National Environmental Update John Hayden, NSSGA PMD ANNUAL MEETING September 12, 2006 Denver, Colorado Issues Update Proposed PM2.5 and PMCoarse NAAQS Ambient Crystalline Silica Wetlands Proposed PM Standards CURRENT PM 2.5 CURRENT PMCoarse Annual: 15 ug/m3 No PMc standard 24-hour: 65 ug/m3 PROPOSED PROPOSED Annual: 15 ug/m3 Annual: None 24-hour: 35 ug/m3 24-hour: 70 ug/m3 PMc Options (70ug/m3 v 150 ug/m3) 150 PMc with a viable exclusion. A crustal exclusion is more likely to pass judicial muster than a source-specific exclusion as proposed. 150 PMc without an exclusion, especially if EPA commits to continue exploring an exclusion. 150 PM10, with exclusion or commitment to continue exploring it. If EPA were to revert to the proposal, we would support the exclusion but not the standard. Ambient Crystalline Silica NSSGA emission factor development program – Proactive in anticipation of EPA action on silica? – MSHA/OSHA/NIOSH changing standards California’s new ambient silica standard – Directed at aggregate mining NSSGA EF Test Sites in North Carolina Plant Processes Haul Roads Other/Silica Tests Sites Outside of North Carolina Plant Processes Haul Roads Other/Silica Ambient Silica Test Results NSSGA upwind/downwind results: 3-5 ug/m3 silica as PM10 California ambient REL silica standard: 3 ug/m3 as PM4 – Initial test results: compliance with REL – Silica running about 7% (1.5 ug/m3) of total PM 4 – Additional tests in 2006: Sacramento/San Diego Wetlands Issues Rapanos and Healdsburg Court decisions How far is the jurisdictional reach of the Corps of Engineers now?
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