## Staff Report

Proposed Amended Rule 1325 – Federal PM 2.5 

### New Source Review Program

December 2014



### Deputy Executive Officer

Planning, Rule Development, and Area Sources

Elaine Chang, Dr.PH

Assistant Deputy Executive Officer

Planning, Ru le Development, and Area Sources

Philip M. Fine, Ph.D.

Planning and Rules Manager

Planning, Rule Development, and Area Sources

Naveen Berry

AUTHORS: Cynthia Carter AQ Specialist

Mike Morris AQ Specialist

REVIEWED BY: Robert Pease Program Supervisor

Will iam Wong Principal Deputy District Counsel

CONTRIBUTOR: Daniel Cervantes Student Intern 

## SOUTH COAST AIR QUALITY MANAGEMENT DISTRICTSOUTH COAST AIR QUAL ITY MANAGEMENT DISTR ICT

GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

VICE CHAIRMAN: DENNIS YATES

Mayor, C hino

Cities of San Bernardino

MEMBERS:

MICHAEL D. ANTONOVIC H

Supervisor, Fifth District

County of Los Angeles

BEN BENOIT

Mayor Pro Tem, Wildomar

Cities of Riverside County

JOHN J. BENOIT

Supervisor, Fourth District

County of Riverside

JOE BUSCAINO

Councilmember, Fifteenth District

City of Los Angeles

MICHAEL A. CACCIOTTI

Councilmember, South Pasadena

Cities of Los Angeles County/Eastern Region

JOSIE GONZALES

Supervisor, Fifth District

County of San Bernardino

JOSEPH K. LYOU , P h . D.

Governor’s Appointee

JUDITH MITCHELL

Mayor, Rolling Hills Estates

Cities of Los Angeles County/Western Region

SHAWN NELSON

Supervisor, Fourth District

County of Orange

DR. CLARK E. PARKER, SR.

Senate Rules Appointee

MIGUEL A. PUL IDO

Mayor, Santa Ana

Cities of Orange County

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN , D. ENV.

## TABLE OF CONTENTS

SECTION PAGE

Introduction

................................ ................................ ................................ ................................ ...... 1

Regulatory History

................................ ................................ ................................ ........................... 1

Proposed Modifications to Rule 1 325

................................ ................................ .............................. 2

Emission Impact Assessment

................................ ................................ ................................ ........... 3

Socioeconomic Impact A ssessment

................................ ................................ ................................ . 4

Cost and Cost

- Effectiveness

................................ ................................ ................................ ................... 4

Incremental Cost

- Effectiveness

................................ ................................ ................................ .............. 4

California Environmental Quality Act (CEQA)

................................ ................................ ............. 4

Comparative Analysis

................................ ................................ ................................ ...................... 5

Public Process

................................ ................................ ................................ ................................ .. 5

EPA Comments and Responses

................................ ................................ ................................ ....... 5

Comment Letter Receive d Subsequent to October 24

................................ ................................ ..... 8Staff Report

Proposed A mended Rule 1325 Page 1 December 2014 

### INTRODUCTIO N

In Ma rch 201 4

, U.S. Environmental Protection Agency ( EPA ) reviewed Rule 1325

– Federal

PM 2.5 

### New Source Review Program for State Implementation Plan approvability and notified

SCAQMD that there were corrections needed in the rule even though the rule inc orporates by

reference federal regulations

. The specific changes are described below under Regulatory

History

.



### REGULATORY HISTORY

Rule 1 325 was adopted June 3, 2011 to incorporate U.S. EPA’s requirements for PM 2.5 

### into

Regulation XIII

– New Source Review

. The rule mirrors federal requirements which include

the definition of major source, significant emissions rate, offset ratios, and the applicability

requirements of LAER, facility compliance, offsets, and control of PM 2.5 

### precursors. The

rule is applicab le to major polluting facilities, which are defined by rule as sources with

actual emissions, or the potential to emit, 100 tons per year or more of PM 2.5 

### or its

precursors.

With respect to precursors, NOx and SOx are considered PM2.5 precursors in all c ases.

Under U.S. EPA’s earlier guidance, VOC and ammonia were presumed not to be precursors

required to be subject to PM2.5 NSR rules. Under a 2013 court discussion decision , U.S.

EPA has been required to apply PM10

- specific provisions of the CAA to PM2.5 . Therefore,

U.S. EPA asked staff to address § 189 (e) of the CAA, under which all precursors, including

ammonia and VOC are subject to the PM10 requirements of the CAA unless U.S. EPA

determines that such sources do not contribute significantly to PM10 l evels (here, PM2.5

levels) which exceed the standard.

On March 10, 201 4 , U.S. EPA specified three desired c larifications with respect to the Clean

Air Act. The specific c larifications described by U.S. EPA are as follows:

1. While Rule 1325 (c)(1)(B) states that offsets are required, it does not contain any specific

requirements that ensure that the offsets meet federal requirements, ie. :

a ) That the offsets are in effect by the time of permit issuance and enforceable by the

time the source commences operat ion ;

b ) That the offsets are based on real reductions in actual emissions ; and

c ) T hat emission reductions must be surplus to other Part D offset requirements

(CAA § 173(c))

.

2. The definition of Regulated NSR Pollutant needs to include any language to s atisfy the

provision in 40 CFR 51.165 (a)(1)(xxxvii)(D). To correct this, SCAQMD must addStaff Report

Proposed A mended Rule 1325 Page 2 December 2014 substantially equivalent language to either the definition of Regulated NSR Pollutant or

the definition of 

### PM 2.5

.

3. There are no provisions to implement the enforcemen t procedures of 40 CFR 51.165

(a)(5)(i) to provide that issuance of an approval to construct shall not relieve any owner

or operator of the responsibility to comply fully with applicable provisions of the plan

and any other requirements under local, State or Federal law.

( Staff is treating this comment as pertaining to permits. It should also be noted that a ll

SCAQMD permits have contained this language for decades, but there is no specific rule

provision so stating )

.



### In response to their request, SC AQM D staff has proposed amendments to the rule to address

the U.S. EPA comments

.



### PROPOSED MODIFICATIONS TO RULE 1 325

Applicability (a)

A clarification is included to specify that the rule applies to PM 2.5 

### and its precursors.

Definitions (b)

(b)(3)

- Lowes t Achievable Emission Rate (LAER)

The definition for (LAER) will be deleted as 40 CFR 51.165 is already referenced in the

rule

.

(b)( 7 )

– PM 2.5



### The definition for PM 2.5 

### has been modified to indicate that gaseous emissions which

condense to form PM 2.5 

### at am bient temperatures are also to be included as PM 2.5 

### . The

rule section which contains applicable testing requirements is also specified. This

amendment addresses the second issue identified by U.S. EPA in their March 10, 2104

correspondence.

However, s ta ff’s analysis concluded that all of the applicable sources ( Major Polluting

Facilities actual or potential to emit 100 ton s or greater per year of VOC or ammonia)

make up a small fraction of the overall contribution of gaseous emissions contributing to

amb ient levels of PM2.5. As shown in Table 1 below, all of the Major Polluting

Facilities ’ VOC or ammonia emissions contribute less than two percent of the overall

c ontributions from these potential precursors

. Furthermore, both VOC and ammonia

emissions ar e subject to BACT under the existing NSR at a zero threshold, so those

emissions will still be minimized. VOC emissions are also required to be offset when aStaff Report

Proposed A mended Rule 1325 Page 3 December 2014 

### new or modified source has the potential to emit four tons per year or more of VOC,

which is well below the PM2.5 rule level that would require offsets. So the only practical

difference is that any new or modified source of 100 ton s per year or more of ammonia

will not need offsets. It is staff’s opinion that this showing comports with the

requireme nts of Section 189 (e) of the CAA , such that EPA should find that VOC and

ammonia are not required to be treated as precursors of PM2.5 under this rule

.

Table 1

– Gaseous Emissions Contributions

Pollutant All Sources

(tons per day) Major Polluting Facili ties

(tons per day) Relative

Contribution

Ammonia 99 1 

### 1.7 2 

### 1.7%

VOC 451 3 

### 8.0 2 

### 1.8%

1. ARB Almanac 2013

– Appendix B: County Level Emissions and Air Quality by Air Basin ; County Emission Trends

and Forecasts 2012 Emissions

2. 2013 SCAQMD Annual Emission Report ing

3. 2012 AQMP

- Appendix III: Base and Future Year Emission Inventory; 2014 Annual Average Emissions by Source

Category in South Coast Air Basin



### Requirements (c)(3)

A provision is included to specify that approval to construct does not relieve owners and

operators of the responsibility to comply fully with applicable provisions of the permit and

other requirements under local, State or Federal law

. This amendment addresses the third

issue identified by U.S. EPA in their March 10, 2014 correspondence.

Exc lusions (i)

Rule 1315

– Federal New Source Review Tracking System is included to denote that the

provisions in Rule 1315 do not apply to Rule 1325. The provision that stated that Rule 1325

applied as opposed to other Regulation XIII rules was removed. The removal clarifies that

Rules 1306

– Emission Calculations and 1309

– Emission Reduction Credi ts and Short Term

Credits apply, which addresses the first issue identified by U.S. EPA in their March 10, 2014

correspondence , i

. e. th at the program specifica lly require offsets to meet federal CAA

requirements, because Rules 1309 and 1306 include these requirements

.

M inor corrections of typographical errors are also included in the proposed amended rule

.Staff Report

Proposed A mended Rule 1325 Page 4 December 2014 

### EMISSION IMPACT ASSESSMENT

The proposed amendments are administrative in nature and will not impact the emission

inventory nor result in any emission reductions.



### SOCIOECONOMIC IMPACT ASSESSMENT

The proposed amendments to Rule 1 325 do not significantly affect air quality or emission

limitations and therefor e a socioeconomic impact analysis pursuant to California Health and

Safety Code Sections 40440.8 and 40728.5 is not required.

Cost a nd Cost

- Effectiveness

The proposed amendments will not result in additional costs to industry. Since there is no

additiona l cost and no change in emissions, cost effectiveness is not applicable.

Incremental Cost

- Effectiveness

Under Health and Safety Code Section 40920.6, the SCAQMD is required to perform an

incremental cost analysis when adopting a Best Available Retrofit C ontrol Technology

(BARCT) rule or feasible measure required by the California Clean Air Act. To perform this

analysis, the SCAQMD must (1) identify one or more control options achieving the emission

reduction objectives for the proposed rule, (2) determin e the cost effectiveness for each

option, and (3) calculate the incremental cost effectiveness for each option. To determine

incremental costs, the SCAQMD must “calculate the difference in the dollar costs divided by

the difference in the emission reducti on potentials between each progressively more stringent

potential control option as compared to the next less expensive control option.”

Proposed Amended Rule 1 325 addresses administrative issues identified by the U.S. EPA.

The proposed amended rule does not implement a BARCT rule or a feasible measure

required by the California Clean Air Act. Thus an incremental cost analysis is not required.



### CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

The SCAQMD has reviewed the proposed project pursuant to CEQA Gui delines §15002

(k)(1)

- General Concepts, the first step of a three

- step process for deciding which document

to prepare for a project subject to CEQA. The SCAQMD has determined that that it can be

seen with certainty that there is no possibility that the proposed project may have any

significant effects on the environment, and is therefore, exempt pursuant to CEQA

Guidelines §15061

- Review for Exemption, paragraph (b)(3)

– “general rule” exemption

.Staff Report

Proposed A mended Rule 1325 Page 5 December 2014 

### A Notice of Exemption has been prepared pursuant to CEQA Guidelines §15062

- Notice of

Exemption. If the proposed project is approved, the Notice of Exemption will be filed with

the county clerks of Los Angeles, Orange, Riverside and San Bernardino counties.



### COMPARATIVE ANALYSIS

A comparative analysis is not applicable for Proposed Amended Rule 1325 as the SCAQMD

is adopting the federal mandated requirements for PM 2.5 

### NSR. Proposed Rule 1325 does not

impose a new emissions limitation or standard or make an existing emissions limitation or

standard more stringe nt.



### PUBLIC PROCESS

A public consultation meeting was held on September 23, 2014. Written comments on the

proposal were requested by October 8, 2014. As of October 24, 2014, no comments had

been received

. A comment letter was received on October 28, 20 14 and staff responses are

shown on page 12 of this staff report in the “Comment Letter 1 “ section

.



### EPA COMMENTS AND RESPONSES

The following comments and SCAQMD staff responses address the concerns of U.S. EPA

staff, included in their March 10 , 20 14 e

- mai l.

Comment : Although Rule 1325 Section (c)(1)(B) states offsets are required, it does

not contain any specific requirements that ensure these emissions offsets

are in effect by the time of permit issuance and enforceable by the time the

source commences operation, as required by CAA section 173(c)(1). Thus,

we find Rule 1325 is deficient with respect to the CAA 173(c)(1)

requirement that the rule contain provisions to ensure offsets are in effect

by the time of permit issuance and enforceable by the time the source

commences operation.



### Comment : Although Rule 1325 Section (c)(1)(B) states that offsets are required, it

does not contain any specific requirements that ensure these offsets are

based on real reductions in actual emissions as required by CAA se ction

173(c)(1). Thus, we find Rule 1325 deficient with respect to the CAA

173(c)(1) provision that requires emission increases to be offset by real

reductions in actual emissions.Staff Report

Proposed A mended Rule 1325 Page 6 December 2014 

### Comment: Rule 1325 does not contain any specific requirements that satisfy CAA

173(c)(2) which essentially states that emissions reductions must be

surplus to other part D requirements. Thus, we find Rule 1325 is deficient

with respect to the CAA 173(c)(2) requirement that the rule contain

provisions to prevent emissions reducti ons otherwise required by the Act

from being credited for purposes of satisfying the part D offset

requirements.



### Staff Response: Staff has proposed to revise the “Exclusion” section of the current rule

by removing t he provision that Rule 1325 applied and o ther provisions

of Regulation XIII rules did not

. Furthermore, staff is adding a

reference to Rule 1315

– Federal New Source Review Tracking System

in the “Exclusion” section.

Comment: Definitions which contain language which is either identical or equiv alent

to that found in CAA Sections 169, 169A(g) and 171, and in 40 CFR

51.100 and 51.165(a)(1).

The definition of Regulated NSR Pollutant is deficient because it does not

include any language to satisfy the provision in 51.165 (a)(1)(xxxvii)(D)

which sta tes:

“PM 2.5 emissions and PM 10 emissions shall include gaseous emissions

from a source or activity which condense to form particulate matter at

ambient temperatures. On or after January 1, 2011 (or any earlier date

established in the upcoming rulemaking codifying test methods), such

condensable particulate matter shall be accounted for in applicability

determinations and in establishing emissions limitations for PM 2.5 and

PM 10 in nonattainment major NSR permits. Compliance with emissions

limitations for P M 2.5 and PM 10 issued prior to this date shall not be based

on condensable particulate matter unless required by the terms and

conditions of the permit or the applicable implementation plan.

Applicability determinations made prior to this date without accou nting

for condensable particulate matter shall not be considered in violation of

this section unless the applicable implementation plan required

condensable particulate matter to be included.”Staff Report

Proposed A mended Rule 1325 Page 7 December 2014 To correct the above deficiency, SCAQMD must add substantially

equivalent language to either the definition of Regulated NSR Pollutant or

the definition of PM 2.5

.



### Staff Response: Staff has modified the definition of PM 2.5 

### to address this concern by

adding “Gaseous emissions which condense to form PM 2.5 

### at ambient

te mperatures shall also be included as PM 2.5



### . ”

Comment : Provisions to implement the enforcement procedures of 40 CFR

51.165(a)(5)(i) to provide that issuance of an approval to construct shall

not relieve any owner or operator of the responsibility to comp ly fully

with applicable provisions of the plan and any other requirements under

local, State or Federal law. We could not find any provisions in Rule 1325

to satisfy this requirement. Thus, we find Rule 1325 deficient with respect

to the requirements of 40 CFR 51.165(a)(5)(i).



### Staff Response: Staff is proposing a new provision under 1325 (c)(3) to denote that

approval to construct shall not relieve any owner or operator of the

responsibility to comply fully with applicable provisions of the plan and

any o ther requirements under local, State or Federal law

.

### C O M M E N T L E T T E R 1

Western States Petroleum Association

October 28, 2014Staff Report

Proposed Amended Rule 1325 Page 8 December 2014 Cr

e

dible S olutio n

s • Respo n

si v e Se r vice • S ince 1 9 0

7

P at t y S e n e cal

M a n a g e r

, S o u th er n Califo r nia R e gion a n d I nf r ast r uct ur e I ssues

V I A E L ECT R O N I C M A IL

O c tober 28, 2014

Mr. Mike Mor r is

S outh C o a st Air Q u a l i t y Mana g e ment Distri c t

21865 Copl e y D r i v e

Di a mond B a r, CA 91765

R e : P r o p osed Ru l e 1325, F ed er al P M 2.5 N e w S o u r c e R e view P r og r a m

Mr. Mike Mor r is:

W e ste r n S tat e s P e trol e um Asso c iation (W S P A) is a no n

- p r o f it tr a de a ssoci a t i on r e p re s e nt i ng tw e n t y

- six

c ompani e s that e x plore f o r

, p r odu ce

, refin e

, t r a n s port a nd ma r k e t p e trol e u m, p e trol e um p r odu c ts,

n a tur a l g a s a nd other e n e r g y suppli e s in C a l i fo r nia, A r i z on a

, N e v a d a

, O re g on, a nd Wa shin g ton. WSP A

memb e r c ompani e s op e r a te p e trol e um refin e ri e s a nd other f a c i l i t ies in the S outh Co a st Air B a sin whi c h

is t h e re a son for the foll owing c om m e nts.

This c om m e nt letter is b e ing submi t ted reg a rdi n g the p r opos e d a mend m e n t to Rule 1325

– Fe d e r a l

P M2.5 N e w S our c e R e vi e w P r o g r a m, d a ted 4 S e ptemb e r 201 4

. The purp o s e of the a m e ndment is to

inco rpo r a te c o r re c t i ons to the Rule re ce nt l y re c om m e nd e d b y the U. S

. Environm e ntal P rot ec t ion

Ag e n c y ( E P A) re g a rding o f f

s e t r e quir e ments, the d e finit i ons for R e g ulat e d NSR P ol l u tant a nd

P M2.5, a nd e n f o r c e me n t p r o ce dur e s. S p ec ific a l l y

, th i s a mendm e nt would mod if y the d e finit i on for

P M2.5 t o includ e “ g a s e ous e m i ss i ons that c ond e nse to fo r m P M2.5 a t a mb i e nt temp e r a tu r e s

. ” WSP A is

c on ce rn e d that p r opos e d c h a n g e of t h is d e finit i on m a y c r ea te c onfusion in the p r opo s e d ru l e re g a r ding

w h a t is inclu d e d a s c ond e n s a ble P M2.5; a s oppos e d t o p rec u r s o r e m i ss i on s, a nd in wh a t p h y si c a l

s t a te the mass of such e m i ss i ons a re to be q u a nt i fi e d.

The S outh Co a st Air Q u a l i t y Ma na g e ment Distri c t (S C A Q MD) a dopt e d Rule 1325

– Fe d e r a l

P M2.5 N e w S our c e R e view P r o g r a m on 3 J une 2011 to inco rp o ra te U.S. EPA r e qui r e me n ts for P M2 .5

in t o i t s N e w S ource R e view ( N S R) re g ulati o ns. The rule a ppl i e s to major pol l ut i ng fa c i l i t ies a nd

inco rpor a tes f e d e r a l r e quir e ments re g a rdi n g t h e d e finit i on of major so u r c e

, si g n ific a nt e m i ss i on r a tes,

o f

fs e t r a t i os, a nd the a ppl i ca bi l i t y r e qu i r e ments of L A ER, f ac i l i t y c omp l ian c e

, o f f

s e ts, a nd c ontrol of

P M2.5 p rec u r s o rs. Major pol l ut i ng f ac i l i t ies a re d e fin e d b y rule a s sour ce s with ac t u a l e m i ss i ons, or

the potential to e m i t, 100 tons p e r y e a r or more of P M2.5 or its pr e c u r sors.Proposed Amended Rule 1325 Page 9 December 2014 I n M a r c h 2014, the U.S. EPA r e vie we d Rule 1325 for S tate I mp l e ment a t i on P lan

a ppro va bi l i t y a nd spe c ified thr e e c o rr e c t i ons with r e s p ec t t o the Cle a n Air A c t . Th e se a r e a s

follows:

1) Thou g h o f f

s e ts a re r e q u ir e d b y Rule 1325 (c ) ( 1 ) ( B ), no spe c ific la n g u a ge e nsur e s that

the o f fs e t s me e t f e d e r a l r e quir e m e nts. Th e r e f o re r e qu i r e ments that o f fs e ts a re in e f f

e c t b y

t he t i me of p e rmit is s u a n ce

, b a s e d on r e a l r e d u c t i ons in ac tual e m i ss i ons, a nd a re

surplus to other P a rt D o f fs e t r e qui r e ments should be includ e d in t he Rule.

2) The d e fini t ion of R e g ul a t i on NSR P ol l utant or P M2.5 must include lan g u a ge to

s a t i s f y the p r ovis i on in 40 C F R 51.165 (a ) ( 1 ) ( x x x v i i ) ( D )

, whi c h stat e s that

e m i ss i ons of P M2.5 shall include g a s e ous e m i ss i ons that c ond e nse to f o rm

p a rtic u late matter a t ambient t e mpe ra t u r e s

.

3) P rovisions to e nsure that is s u a n c e of a n a p p rov a l to c onstru c t shall not r e l i e ve a n y

o wn e r o r op e r a t or of the r e spons i bi l i t y to c omp l y ful l y with a ppl ic a ble p r ovis i ons

of the plan a n y other r e quir e m e nts un d e r lo c a l, S tat e , or F e d e r a l la w should be

i n c luded in the r u l e a s per 40 C F R 51.165 ( a ) ( 5 ) (i )

.

To a ddr e ss t he s ec ond c o r rec t i on, S CA Q MD h a s p ropos e d to am e nd the d e f in i t i on f o r PM2.5

t o inc l ude g a s e ous e m i ss i ons that c ond e nse to fo r m P M2.5 a t a m bi e nt temp e r a tur e s. Ho w e v e r,

the rule do e s not s p ec i f y whi c h e m i ss i ons a re to be c ons i d e r e d a s co n d e n s a ble PM2.5, a s

opposed to p r e c u r sors, a nd in wh a t p h y sic a l s t a te those e m i ss i ons a re to be m ea sur e d. T h e re is

potential for double c ount i n g b e tw e e n p r e c u r sor e m i ss i ons a nd c ond e nsable P M2.5 e m i ss i ons,

spe c i f ic a l l y a double c ount i ng of N O x a nd S Ox whi c h c ould be c ounted in a g a s e ous s t a te

a s p r e c u rs o rs a s w e ll a s in s ol i d

- state a m m onium salts as c ond e nsable P M2.5.

WSP A r e c om m e nds that S CA Q MD inco rp o r a te a n e w d e finit i on for “ Cond e nsable P M2.5”

in Pr opos e d Ru l e 1325, whi c h would e xpl i c i t l y be l i m i ted to s e m i

- volati l e o r g a n i c c o mpounds

that c ond e nse a t a mb i e nt temp e r a tu r e s a s w e ll a s a m m onia. L a n g u a ge in the rule should a lso

c la r i f y that Cond e nsable P M2.5 e m i ss i ons shall be qu a nt i fi e d in t h e ir g a s e ous stat e in o rd e r to

a void double c ount i n g

, with s e m i

- vol a t i le o r g a nic c ompounds qu a nt i fi e d a s meth a n e

, a nd that

Co n d e nsable P M2.5 e m i ss i o ns shall e x c lude N O X a nd S OX b y d e finit i on. W i t h the a ddi t ion

of a d e finit i on for Cond e nsable P M2.5, it i s r e c om m e nd e d that the d e finit i on for P M2.5 be

r e vised to ind ica te that P M2.5 includ e s Cond e nsable P M2.5 e m is s ions a s d e fin e d in the Rule,

r a ther than a n y “ g a s e ous e m i ss i ons” that c ond e nse fo r m P M2.5 at a mb i e nt t e mpe r a tur e s.

L a st l y

, WSP A r e c om me nds that the discussion r e g a rding the d e finit i on of P M2.5 be r e vised in

the S ta f f R e port for P ropos e d Rule 13 2 5. This discussion sho u ld r e fl e c t the re c om me nd a t i ons

h e r e in reg a rdi n g a s e p a r a te d e finit i on f o r Cond e n s a b le PM2.5. This d i s c uss i on a lso n e e ds to be

re vi s e d to i n c lude the f a c t t h a t the U

. S . EPA is de f in i ng volati l e o r g a n ic c ompounds a nd

a m m o nia a s co n d e n s a ble PM2.5.

Th a nk y o u in adv a n c e f o r y o u r c onsid e r a t i on of these c om m e nts and r ec o m mend a t i ons.

S inc e r e l y

, 1

- 1

1

- 2

1

- 3Proposed Amended Rule 1325 Page 10 December 2014 

### Response to Comments

1

- 1 Rule 1325 implements federal requirements for major sources of PM 2.5 and its

precursors. Precursors to PM 2.5 are NOx and SOx as detailed in definition (b)(8).

To implement federal requirements, the rule mirrors US EPA language and by and

large incorporates 40 CFR 51.165. The proposed amendme nts do not change the

definition of precursors nor change the test method. To wit, t he test method that

ex is ted prior to th is amendment has not been changed nor have the compounds

considered to be condensable PM2.5. The test method in the rule is the US E PA

required test method for PM 2.5.

The test method for PM2.5 includes condensables as those compounds that condense

to form particulate matter at ambient temperatures as specified in the WSPA letter

Item #2. This was addressed by EPA through the recent revision to EPA Method 202

to include, among other changes, collection of the sample at ambient temperatures.

Gaseous emission s such as NOx and SOx are measured separately. EPA has

determined that Method 202 shall be used to determine emissions that are considered

as directly emitted PM and that the gaseous precursors are measured by a different

test method and considered independently under the rule. As each pollutant is

addressed by itself concerning the applicability of Rule 1325, there should not be any

double counting of pollutants.

1

- 2 The definition for PM 2.5 is as requested by US EPA. PM 2.5 emissions are defined

as those measured by the US EPA reference test method.

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- 3 Condensable emissions are those that are measured by the US EPA test met hod as

specified in section (h) of the rule. There are no specific requirements in the rule for

VOC or ammonia as neither is considered a precursor to PM 2.5 as noted in response

to comment 1

- 1.