August 19 Health Department Revises Proposed State Implementation Plan for Fine Particulates
AUGUST 30, 2019 | POSTED BY CAC USER
[This webpage provides an inventory of resources relating to the Proposed (Revised) State Implementation Plan for Fine Particulates posted by the Allegheny County Health Department on August 19, 2019.]
12. EPA, Status of SIP Required Elements for Pennsylvania Designated Areas (as of August 30, 2019), https://www3.epa.gov/airquality/urbanair/
SUMMARY: As of August 30, 2019, the Health Department has not submitted to EPA the required revision of its state implementation plan for fine particulates, which was due on October 15, 2016. (scroll down to ninth chart from the bottom, titled "Pennsylvania: PM-2.5 (2012) / Allegheny County".
These revisions include the following: emission inventory, reasonable available control measures/ reasonable available control technologies, attainment demonstration, reasonable further progress demonstration, quantitative milestones, contingency measures, nonattainment new source review.
11. Proposed (Revised) Nonattainment Demonstration (August 19, 2019)
SUMMARY: the Health Department proposes a revised attainment demonstration for fine particulates, in advance of a Board of Health meeting scheduled for September 11, 2019.
Appendixes A-M are available on the Health Department's website: https://www.alleghenycounty.us/Health-Department/Programs/Air-Quality/Regulations-and-SIPs.aspx (Proposed SIP Revisions, 90 SIP Revision).
Appendix M includes the Summary of Comments and Responses:
Several days later, the Health Department posts a revised response to comments:
10. Comments on Proposed Attainment Demonstration for Fine Particulates (June 11, 2019)
a. Clean Air Council's Comments
SUMMARY: Clean Air Council submits written comments on the proposed attainment demonstration on behalf of itself, Climate Reality Project: Pittsburgh & Southwestern PA Chapter, and the Breathe Project.
b. Group Against Smog and Pollution's Comments
SUMMARY: Group Against Smog and Pollution submits written comments on the proposed attainment demonstration.
9. Proposed Nonattainment Demonstration (April 22, 2019)
SUMMARY: the Health Department proposes an attainment demonstration for fine particulates, subject to a public comment period ending on July 11, 2019. (Appendixes were included, but are not posted here):
8. Finalized Regulations for Nonattainment New Source Review (March 6, 2019)
a. Transmittal Letter to Pennsylvania Department of Environmental Protection, March 6, 2019
SUMMARY: the Health Department submits a revision of its nonattainment new source regulations to the Pennsylvania Department of Environmental Protection.
b. Revision Tracking No. 90A (including Summary of Comments and Responses on pages 19-21)
SUMMARY: In its "Summary of Comments and Responses," the Department rejects the comment recommending an increased offset ratio for major sources locating in the nonattainment area.
"Response: This regulation revision establishes emission offset ratios for VOC and ammonia as PM2.5 precursors. This regulation does not propose changing the existing offset ratio for direct PM2.5 found at 25 Pa. Code § 127.2 10, which is incorporated by reference under Article XXI, §2102.06.
The offset ratio for sources of particulates in this area has rarely been implemented. Sources in Allegheny County requiring installation permits tend to stay under the tonnage limit requiring an emission offset. An increased offset ratio would have no effect on the timeline to bring the County into attainment."
7. Clean Air Council's Comments on Proposed Regulations for Nonattainment New Source Review Program (December 18, 2018), Clean Air Council Comments
SUMMARY: Clean Air Council submits written comments on behalf of itself, Communities First–Sewickley Valley, Rail Pollution Prevention Pittsburgh (RP3), Allegheny
County Clean Air Now (ACCAN), and the Breathe Project.
The Council recommends that the Department require an increased offset ratio for new or modified major sources of fine particulates in Allegheny County.
For such projects to go forward, a facility already must obtain a reduction of emissions of fine particulates from other projects or sources to offset the increase in emissions from the project. (The minimum ratio is 1:1).
The Council recommends that the Department require an increased offset ratio of 1:5 to 1, following an example in California.
6. Additional Requirements for Fine Particulate Matter in the Nonattainment New Source Review Program (Proposed December 2018), Revision Tracking No. 90A.
SUMMARY: the Health Department proposes a revision of its nonattainment new source review regulations -- one part of the larger submission that was due on October 15, 2016.
This proposal involves the regulatory requirements for the construction or modification of major sources of air pollutants in Allegheny County. (There are 32 of these sources in the county, including the three U.S. Steel facilities).
5. Findings of Failure To Submit State Implementation Plan Submissions for the 2012 Fine Particulate Matter National Ambient Air Quality Standards (NAAQS), 83 Fed. Reg. 14,759 (April 6, 2018),
https://www.govinfo.gov/content/pkg/FR-2018-04-06/pdf/2018-06989.pdf
SUMMARY: Effective May 7, 2018, EPA publishes a finding that the Department failed to make the submissions that required by October 15, 2016.
The publication of this notice starts the 18-month clock for sanctions under the Clean Air Act. See 42 U.S.C. §7509(a), https://www.law.cornell.edu/uscode/text/42/7509, 40 C.F.R. §52.31(c),(d), https://www.law.cornell.edu/cfr/text/40/52.31.
That 18-month period will end on November 7, 2019.
4. Final Rule, Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan Requirements, 81 Fed. Reg. 58,010, 58,026 (col. 2), 58,152 (col. 3) (August 24, 2016),
https://www.govinfo.gov/content/pkg/FR-2016-08-24/pdf/2016-18768.pdf
SUMMARY: EPA sets an attainment date of December 31, 2021 for moderate nonattainment areas, including Allegheny County.
By October 15, 2016 (18 months after the effective date of the nonattainment designation), Allegheny County is required to submit a revision of its state implementation plan to address nonattainment with the lowered standard. See 81 Fed. Reg. 58,010, 58,026 (col. 2), 58,152 (col. 3).
3. Additional Air Quality Designations and Technical Amendment To Correct Inadvertent Error in Air Quality Designations for the 2012 Primary Annual Fine Particle (PM2.5), 80 Fed. Reg. 18,535, 18,537-18,538, 18,549 (April 7, 2015),
https://www.govinfo.gov/content/pkg/FR-2015-04-07/pdf/2015-07948.pdf
SUMMARY: This notice by EPA corrects the error in the previous notice in which EPA designated the “remainder” of Allegheny County as being unclassifiable/attainment (80 Fed. Reg. 2266):
“This technical amendment clarifies that the entirety of Allegheny County, Pennsylvania is designated nonattainment.” 80 Fed. Reg. 18,537.
2. Air Quality Designations for the 2012 Primary Annual Fine Particle (PM2.5), 80 Fed. Reg. 2206, 2264, 2266 (January 15, 2015) (to be codified at 40 CFR 81.339),
https://www.govinfo.gov/content/pkg/FR-2015-01-15/pdf/2015-00021.pdf
SUMMARY: Under the new standard, EPA designates all of Allegheny County as a nonattainment area effective April 15, 2015. 80 Fed. Reg. 2206, 2264.
On a different page of the notice, EPA designates the “remainder” of Allegheny County as unclassifiable/attainment (Id. at 2266), but this was an error that was corrected in a subsequent notice.
1. Final Rule, National Ambient Air Quality Standards for Particulate Matter, 78 Fed. Reg. 3086, 3088, 3277 (January 15, 2013) (to be codified at 40 CFR 50.18(a)),
https://www.govinfo.gov/content/pkg/FR-2013-01-15/pdf/2012-30946.pdf
SUMMARY: EPA lowers the annual standard from 15.0 micrograms per cubic meter (15.0 µg/m3) to 12.0 micrograms per cubic meter (12.0 µg/m3).
In lowering the standard, EPA concludes that fine particulates cause premature mortality:
“Using a more formal framework for reaching causal determinations than used in prior reviews, [footnote omitted] the EPA concludes that a causal relationship exists between both long and short-term exposures to PM2.5 and premature mortality and cardiovascular effects and a likely causal relationship exists between long- and short-term PM2.5 exposures and respiratory effects.” 78 Fed. Reg. 3103.
Background: Nonattainment Status in Allegheny County
The annual standard is a yearly standard based on a design value.
The design value results from averaging the hourly concentrations over a period of one year, and then averaging these annual averages over a period of three years. If the design value is greater than the standard, the area is in nonattainment.
The following are the Health Department's yearly reports relating to design values, prepared for the years 2015 to the present:
(The annual report for 2018 has not yet been posted. See https://www.alleghenycounty.us/Health-Department/Resources/Data-and-Reporting/Air-Quality-Reports/Air-Quality-Reports-and-Studies.aspx).
2017 design value: 13.0 (2015-2017), 2017 Air Quality Annual Report
2016 design value: 12.8 (2014-2016), 2016 Air Quality Annual Report
2015 design value: 12.6 (2013-2015), 2015 Air Quality Annual Report