Download - Air Quality Strategies & Standards Update
Air Quality Strategies & Standards Update
Joseph PaisieAir Quality Strategies & Standards Division,
Office of Air Quality Planning & Standards, EPA
WESTAR Fall Business Meeting, San Diego, CA September 22, 2005
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PM2.5 Implementation Program
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PM2.5 Implementation Schedule
September 8, 2005: Proposed implementation rule signed by Administrator
Summer/Fall 2006: Finalize implementation rule December 2007: Regional haze implementation plans due April 2008: PM2.5 SIPs due
EPA encourages States to coordinate development of regional haze and PM2.5 plans and intends to review these plans together
8-hour Ozone and PM2.5 Nonattainment Areas
Designated NonattainmentPM2.5 only*Both 8-hour Ozone and PM2.5*8-hour Ozone Only
* For PM2.5, the designated partial county areas are shown as actual boundaries designated.
OAQPS,AQSSDApril 28, 2005
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PM2.5 Implementation Rule Issues
Attainment dates Classifications PM2.5 precursors Modeling and attainment demonstration Reasonably available control technology (RACT) Reasonably available control measures (RACM) Reasonable further progress (RFP) New source review
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Attainment Dates State attainment demonstrations and SIP revisions are due
April 2008 Attainment demonstrations need to provide the supporting
analysis for State adoption of measures that will result in the area attaining the standard “as expeditiously as practicable”
Attainment date is no later than five years from date of designation (e.g., April 2010) Extensions of 1-5 years are possible
Attainment determination would be based on most recent 3 calendar years (e.g., 2007-2009 for April 2010 attainment date)
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Classifications
Option 1: No classification system Keeps it simple under subpart 1
Option 2: Moderate & serious classifications Request comment on criteria for two-tier system (examples:
attainment date within 5 years or not; design value threshold)
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Coverage of PM2.5 Precursors
Atmospheric chemistry leading to PM2.5 formation is complex
Proposed approach for PM2.5 implementation and new source review:
PM2.5 direct emissions (includes organic carbon, elemental carbon, and crustal material) and SO2 must be addressed
NOx must be addressed in all areas, unless the State and EPA provide a demonstration finding that NOx is not a significant contributor in a specific area.
VOC and ammonia would not be addressed, unless EPA or the State provides a demonstration that VOC or ammonia is a significant contributor in a particular area.
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Modeling and Attainment Demonstrations All nonattainment areas need to
submit an attainment plan having appropriate modeling according to PM2.5 modeling guidance
One-atmosphere modeling recommended (ozone, PM, haze)
Years to model: coordinate with ozone and regional haze attainment & reasonable progress dates to the extent possible
Mid-course reviews will be required on a case-by-case basis through SIP approval process Check progress in 2010 and
2013; if not on track, conduct new modeling and evaluate new measures
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Reasonably Available Control Technology (RACT)
RACT is the lowest emission limit that a source is capable of meeting with available control technology, considering technological and economic feasibility. Option 1: RACT required for all stationary sources with the potential
to emit (pte) more than 100 tpy of direct PM2.5 or any precursor Also requesting comment on thresholds of 70 and 50 tpy
Option 2: RACT required for stationary sources only to the extent it is needed for expeditious attainment or to meet RFP
Option 3: Option 2 for areas with attainment dates within 5 years Option 1 for areas with attainment dates > 5 years
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Reasonably Available Control Measures (RACM) A RACM demonstration must show that the State has adopted all
reasonable measures needed to attain the standard as expeditiously as practicable and meet RFP The demonstration should show that there are no additional
measures available that would advance the attainment date or contribute to RFP.
In determining RACM for an area, the state must consider the cumulative impact of implementing the available measures and whether such measures taken together would advance the attainment date.
Limited RACM analysis for areas with attainment dates of April 2010 or earlier
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Reasonable Further Progress (RFP)
RFP: annual incremental reductions in emissions for purpose of ensuring timely attainment
Baseline emission inventory year is 2002 RFP plan due with attainment demonstration in 2008
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PM2.5 and New Source Review
NSR applies upon effective date of PM2.5 designations PM2.5 rule includes changes to NSR program OAQPS April 5, 2005 guidance memo addresses interim period from
effective date of designations to date of final rule Key Points
Use PM10 major NSR program as surrogate, using either Appendix S or State’s SIP-approved PM10 program
Major stationary source: potential to emit 100 tpy of PM10 (including condensable emissions)
Offset ratio: 1 to 1 Significant emissions rate for modifications: 15 tpy of PM10 Precursors not included in applicability for PM2.5 major NSR program
at this time Until final NSR rules for PM2.5 are issued, address NOx under NSR
program for ozone or PSD program for NO2 NAAQS, address VOC under NSR if area is also an ozone nonattainment area, and address SO2 under PSD program for the SO2 NAAQS.
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PM2.5 Implementation Rule - Other Issues
Technical overview – chemistry, sources, ambient data
Transportation conformity and general conformity Contingency measures Innovative program mechanisms PM2.5 source test methods / condensibles Improved monitoring techniques to reduce
emissions Emission inventories Tribal issues
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For more information …
PM2.5 designations and the proposed PM2.5 Implementation Rule are available at: www.epa.gov/pmdesignations
Technical information is located at: www.epa.gov/ttn/naaqs/pm/pm25_index.html
Contacts: Rich Damberg, [email protected] Amy Vasu, [email protected] Joe Paisie, [email protected] Raj Rao, [email protected] (NSR issues)
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BART
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Regional Haze/BART Current Timeline
Feb 2005: DC Cir. in CEED vacates “WRAP Annex Rule” due to BART-related provisions Court remanded trading programs for WRAP states
June 15, 2005: Final BART Rule
Sept. 2005: CEED + UARG file “intent to sue”
November 8, 2005: Final BART Trading & WRAP Annex rule
Dec 17, 2007: Regional Haze SIPs due
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3 Steps in Determining BART Is a source BART-eligible?
Major sources >250 tons per year Built between 1962 and 1977 26 source categories, including EGUs & industrial boilers, kraft pulp
mills, and refineries
Is the source reasonably anticipated to cause or contribute to regional haze in any Class I area? If so, the source is subject to BART Determined through modeling of individual source visibility impacts
For sources subject to BART, make a BART determination CAA lays out five factors in determining what controls, if any, should be
applied Factors include cost, visibility impacts, remaining useful life, energy
impacts, non-air-quality environmental impacts
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BART Guidelines Package Overview
How to determine if a source meeting initial CAA criteria is “reasonably anticipated to cause or contribute to haze” – i.e. is subject to BART
How to determine what BART is at a particular source – i.e., how to apply the 5 CAA factors
States have a a fair amount discretion in making BART determinations
Determination that Clean Air Interstate Rule (CAIR) is “better than BART” and thus can substitute for BART for EGUs in the CAIR states
Presumptive limits for EGUs > 200 MW
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WESTAR Conference – August 2005
EPA staff attended and discussed BART requirements Remaining questions:
Technical/modeling issues: Modeling the 98th percentile day Modeling for 750 MW power plants 0.5 deciview threshold, 1.0 deciview threshold– differences and use in
setting permit limits
Trading issues, esp. “What is incentive to do alternative trading program?” Need to estimate what BART controls will be, in order to compare trading
to case-by-case BART Continuing legal challenges to implementing BART rule without individual
source assessment
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For more information:
EPA staff currently working to assemble a Q&A document covering the most common concerns about BART – draft expected fall 2005
EPA contacts: Todd Hawes ([email protected]) Kathy Kaufman ([email protected]) Joe Paisie ([email protected])
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8-Hour Ozone NAAQS Implementation Rule:Phase 2
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Phase 2 Ozone Implementation RuleKey issues addressed
• Attainment Demonstration & Modeling provisions• Reasonable Further Progress (RFP) requirements• Reasonably Available Control Technology (RACT)• New Source Review (NSR)
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Other Issues Covered in Rule/Preamble
Transport (long-range) Reformulated Gasoline Contingency Measures RACM Applicability to Ozone Transport Region (OTR) Clean Air Development Communities Optimal mix of controls – PM2.5 & O3 Emission Inventory Ambient Monitoring Timing after redesignations (attainment to nonattainment) Relevance to tribal areas CMAQ funding discussion Relationship of 8-hr O3 SIP and Title V Permit Program Will need an Information Collection Request (ICR)
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Timing of Phase 2 Rule
Rule currently under review by OMB Administrator’s signature expected fall 2005 Publication in Federal Register expected 2-3 weeks
after signature
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2005 Air Innovations Conference 349 attendees
33 States, 49 local agencies, and 11 tribes represented 9 sessions with 75 presentations and 23 exhibitors
“Financing Innovative Programs” and “On the Horizon” most popular
Announced new guidance on SIP credit for bundled measures Supports States’ use of voluntary and emerging measures
Air Innovations Website: http://www.epa.gov/ttn/airinnovations Breakout sessions suggested increased emphasis on:
Future policy and guidance to support innovative measures Multi-pollutant control strategy development Promoting co-benefits of innovative measures Providing incentives for voluntary programs
Planning for next year’s conference has begun
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Air Strategy Assessment Program (ASAP)
PC-based screening tool that allows users to: Identify and compare the cost-effectiveness of alternative multi-
pollutant emissions control strategies Assess air quality and health impacts of emissions reductions
from particular source sectors Compare costs and benefits across control strategies
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ASAP (continued)
ASAP is an integrated tool that links 3 analytical components: AirControlNET – existing tool that evaluates multi-pollutant control
strategies (emissions reductions and costs) Response Surface Model – new tool for predicting the air quality
impacts of emissions reductions BenMAP – existing model that calculates health benefits
associated with air quality improvements
ASAP is used via a user-friendly graphical interface with a report generator to review, interpret, and share outputs.
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ASAP Development Schedule
Current work Develop demo version of ASAP for conducting O3
assessments for Eastern US (to be released for beta testing late 2005)
Near-Future Work Develop PM version of ASAP for national assessments as
part of PM NAAQS Review proposal RIA (Dec 2005) Develop multi-pollutant version for Final PM NAAQS Review
RIA (Fall 2006) Future Work and Applications (2006 & beyond)
Provides template for others to develop targeted regional and/or local assessment capabilities