1. Summary of EPA Proposal to Revise the PM NAAQS and Draft WRAP Technical Comments

2. PM2.5 Annual primary standard currently 15 ug/m3
No change in the proposal
Taking comment on 13 or 14 ug/m3
24-hr primary standard currently 65 ug/m3
Proposal would reduce to 35 ug/m3
Taking comment on ug/m3
Secondary standards would be equivalent
Taking comment on urban visibility standard of ug/m3 averaged over 4-8 daylight hours

5. PM2.5
Draft WRAP technical comments support secondary standard for urban visibility
Would have direct benefits to Class I areas impacted by urban areas

7. PM10 Proposal would revoke annual standard in all areas
Proposal would revoke 24-hr standard in all areas except in urbanized areas where:
Population is at least 100,000, and
At least one monitor is violating the standard
24-hr standard would remain in areas above until PM designations occur

8. Locations where EPA proposes to retain the 24-hr PM10 standard.

9. Current PM10 nonattainment areas where EPA proposed to revoke the 24-hr standard.

10. 69 PM10 nonattainment and maintenance areas in the WRAP region.

11. PM10
EPA taking comment on retaining 24-hr standard in areas with population less than 100,000
Draft WRAP technical comments support elimination of 100,000 population distinction

12. PM10-2.5
PM defined as:
Any ambient mix of PM that is dominated by resuspended dust from high-density traffic on paved roads and PM generated by industrial sources and construction sources.
This definition excludes any ambient mix of PM that is dominated by rural windblown dust and soils and PM generated by agricultural and mining sources.
Agricultural sources, mining sources, and other similar sources of crustal material shall not be subject to control in meeting this standard.

13. PM10-2.5
The indicator is not defined or limited to any specific geographic area, but includes a mix of PM in any location that is dominated by these sources.
24-hr primary standard set at 70 ug/m3
3-year average of 98th percentile
No annual primary standard
Secondary standards equivalent to primary
Does this protect visibility?

14. PM10-2.5 EPA taking comment on:
Alternative approaches for selecting level of PM standard
Selecting an unqualified PM indicator
Alternative approaches to retaining the 24-hr PM10 standard

15. Draft WRAP Technical Comments on PM10-2.5 Standard
Eliminate distinction of urban PM10-2.5
Eliminate exemption for ag, mining, and rural windblown dust
Without eliminating these two provisions, the ability to make reasonable visibility progress in Class I areas will be jeopardized
EPA should adopt a 24-hr PM standard in the range of ug/m3

16. Percentage of IMPROVE sample days between 1997 and 2002 when haze
from dust (coarse mass plus fine soil) is the largest component.

18. Annual PM10-2.5 concentration from the IMPROVE network for 2004.

19. Modeled windblown dust emissions for 2002.

20. Average 2002-04 98th percentile PM10-2.5 concentration values
for the IMPROVE Network sites.

21. PM10-2.5 98th percentile concentrations for sites with
three year mean values above 30 μg/m3.

22. Chiricahua NM Typical Visibility Day

23. Chiricahua NM Worst Visibility Day

24. Chiricahua NM Typical Visibility Day + 135 ug/m3 of PMcoarse

25. Chiricahua NM Typical Visibility Day + 100 ug/m3 of PMcoarse

26. Chiricahua NM Typical Visibility Day + 70 ug/m3 of PMcoarse

27. Chiricahua NM Typical Visibility Day + 50 ug/m3 of PMcoarse

28. PM10-2.5 Monitoring Only required in MSAs > 100,000 people
0-5 sites per MSA
sites across 150 MSAs
Emphasis on continuous mass conc. monitors
Additionally …
Non-required PM concentration sites to assess urban/rural differences
speciation monitors at urban/rural sites

30. PM10-2.5 Monitoring Draft WRAP technical comments
Too little emphasis on non-urban areas
Too little emphasis on speciation
EPA should endorse use of IMPROVE PM monitoring and support speciation of IMPROVE PM samples