On August 24, 2016, EPA issued final State Implementation Plan (SIP) requirements for the Fine Particulate Matter National Ambient Air Quality Standard (NAAQS). The rule requires states with nonattainment areas for particulate matter less than or equal to 2.5 micrometers (PM2.5) to amend their Nonattainment New Source Review (NNSR) regulations to include volatile organic compounds (VOC) and ammonia (NH3) as PM2.5 precursors. Currently, Pennsylvania's NNSR rules only include NOX and SO2 as PM2.5 precursors. Failure to submit the SIP revision results in the loss of highway funding and other sanctions.

The rule affects major facilities that trigger NNSR requirements and must to identify offsets. The amendments to the definition of major source include facilities with a potential to emit (PTE) of 100 tons per year of VOC or NH3 in a moderate PM2.5 non-attainment area or 70 tons per year in a serious PM2.5 non-attainment area.

On August 2nd, the Pennsylvania Department of Environmental Protection (PADEP) presented proposed amendments to 25 PA Code 121 definitions and 25 PA Code 127, Subchapter E regulations incorporating these federal requirements to the Air Quality Technical Advisory Committee (AQTAC). In Pennsylvania, the rule change affects Allegheny, Delaware and Lebanon counties, which are classified nonattainment at this time, though PADEP is preparing requests to reclassify Delaware and Lebanon counties as attainment and Allegheny County Health Department (ACHD) is preparing the attainment demonstration for its county.

The proposed amendments to 25 PA Code 121.1 establish VOC and NH3 as PM2.5 precursors, and establishes their significant emission rates for net emissions increase calculations under 25 PA Code 127.203a at 40 tpy each. The proposed amendments also include the Significant Impact Levels (SIL) of 0.2 ug/m3 for the PM2.5 annual standard and 1.2 ug/m3 for the 24-hour standard. The amendments establish the offset ratios for both precursors at a 1:1 ratio to PM2.5. This is the minimum ratio required for NSR programs and matches the established sulfur dioxide (SO2) and nitrogen oxides (NOx) offset ratios.

During its August 2nd meeting, AQTAC voted to pass the draft onto the Environmental Quality Board (EQB) for review, the next step in PADEP's regulatory promulgation process.

Please contact Wendy Merz, Principal Consultant at (610) 280-3902 x301 for more information on these proposed changes.