NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PARTICULATE MATTER: POTENTIAL IMPLICATIONS FOR PRESCRIBED FIRE IN KENTUCKY

Follow-up to the 6 th Annual Kentucky Prescribed Fire Council Meeting September 16, 2014, at WHFRTC Jennifer F. Miller Kentucky Division for Air Quality

National Ambient Air Quality Standards for Particulate Matter: Potential Implications for Prescribed Fire in Kentucky • This short PowerPoint seeks to provide participants at the Kentucky Prescribed Fire Council’s Annual Meeting with a quick overview of National Ambient Air Quality Standards and to provide context regarding the discussions that followed the committee break-out sessions.

National Ambient Air Quality Standards (NAAQS) • The Clean Air Act requires the EPA to set and revise National Ambient Air Quality Standards (NAAQS) for certain common pollutants, known as criteria pollutants. • Six criteria pollutants presently: • Sulfur Dioxide (SO2) • Nitrogen Dioxide (NO2) • Carbon Monoxide (CO) • Ozone (O3) • Lead (Pb) • Particulates • Particulate matter with a diameter of 2.5 microns or less (PM2.5) • Particulate matter with a diameter of 10 microns or less (PM10)

NAAQS: Primary Standards • Set at a level requisite to protect public health with an adequate margin of safety. • “Public health” includes the health of “sensitive populations,” such as asthmatics, children, and the elderly. Secondary Standards • Set at a level requisite to protect public welfare. • “Public welfare” includes protection against decreased visibility, as well as protection of crops, soils, animals, vegetation, and buildings.

Current National Ambient Air Quality Standards Pollutant Carbon Monoxide 8-Hour Average 1-Hour Average Lead Rolling 3-Month Average Nitrogen Dioxide Annual Average 1-Hour Average Particulate Matter (measured as PM10) 24-Hour Average Particulate Matter (measured as PM2.5) Annual Average 24-Hour Average Ozone 8-Hour Average Sulfur Dioxide 1-Hour Average 3-Hour Average

Primary Standard

Secondary Standard

9 ppm 35 ppm

-----------------

0.15 µg/m3

Same as primary

53 ppb 100 ppb

Same as primary ---------

150 µg/m3

Same as primary

12.0 µg/m3 35 µg/m3

15.0 µg/m3 Same as primary

0.075 ppm

Same as primary

75 ppb ---------

--------0.5 ppm

NAAQS: A criteria pollutant may have more than one primary standard and/or secondary standard in order to represent both short and long term exposure impacts. For example: • PM2.5 has two primary standards: • 24-Hour Standard • Annual Standard Pollutant Particulate Matter (measured as PM2.5) Annual Average 24-Hour Average

Primary Standard 12.0 µg/m3 35 µg/m3

Secondary Standard 15.0 µg/m3 Same as primary

PM2.5 also has two secondary standards, but secondary standards tend to be set a level that are either equal to or far less stringent than secondary standards.

NAAQS Revisions: Particulate Matter In December 2012, the EPA revised the NAAQS for particulate matter. Pollutant Particulate Matter (measured as PM2.5) Annual Average 24-Hour Average

Primary Standard 12.0 µg/m3 35 µg/m3

Secondary Standard 15.0 µg/m3 Same as primary

• The primary annual PM2.5 NAAQS was lowered from 15.0 ug/m3 down to 12.0 ug/m3.

• The primary 24-hour PM2.5 NAAQS was kept at 35 ug/m3.

Note: Micrograms per cubic meter (ug/m3 and µg/m3) are concentration units that represent the mass of a pollutant that can be found in one cubic meter of air.

PM2.5 NAAQS: Next Steps While a lot of information is considered, the EPA primarily uses the data collected at ambient air monitoring stations to determine if a county or group of counties is in compliance with a NAAQS.

• Attainment: All monitors in compliance • Unclassifiable (no monitors present) • Non-Attainment: One or more monitors exceed the NAAQS • Maintenance Area: An area formerly in non-attainment

Metropolitan Statistical Areas (MSAs) (The Other Piece of the Puzzle)

• MSA- County or counties associated with one or more urbanized areas with a population of 50,000 or more.  Some MSAs cross state

boundaries: Cincinnati,

OH-KY-IN Clarksville, TN-KY Evansville, IN-KY Huntington-Ashland, WV-KY-OH Louisville-Jefferson County, KY-IN  EPA may designate one or all

counties in an MSA as nonattainment, even if only one monitor is out of compliance and even if that monitor is in a different state.

PM2.5: Next Steps • EPA has recommended that portions of the Jefferson County, KY-IN MSA and the Cincinnati, OH-KY-IN MSA be designated as non-attainment for the 12.0 ug/m3 annual PM2.5 NAAQS. • Final designations will be issued by the EPA in December 2014.

Potential Implications (Not KY Specific): Source: Pete Lahm, USFS 1.

The lowering of the standard will result in new nonattainment areas which will: a. Require federal agencies using prescribed fire or conducting polluting activities in or near these areas to conduct a General Conformity Determination to ensure that they do not cause or worsen air quality violations or delay timely attainment of the standard; and, b. Make prescribed burning more difficult in or near these areas as all sources of PM 2.5 will be under greater scrutiny and impacts could be more regulated.

2. Tighter standards mean there are more instances when wildfire and prescribed fire could contribute to an exceedance of the standard.

Exceptional Events Rule • Air agencies can request that certain data be excluded from comparisons against a NAAQS if they can prove that the data was affected by an “Exceptional Event.” An Exceptional Event: • affects air quality • causes concentrations beyond normal historical fluctuation • is a natural event or is caused by a human activity that is unlikely to recur at a particular location • is not reasonably controllable or preventable • has a clear causal relationship to an exceedance Some examples of Exceptional Events:

Structural Fires

African Dust Transport

Demolition

Wildfires

Volcanic Eruptions

Fireworks

Exceptional Events Rule • Does not include meteorological conditions, such as drought, high temperatures, inversions, or stagnations.

Some examples of events that are not exceptional:

Drought

Vehicle Emissions

Industrial Emissions

High Temperatures

Construction

Inversions

Exceptional Events and Prescribed Fire If a State demonstrates to EPA's satisfaction that emissions from prescribed fires caused a specific exceedance, that data can be excluded from the data that determines an areas attainment status. Provided that: •it meets the definition of an “Exceptional Event”; and,

•the State has certified to EPA that it has adopted and is implementing a Smoke Management Program (SMP); or, •the State has ensured that the burner employed basic smoke management practices (BSMPs). Note: The terms best smoke management practices and basic smoke management practices are often used interchangeably.

Smoke tends to have the biggest impacts on particulates, especially PM2.5, and ozone... Pollutant Carbon Monoxide 8-Hour Average 1-Hour Average Lead Rolling 3-Month Average Nitrogen Dioxide Annual Average 1-Hour Average Particulate Matter (measured as PM10) 24-Hour Average Particulate Matter (measured as PM2.5) Annual Average 24-Hour Average Ozone 8-Hour Average Sulfur Dioxide 1-Hour Average 3-Hour Average

Primary Standard

Secondary Standard

9 ppm 35 ppm

-----------------

0.15 µg/m3

Same as primary

53 ppb 100 ppb

Same as primary ---------

150 µg/m3

Same as primary

12.0 µg/m3 35 µg/m3

15.0 µg/m3 Same as primary

0.075 ppm

Same as primary

75 ppb ---------

--------0.5 ppm

Prescribed Fire and Exceptional Events • The Exceptional Events Rule is a “back-up plan” should impacts occur despite a burner using best smoke management practices (BSMPs). • It can be difficult to get EPA-approval of an Exceptional Event. The best policy is to ensure that impacts don’t occur in the first place by using BSMPs. • If burners are using BSMPs, impacts should not occur except under the rarest of circumstances.

A Bit of Perspective... • What are our common smoke sensitive targets that we want to avoid impacting?  Schools  Hospitals  Nursing Homes  Roads  Airports  Class 1 Areas (Regional Haze)  Ambient Air Monitoring Stations  Populated Areas • Where do our non-attainment areas tend to be located?  Populated Areas For now, our non-attainment areas tend to be isolated to the areas in and surrounding major cities. But, this could change if National Ambient Air Quality Standards continue to be lowered.

While not required, KDAQ does request that you notify us when conducting a burn.

Map reflects the locations of ambient air monitors as proposed in the 2014 Air Quality Network Surveillance Plan. The 2014 KDAQ and LMAPCD networks are subject to EPA approval. Annual network surveillance plans can be obtained from the KDAQ website at:

Best smoke management practices are not just exercises in avoiding impacts on ambient air quality monitors. There are real public health impacts from smoke that must be considered and mitigated.

Protecting Air Quality AND Protecting Fire Dependent Ecosystems Smoke management allows us to achieve BOTH goals simultaneously.

Developing a smoke management program is a big task with a lot of factors to consider. The ultimate goal of both KDAQ and the KPFC Air Quality Committee is to give you the information and tools you need to make smart decisions in the field.

Kentucky Division for Air Quality Contacts Phone: 502-564-3999 Jennifer F. Miller Ext: 4050

KDAQ Activities with the KY Prescribed Fire Council Ambient Air Monitoring Exceptional Events Interim Air Quality Policy on Wildland and Prescribed Fires Roberta Burnes Ext: 4403

Open Burning Public Outreach

John Gowins Ext: 4420

State Implementation Plan

Martin Luther Ext: 4412

Regional Haze

October 2014 KPFC Air Quality Updates.pdf

Page 1 of 23. Follow-up to the. 6. th Annual Kentucky Prescribed Fire. Council Meeting. September 16, 2014, at WHFRTC. Jennifer F. Miller. Kentucky Division ...

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