Update on the National Air Pollution 

Standards and Related Activities

1

Bill Harnett

U.S. EPA Office of Air Quality Planning and Standards

Clean Air Act Advisory Committee 

Meeting of Subcommittee on Permits, New Source Review and Toxics 

Washington, DC

November 16, 2011
Outline of Presentation

• NAAQS Review Schedule and Implementation 

Milestones

– SO2

– NO2

– NO2/SO2 secondary

– Lead

– Carbon Monoxide

• Indian Country Designations Policy

• Regional Haze Implementation

• GHG Permitting

• MACT/NESHAP/NSPS

• National Air Emissions Measurement Study for Animal 

Feeding Operations

2
Current Schedule for Ongoing NAAQS 

Reviews (September 20, 2011)

3

NOTE: Underlined dates indicate court-ordered or settlement agreement deadlines.

MILESTONE

POLLUTANT

PM NO2

/SO2

Secondary Ozone Lead NO2

Primary

SO2

Primary CO

Proposal TBD July 12, 2011 Fall 2013 Winter 

2013

Summer 

2015

Winter 

2015

Spring 

2016

Final TBD Mar 20, 2012 July 2014 Fall 2014 Spring 

2016

Spring 

2016

Winter 

2016

NAAQS Review Schedule
Anticipated NAAQS

Implementation Milestones

Pollutant

NAAQS

Promulgation 

Date

Designations

Effective

110(a) SIPs 

due

(3 yrs after NAAQS 

promulgation)

Attainment 

Demonstration 

Due

Attainment 

Date

PM2.5 (2006) Sept 2006 Dec 2009 Sept 2009 Dec 2012 Dec 

2014/2019

Lead Oct 2008

Dec

2010/2011 Oct 2011

June

2012/2013

Dec 

2015/2016

NO2 (primary) Jan 2010 Feb 2012 Jan 2013 Aug 2013 Feb 2017

SO2 (primary) June 2010 July 2012 June 2013 Jan 2014 July 2017

Ozone (2008) Mar 2008 2012 Mar 2011 2015 2015-2035

Ozone

(current review)

July 2014 2016 July 2017 2019/2020 2019-2039

PM2.5 

(current review)

TBD TBD TBD TBD TBD

NO2/SO2

Secondary Mar 2012 TBD Mar 2015 TBD TBD

4
SO2 NAAQS

• New 1-hr 75 ppb SO2 NAAQS promulgated June 3, 2010

• Epidemiologic studies have associated exposure to SO2 with 

increased emergency room visits and/or hospitalizations. 

• Clinical studies reported that five minute SO2 exposures ≥ 200 

ppb can result in respiratory problems, such as narrowing of 

the airways, which can cause difficulty breathing and 

increased asthma symptoms. 

• Standard provides substantial protection from high, 5–10 

minute concentrations of concern.

5
SO2 Monitor Design Values

2008-2010

6
SO2

Implementation Guidance

• Challenge in determining nonattainment/attainment areas. Difficult to have 

sufficient ambient monitoring. 

• Proposed approach: use monitoring (59 violating monitors with 2008-10 data) 

AND modeling information. Account for reductions from major rules by 2017.

• Sept. 2011: implementation and modeling guidance out for public comment. 

Final version in late 2011. See http://www.epa.gov/air/sulfurdioxide/implement.html 

• Future rulemaking is planned for 2012

7

SO2 NAAQS Implementation

Nonattainment Areas 

Based on Monitoring Other Areas

2012: Designate nonattainment areas (to 

attain by 2017)

2012: Designate areas without monitoring 

as “unclassifiable”

2013: Sec. 110 infrastructure plans due 2013: Sec. 110 infrastructure plans plus

attainment and maintenance plan due; with 

modeling, show attainment by 2017 

2014: Attainment plans due, with modeling

2017: Attainment date 2017: Verify attainment
NO2 NAAQS Implementation

• On January 22, 2010, EPA strengthened the primary national ambient air quality 

standard (NAAQS) for nitrogen dioxide (NO2) to increase protection of public health

– Added a 1-hour NO2 standard at 100 parts per billion (ppb); and 

– Retained the annual average NO2 standard at a level of 53 ppb

– Scientific evidence links short-term NO2 exposures with an array of adverse respiratory 

effects including increased asthma symptoms

• To determine compliance, EPA also made changes to the NO2 air quality monitoring 

network requirements. Monitoring is needed to measure: 

– Peak, short-term concentrations. 52 near-road sites in cities with population > 1 million 

(2013-14)

– Highest concentrations of NO2 that occur over wider community areas, 

– Concentrations impacting susceptible and vulnerable groups

• No violating monitors based on existing community-wide monitoring network. No 

nonattainment areas expected to be designated initially. 

• Guidance on NO2 PSD permit modeling issued June 29, 2010 

http://www.epa.gov/NSR/guidance.html

– Estimating ambient NO2 concentrations and determining compliance with the new 1-hour NO2 

standard

8
Ecosystem Effects of Nitrogen and Sulfur

(Ammonia)

Fine Particle Formation

(e.g. Ammonium Sulfate and 

Ammonium Nitrate)

cough
NO2

/SO2 Secondary Standards

• Intended objective: develop combined secondary standard to address 

ecological effects associated with both pollutants (with a focus on 

effects to aquatic ecosystems)

• In July 2011, EPA proposed to revise the secondary NO2 and SO2

standards by establishing an additional set of secondary standards 

identical to the new health-based primary standards set in 2010

– Because of remaining complexities and uncertainties, EPA cannot judge whether 

a new, multi-pollutant standard would provide the appropriate degree of 

protection

– Planning a 5-year field pilot program to collect and analyze data to inform next 

NAAQS review

– 3-5 locations in acid-sensitive ecoregions (starting 2013)

– Final decision on revised NAAQS due March 2012

• Exploring ways to align any new future implementation requirements 

with primary standards

10
Lead NAAQS 

Implementation

• Lead NAAQS promulgated in October 2008 

– Exposure causes neurological effects in children and cardiovascular effects (e.g., 

high blood pressure and heart disease) in adults.

– Infants and young children are especially sensitive to even low levels of lead, which 

may contribute to behavioral problems, learning deficits and lowered IQ.

– Standard: 0.15 μg/m3 (rolling 3-month average)

• Area Designations

– December 2010: Round 1 (16 nonattainment areas). SIP deadline June 2012; 

Attainment deadline December 2015.

– Late 2011: Round 2 (5 new areas). SIP deadline June 2013. Attainment deadline 

December 2016.

– http://www.epa.gov/leaddesignations/2008standards/ 

• Implementation Assistance

– Draft technical note on modeling (February 5, 2009) available at 

http://www.epa.gov/ttnamti1/files/ambient/pb/ModelingQA.pdf

– Implementation Q & A covering general implementation issues, monitoring and 

modeling (July 8, 2011) available at 

http://www.epa.gov/airquality/lead/implement.html 

– Updating control technology guidance for stationary sources (final in 2012) 11
12
CO NAAQS Implementation

• Final decision to retain existing standards (9 ppm 8-hr, 35 ppm

1-hr) issued on August 12, 2011

• Current implementation approach will continue

• Final ambient air monitoring requirements include co-locating 

one CO monitor with a “near-road” NO2 monitor in urban areas 

having populations of 1 million or more

– Approximately 52 CO monitors within 52 urban areas, as part of the 

overall CO monitoring network

– States may request that an alternative near-road location be used to 

house a required near-road CO monitor, to be approved by the EPA 

Regional Administrator on a case-by-case basis

13
Policy for Separately Designated

Areas of Indian Country

• Draft policy for consultation with Tribes regarding 

nonattainment area designation process

– Distributed for comment and undergoing final revision

• On a case-by-case basis, and after consultation with tribes, 

EPA may designate an area of Indian country separately 

from adjacent areas

• Indian country to be acknowledged explicitly in Area 

Designations tables in Code of Federal Regulations (part 81)

• Key points

– Encourage states and tribes to coordinate on nonattainment 

recommendations

– Same factors evaluated for Indian Country as for state areas

– Where Indian Country is designated separately from an adjacent state 

area, redesignation to attainment will be independently evaluated for 

Indian Country

14
EPA Actions on 

Regional Haze SIPs

• For the protection of visibility in national parks and wilderness areas

– Ensure “reasonable progress” toward Clean Air Act goal of remedying existing 

impairment

– Best Available Retrofit Technology on major contributing sources

– Plans required from all States in 2008. 

• Complaints filed by environmental groups to spur additional action by States 

and EPA

– To address States that have not submitted a plan, or to require additional action by 

EPA on already-submitted plans

– In some cases, EPA has required a Federal implementation plan to require control 

measures from specific sources

• Rule proposing that Transport Rule can satisfy BART for certain sources is 

under development

– Expect proposal in December 2011 and final in May 2012

• Upcoming requirements

– 2013 progress review (5-year mark)

– 2018 state implementation plan revision (required every 10 years) 

15
Regional Haze Program Status

16

6

States with final SIPs submitted 

(also AK)

San Juan GS FIP (FINAL)

States that have not submitted SIPs 

(also HI and VI)

7 Proposed SIP or FIP

2 Final SIP (full program)

3 Final SIP – BART only

Four Corners and Navajo FIPs
Status of State 

GHG Programs

• In 2010, EPA took a series of actions to ensure that permitting 

would continue without disruption after the date when GHG 

emissions became subject to PSD regulations - January 2, 2011. 

• “SIP Call,” requiring 13 states to revise their PSD programs to 

cover GHG emissions. 

– Arizona (Pinal Co., Rest of AZ), Arkansas, California 

(Sacramento), Connecticut, Florida, Idaho, Kansas, Kentucky 

(Rest of KY, Jefferson Co.), Nebraska, Nevada (Clark Co.), 

Oregon, Texas, Wyoming 

• FIPs to cover those programs that did not address how the 

program will apply to pollutants newly subject to regulation or that 

did not submit revised SIPs by their selected deadline.

– Arizona (Pinal Co. and Rest of AZ), Arkansas, Florida, Idaho, 

Kansas, Kentucky (Jefferson Co.), Oregon, Texas, Wyoming

17
Status of State 

GHG Programs

• As of October 2011, 5 of the 13 “SIP Called” states have 

received approval of their plans to regulate GHGs and 5 of 

these states are awaiting approval of their plans to receive 

that authority

– Approved 

• Connecticut, Kansas, Kentucky (Rest of KY), 

Nebraska, California (Sacramento)

– Awaiting Approval (States with * are Delegations)

• Arizona (Pinal Co.*, Rest of AZ)*, Kentucky 

(Jefferson Co.), Nevada (Clark Co.), Oregon, Idaho

• Once EPA approves the plan for Nevada (Clark Co.), EPA 

or the states will have authority to permit GHG sources for 

all the states

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GHG Permit Status

• As of November 2011, about 100 permit applications that likely include a 

GHG component have been submitted and include source categories such 

as:

– Biofuel Production

– Cement Plants

– Electric Generating Units

– Lime Production Facilities

– Outer Continental Shelf Exploration

– Pulp and Paper Mills

– Refineries

• 16 companies/plants have been issued GHG permits

– EPA issued 2 of these permits (Palmdale Hybrid Energy Center in Antelope Valley, CA and 

Eni Holy Cross Drilling Project in OCS Eastern GOM) 

– SIP-approved state/local permitting authorities issued the other 13

• EPA has provided comments on 15 draft GHG permits to be issued by state 

agencies

• EPA is currently reviewing approximately 15 GHG permit applications for 

which EPA will issue the permits

19
EPA Comments on 

GHG Permits

• Include adequate support and explanation for form of GHG BACT 

emissions limit

– Numerical emissions limit, or design standard or some other 

requirement if numerical limit deemed infeasible.

– Must specify averaging time for limits.

– Consider setting output based limits for GHG (lb/MWh).

– Limits can be on CO2e basis or individual gas basis.

• Ensure practical enforceability, adequate compliance monitoring to 

measure emissions or efficiency over time.

– Consideration of a source’s non-CO2 constituents– e.g., CH4 and 

N2O at combustion sources.

– CEMS or other CO2 measurement- preferably direct 

measurement for EGUs and other large sources.

20
EPA Comments on GHG 

Permits (Cont.)

• Provide adequate explanation for rejecting control options 

(e.g., CCS) based on feasibility or cost. 

– BACT analysis should explain if most efficient turbine or 

boiler was not selected.

– Permit record should clearly show where CCS was 

eliminated as a potential BACT control technology.

• Affirm that the CO2e emissions during start-up and shut-down 

are included in the compliance calculation for the CO2e BACT 

limits.

• Bottom line: documentation of GHG control 

considerations and BACT limits is important for a robust 

permit record

21
Biomass and GHG 

Permitting

• Biomass Deferral

– In Jan 2011, EPA announced an expedited rulemaking to defer 

completely the application of pre-construction permitting 

requirements to biomass-fired CO2 and other biogenic CO2

emissions for a period of three years.

• Final Rule, Fact Sheet, and Response to Comments at: 

http://www.epa.gov/nsr/actions.html; 

• Deferral applies to CO2 emissions only.

• EPA recently sent the Biomass study to SAB for 

review

• Spring 2012: SAB Biomass scientific study released

• Late 2012:If necessary, proposed rule addressing 

biomass study

22
Future GHG 

Permitting Activities

• Ongoing GHG permitting implementation

– Tailoring Rule Steps 1 & 2

– Q&A website

• Winter 2012 – Proposed Tailoring Step 3 Rule

• July 2012 – Scheduled Final Tailoring Step 3 Rule (one 

year for states to adopt)

• July 2013 – Tailoring Rule Step 3 goes into effect

• 2016 - 5-year GHG NSR study and Step 4 final rule

23
Oil and Gas Sector 

Rulemakings

• NSPS improvements are being considered 

for several emission points, including:

– Completions of hydraulically fractured 

(“fracked”) gas wells

– Compressors

– Storage vessels

– Pneumatic devices

– Equipment leaks

• NESHAP revisions are being considered for:

– Glycol dehydrators

– Storage tanks

• Oil and Gas Sector NESHAP and NSPS

– Proposal issued July 28, 2011

– Comment period ends November 30, 2011

– Final to be issued February 28, 2012

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Pollutant 2005 Emissions 

(tpy)

VOC 3,000,000 

HAP 130,000

Methane 300 MMT CO2e
Oil and Gas Sector 

Rulemakings

• On July 28, 2011, the U.S. Environmental Protection Agency (EPA) proposed a suite 

of highly cost-effective regulations that would reduce harmful air pollution from the 

oil and natural gas industry while allowing continued, responsible growth in U.S. oil 

and natural gas production.

• The proposal includes the first federal air standards for wells that are hydraulically 

fractured. The standards would:

– Reduce emissions of smog-forming volatile organic compounds (VOCs), and air 

toxics including the carcinogen benzene.

– Yield a significant environmental co-benefit by reducing methane emissions 

from new and modified wells. Methane is a potent greenhouse gas –more than 

20 times as potent as carbon dioxide.

• The updated, flexible standards level the playing field by relying on existing, costeffective technology and will institutionalize best practices that are already in place 

in some states and in use by several companies.

• The technologies and best practices allow operators to capture and sell natural gas 

that currently escapes into the air, threatening public health and wasting a valuable 

resource.

• These technologies will allow the industry to save nearly 30 million dollars per year 

even as they cut their emissions

25
Power Plant Mercury 

and Air Toxics Rule

• On March 16, 2011, EPA proposed Mercury and Air Toxics 

Standards, the first national standards to reduce emissions of toxic 

air pollutants from new and existing coal- and oil-fired power plants 

• Proposed rule reaffirms the 2000 “appropriate and necessary” finding 

• Standards will reduce emissions of:

– Metals, including mercury (Hg), arsenic, chromium, and nickel

– Acid gases, including hydrogen chloride (HCl) and hydrogen fluoride (HF)

– Particulate Matter

• Proposed standards create uniform emissions-control requirements 

based on proven, currently in-use technologies and processes

• Compliance time line set by Clean Air Act: up to 4 years (3 years plus 

an additional year if granted by the permitting authority)

26
Power Plant Mercury 

and Air Toxics Rule

27

Requirements for Coal-Fired Units

► Mercury: numeric emission limit would prevent 91% of mercury in coal from being 

released to the air

► Acid gases: HCl emission limit as a surrogate for all acid gases; alternatively, SO2 can 

be monitored as a surrogate

► Non-mercury metallic toxic pollutants such as arsenic and chromium: numeric emission 

limit for total PM as a surrogate, with alternate surrogate of total metal air toxics

► Organic air toxics (including dioxin): Work practice standards, instead of numeric 

standards, due to low-detected emission levels. Would ensure optimal combustion, 

preventing dioxin/furan emissions 

Requirements for Oil-Fired Units

► Acid gases: Require numerical emission limits for HCl and HF 

► Metal air toxics: Numerical emission limits for total metal air toxics (including Hg) with 

individual metal air toxics as alternate.

► Organic air toxics (including dioxin): Work practice standards, instead of numeric 

standards, due to low-detected emission levels. Would ensure optimal combustion, 

preventing dioxin/furan emissions. 
 Boiler MACT and CISWI 

Reconsideration

 

• Issues identified by EPA 

– Full load stack test requirement for carbon monoxide coupled with 

continuous oxygen monitoring 

– Dioxin emission limit and testing requirements

– Data considered in setting emission limits may not fully reflect 

comments received

– PM standards under GACT for existing area source oil-fired boilers

• Issues identified by Industry

– Dioxin and CO limits 

– New source limits and HAP testing 

– PM limits for some biomass boilers 

• EPA issued a stay on May 18, 2011

• We are working expeditiously on the reconsideration

• Reconsideration proposals will be issued November 30, 2011

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Petroleum Refinery 

Sector Rulemakings

• 150 domestic refineries 

• Taking an integrated approach 

across the sector to coordinate 

MACT and NSPS requirements

• Sector NESHAP and NSPS

– Proposal: December 10, 2011

– Final: November 10, 2012

Pollutant 2005 Emissions 

(TPY)

NOx 146,185

SO2 247,239

VOCs 114,852

HAP 14,000

PM2.5 30,333

29
Integrated Sector-Based Approach:

 Petroleum Refinery Sector

Emission Point Current Regulations

Boilers NSPS, MACT

Process Heaters NSPS

Flares NSPS, MACT

FCCU, Reformer, Sulfur Plant NSPS, MACT

Process Vents MACT

Heat Exchangers MACT

Wastewater MACT, NESHAP, NSPS, CTG

Storage MACT, NESHAP, NSPS, CTG

Loading MACT, NESHAP

Equipment Leaks MACT, NSPS, NESHAP, CTG

Rulemaking 

Approach

To be amended to 

reference the 

Uniform Standards

MACT and 

NSPS 

amended

NSPS = New Source Performance Standards; MACT = Maximum Achievable Control Technology Standard; 

NESHAP = National Emission Standards for Hazardous Air Pollutants; CTG= Control Techniques Guidelines 

30
Fenceline Monitoring

• We are considering fenceline monitoring as a possible component of what 

we may propose for the NESHAP

• Locate passive samplers around the perimeter of each refinery

• If any concentration exceeds the action level, initiate tiered approach to 

positively identify facility contribution to risk

• If facility contribution to risk is unacceptable, initiate steps to reduce it

N

31
Upcoming Chemical Sector 

Rulemakings

32

• Over 450 major source facilities emitting 

15,000 tpy of HAP across entire sector

• Proposing NESHAP, based on risk and 

technology review, for: – Pesticide Active Ingredients (PAI) – Polyether Polyols (PEPOs) – Polymers and Resins IV (P&R IV)

• Court orders require proposal for 

portions of this sector by November 30, 

2011 and a final rule by November 30, 

2012

Pollutant

Emissions 

(tpy)

Methanol 3,139

Hexane 3,080

Toluene 1,324

Styrene 848

Benzene 661

Butadiene 629

Xylenes 531

Ethylene glycol

 464 32
33

Iron and Steel Sector 

Rulemakings

• Revision of the electric arc furnace 

(EAF) area source MACT rule

– Compiling data collected from the information 

collection request (ICR)

– Considering Hg emission limits with 

enhanced monitoring

– Plan to propose revised rule in early 2012

• Consider listing EAFs as a major source 

for MACT standards

• Review NSPS for EAF and Integrated 

Iron & Steel

• Address remand of Integrated Iron & 

Steel MACT

• Evaluate Coke Oven residual risk

Pollutant 2005 Emissions 

(TPY)

PM2.5 14,210 

Metal HAP 377 

Coke oven 

emissions 390
National Air Emissions 

Monitoring Study

• Background

– 2-year, industry-funded study coordinated 

by Purdue University with EPA oversight

– 24 sites in 10 states were monitored from 

2007-2010

– Study gathered emissions data for PM 

(PM10, PM2.5, TSP), NH3, H2S and VOCs

– Data will be used to develop emission estimating methodologies for broiler, 

egg layer, swine and dairy AFOs

• USDA collaboration

– Members from Natural Resources Conservation Service and Agriculture 

Research Service have taken part in the development of the 

methodologies

34
• All stakeholder groups requested to be involved in the emissions 

estimating methodologies related to the ongoing work in NAEMS

• Responding to these concerns, OAR has requested EPA’s Science 

Advisory Board (SAB) to review the draft emission estimating 

methodologies (EEMs)

• SAB Schedule

– September 1, 2011, SAB published a Federal Register Notice (FRN) 

announcing a request for nominations of experts for SAB’s AFO review panel 

(Volume 76, No 170)

– Nomination period closed September 22, 2011

– Afterwards, SAB will post the list of candidates on their website

– The public will have 21 days to comment on this list

– Anticipate finalizing panel membership by November/December 2011 with first 

meeting occurring January 2012

– EPA’s goal is to finalize all four EEMs in Summer 2012

• Issues identified by the SAB may impact the schedule

35

National Air Emissions 

Monitoring Study
• SAB Process

– OAR will send draft methodologies to SAB panel for review

• Panel will have a minimum of 30 days to review the drafts prior to the meeting

– Draft package will be released publicly, concurrent with submittal to SAB

• Public will have the opportunity to comment to both OAR and SAB

– Multiple meetings may be held to adequately address the four animal 

species

– SAB panel reports their findings to full SAB committee

– SAB issues final letter of recommendations to OAR

– OAR will incorporate SAB’s recommendations and issue the final 

emissions estimating methodologies

• General information concerning the EPA Science Advisory Board can be 

found at http://www.epa.gov/sab. 

– Additional questions and concerns should be addressed to:

Mr. Edward Hanlon, SAB Designated Federal Officer

Phone: (202) 564-2134; Email: hanlon.edward@epa.gov 

36

National Air Emissions 

Monitoring Study