PM2.5 Implementation Rule RACT/RACM

1. PM2.5 Implementation RuleRACT/RACM Tim Smith, EPA/OAQPS Presentation to Chicago PM2.5 Workshop June 20, 2007

2. Overview • Will discuss • Overall approach to RACM/RACT in the final PM2.5 implementation rule • Steps in RACM/RACT process • Take your questions

3. RACT and RACM • For PM2.5 nonattainment areas: 51.1010 in FR based on 172(c)(1) of the CAA • (a) SIP must include demonstration that State “has adopted all RACM (including RACT) necessary to demonstrate attainment as expeditiously as practicable and to meet any RFP requirements.” SIP shall include list of measures considered and information sufficient to support that has adopted all RACM, including RACT. • (b) In determining RACM, cumulative analysis. Must adopt technically and economically feasible measures if collectively would advance attainment date by 1 year

4. Approach to RACM and RACT in final rule (preamble II.F.2) • For PM2.5 (unlike O3) RACT is part of RACM (not an independent requirement) • Greater flexibility to tailor solutions to unique problems of given nonattainment area • Responsibility to conduct analysis to show that all RACT and RACM have been adopted • (As discussed with flowcharts earlier, needed documentation will vary, depending on attainment date, likely more streamlined for pre-2009 measures)

5. Steps to RACM and RACT in final rule • Identify technically and economically feasible measures and associated emissions reductions • Conduct air quality modeling and related analysis • Select RACT/RACM

6. Technical Feasibility (preamble II.F.4) • Is there a measure that works (in reducing emissions of PM2.5 and/or precursors)? • Consider factors such as: • Process and operating conditions • Raw materials • Physical Plant layout • Non-air quality and energy impacts • (Time needed to install and operate controls)

7. Economic Feasibility (preamble II.F.5) • Is the cost of the potential measure reasonable for the regulated entity to bear? • Consider costs, $/ton, economic effects on plant and local economy • $/ton for previous measures is an indicator of reasonableness but ability to absorb may differ across categories • For some (particularly mobile source) measures, feasibility depends on availability of public funding and resources

8. Economic feasibility (cont) • No fixed $/ton for reasonableness • Reasonable $/ton likely higher for direct PM2.5, because very likely to have higher ug/ton • References for cost include EPA cost manual, others

9. Economic Feasibility (cont) • If source contends can’t afford technology that appears to be RACT/RACM for others, thorough economic support needed • If severe impacts on local economy (shutdown, severe curtailment) need economic analysis to support

10. Measures to Consider (Preamble II.F.6) • Preamble includes examples of measures that States should consider as a starting point for RACT/RACM assessment • We’ll discuss candidate control measures in more detail tomorrow • Need to address measures identified in public comments • EPA wants to promote information sharing, particularly among States with similar air quality and source characteristics

11. Identifying measures – additional points • No tonnage threshold for RACT • Screening assessments likely can inform choice of sources/measures to evaluate • Areas with more severe problem likely will need to evaluate smaller sources • Need to evaluate sources throughout the nonattainment area for available controls • Guiding principle for analysis: show that selected RACT/RACM does not exclude any group of reasonable controls (including controls on smaller sources) that together could advance the attainment date

12. Consideration of intrastate sources outside the nonattainment area • In defining attainment date “as expeditiously as practicable” take into account intrastate sources as well as RACT/RACM • (Preamble pages 20600 and 20601; attainment date discussion on 20613) • SIPs must address this issue • Basic question: could transport from reasonably controllable intrastate sources contribute to advancement of the attainment date?

13. Air Quality and Related Analyses • (covered by Rich and more detail upcoming by Brian)

14. Selection of RACT and RACM • End point of analysis: • Decisions on RACM, RACT, intrastate measures and the “expeditiously as practicable” attainment date • Must include reasonable, technically and economically feasible measures if necessary for attainment as expeditiously as practicable • May exclude measures if collectively would not advance attainment date

15. CAIR vs RACT (Preamble II.F.7) • SO2 presumption • in States fulfilling CAIR reduction entirely through EGU reductions: • compliance by EGUs with approved CAIR SIP or FIP would satisfy RACT • States may rely on this presumption without further analysis • Must respond to any public comments • A State may impose additional requirements on a specific plant if State determines it is reasonable means to attain expeditiously • However, several factors should be considered re: potential disbenefits of beyond-CAIR controls • Addressed case-by-case through SIP development process

16. CAIR vs RACT (cont) • NOx presumption: • In States subject to annual CAIR reduction entirely through EGU reductions • Compliance by EGUs with approve CAIR SIP or FIP would satisfy RACT provided that source with existing SCR operate year-round • Year round-SCR • For “existing SCR” (in place by November 1, 2005) • Year round operation must be required by SIP

17. CAIR vs RACT (cont) • No presumption for direct PM2.5 emissions

18. Deadlines for submission and implementation of RACT/RACM (II.F.8) • Submission: • With SIP in April 2008 • Implementation: • No later than beginning of year before the attainment date • Provisions for demonstration that more time is needed for implementation consistent with expeditious schedule

19. Pollutants for RACT/RACM (II.F.9) • Direct PM.25 • SO2 • Other pollutants considered precursors consistent with earlier discussion • NOx: presumptively in • VOC, Ammonia: presumptively out

20. RACT for Sources subject to previous RACT/BACT/LAER/MACT (II.F.10) • State must assure that RACT is met, either through: • New RACT determinations OR • Certification that previously required RACT controls represent RACT • New RACT required if: • previously concluded RACT = no control • previous determination didn’t address the pollutant

21. Previous determinations (cont) • BACT/LAER (and MSW under 111d, etc) • Not automatically RACT • Must present reasoning why represents RACT • MACT: • Further VOC controls unlikely and expect streamlined determination • PM2.5. Not automatic. Issues: fine fraction, emissions capture • NOx: Should consider year-round if not required by previous determination

22. Questions • ???????????????