Controlling PM2.5 Underthe Clean Air Act:A Menu of Options

May 25, 2005

Presented by ESI International for STAPPA/ALAPCO

Sections• I. Introduction• II. Effects of Particulate Matter on Human

Health and the Environment • III. Regulatory Framework• IV. Characterization of PM Sources• V. Mobile Sources• VI. Stationary Sources • VII. Area Sources• VIII. Pollution Prevention

Section Structure

• Description of Sources– Describes usage, applications, sales,

contribution to emission inventories, and other relevant information

• Emission Control Technology Options (where applicable)– Describes both engine-based and exhaust-

based emission control technologies

Section Structure

• Potential Emission Reductions– Describes potential emission reductions

available by adoption of new standards or employing the strategies discussed in the different sections

• Costs and Cost-Effectiveness– Provides information on the cost or cost-

effectiveness of new standards or the strategies discussed in the different sections

Section Structure

• Tables• Figures• Web Sites• References

Section II.Effects of Particulate Matter on

Human Health andthe Environment

Section II – Topics Covered

• Effects of Particulate Matter on Human Health– Introduction– Biological Mechanisms– Short-Term Exposure– Long-Term Exposure– Populations at Risk

• Effects of Particulate Matter on the Environment

Section II – Summary• Short-term exposure to PM

– Can aggravate lung disease, causing asthma attacks and acute bronchitis

– May also increase susceptibility to respiratory infections

– In people with heart disease, short-term exposures have been linked to heart attacks and arrhythmias

• Short-term studies– National Morbidity, Mortality and Air Pollution Study

(NMMAPS) - Dr. Jonathan Samet and others developed and applied a methodology for examining pollution effects across many cities

• In its study of the 90 largest U.S. cities, NMMAPS found strong evidence linking daily increases in particle pollution toincreases in death

Section II – Summary• Long-term exposure to PM

– Have been associated with problems such as reduced lung function and the development of chronic bronchitis – and even premature death

– Other symptoms range from premature births to serious respiratory disorders

• Long-term studies– 1993 Six Cities Study - Harvard University researchers over a

period of 14 to 16 years followed the health of more than 8,000 people in six small cities

• As particle concentrations increased, there was an almost directly proportional increase in the death rate in the residents studied

– 1995 American Cancer Society Study - Study reported an association between fine particle air pollution and premature death by cardiopulmonary and other causes in a study group of over half a million people in 151 U.S. cities

Section II – Summary

• Long-term studies (cont.)– A 2004 American Heart Association (AHA) scientific

statement concluded that exposure to air pollution contributes to the development of cardiovascular diseases

– A 2004 follow-up analysis to the 1995 American Cancer Society study tracked half a million people over 16 years and reported that chronic exposure to fine particle pollution in the U.S. poses a risk of cardiac death comparable to that associated with being a former smoker

Section II – Summary• Effects of PM on the Environment

– Airborne particles can cause soiling and damage to materials

– PM deposition on vegetation reduces light transmission to the plant, which decreases photosynthesis

– Fine particles are a major cause of visibility impairment

• In many parts of the U.S., the visual range has been reduced 70 percent from natural conditions

– In the eastern United States, reduced visibility is mainly attributable to secondarily-formed sulfates

– Secondarily-formed particles account for a major portion of particulate loading in the West, but primary emissions from sources like wood smoke contribute a larger percentage of the total particulate loading than in the East

Section III.

Regulatory Framework

Section III – Topics Covered

• The Clean Air Act– Background– Development of the PM NAAQS– Litigation Related to the PM2.5 NAAQS– Nonattainment Areas under the PM2.5 NAAQS

• Regulatory Efforts– Stationary Sources

• States’ Authority to Regulate Emissions– Mobile Sources

• States’ Authority to Regulate Emissions• California

Section III – Summary

• Basis for federal clean air program is the requirement under the 1970 CAA for EPA to establish NAAQS for “criteria” pollutants– particulate matter (PM)– sulfur dioxide (SO2)– carbon monoxide (CO)– nitrogen oxide (NOx)– ozone– lead (Pb)

• Courts have confirmed that the CAA requires EPA to set the NAAQS without considering the cost of compliance or technical feasibility of controlling the emissions

Section III – Summary

• EPA promulgated the NAAQS for PM2.5 in July 1997– Annual standard of 15 µg/m3

– 24-hour standard of 65 µg/m3

• On December 17, 2004, EPA designated 47 nonattainment areas under the PM2.5 NAAQS.– Nonattainment areas encompass 191 entire and 34

partial counties in 20 states and include 95 million people

Section III – Summary

Section III – Summary

• Stationary Source Regulations– Major CAA provisions that affect stationary sources

• New Source Performance Standards (NSPS)• Prevention of Significant Deterioration (PSD) Program• New Source Review (NSR) Program• Acid Rain Program• National Emission Standard for Hazardous Air Pollutants

(NESHAP) Program• NOx SIP Call• Regulations resulting from state petitions under Section 126

of the CAA

Section III – Summary

• Mobile Source Regulations– CAA directs and authorizes EPA to establish

standards regulating the emissions from mobile sources and to establish a compliance program to implement and enforce the mobile source emission control program

– CAA prohibits States from regulating emissions from new vehicles and engines

• California granted unique authority to adopt its own mobile source emission control standards and compliance program

Section IV.

Characterization of PM Sources

Section IV – Topics Covered

• Characterization of PM Sources– Chemistry and Size Distribution of Particles– Sources and Formation Processes– Primary PM Emissions vs. Secondary PM

Emissions– Source Apportionment– Trends in PM2.5 Levels

Section IV – Summary

• Source apportionment - mathematical methods are used to estimate the relative contributions of different sources to a range of species at a given receptor site– For air pollution source apportionment, the

species of interest are air pollutants (e.g., PM) and the receptor sites are most often areas of significant concern (e.g., metropolitan areas)

Section IV – Summary

• A 2002 study conducted by James Schauer and others looked at air pollutant data in southern California during a severe summertime smog episode– Fine particle mass was composed of noticeable contributions

from gasoline-powered motor vehicle exhaust, diesel engine exhaust, meat cooking, and paved road dust

– Smaller contributions from vegetative detritus and tire wear debris

• A 2003 EPA literature compilation summarized where PM2.5 source apportionment research has been conducted– Commonly identified source categories include: secondary

sulfate/coal burning, secondary organic carbon/mobile sources, crustal sources, biomass burning, industrial processes, smelters and metal processing, and sea salt in coastal regions

Section IV – Summary

• PM2.5 concentrations have decreased 10 percent nationally since 1999– Generally, PM2.5 has decreased the most in regions with the

highest concentrations• Southeast (20 percent)• Southern California (16 percent)• Midwest (nine percent)

• National programs that affect regional emissions have contributed to lower sulfate concentrations and, consequently, lower PM2.5 concentrations

• National ozone-reduction programs designed to reduce emissions of VOCs and NOx also have helped reduce carbon and nitrates, both of which are components of PM2.5

Section IV – SummaryAnnual National Emissions Estimates of Primary PM and PM Precursors

(thousand short tons), 1999

Source NOx SO2 NH3 VOCa Primary PM2.5

Primary PM10-2.5

Fuel Combustion 10,026 16,091 48 904 766 263

Industrial Processes 942 1,465 289 7,996 913 350

On-Road Vehicles 8,590 363 260 5,297 229 66

Nonroad Engines and Vehicles 5,515 936 10 3,232 411 47

Agriculture 0 0 769 8 860 3,438

Fire - - - 699 853 133

Livestock 0 0 3,552 0 89 501

Miscellaneous 320 12 - 9 22 2

Fugitive Dust 0 0 0 0 2,631 12,105

Biogenic//Natural 2,315 - 35 48,500 n/e n/e

Total 27,708 18,867 4,964 66,645 6,773 16,906

n/e = not estimated. Direct PM emissions due to wind erosion on natural surfaces are not estimated because this source is highly sporadic, resulting in emissions too highly uncertain to be included.aVOC emissions have been estimated for compounds known to contribute to ozone formation; the organic compounds that are most important to secondary organic aerosols are a subset of this category, and may include other semi-volatile compounds.Source: EPA (2001)

Section V.

Mobile Sources

Section V – Sources Covered

• Diesel Engines– New engines and existing engines– Includes trucks, buses, refuse haulers,

agriculture, construction, marine, locomotives, industrial, mining, and gensets

• Gasoline Engines– New and existing engines– Cars, trucks, motorcycles, nonroad SI

engines, recreational vehicles, and marine

Section V – Sources Covered

• Conventional Fuels and Lubricants– Diesel fuel and lubricants, and gasoline fuel

and lubricants• Alternative Fuels, Additives, and Fuel

Emulsions• Advanced Technology Vehicles• Aircraft

Section V – Summary of Strategies• Diesel Retrofit (Existing Diesel Engines)

– Includes discussion applicable to both onroad and offroad applications (large and small engines)

– Includes discussion of funding opportunities and possibilities

– Includes discussion of key program elements– Includes examples of both mandatory and voluntary

programs (domestic and international)• Examples include different mandatory programs, multi-

faceted programs (a combination of incentives/funds/agreements), publicly-owned fleets, green construction, state-funded programs, and SEP-funded programs

Section V – Summary of Strategies• Diesel Retrofit (Existing Diesel Engines) (cont.)

– Includes discussion of retrofitting marine, locomotive, and diesel stationary engines (DG)

– Includes discussion of costs and potential emissions reductions

• In-Use Smoke Testing– Includes discussion on the background and some

details of in-use smoke testing– Includes discussion of potential emission reductions

• Heavy-Duty Vehicle Emission Testing

Section V – Summary of Strategies

• Anti-Idling and Operational Changes– Describes available technologies, costs, and

emission reductions– Truck stop electrification– Gives examples of some State initiatives

• Existing Gasoline Engines– Catalyst replacement programs– Forklift retrofit– I/M

Section V – Summary of Strategies

• Fuels– Highlights the benefits of better fuel quality,

emulsified fuels and alternative fuels– Discusses costs

• A Number of Other Mobile Source-Related Strategies Are Included in Section VIII. Pollution Prevention– TCMs, airport emission budgets, SECAs,

lawnmower replacement, fleet scrappage, and others

Section VI.

Stationary Sources

Section VI – Sources Covered

• Electric Power Fuel Combustion• Industrial and Commercial Fuel

Combustion• Metallurgical Industry• Mineral Products Industry• Wood, Pulp and Paper• Chemical Manufacturing• Grain Handling and Processing• Incineration• Petroleum Refining

Section VI – Summary of Strategies• Electric Power Fuel Combustion

– Primary PM2.5 Controls - ESP, FF, Hybrids– Secondary PM2.5 Controls - SO2, NOx, and

Multi-P• Coal-Fired Units• Oil-Fired Units

• Strategies would include:– Regional or state cap-n-trade programs– More stringent requirements for CAIR– Imposing tighter state permits– Provide capital recovery mechanism

Section VI – Summary of Strategies• Industrial and Commercial Fuel Combustion

– Primary PM2.5 Controls• Coal-Fired Units• Oil-Fired Units

– Secondary PM2.5 Controls - SO2, NOx, and Multi-P• Coal-Fired Units• Oil-Fired Units• Wood Waste-Fired Units

• Strategies would include:– Include sources under CAIR rule cap– Imposing tighter state permits– Upgrading control technologies– Reducing SO2 and NOx

– Burn lower sulfur fuel oils

Section VI – Summary of Strategies• Metallurgical Industry

– Iron and Steel– Lead Smelters– Aluminum Production Plants– Zinc Smelters– Cooper Smelters

• Strategies would include:– Replacement of old/low performance controls– Process optimization for lower emissions– Include sources under CAIR rule cap

Section VI – Summary of Strategies• Mineral Products Industry

– Portland Cement Plants– Asphalt Plants– Glass/Fiberglass Manufacturing Plants– Lime Manufacturing Plants– Phosphate Rock Plants

• Strategies would include:– Increase treatment time particulate collection in FF– Increase air-to-cloth ratio for better particulate

removal– Add polishing device (FF behind ESP)– Process optimization for lower emissions– Include sources under CAIR rule cap

Section VI – Summary of Strategies• Wood, Pulp and Paper

– Kraft, Sulfite, Semi-Chemical & Mechanical Pulping

• Strategies would include:– Upgrade ESPs or scrubbers used for recovery

boilers– Add polishing device (FF behind ESP)– Process optimization for lower emissions– Include sources under CAIR rule cap– NOx control (SNCR) for recovery boilers

Section VI – Summary of Strategies• Chemical Manufacturing

– Carbon Black– Organic Chemicals– Detergents– Acid Production (Nitric, Sulfuric, Phosphoric)– Ammonia/Urea

• Strategies would include:– Increase process optimization for lower emissions– Reduce fugitive particulate emissions for operations:

• Bagging• Bulk transfer

• Grain Handling and Processing– Grain Elevators– Grain Mills– Feed Mills

• Strategies would include:– Upgrade cyclones used for grain elevators– Add polishing device (FF behind cyclone)– Oil suppression - Soybean and mineral oil for

fugitive dust control

Section VI – Summary of Strategies

Section VI – Summary of Strategies

• Incineration– Municipal Waste Combustors– Medical Waste Incinerators– Hazardous Waste Combustros– Sewage Sludge Incinerators

• Strategies would include:– FF and high pressure-drop wet scrubbers– Shutdown of smaller, less efficient incinerators

• Petroleum Refining• Strategies would include:

– Installing ESPs– Investigate possibility of high temp. FF

options– NOx controls (SNCR) for FCCUs

Section VI – Summary of Strategies

Section VII.

Area Sources

Section VII – Sources Covered• Fugitive and Re-Entrained Dust• Agricultural Sources• Combustion Sources• Commercial Cooking

Section VII – Summary of Strategies• Fugitive and Re-Entrained Dust

– Includes discussion of unpaved and paved roads, surface mining, stone quarries

– Includes discussion of:• Chemical

– surface treatments of emulsions, acrylics, salts– roads and storage piles

• Physical – paving roads (asphalt recycling)– physical cleaning (mechanical, vacuum, street flushing)

• Vegetative– direct seeding – transplanting

Section VII – Summary of Strategies• Agricultural

– Includes discussion of field crops, orchard crops, confined animal facilities

– Includes discussion of:• Field Crops - crop residue management, vegetation

establishment, windbreaks, row orientation, cover crops, etc.• Orchard Crops - row spacing, grind of pruning, night farming• Confined Animal Facilities - manure handling, storage pile

management, soil stabilization

Section VII – Summary of Strategies• Combustion Sources

– Includes discussion of residential wood combustion, open burning, prescribed burning, wildfires

– Includes discussion of:• Residential Wood Combustion -

– Fireplace conversion– Alternative fuels (natural gas, duraflame logs, etc.)– Wood stove design (examples of change-out programs)

• Open & Prescribed Burning/Wildfires – Smoke management plans– Public education– Surveillance and enforcement– State oversight - coordination with other agencies (forestry and

agriculture)

Section VII – Summary of Strategies• Commercial Cooking

– Includes discussion of charbroilers, deep fat fryers, griddles

– Includes discussion of:• Catalytic oxidizers• Self-cleaning ceramic filters• Fiber-bed filters• Catalytic incineration• Thermal incineration• ESPs• Wet scrubbers

– Discussion of California rulemaking

Section VIII.

Pollution Prevention

Section VIII – Summary

• Mobile Source Alternative Measures– Transportation control policies & practices– Transportation management

• Flow improvements• Land use • Transit improvements

– Additional measures & strategies• Electronic/Automatic Toll lanes• Traffic Management Centers• Restricted Access/Green Curbs• Congestion pricing

Section VIII – Summary– Additional measures & strategies (cont.)

• Transit improvements• Location Efficient Mortgages• AFV Rebates/Fee-bate• Airport Emission Budgets• State AFV Tax Incentives (loan guarantees, income tax

credit, sales tax exemption)• Lawnmower trade-in/voucher• Windshield wiper fluid • Episodic programs and measures – mobile and stationary• Smoking vehicle programs (enforcement)• Fleet scrappage

Section VIII – Summary• Stationary Source Alternative Measures

– Source voluntary measures (SIP credit)• P2 and/or process changes• Source-to-source mentoring• Reduced steam utilization• Reduced process dryer temperatures• “Time-smart” emergency generator testing

– Economic incentive programs• Trading programs• Financial programs (subsidies for lower emitting equipment)• Clean air investment funds• Public information programs (product certification, ozone

action days, etc.) – Early action compacts - Harmonize 8-hr ozone with

PM2.5 requirements

Section VIII – Summary• Stationary Source Alternative Measures (cont.)

– Reduced energy consumption• State renewable portfolio standards• Participate in residential & commercial Energy Star by

specifying & purchasing conforming:– Traffic signals and signs– Building exit signs– Office equipment

– Construction & maintenance• Landscaping• Low VOC emitting products • Energy efficient construction requirements• Reduce urban heat islands (roofing materials, reflective

roads and parking lots)– Public education

Contact Information

• ESI International– David Foerter

• dfoerter@esi-intl.net• (202) 775-8868

• STAPPA/ALAPCO– Amy Royden-Bloom

• aroyden-bloom@4cleanair.org• (202) 624-7864