August 26, 1996

Draft Summary

August 21, 1996 Base Programs Analyses and Policies Work Group Conference Call

I.	OVERVIEW

The Base Programs work group held a conference call on August 21, 1996 to discuss the issue paper on "Integration of NAAQS Implementation Programs".

II.	PARTICIPANTS

Work group:

Jerry Golden-Chair, Joe Paisie-Chair, David Baron, Vince Brisini, John Crouch, Jeff Gabriel, Robert Kappelmann, Dennis Lawler (substitute), Arthur Lee, Brock Nicholson, Bob Palzer, Steve Pezda, Greg Schaefer, Jim Salvaggio, Eric Skelton, Herb Williams (substitute), and Jean Vernet.

Work group members not in attendance:

Glen Cass, Gregory Dana, Richard Dworek, Steve Gerritson, Rich Halvey, Dick Long, Richard Phelps, Don Pickrell, Jim Ralston, Conrad Schneider, and Mel Zeldin.

Other attendees:

Beth Friedman (EC/R--Environmental Protection Agency (EPA) contractor support).

III.	ACTION ITEMS

Upcoming Calls and Meetings. The Base Programs work group will hold a face-to-face meeting on August 27 and 28, 1996 in Durham, North Carolina to prepare for the September 26 and 27 Federal Advisory Committee Act (FACA) subcommittee meeting in Norfolk, Virginia. A representative from the National and Regional Strategies (NRS) work group will be asked to attend.

IV.	MEETING SUMMARY

Integration of NAAQS Implementation Programs

Bob Kappelmann presented an overview of the draft issue paper titled Integration of NAAQS Implementation Programs and updated the group on the status of the integrated version of the paper that is being developed by the NRS work group. The NRS paper is located on the EPA Technology Transfer Network (TTN) bulletin board for review and comment, and it contains ideas from both the Science and Technical Support (STS) and Base Programs work groups. The group agreed that having a representative from NRS to discuss this issue would be helpful at the upcoming face-to-face meeting.

Mr. Kappelmann's paper is designed to pull together the discussion of the Base Programs group on the integration of the implementation programs. The current version focuses on issue identification and option development. At this point, conclusions have not been added. The paper presents the historical background of National Ambient Air Quality Standards (NAAQS) implementation and notes that the new NAAQS provide an opportunity to integrate the implementation. Areas for potential integration include monitoring, compliance strategies and programs, timelines and milestones, and related national programs and initiatives. The paper also presents options related to discouraging the inappropriate uses of integration.

Mr. Salvaggio supports the idea of integrated monitoring and noted that it is particularly important in cases where transport is a key contributor. Monitoring to identify local problems is less likely to require integrated sampling. Mr. Kappelmann noted that there is disagreement about whether local contributions or transport drives the problem in a given area.

Mr. Pezda said the paper should also address the regional nature of secondarily formed fine particulate matter (PM-fine). Mr. Kappelmann said, while the literature shows that secondarily formed PM-fine does play a role in regional transport, it does not preclude the possibility that small primary PM-fine particles are not transported. Mr. Paisie said data from the IMPROVE network identifies a mixture of primary and secondary PM-fine in the East, and PM-fine from burning seems to play a large role in long-range transport in the West. Mr. Pezda clarified there is a need to distinguish between primary and secondary PM-fine, when it is relevant.

The group then discussed the importance of obtaining speciated PM data. Mr. Kappelmann said speciated data could play a role in developing control strategies and in making qualitative judgements regarding health impact data. For example, having an organic component or being water soluble could make a difference in health impacts. Mr. Palzer noted that in the case of asbestos and fiberglass health impacts are driven solely by particle size.

Mr. Schaefer asked what type of monitoring is envisioned in the NRS integrated paper. Mr. Kappelmann said these details have not been addressed, but an outcome could be to provide new ideas for guidance to EPA. Mr. Paisie suggested that this is an issue for the science group. Mr. Golden suggested that a benefit of co-location of monitors would be to encourage the use of monitoring data to measure progress and as a means of prioritizing integrated control options. Mr. Kappelmann said guidance would be needed on when co-location is beneficial, neutral, or counterproductive.

Mr. Brisini said the language in the integration of compliance strategies discussion is too vague and sweeping. He noted that he has never been required to retrofit new controls because of subsequent regulatory requirements, but the paper claims this is a frequent occurrence. A larger issue is that integration of compliance strategies itself should be viewed more broadly. The issue is not just avoiding unreasonable demands on individual sources with changing requirements. The key is that integration is needed between source categories. For example, programs to encourage diesel fuel in one sector are appropriately considered with a need to reduce PM-fine from other sectors. Mr. Brisini said the focus should be on measuring the air quality benefits of a wide variety of programs.

Mr. Kappelmann said the utility industry is facing control decisions for future requirements that conflict those designed to meet other (recent) requirements. Mr. Golden and Mr. Paisie suggested revising the paper to clarify that this could be an issue in some cases. Mr. Brisini does not want to say that intermediate steps are never appropriate. A market-based system could resolve this problem by allowing sources to select the most attractive strategies first.

Mr. Paisie asked whether the overall integration issue has both a regional and local component and whether this is more of a Phase I or a Phase II issue. Mr. Kappelmann's goal is to have the integrated paper reflect the (new NAAQS) Phase I timeline. Mr. Palzer agreed this is a Phase I issue and supports a broad view of integration.

Mr. Kappelmann stressed that integrating compliance programs does not necessarily result in common dates.

Mr. Pezda said there are such fundamental differences between ozone and PM that, except for monitoring, he sees no point in integration at all. Mr. Golden said integration for designation, compliance plan dates, etc. could still be useful. As for the integration of attainment dates, this issue will be developed in the "Attainment Dates" issue paper.

The group then discussed whether ozone planning should be delayed in areas where common problems are perceived to exist to allow time to gather and assess the needed PM data. Mr. Kappelmann said the Clean Air Power Initiative (CAPI) provides a "safe harbor" for sources taking actions in the face of regulatory uncertainty. Similarly, the early reductions program for air toxics provides relief for sources taking early reductions to maximum achievable control technology (MACT) emissions limitations. Mr. Golden added that there could also be delays in obtaining the necessary ozone data if monitors have to be added or moved. Mr. Paisie noted there will be pressure to implement the new ozone standard despite possible long-term benefits of delaying implementation to ensure coordination. Mr. Golden suggested the interim implementation plan (IIP) should be able to address the need for a continuing ozone program and still allow integration of implementation of the new NAAQS to occur. He noted that designation and State implementation plan (SIP) issuance timelines could be the same, but that implementation timelines could vary between the pollutants. Mr. Lee would like to stay away from integrating implementation timelines, because integration is not always warranted. Mr. Brisini said there is a need to address the effects of multiple programs in developing implementation timelines.

Mr. Pezda said a SIP cannot be developed without speciation data on fine particles and without more information on health effects. Mr. Golden said the states will have (up to) three years to address the state of knowledge and that health effects are taken care of in the form of the standard. Mr. Palzer added that the form of the standard will still be set on the size of the PM, and control strategies will need to be developed on that basis. Mr. Paisie suggested a review of IMPROVE data might help address some of these issues.

Mr. Salvaggio noted there will be benefits from the ozone program that will help address PM-fine. Mr. Baron saw no need to slow down one program to coincide with another program. Mr. Salvaggio responded there are inevitable schedule consequences of trying to address PM-fine. However, there are also inevitable ozone program developments, such as the Ozone Transport Assessment Group (OTAG) nitrogen oxides (NOx) reductions, that will affect PM-fine. Mr. Baron recognizes that integrating when there are common sources makes sense. However, he said the absolute need for different timelines has not been established. For example, it should be possible to obtain speciated PM-fine data, if needed. Mr. Lee agreed that not delaying the ozone timeline is reasonable, but said obtaining speciated data is very difficult and a Federal reference method is still needed. Mr. Lee is concerned about focusing controls on the wrong component. Mr. Paisie clarified that the new NAAQS will not be chemical specific, but there will be a need for this information in the future.

Mr. Kappelmann concluded that measures under the ozone and PM-fine programs will provide reasonable further progress for the regional haze program.