Evaluation of the SO2 and NOX offset ratio method to account for secondary PM2.5 formation

The U.S. Environmental Protection Agency (EPA), state and local agencies have focused their efforts in assessing secondary fine particulate matter (aerodynamic diameter ≤2.5 µm; PM_2.5) formation in prevention of significant deterioration (PSD) air dispersion modeling. The National Association of Clean Air Agencies (NACAA) developed a method to account for secondary PM_2.5 formation by using sulfur dioxide (SO₂) and nitrogen oxides (NO_x) offset ratios. These ratios are used to estimate the secondary formation of sulfate and nitrate PM_2.5. These ratios were first introduced by the EPA for nonattainment areas in the Implementation of the New Source Review (NSR) Program for Particulate Matter Less than 2.5 Micrometers (PM_2.5), 73 FR 28321, to offset emission increases of direct PM_2.5 emissions with reductions of PM_2.5 precursors and vice versa. Some regulatory agencies such as the Minnesota Pollution Control Agency (MPCA) have developed area-specific offset ratios for SO₂ and NO_x based on Comprehensive Air Quality Model with Extensions (CAMx) evaluations for air dispersion modeling analyses. The current study evaluates the effect on American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) predicted concentrations from the use of EPA and MPCA developed ratios. The study assesses the effect of these ratios on an electric generating utility (EGU), taconite mine, food processing plant, and a pulp and paper mill. The inputs used for these four scenarios are based on common stack parameters and emissions based on available data. The effect of background concentrations also evaluates these scenarios by presenting results based on uniform annual PM_2.5 background values. This evaluation study helps assess the viability of the offset ratio method developed by NACAA in estimating primary and secondary PM_2.5 concentrations. An alternative Tier 2 approach to combine modeled and monitored concentrations is also presented.

Implications:

On January 4, 2012, the EPA committed to engage in rulemaking to evaluate updates to the Guideline on Air Quality Models (Appendix W of 40 CFR 51) and, as appropriate, incorporate new analytical techniques or models for secondary PM_2.5. As a result, the National Association of Clean Air Agencies (NACAA) developed a screening method involving offset ratios to account for secondary PM_2.5 formation. The use of this method is promising to evaluate total (direct and indirect) PM_2.5 impacts for permitting purposes. Therefore, the evaluation of this method is important to determine its viability for widespread use.