1
"
Emission
inventory
analysis
for
39
PM2.5
Nonattainment
Areas,"
memo
by
Richard
Damberg
to
docket
OAR­
2003­
0062.
Draft
8/
19/
05
Revised
RACM
source
category
section
16.
What
specific
source
categories
and
control
measures
should
a
State
evaluate
when
determining
RACM
for
a
nonattainment
area?
Section
172
does
not
provide
a
specific
list
of
source
categories
and
control
measures
that
must
be
evaluated
for
RACM
for
PM2.5.
In
order
to
provide
further
guidance
to
States
in
the
form
of
a
starting
list
of
source
categories
to
consider
in
a
RACM
analysis,
we
reviewed
2001
national
emission
inventory
information
for
the
more
than
200
counties
comprising
PM2.5
nonattainment
areas.
We
have
identified
the
detailed
stationary,
mobile,
and
area
source
categories
that
are
major
contributors
to
total
emissions
of
PM2.5
and
its
precursors
in
these
counties.
1
Based
on
our
review
of
this
emission
inventory
data
and
air
quality
monitoring
data
from
the
speciation
trends
network,
we
recognize
that
a
wide
variety
of
source
categories
contribute
to
PM2.5
concentrations
in
nonattainment
areas
across
the
country.
However,
it
is
also
apparent
that
certain
source
categories
(
such
as
electric
generating
units
and
diesel
engine
emissions)
are
common
contributors
to
the
PM2.5
problem
in
virtually
all
nonattainment
areas.
We
have
also
reviewed
a
wide
variety
of
information
sources
to
identify
available
control
measures
for
many
of
these
categories.
Based
on
this
analysis,
a
list
of
potential
RACM
measures
is
included
at
the
end
of
this
section.
Emission
reduction
measures
constituting
RACM
should
be
determined
on
an
area­
by­
area
basis.
We
believe
that
a
State
should
consider
each
of
the
measures
listed
in
this
section
to
determine
if
each
measure
is
reasonably
available
in
the
applicable
nonattainment
area.
However,
under
current
EPA
policy
we
do
not
presume
that
each
of
these
measures
is
reasonably
available
in
each
nonattainment
area.
We
propose
that
each
State
use
the
list
of
source
categories
in
this
section
as
a
starting
point
for
identifying
potentially
available
control
strategies
for
a
nonattainment
area.
States
are
encouraged
and
expected
to
add
other
potentially
available
measures
to
the
list
based
on
its
knowledge
of
the
particular
universe
of
emissions
sources
in
the
area
and
comments
from
the
general
public.
We
expect
that,
depending
on
the
potential
measure
being
analyzed,
the
State's
degree
of
evaluation
will
vary
as
appropriate.
Stationary
source
measures
­
Stationary
diesel
engine
retrofit,
rebuild
or
replacement,
with
catalyzed
particle
filter
2
See
Clean
School
Bus
USA
program
at
http://
www.
epa.
gov/
cleanschoolbus/.
See
also:
"
What
You
Should
Know
About
Diesel
Exhaust
and
School
Bus
Idling",
(
June
2003,
EPA420­
F­
03­
021)
at
http://
www.
epa.
gov/
otaq/
retrofit/
documents/
f03021.
pdf.

3
See
EPA's
voluntary
diesel
retrofit
program
web
site
at
http://
www.
epa.
gov/
otaq/
retrofit/
overfleetowner.
htm.

4
See
EPA's
voluntary
diesel
retrofit
program
web
site
at
http://
www.
epa.
gov/
otaq/
retrofit/
idling.
htm.

5
See
EPA's
website
on
transportation
control
measures
at
http://
www.
epa.
gov/
otaq/
transp/
traqtcms.
htm.
­
New
or
upgraded
emission
control
requirements
for
direct
PM2.5
emissions
at
stationary
sources
not
covered
by
RACT
(
e.
g.,
installation
or
improved
performance
of
control
devices
such
as
a
baghouse
or
electrostatic
precipitator;
revised
opacity
standard;
improved
compliance
monitoring
methods)
­
New
or
upgraded
emission
controls
for
PM2.5
precursors
at
stationary
sources
not
covered
by
RACT
(
e.
g.,
year­
round
NOx
controls
such
as
low
NOx
burners,
selective
catalytic
reduction,
or
selective
non­
catalytic
reduction;
SO2
controls
such
as
wet
or
dry
scrubbers,
or
reduced
sulfur
content
in
fuel;
improved
compliance
monitoring
methods)
­
Improved
monitoring
of
emissions
controls
and
process
operations
at
stationary
sources
(
e.
g.,
continuous
emission
monitors,
improved
approaches,
and
compliance
assurance
monitoring
techniques)
­
Extension
of
seasonal
emission
controls
for
NOx
to
year­
round
operation
­
Energy
efficiency
measures
to
reduce
fuel
consumption
and
associated
pollutant
emissions
(
either
from
local
sources
or
distant
power
providers)
Mobile
source
measures
­
Onroad
diesel
engine
retrofits
for
school
buses2
and
trucks
using
EPA­
verified
technologies
­
Nonroad
diesel
engine
retrofit,
rebuild
or
replacement,
with
catalyzed
particle
filter3
­
Diesel
idling
programs
for
trucks,
locomotive,
and
other
mobile
sources4
­
Transportation
control
measures
(
including
those
listed
in
section
108(
f)
of
the
CAA
as
well
as
other
TCMs),
as
well
as
other
transportation
demand
management
and
transportation
systems
management
strategies5
­
Programs
to
reduce
emissions
or
accelerate
retirement
of
high
emitting
vehicles,
boats,
and
lawn
and
garden
equipment
­
Emissions
testing
and
repair/
maintenance
programs
for
onroad
vehicles
6
See
EPA's
web
site
on
nonroad
engines,
equipment,
and
vehicles
at
http://
www.
epa.
gov/
otaq/
nonroad.
htm.
­
Emissions
testing
and
repair/
maintenance
programs
for
nonroad
heavy­
duty
vehicles
and
equipment6
­
Programs
to
expand
use
of
clean
burning
fuels
­
Prohibitions
on
the
sale
and
use
of
diesel
fuel
that
exceeds
a
high
sulfur
content
­
Low
emissions
specifications
for
equipment
or
fuel
used
for
large
construction
contracts,
industrial
facilities,
ship
yards,
airports,
and
public
or
private
vehicle
fleets
­
Opacity
or
other
emissions
standards
for
"
gross­
emitting"
diesel
equipment
or
vessels
­
Reduce
dust
from
paved
and
unpaved
roads
Area
source
measures
­
New
open
burning
regulations
and/
or
measures
to
improve
program
effectiveness
­
Smoke
management
programs
to
minimize
emissions
from
forest
and
agricultural
burning
activities
­
Programs
to
reduce
emissions
from
woodstoves
and
fireplaces
­
Controls
on
emissions
from
charbroiling
or
other
commercial
cooking
operations
­
Reduced
solvent
usage
or
solvent
substitution
(
particularly
for
organic
compounds
with
7
carbon
atoms
or
more,
such
as
toluene,
xylene,
and
trimethyl
benzene)
­
Reduce
dust
from
construction
activities
and
vacant
disturbed
areas
We
request
comment
on
the
specific
sources
and
potential
control
measures
recommended
for
RACM
analysis
on
this
list.
Commenters
supporting
the
inclusion
or
exclusion
of
measures
for
this
list
should
provide
detailed
supporting
information
as
part
of
their
comments.
