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STAPPA State and Territorial Air Pollution Program Administrators ALAPCO Association of Local Air Pollution Control Ofcials March 2006 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options STAPPA State and Territorial Air Pollution Program Administrators ALAPCO Association of Local Air Pollution Control Offi cials March 2006 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options Acknowledgements i Acknowledgements On behalf of the State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Offi cials (ALAPCO), we are pleased to provide Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options. Our associations developed this document to assist states and localities in determining the most effective ways to control emissions of fi ne particles (PM 2.5 ) and PM 2.5 precursors from sources in their areas. We hope that states and localities fi nd this document useful as they prepare their State Implementation Plans (SIPs) for attaining or maintaining the PM 2.5 standard. STAPPA and ALAPCO express gratitude to M.J Bradley & Associates, Inc. for its assistance in drafting this document, in particular, Ann Berwick, Michael Bradley, Tom Curry, Will Durbin, Dana Lowell and Chris Van Atten. We thank Brock Nicholson (North Carolina) and Lynne Liddington (Knox County, Tennessee), co-chairs of the associations’ Criteria Pollutants Committee, under whose guidance this document was prepared. We also appreciate the efforts of the STAPPA and ALAPCO PM 2.5 Menu of Options Review Workgroup, who helped shape the options presented in this document. We thank Bill Becker, Executive Director of STAPPA and ALAPCO, and Amy Royden-Bloom, Senior Staff Associate of STAPPA and ALAPCO, who oversaw the project. Finally, we express our gratitude to EPA for providing the funding for this project. Once again, we believe that Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options will serve as a useful and important resource for states and localities as they develop approaches to regulate emissions of PM 2.5 and PM 2.5 precursors and thank all who contributed to its development. Eddie Terrill John Paul STAPPA President ALAPCO President Contents iii Contents Introduction 1 Chapter 1. The Highlights 5 Chapter 2. Effects of Particulate Matter on Human Health and the Environment 16 Chapter 3. Fine Particulate Matter and Precursor Emissions 22 Chapter 4. The Clean Air Act 32 Chapter 5. Boiler Technologies 42 Chapter 6. Industrial and Commercial Boilers 60 Chapter 7. Electric Generating Units 86 Chapter 8. Pulp and Paper 108 Chapter 9. Cement Manufacturing 120 Chapter 10. Iron and Steel 136 Chapter 11. Petroleum Refi neries 158 iv Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options Chapter 12. Diesel Engine Technologies 172 Chapter 13. Diesel Trucks and Buses 188 Chapter 14. Nonroad Equipment 202 Chapter 15. Light-Duty Cars and Trucks 216 Chapter 16. Airports 228 Chapter 17. Marine Ports 238 Chapter 18. Residential Fuel Combustion and Electricity Use 252 Chapter 19. Commercial Cooking 266 Chapter 20. Fugitive Dust 274 About STAPPA and ALAPCO v The State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Offi cials (ALAPCO) are the two national associations of air quality offi cials in the states, territories and major metropolitan areas throughout the country. The members of STAPPA and ALAPCO have primary responsibility for implementing our nation’s air pollution control laws and regulations. The associations serve to encourage the exchange of information and experience among air pollution control offi cials; enhance communication and cooperation among federal, state About STAPPA and ALAPCO and local regulatory agencies; and facilitate air pollution control activities that will result in clean, healthful air across the country. STAPPA and ALAPCO share joint headquarters in Washington, DC. For further information, contact STAPPA and ALAPCO at 444 North Capitol Street, NW, Suite 307, Washington, DC 20001 (telephone: 202-624-7864; fax: 202-624-7863; email 4cleanair@4cleanair.org) or visit our associations’ web site at www.4cleanair.org. Introduction 1 The State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Offi cials (ALAPCO) have prepared Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options (PM 2.5 Menu of Options) to assist state and local air pollution control offi cials in evaluating the options for reducing fi ne particulate matter (PM 2.5 ) and PM 2.5 -precursor emissions. Areas throughout the eastern U.S. and California (and one area in Montana) currently exceed EPA’s National Ambient Air Quality Standards (NAAQS) for PM 2.5 , and states must submit State Implementation Plans (SIPs) by April 2008 detailing their plans for achieving the national standards. Meanwhile, the PM 2.5 NAAQS are once again undergoing the periodic review that §109(d)(1) of the Clean Air Act requires take place at fi ve-year intervals. Under the terms of a consent decree, EPA is to issue fi nal standards by September 27, 2006. The Agency proposed new standards on January 17, 2006. EPA estimates that meeting the current PM 2.5 standards would avoid tens of thousands of premature deaths annually and save hundreds of thousands of people from signifi cant respiratory and cardiovascular disease. The Agency further estimates that the monetized health benefi ts of improvements in PM 2.5 air quality exceed the costs by a substantial margin. PM 2.5 is a complex pollutant with many sources Introduction contributing to the ambient air quality problem. As a result, this PM 2.5 Menu of Options addresses a broad array of emission source categories, ranging from household furnaces to petroleum refi neries. The challenge confronting air quality offi cials is tremendous, as evidenced by the sheer number of options that we identify for improving air quality. But therein lie the opportunities, as well. Like STAPPA’s and ALAPCO’s previous document— Controlling Particulate Matter Under the Clean Air Act: A Menu of Options—this document compiles and analyzes secondary information. It is intended to serve as a general reference for a national audience, and it will in no way substitute for a thorough analysis by state and local agencies of local emissions sources and conditions, using appropriate guidance from EPA and other available information. What To Regulate The national focus of this report should not obscure an absolutely central point: local choices about the sources and pollutants to control will need to be informed by highly local considerations. A particular source category may account for a small share of national PM 2.5 emissions, but it may nonetheless dominate the local inventory. The chemistry and physics of PM 2.5 formation in the atmosphere is incompletely understood. Some PM 2.5 is 2 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options released directly to the atmosphere, and some forms from emissions of sulfur dioxide (SO 2 ) and nitrogen oxides (NO x ) (which are currently viewed as the most signifi cant precursors and are the only ones addressed in this report). Ammonia and volatile organic compounds (VOCs), which are not included in this report, can also contribute to ambient PM 2.5 . Direct PM 2.5 emissions may be largely responsible for one area’s nonattainment, while SO 2 emissions may cause the problem elsewhere. The choice of whether to focus on reducing direct PM 2.5 , SO 2 or NO x —or all of them, or ammonia or VOCs—will depend on local source contributions and atmospheric chemistry. There are further challenges for SIP writers. In a perfect world, control-effi ciency and cost-effectiveness data would be at hand; however, it is not consistently available. Of course, even when information of this sort can be found, it may not be applicable to all sources. And another source of uncertainty complicates the job. As we discuss in Chapter 3, Fine Particulate Matter and Precursor Emissions, there are important distinctions between fi lterable and condensable PM 2.5 . Further, some methods used to measure PM emissions refl ect only the fi lterable components and, to exacerbate the problem, the fi lterable components vary depending on the test method used. Although we discuss this issue in Chapter 3 in the context of the national PM 2.5 inventory, the distinction between fi lterables and condensables also raises regulatory and permitting issues. The Authority to Regulate Having decided what sources and pollutants need to be controlled in order to address PM 2.5 nonattainment, regulators must then ascertain their authority to do so. The Clean Air Act divides responsibility for various types of air pollution sources and air pollutants between the states and localities on the one hand and the federal government on the other. Generally, state and local regulators share responsibility with EPA for regulating so-called “criteria” pollutants from stationary and area sources (see Chapter 4, The Clean Air Act), with states and localities assigned the lead role in addressing emissions from these source categories. States and localities are free under federal law to adopt more stringent standards for stationary and area sources than the Clean Air Act requires. However, some states may be limited by state law or policy in whether they can enact requirements that are more stringent than federal standards. Here, we outline the possible approaches to tightening federal standards that states and localities may consider, and to developing standards where no federal programs exist. For states that have no latitude or little latitude beyond what the Clean Air Act prescribes, the priority will be to ensure strict compliance with the limits that the Act and federal regulations impose on particulates and precursor pollutants. In these states, the precise language of the statutory limitation will inform the degree of regulatory latitude. For example, regulators in at least some of these states may not be able to set more stringent standards for those sources that federal law or regulations actually address, but in some of these states regulators may see their way clear to setting standards for smaller sources than those covered by federal requirements. Moreover, there are no actual federal Reasonably Available Control Technology (RACT) standards—EPA issues only guidelines (and although the RACT standards are intended to refl ect real-time advancements in technology, many of the guidelines are seriously outdated). Since the guidelines do not set actual limits, even state prohibitions against enacting more stringent state standards may be inapplicable. States and localities that are not limited to the requirements promulgated under federal law will want to look to the most stringent standards that regulators in other jurisdictions have imposed; we have identifi ed these throughout this Menu of Options. State and local authority to impose such limits derives from the federal requirement to attain the NAAQS. The options for imposing more stringent requirements than current federal regulations include the following: Under the state or local version of federal regulatory air pollution programs, or through permit determinations, adopt the most stringent standards that appear to be feasible, even if they are more stringent than federal rules impose; or apply the federal or stricter standards to sources that are smaller than those covered by the federal requirements. Craft state or local regulatory programs or permits that impose on sources the most stringent standards that appear to be feasible. For example, this might include the imposition of Best Available Control Tech nolog y (BACT)-level st anda rd s on existi ng sources, even in the absence of a modifi cation that would trigger New Source Review (NSR). Through regulations or permits, set limits on sulfur levels in coal and oil for sources that burn these fuels. For sources that are permitted to burn more than one type of fuel, impose permit conditions that strictly limit the extent to which they may burn the more polluting fuel. Consider the imposition of regulatory standards that can be met by most, but not necessarily all, sources to which the standard is applicable, with an opportunity • • • • • Introduction 3 for sources to demonstrate that the standards are technically infeasible in light of particular circumstances. Adopt a state-level cap-and-trade program or participate in a regional trading program for a particular source category or group of source categories. The discussion above applies to stationary and area sources, but not to mobile sources, as to which all states other than California have less leeway to impose their own standards. For new vehicles, states are limited to federal standards or to the more stringent standards that California has adopted. For existing onroad vehicles, all states can impose their own standards; although for existing nonroad vehicles, they once again have only the choice of federal or California standards. However, by no stretch of the imagination does this mean that states should overlook the possibilities for mobile source strategies as a way of tackling PM 2.5 nonattainment. As we discuss in the chapters that follow, states have a range of opportunities for addressing these sources. Energy Effi ciency The rising cost of fossil fuels has focused the nation’s attention on the opportunities for reducing fuel consumption, including energy effi ciency measures, some of which are addressed in this report. For example, Chapter 18, Residential Fuel Combustion and Electricity Use, discusses several demand-side effi ciency measures. However, other source categories surely present opportunities for increased effi ciency that regulators should not overlook. On the supply side, energy effi ciency measures involve increasing the effi ciency of the fuel combustion process or of the way the fuel is utilized. At a conventional power plant, two-thirds of the potential energy in the fuel burned to produce electricity is inevitably lost to waste heat. Meanwhile, facilities burn additional fuel to satisfy their thermal needs (for hot water, space heating and the like). Combined heat and power (CHP or cogeneration) facilities located at or near a facility address this problem by recovering the waste heat and putting it to productive use. CHP systems can achieve overall effi ciencies of greater than 80 percent (Elliott, 1999; EPA, 2000). In the late 1990s, 9 percent of this country’s electricity came from cogeneration plants, although a number of other countries garnered a much higher percentage: Denmark (40 percent), Finland and the Netherlands (30 percent each), the Czech Republic (18 percent), and Germany (15 percent) (Elliott, 1999). A number of the industry sectors we profi le in this • report are candidates for cogeneration. The petroleum refi ning and pulp and paper industries already employ cogeneration to some degree, but the practice has room to grow further in those industries and others, such as cement manufacturing and iron and steel production (Elliott, 1999). There are unquestionably disincentives to the development of CHP in this country (e.g., high prices for excess power that CHP projects sell to the grid, long tax depreciation periods for CHP equipment), although increasing fuel prices make cogeneration more attractive. Environmental regulators can reverse some of the disincentives; for example, by writing air pollution permits on an electricity (and, where appropriate, thermal) output rather than on a heat input basis, to encourage effi ciency in the use of fuel. This Report As indicated, this report addresses a broad range of source categories. These sources do not represent the entire inventory of PM 2.5 , SO 2 and NO x emissions, although they do cover a large share of the national inventory. Each source category chapter provides an overview of the category, background on the technical as opposed to the policy options for reducing emissions, and an overview of existing regulatory authority (with the regulatory authority issues discussed up-front in the mobile source chapters because of the preeminence of preemption considerations). Each chapter concludes with a discussion of state and local policy measures. Additionally, the report has two separate technology chapters—one on boiler and another on diesel engine technologies. The boiler technology chapter informs the industrial and commercial boiler and electric generating unit chapters, as well as the chapters on other source categories that burn process fuels (e.g., pulp and paper). The chapter on diesel engine technologies is useful for understanding the three mobile source chapters, as well as substantial portions of the airport and marine port chapters. The report begins with the The Highlights of the source category chapters. Although these do not substitute for the detail provided in each chapter, they cull the most signifi cant emissions reductions opportunities. Prior to the sector-specifi c chapters, Chapter 2 discusses the health effects of PM 2.5 , Chapter 3 discusses the national emissions inventory, and Chapter 4 provides an overview of the Clean Air Act. References Elliott, R. Neal, and M. Spurr, American Council for an Energy-Effi cient Economy. Combined Heat and Power: 4 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options Capturing Wasted Energy, May 1999. http://www.aceee. org/pubs/IE983.htm. U.S. Environmental Protection Agency (EPA). Combined Heat and Power, January 2000. http://yosemite.epa.gov/ oar/globalwarming.nsf/UniqueKeyLookup/SHSU5BPLD4/ $File/combinedheatandpower.pdf. State and Territorial Air Pollution Program Administrators and the Association of Local Air Pollution Control Offi cials (STAPPA/ALAPCO). Restrictions on the Stringency of State and Local Air Quality Programs: Results of a Survey by the State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Offi cials (ALAPCO), December 17, 2002. http://www.4cleanair.org/stringency-report.pdf. [...]... National Ambient Air Quality Standards for Particulate Matter (Second Draft PM Staff Paper, January 2005): A Review by the Particulate Matter Review Panel of the EPA Clean Air Scientific Advisory Committee (EPASAB-CASAC-05-007), June 2005 www.epa.gov/sab /pdf/ casac-05-007 .pdf (2005b) Chapter 2 - Effects of Particulate Matter on Human Health and the Environment 21 Chapter 3 Fine Particulate Matter and... recently there has been a comprehensive reanalysis of data from the Six Cities and ACS studies, and new analyses using updated data from the AHSMOG and ACS Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options studies The reanalysis of the Six Cities and ACS studies confirms their original findings, suggesting an association with both total and cardiorespiratory mortality and exposure... national and regional approaches to achieving more stringent and expeditious reductions than CAIR STAPPA and ALAPCO’s strategy calls for a national SO2 cap of 1.26–1.89 million tons per year (as compared to a baseline of 10.6 million tons in 2001) by 2013, and a NOx cap of 0.88–1.26 million tons Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options per year by the same date (as compared... Luepker, M Mittleman, J Samet, S.C Smith, Jr, and I Tager Air Pollution and Cardiovascular Disease: A Statement for Healthcare Professionals from the Expert Panel on Population and Prevention Science of the American Heart Association,” Circulation 109: Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options 2655-71, June 1, 2004 reprint/109/21/2655 .pdf http://circ.ahajournals.org/cgi/... to date, however, areas throughout the eastern U.S and California exceed EPA’s National Ambient Air Quality Standards (NAAQS) for PM2.5 In this chapter, we discuss the characteristics of ambient PM, including size and chemical composition We also discuss the sources that contribute to ambient PM2.5 concentrations 22 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options diameter,... effects of PM on materials have been investigated for metals, wood, stone, painted surfaces, electronics and fabrics Particulate pollution may soil and discolor these materials, reducing their aesthetic appeal It may also cause other physical and chemical degradation of materials through the action of acidic particles PM NAAQS Review As discussed in Chapter 3, EPA is required by the Clean Air Act to... for the irregular shape and varying density of most particles Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options distances by wind and weather, traveling thousands of miles from where they were formed Fig 2.1 The Human Respiratory System As discussed later in this report, the concentration and composition of particle pollution in the atmosphere vary by time of year and by... Phoenix PM2.5 Aerosol with the Unmix Receptor Model,” Journal of the Air and Waste Management Association, 53(3): 325-38, March 2003 Ramadan, Z., X.H Song, and P.K Hopke “Identification of Sources of Phoenix Aerosol by Positive Matrix Factorization,” Journal of the Air and Waste Management Association 50: 1308-1320, 2000 Sardar, S.B., P.M Fine, and C Sioutas “Seasonal and Spatial Variability of the Size-Resolved... http://cfpub.epa.gov/ncea/cfm/ partmatt.cfm (2004b) U.S Environmental Protection Agency (EPA) Review of the National Ambient Air Quality Standards for Particulate Matter: Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper (EPA-452/R05-005), June 2005 www.epa.gov/ttnnaaqs/standards/pm/ data/pmstaffpaper_20050630 .pdf (200 5a) U.S Environmental Protection Agency (EPA) EPA’s Review of the National... Another major multi-city study used data from ten of the NMAPS cities where daily PM10 monitoring data were available (Schwartz, 2003) Again, the authors reported 18 a statistically significant association between PM10 and total mortality, with a reported health risk larger than that reported in the NMMAPS study The authors of the study suggest that the availability of more frequent monitoring data may partly . Particulate Matter Under the Clean Air Act: A Menu of Options STAPPA State and Territorial Air Pollution Program Administrators ALAPCO Association of. Program Administrators (STAPPA) and the Association of Local Air Pollution Control Of cials (ALAPCO) are the two national associations of air quality of