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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 Officials 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 Officials March 2006 Acknowledgements On behalf of the State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (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 fine particles (PM2.5) and PM2.5 precursors from sources in their areas. We hope that states and localities find this document useful as they prepare their State Implementation Plans (SIPs) for attaining or maintaining the PM2.5 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 PM2.5 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 PM2.5 and PM2.5 precursors and thank all who contributed to its development. Eddie Terrill John Paul STAPPA President ALAPCO President Acknowledgements i 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 Refineries ................................................................................................... 158 Contents iii 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 iv Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options About STAPPA and ALAPCO The State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO) are the two national associations of air quality officials 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 officials; enhance communication and cooperation among federal, state 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. About STAPPA and ALAPCO v Introduction The State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO) have prepared Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options (PM2.5 Menu of Options) to assist state and local air pollution control officials in evaluating the options for reducing fine particulate matter (PM2.5) and PM2.5-precursor emissions. contributing to the ambient air quality problem. As a result, this PM2.5 Menu of Options addresses a broad array of emission source categories, ranging from household furnaces to petroleum refineries. The challenge confronting air quality officials is tremendous, as evidenced by the sheer number of options that we identify for improving air quality. But therein lie the opportunities, as well. Areas throughout the eastern U.S. and California (and one area in Montana) currently exceed EPA’s National Ambient Air Quality Standards (NAAQS) for PM2.5, and states must submit State Implementation Plans (SIPs) by April 2008 detailing their plans for achieving the national standards. 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. Meanwhile, the PM2.5 NAAQS are once again undergoing the periodic review that §109(d)(1) of the Clean Air Act requires take place at five-year intervals. Under the terms of a consent decree, EPA is to issue final standards by September 27, 2006. The Agency proposed new standards on January 17, 2006. EPA estimates that meeting the current PM2.5 standards would avoid tens of thousands of premature deaths annually and save hundreds of thousands of people from significant respiratory and cardiovascular disease. The Agency further estimates that the monetized health benefits of improvements in PM2.5 air quality exceed the costs by a substantial margin. PM2.5 is a complex pollutant with many sources 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 PM2.5 emissions, but it may nonetheless dominate the local inventory. The chemistry and physics of PM2.5 formation in the atmosphere is incompletely understood. Some PM2.5 is Introduction 1 released directly to the atmosphere, and some forms from emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) (which are currently viewed as the most significant 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 PM2.5. Direct PM2.5 emissions may be largely responsible for one area’s nonattainment, while SO2 emissions may cause the problem elsewhere. The choice of whether to focus on reducing direct PM2.5, SO2 or NOx—or all of them, or ammonia or VOCs—will depend on local source contributions and atmospheric chemistry. 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. There are further challenges for SIP writers. In a perfect world, control-efficiency 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. Moreover, there are no actual federal Reasonably Available Control Technology (RACT) standards—EPA issues only guidelines (and although the RACT standards are intended to reflect 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. 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 filterable and condensable PM2.5. Further, some methods used to measure PM emissions reflect only the filterable components and, to exacerbate the problem, the filterable components vary depending on the test method used. Although we discuss this issue in Chapter 3 in the context of the national PM2.5 inventory, the distinction between filterables and condensables also raises regulatory and permitting issues. The Authority to Regulate 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 identified 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 Technology (BACT)-level standards on existing sources, even in the absence of a modification 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 Having decided what sources and pollutants need to be controlled in order to address PM2.5 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. 2 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options 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 PM2.5 nonattainment. As we discuss in the chapters that follow, states have a range of opportunities for addressing these sources. Energy Efficiency The rising cost of fossil fuels has focused the nation’s attention on the opportunities for reducing fuel consumption, including energy efficiency measures, some of which are addressed in this report. For example, Chapter 18, Residential Fuel Combustion and Electricity Use, discusses several demand-side efficiency measures. However, other source categories surely present opportunities for increased efficiency that regulators should not overlook. On the supply side, energy efficiency measures involve increasing the efficiency 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 efficiencies 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 profile in this report are candidates for cogeneration. The petroleum refining 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 efficiency 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 PM2.5, SO2 and NOx 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 significant emissions reductions opportunities. Prior to the sector-specific chapters, Chapter 2 discusses the health effects of PM2.5, 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-Efficient Economy. Combined Heat and Power: Introduction 3 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 Officials (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 Officials (ALAPCO), December 17, 2002. http://www.4cleanair.org/stringency-report.pdf. 4 Controlling Fine Particulate Matter Under the Clean Air Act: A Menu of Options