1. Update on Changing Federal AQ Standards
(And What They Mean to You!)
Minnesota’s Clean Air Dialogue
May 2, 2012
Duluth, MN

2. A Brief History of the Clean Air Act
• To understand AQ Standards,
need a bit of history
• 1955
Air
Pollu,on
Act
– Research
on
cause
and
effect
of
Pollu2on
• 1963
Clean
Air
Act
– States
primarily
responsible

3. A Brief History of the Clean Air Act
• 1967
Air
Quality
Act
– States
designate
Air
Quality
Control
Regions
(AQCRs)
– States
develop
standards
– States
have
primacy
within
AQCR’s,
Feds
between
– Progress?
• Less
than
36
AQCR’s
adopted
by
1970
– (7
in
MN,
most
of
the
rest
in
CA,
NY)
• No
state
had
full
pollu2on
control
plan
– (MN,
CA,
NY
and
PiOsburgh
were
closest)
• First
Earth
Day,
1970,
provided
impetus
for
passage
– (Yes
I
was
too
there!)

4. A Brief History of the Clean Air Act
• 1970 Clean Air Act
– Federal Government now has primary
responsibility for developing standards
– US EPA created to take on those
responsibilities
– US EPA develops standards for six criteria
pollutants:
• Particulate matter, ozone, carbon monoxide,
sulfur dioxide, nitrogen oxides and lead
– States designate areas as attaining standards
or not attaining standards
– States develop plans (State Implementation
Plans or SIPs) to “attain and maintain” the
NAAQS.

5. A Brief History of the Clean Air Act
• 1977 Clean Air Act Amendments
– NAAQS
• Extended deadlines for re-designation
– New Permit Program for New Sources
• New Source Review or NSR
• For sources over 250 tpy, or 100 tpy for listed sources
• Non-attainment NSR
– LAER, offsets, demonstrate progress
• Prevention of Significant Deterioration
– BACT, increments
– Added new “NAAQS”
• Air Quality Related Values (AQRVs)
• E.g. visibility in Class I areas

6. A Brief History of the Clean Air Act
• 1990 Clean Air Act Amendments
– Designated levels of non-attainment
• For Ozone, CO and PM
• Marginal, moderate, serious, severe,
extreme
• Different timeframes for each level
– SIPs & SIP elements more
prescriptive
• RACM/RACT, I/M, Conformity
– Regional Haze SIPs to address
Visibility in Class I areas

7. Structure of CAA
• There are NAAQS
• You’re in attainment or you’re not
• If you’re not in attainment:
– SIP & schedule to attain & maintain NAAQS
– New & modified sources must obtain permits
– Install LAER, obtain offsets, demonstrate
progress
– Other requirements

8. Structure of CAA
• If you are in attainment:
– May be subject to maintenance SIP
– May need to get permit
– May have to install BACT/LAER
– May have modeling limitations
– May have limitations to avoid BACT/LAER
• Synthetic minor

9. MN History of Non-attainment
• Current – lead – Eagan
• Past (maintenance SIPs)
– CO
• Twin Cities, Duluth, St. Cloud
– TSP
• Twin Cities, Duluth
– PM10
• Rochester, Ramsey County
– SO2
• Twin Cities, (refineries),Rochester,

10. U.S. EPA has been very, very busy revising
NAAQS
• To date:
− 2006: 24-hr PM2.5
− 2008: Lead
− 2010: NO2, SO2
− 2008-2011: Ozone
− 2011: CO
• More to come:
− 2012-2013: PM2.5
− 2013-2014: Ozone

11. PM2.5 Air Quality Standard
• Annual standard – 15 µg/m3, annual mean
averaged over a three year period
• 24-hour standard- 35 µg/m3, 98th percentile
averaged over a three year period
• Anticipate revised standard proposed in 2012 and
finalized in 2013.
• 24-hour standard could be lowered to 30 µg/m3
• Annual standard could be lowered to 11-12 µg/m3

12. Daily PM2.5 NAAQS Design Values 2008-2010
40
37
36
Current
NAAQS
35
31
31
31
Future
NAAQS?
30
29
29
PM2.5
Concentra2on
(µg/m3)
26
25
22
21
20
17
15
10
5
0

13. Estimated Daily PM2.5 NAAQS Design Values
2009-2011*
40
35
33.7
30
32.9
Future
NAAQS?
30.5 29.6 29.2
Concentration (µg/m3)
31.1
27.9 26.7
25
24.3
20 21.1
19.3
15 16.5
10
5
Dark blue: 1:3 day sampling
2 high values to reach max
0
Light Blue: Daily Sampling
6 high values to reach max
98th Percentile Max observed NAAQS
*
Through
September
30,
2011.
Preliminary
and
subject
to
change

14. PM2.5 – Where does it come from?
Vehicle
Exhaust
Direct
Wood
PM2.5
Burning
Emissions
Power
Plants
Ambient Vehicle
PM 2.5 Exhaust
Secondary Wood
PM2.5
Formation Burning
(from NOx
+ SO2 Ag.
+NH3+…) Fertilization
Power
Plants

15. Requirements for PM2.5 NA Areas - CAAA
• The required SIP elements for PM2.5
nonattainment areas are:
– Emissions Inventory
– PM2.5 RACM/RACT
– PM2.5 Nonattainment Area NSR Program
– PM2.5 RFP
– PM2.5 Attainment Demonstration
– PM2.5 Contingency Measures

16. Emission Inventory
• Must include:
– Direct PM2.5
– SO2
– NOx
• May need to include
– VOC
– NH3
• From:
– Mobile Sources
– Area Sources
– Stationary Sources

17. PM2.5 RACM/RACT
• RACM = Reasonably Available Control
Measures
• RACT = Reasonably Available Control
Technology (RACT is subset of RACM)
• Need to investigate for:
– Direct PM2.5, SO2, NOx
• May need to investigate for:
– VOC, NH3, …
• Need to investigate for all EI Sources
– Mobile, Area and Stationary

18. PM2.5 RACM/RACT (continued)
• No tonnage threshold for RACT
• Screening assessments can inform choice of
sources/measures to evaluate
• 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

19. PM2.5 RACM/RACT (continued)
• The following were the source categories initially
selected for further consideration (New Jersey):
– Boilers – serving electric generating units (EGUs) firing No. 6
fuel oil and coal,
– and industrial, commercial and institutional (ICI) fossil fuel-fired
units;
– Fluid catalytic cracking units (FCCUs) at petroleum refineries;
– Furnaces – such as glass, and iron and steel;
– Municipal waste combustors (MWCs);
– Stationary diesel engines; and
– Fugitive Dust Sources.

20. PM2.5 RACM/RACT (continued)
• Other potential sources (Maryland):
– Automobile Refinishing
– Expandable Polystyrene Products
– Yeast Manufacturing & Commercial Bakery Ovens
– Municipal Landfills
– Surface Cleaning/Degreasing
– Screen Printing & Graphic Arts
– Reformulated Gasoline?
– I/M?? (or remote sensing?)

21. Example Control Measures
• Diesel retrofits (trucks, school • Year-round measures to reduce
buses, stationary engines) VMT (Commuter Choice, carpooling
• Diesel idling (trucks, trains, port incentives, etc.)
equipment, etc.) • Open burning laws and better
• Programs to reduce emissions from enforcement
poorly maintained vehicles • Programs to reduced emissions
• New or improved direct PM and from residential wood combustion
precursor controls on stationary and back yard barrel burning
sources • Smoke management plans
• Year-round operation of seasonal • Improved monitoring techniques
stationary source NOx controls and more frequent monitoring on
• Increase use of alternative fuel, sources with control devices
hybrid vehicles • Reducing emissions of volatile
• Buy-back programs for small aromatic compounds (surface
engines (boats, vehicles, coatings, gasoline, solvents, etc.)
equipment)

22. PM2.5 Nonattainment Area NSR Program
• Applies to sources >100 tpy (not 250 tpy)
• Same modification threshold (15 tpy)
• Requires LAER – Lowest Achievable Emission
Reduction
• Requires modeled demonstration of direct PM2.5
attainment
– May require modeled demonstration of secondary
formation (photochemical modeling)
• Requires Offsets (likely 1:1)

23. PM2.5 Attainment Demonstration
• Modeled demonstration of direct PM2.5 and
secondary formation
– photochemical models
• Geographic range of SO2 and NOx emission
sources included in RFP plan could extend up to
200 km beyond nonattainment area boundary
• Not just Twin Cities!!

24. Overview of CAA Ozone Planning & Control
Mandates by Classification
NSR Major
offset source
ratio threshold
1.5 : 1 10
TRAFFIC
CONTROLS
DURING
CONGESTION
Extreme
EXTREME
CLEAN
FUELS
REQUIREMENT
FOR
BOILERS
1.3 : 1 25
(20
years
to
aCain) PENALTY
FEE
PROGRAM
FOR
MAJOR
SOURCES
LOW
VOC
REFORMULATED
GAS
Severe
SEVERE
VMT
GROWTH
OFFSET;
1.2 : 1 50
(15/17
years
to
aCain)
VMT
DEMONSTRATION
(&
TCMs
IF
NEEDED)
NSR
REQUIREMENTS.
FOR
EXISTING
SOURCE
MODS
Serious
ENHANCED
I/M CLEAN
FUELS
PROGRAM
(IF
APPLICABLE)
MILESTONE
CONTINGENCY
MODELED
DEMO
OF
ATTAINMENT MEASURES
FOR
RFP
SERIOUS
18%
RFP
OVER
6
YEARS ENHANCED
MONITORING
PLAN
(9
years
to
aCain) STAGE
II
GASOLINE
VAPOR
RECOVERY 1.15 : 1 100
BASIC
I/M CONTINGENCY
MEASURES
FOR
FAILURE
TO
ATTAIN
Moderate
15%
RFP
OVER
6
YEARS
MODERATE
MAJOR
SOURCE
VOC/NOx
RACT ATTAINMENT
DEMONSTRATION
(6
years
to
aCain) TRANSPORTATION
CONFORMITY
DEMONSTRATION 1.1 : 1 100
NEW
SOURCE
REVIEW
PROGRAM MAJOR
SOURCE
EMISSION
STATEMENTS Marginal
MARGINAL
BASELINE
EMISSION
INVENTORY
(EI) PERIODIC
EMISSION
INVENTORY
UPDATES
(3
years
to
aCain)

25. Sanctions
• As a result of failure to submit a SIP or implement a SIP.
• Within 18 months of a finding one of two offsets can be
imposed; the second within 2 years.
• A ratio of at least 2:1 emissions reductions within the
nonattainment area for new or modified major facilities
undergoing NSR.
• Highway funding sanctions. FHWA is required to impose
funding moratorium for all but exempt projects (safety,
mass transit).
25

26. Other Issues
• Improved source monitoring
• Transportation conformity
• General conformity

27. Voluntary Measures
• We’ve already done a bunch
– Clean Air MN (I)
– Project Green Fleet
• Other options ?

28. Voluntary Measures
• Ozone Advance
– EPA website:
http://www.epa.gov/ozoneadvance/
– Basic Information
– Eligibility
– Participation
– Ozone Flex
– Resources
– Frequent Questions

29. Voluntary Measures
• Ozone Advance (PM2.5 prototype?)
– State, tribal, and/or local governments can
participate in Ozone Advance if they meet the
basic program eligibility criteria:
– The area(s) designated is/are not designated
nonattainment for either the 1997 8-hour or the
2008 ozone NAAQS.
– Identify and report on the air monitor(s) that
reflect the air quality in the area(s).
– Emissions inventory reporting must have
occurred prior to participation in Ozone Advance.

30. Voluntary Measures
• Ozone Advance
– promotes local actions to reduce ozone precursors in attainment
areas to help these areas continue to maintain the ozone
NAAQS.
– To apply for participation in Ozone Advance, an area should
submit a brief sign-up letter. This letter should express the areas
willingness to coordinate with EPA, state, tribal and/or local
stakeholders and to quickly implement measures to reduce
ozone. Each of the program eligibility criteria should be
addressed.
– Specific measures do not need to be identified in the letter of
intent, although if the applicant would like to highlight any
existing measures and programs, they are welcome to do so.
The letter should be signed by the appropriate state, tribal and/or
local officials with the authority to implement the program and
assist in leveraging staff and program funds as needed.

31. Clean Construction
• Score requirements
– Fleet average
– Self-reporting by contractor

33.
Rail Partnership
• Variable
opera2ons
• Mul2ple
types
of
vehicles
• Switchers
• Hostlers
• Cranes
• Li_s
• Trucks
• Idling
Modeling
by
LADCO
resourceful. naturally.

34. Voluntary Measures
• EPA’s Voluntary Residential Wood Smoke
Reduction Initiative
– Great American Woodstove Changeout
Campaign (Main focus)
– Outdoor Wood-fired hydronic heaters
– Voluntary Fireplace Emission Standard
– “Burn Wise” National Education and Outreach
Campaign

35. Voluntary Measures
• Wood Stove Change out
• Voluntary, incentive-based (e.g., cash
rebates, vouchers) effort to encourage
owners of old, inefficient woodstoves to
replace with a cleaner burning hearth
appliance, like:
• Gas stoves
• Wood pellet stoves
• EPA-certified wood stoves

36. Thanks!!
• Mike Hansel
– Barr Engineering
– mhansel@barr.com
– 952.832.2878
• Bill Droessler
– Environmental Initiative
– bdroessler@environmental-initiative.org
– 612-334-3388 ext. 103