ANPR: Transition to New or Revised PM NAAQS

1. ANPR: Transition to New or Revised PM NAAQS WESTAR Business Meeting March 2006

2. 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 PM10-2.5 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

3. 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

4. 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

5. Timeline Comparison for PM standards including proposed 2006 PM2.5 standards

6. Timeline for New PM10-2.5 Standard* *Schedule based on monitor deployment in 2009

7. 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

8. Transition from the PM10 standards to any new PM10-2.5 NAAQS – Proposed in ANPR • Revoking 24-hrPM10 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

9. Transition from the PM10 standards to any new PM10-2.5 NAAQS: NSR Issues • Does PM10 continue to be aregulated NSR pollutant for PSD where 24-hr PM10 isrevoked? • 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

10. 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

11. 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?

12. 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?

13. 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