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PSD Issues in PM2.5 Transition Proposal

PSD Issues in PM2.5 Transition Proposal. WESTAR 2006 Spring Meeting Las Vegas, NV John Coefield MDEQ. ANPR for PM2.5 PSD Transition. Option 1 Reset Baseline and set new trigger dates.

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PSD Issues in PM2.5 Transition Proposal

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  1. PSD Issues in PM2.5 Transition Proposal WESTAR 2006 Spring Meeting Las Vegas, NV John Coefield MDEQ

  2. ANPR for PM2.5 PSD Transition • Option 1 Reset Baseline and set new trigger dates. • Option 2 Convert PM10 to PM2.5 and keep baseline dates and current status of increment consumption and expansion. • Common Issues

  3. Option 1 New Baseline Dates • Option 2 is too problematic. • PM2.5 and PM(2.5-10) are new pollutants. • EPA is allowed to reset and start over.

  4. Option 1 Discussion • EPA is requesting comments on where to set the new increments. • Different impacts for areas depending on increment status.

  5. Option 1 Discussion (Cont) • For areas that have seen emission reductions and increment expansion, Option 1 will further restrict development. • For areas that have seen emission growth and where increment consumption is limiting development Option 1 will allow more growth.

  6. Option 2: Convert PM10 to new NAAQS • Keep PM baselines already established. • Determine PM2.5 and PM(2.5-10) emissions at time of baseline. • Calculate current status of increments and go forward. • Similar to process when PM10 replaced TSP. • EPA is requesting comments on where to set the new increments.

  7. Option 2 Discussion • Solves inequality issues. • Maintains Status Quo. • Provides continued protection to areas already threatened by development. • Determination of PM2.5 emissions at time of baseline may never be defensible. • Prolonged litigation over technical issues may occur.

  8. Issues common to both options • Emission estimation for PM2.5 and PM(10-2,5) can be problematic. • Many factors in AP-42 are ratios of PM10 emissions that were ratios of TSP emissions. • EPA is not supporting new emission factor development or committed to keeping AP-42 up to date.

  9. Common issues (cont) • Current guidance for PM2.5 (Seitz Memo-1997) uses PM10 procedures as a surrogate for PM2.5. • With the NAAQS at the proposed 24 hour level or lower, Modeled direct PM2.5 emissions will be a problem by themselves and secondary particle formation from precursors can no longer be ignored. (John C.)

  10. Common issues (cont) • Draft guidance on modeling and analysis techniques for PM2.5 was issued in 2001 • Subsequent legal actions have made some provisions moot. • Still no final document • This guidance appears to preclude the use of CALPUFF in modeling secondary particle formation.

  11. Common issues Summary • We can’t measure it. • We can’t analyze it. • We still have to demonstrate compliance with the NAAQS to issue a defensible permit or resolve a non-attainment designation. • Still looking for a paddle.

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