COARSE
PARTICULATE
MATTER
MEETING
JEFF
HOLMSTEAD
FEBRUARY
2,
2005
Background/
Introduction
 
This
meeting
builds
upon
an
earlier
meeting
in
October,
2003
and
a
follow­
on
with
OAQPS
in
August,
2004,
to
discuss
revision
of
the
ambient
air
quality
standards
for
coarse
particulate
matter
(
PM(
10­
2.5)
or
PMc).

 
In
these
meetings
our
concerns
have
addressed
questions
surrounding
the
scientific
and
technical
basis
to
go
forward
with
a
PMc
standard
at
this
time.

 
In
particular,
we
have
highlighted
the
existence
of
serious
regional
compliance
problems
with
such
a
standard
largely
resulting
from
fugitive
dust
emissions,
particularly
in
the
West.
1
 
Up
until
yesterday,
the
context
for
our
discussion
was
the
first
draft
Staff
Paper
(
SP),
which
raised
particular
concerns
resulting
from
broad
ranges
for
recommended
standards
that
did
not
appear
to
reflect
the
limitations
of
the
scientific
data
for
PMc,
as
reported
in
the
PM
Criteria
Document
(
CD)
and
related
deliberations
of
the
Clean
Air
Scientific
Advisory
Committee
(
CASAC).

 
The
PM
CD
is
now
complete.
The
new
draft
SP
sets
the
stage
for
further
interaction
between
CASAC
and
OAR
and
provides
an
opportunity
for
us
to
highlight
our
evolving
concerns.

 
The
current
PM10
standards
are
50
ug/
m3
(
annual)
and
150
ug/
m3
(
24­
hour).
The
new
draft
SP
recommends
consideration
of
a
new
24­
hour
PMc
standard
at
75
or
85
ug/
m3.
It
also
states
that
an
annual
standard
"
could"
be
considered
as
part
of
the
"
margin
of
safety,"
and
that
the
data
might
support
a
24­
hour
standard
as
low
as
30
ug/
m3,
though
that
would
give
great
weight
to
"
very
limited
and
uncertain"
epidemiological
evidence.

Coarse
Particulate
Matter
Discussion
Points
Annual
standard.
There
is
no
rational
basis
for
an
annual
standard
for
PMc.
Both
CASAC
and
the
PM
Criteria
Document
recognize
that
there
are
no
long­
term
health
data
for
PMc.
A
new
standard
cannot
be
justified
on
the
basis
of
adding
a
"
margin
of
safety"
when
a
primary
threat
to
public
health
has
not
been
shown.

24­
hour
standard.
EPA
should
consider
options
less
stringent
than
those
recommended
for
24­
hour
PMc
standards.
Both
CASAC
and
the
PM
CD
conclude
that
the
epidemiological
evidence
for
PMC
is
indeed
"
very
limited
and
uncertain."
The
final
CASAC
report
on
the
PM
CD
expresses
continuing
concern
with
the
limits
of
the
PMc
data,
and
three
key
CASAC
members
expressly
question
whether
the
data
are
sufficient
to
support
any
standard.

1
This
is
a
long­
standing
issue
that
OAR
has
been
well
aware
of
for
many
years.
2
PM10
equivalence.
The
new
draft
SP
justifies
the
24­
hour
recommendation
in
part
as
"
about
as
protective
as"
the
current
24­
hour
standard
for
PM10.
However,
at
least
three
key
CASAC
members
already
have
abandoned
the
"
equivalent
standard"
approach,
questioning
whether
any
standard
is
justified.
Further,
emissions
data
presented
to
CASAC
indicates
that
standards
at
the
recommended
levels
would
be
more
stringent
than
the
current
PM10
standards
at
some
operations.

Crustal
material.
EPA
should
consider
special
treatment
of
PMc
emissions
consisting
primarily
of
crustal
material.
CASAC
and
the
final
PM
CD
recognize
that
PM
emissions
consisting
primarily
of
crustal
material
have
not
been
shown
to
be
harmful
at
current
exposure
levels.
The
new
SP
recommendations
do
not
appear
to
take
this
finding
into
account.

Further
discussion.
We
would
appreciate
an
opportunity
to
discuss
these
issues
in
more
detail
upon
further
review
of
the
new
draft
SP.

131422_
1.
DOC
