant since
retained in some areas; PSD continues to apply – but only BACT
since non-criteria pollutant
– Option 2: interpret definition to be area-specific, so PM10 no
longer regulated NSR pollutant and none of the PSD
requirements would apply
• Does the CAA require continued obligation for some
form of PM increment?
– Option 1: Conclude § 166(f) and § 163 requirements no longer
applicable and develop new increments for PM2.5 and PM10-2.5
establishing new baseline and trigger dates
– Option 2: Substitute PM10 increments with two new increments
PM2.5 and PM10-2.5 – retain existing baseline and dates
Transition from the PM10 standards to any new PM10-2.5
NAAQS: NSR Issues cont’d
• How should permitting authorities implement the PM2.5 program
upon revocation of PM10?
– Option 1: Continue to use PM10 as surrogate – but compare PM10
emissions concentrations with the PM2.5 NAAQS - conservative
– Option 2: Continue to apply existing surrogate policy for implementing
the PM2.5 program – compare PM10 emissions with former PM10 NAAQS
• How to implement PSD program for PM10-2.5 upon the effective date
of promulgation for PM10-2.5?
– Option 1: Use PM10 as a surrogate – compare PM10 emissions
concentrations with the PM10-2.5 NAAQS - conservative
– Option 2: Compare PM10 analysis to former PM10 NAAQS and use
compliance with this as surrogate for compliance with new PM10-2.5
NAAQS for a temporary period
– Option 3: Use compliance with BACT for PM10-2.5 as a surrogate for the
PM10-2.5 compliance demonstration
PM10-2.5 NAAQS : NSR Issue
• How should ambient PM10-2.5 dominated by rural
windblown dust and soils, and generated by agricultural
and mining sources be treated in the NSR program for
the proposed PM10-2.5 standard?
– Definition of proposed PM10-2.5 standard suggests that NSR
applicability test would exclude these sources from
consideration. How do we implement the NSR program if a
NAAQS with these characteristics is promulgated?
Applicable emission inventory requirements
for PM2.5 and PM10-2.5 NAAQS
• EPA’s emission inventory program is specified in the
Consolidated Emissions Reporting Rule, the Air
Emissions Reporting Requirements, and guidance
– Are the data elements specified in the CERR and AERR
sufficient to develop adequate SIPS for PM2.5 and PM10-2.5?
– Fugitive emissions are significant contributors to PM10-2.5
• Should EPA require/develop more precise methods for estimating
these emissions
– Should EPA require any additional emission inventory data
elements or temporal allocation techniques to estimate more
accurately daily emissions and their variability?
– Other inventory issues which need to be defined?
Next Steps
• ANPR published in FR on Feb 9 (71 FR 6718)
w/ 60 day comment period ending April 10, 2006
• Evaluate comments and develop proposal
sometime after NAAQS are finalized in
September 2006