EPA PARTICULATE MATTER 2.5 RULE
NSSGA POSITION:
The Environmental Protection Agency (EPA) has acknowledged that the intent of the final PM2.5 particulate matter rule is to control combustion sources that generate particles 2.5 microns or less in diameter. NSSGA believes the aggregates industry should not be considered in any regional, state or federal control strategies for fine particulate because the aggregate industry primarily generates coarse crustal particulate (>PM10-2.5).
BACKGROUND:
The Clean Air Act (CAA) directs EPA to identify and set national standards for air pollutants, that cause adverse effects to public health and the environment. EPA is required by the CAA to review the health and welfare-based standards at least once every five years to determine whether or not revisions to the standards are necessary to continue to protect public health and the environment.
Particulate matter is a mix of coarse and fine particles that cannot be seen individually by the naked eye, but often appears as haze, dust clouds or sooty emissions. Sources of coarse particles include industrial crushing and grinding operations, material handling, vehicle travel on unpaved roads, and windblown dust. Fine particles result from industrial, motor vehicle and power generating fuel combustion, as well as burning wood and brush. Research by NSSGA over the past decade has demonstrated that aggregate operations do not contribute significant PM2.5 emissions to the ambient air as once thought by EPA. Therefore, most aggregate facilities are not required to have a Clean Air Act Title V permit as major sources of particulate matter.
TALKING POINTS:
- The aggregates industry produces primarily coarse particulate matter that has not been shown to have adverse ambient environmental impacts on public health or welfare.
- The intent of the EPA rule for fine particulate is to control traditional stationary combustion sources. The aggregates industry should not be included in any regulatory control strategies for fine particulate.
- The aggregates industry is composed predominately of small businesses. The economic impact on these small businesses of controlling fine particulate is considerable due to increased monitoring, increased permitting and additional duplicative emission controls that will be required for sources that already use the best available control technologies to supress fugitive air emissions.
- Industry/EPA cooperative emission testing programs for PM10 and PM2.5 have shown that the aggregates industry is not the major emitter of particulate matter as once thought by EPA.
- EPA should focus on better characterization of fine particle pollution, while facilitating additional research, before initiating any possible regulatory initiatives for coarse particulate.
Updated: November 2008
