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Texas, El Paso Area, Particulate Matter (PM-10), Attainment Plan Summary

Texas, El Paso PM-10 Attainment Demonstration Summary

Purpose of Plan: To demonstrate that El Paso will attain Federal PM-10 standards, but for emissions emanating from Mexico, by December 31, 1994

Area Covered: El Paso, Texas

Type of Pollutant: Particulate matter with diameter 10 micrometers or smaller (PM-10)

Under the 1990 Clean Air Act Amendments, El Paso, Texas was designated nonattainment of the PM-10 National Ambient Air Quality Standards (NAAQS) and classified as moderate.  The Clean Air Act requires that states with moderate PM-10 nonattainment areas submit revisions to the State Implementation Plan (SIP) detailing how the area will attain the NAAQS by the December 31, 1994, deadline.

On November 5, 1991, Texas submitted a PM-10 SIP revision for El Paso.  This revision included PM-10 control measures, an emission inventory, and a modeling demonstration, under Section 179B, providing for timely attainment but for particulate emissions from Mexico.  On January 18, 1994, the EPA approved the El Paso PM-10 SIP revision, and approved the attainment demonstration SIP as meeting the requirements of Section 179B, showing that the area would timely attain the PM-10 standard but for emissions from Mexico.

Pollution Data:
Texas submitted two emissions inventories for El Paso, actual emission levels for base-year 1990, and projected emission levels for 1994.  For 1990, the State calculated a total of 7413 tons per year of PM-10 emissions.  The State projected 7552 tons per year emissions in 1994.

A study conducted in 1990 - "El Paso/Juarez Winter PM-10 Receptor Modeling Scoping Study" - showed that PM-10 concentrations were generally higher in  Juarez, Mexico (adjacent to El Paso) than in El Paso and that when high concentrations of PM-10 were found in El Paso, many of the air parcels were from sources in and around the Juarez area.

Texas also used a Gaussian Plume Multiple Source Air Quality Algorithm model to model the PM-10 concentrations in 1990 and 1994, using the El Paso emission inventories.  The modeling showed that, if the El Paso area were affected only by emissions originating within the area, the area would be in attainment of the PM-10 NAAQS in both 1990 and 1994.

Pollution Control Measures:
As part of its El Paso PM-10 SIP revision, Texas submitted PM-10 control measures, including permits issued under the EPA-approved Texas permitting rules.  These federally-enforceable permits showed that Reasonably Available Control Technology (RACT) was being implemented at all major and other stationary sources in the El Paso area. In addition, the EPA viewed the State's submitted rules for prescribed burning, fugitive dust, and residential wood combustion control measures and the submitted El Paso City Ordinance 9.38, as contingency measures since they go beyond the core RACM control strategy.  The regulations and ordinance are listed in the table below.

Regulation Description State Adoption EPA Approval into SIP Federal Register Citation
30 TAC 111.101, .103, .105, and .107 Prescribed Burning: sets requirements for outdoor burning, including agricultural and silvicultural burning 06/16/1989 01/18/1994 59 FR 02532
30 TAC 111.111 Requirements for Specified Sources: sets visible emissions requirements 10/25/1991 01/18/1994 59 FR 02532
30 TAC 111.141-149 Fugitive Dust Control: requires dust control measures on roads, streets, alleys, parking lots, construction and demolition sites, and materials handling 06/16/1989, revised 10/25/1991 01/18/1994 59 FR 02532
El Paso City Ordinance,  Chapter 9.38 Residential Wood Burning: definitions, no-burn periods, notice requirements, exemptions, rebuttable presumption, and violation penalties 12/11/90 01/18/1994 59 FR 2534

Texas submitted, as part of its SIP, a Memorandum of Understanding dated November 5, 1991, between the City of El Paso and the State which defines the division of responsibility for, and the commitments to carry out, the above rules and the ordinance.  The EPA approved this as part of the El Paso PM-10 SIP.

Texas will report to the EPA every three years, beginning on November 15, 1994, the following information: (1) The status and effectiveness of the existing controls in comparison to those projected in the El Paso PM_10 SIP submittal; (2) Significant emission changes due to new source growth or other activities; and, (3) an evaluation of any additional feasible controls to reduce exposure.

The EPA also approved a waiver for the El Paso area of the requirement to adopt control requirements for major stationary sources of PM-10 precursors.  The EPA found that these sources of PM-10 precursors in the El Paso area do not significantly contribute to PM-10 levels that exceed the PM-10 standard in the area.

Contingency Measures:
The EPA found that the State's submitted rules for prescribed burning, fugitive dust, and residential wood combustion control measures and the submitted El Paso City Ordinance 9.38, went beyond the core RACM control strategy.  Therefore, EPA approved these rules and the ordinance as the contingency measures plan for the El Paso PM-10 area.

Subsequent Action and Events:

The State submitted a revision to the El Paso PM-10 SIP on March 30, 1994, for an alternate PM-10 control plan for the ASARCO copper smelter in El Paso. ASARCO had requested a waiver from paving the slag haul road and certain segments of other low_traffic roads, and control them with other methods of dust control. The SIP revision included ASARCO’s Permit No. 20345 approved by the State on May 8, 1992, an Order adopted by the State on March 9, 1994 granting a waiver to the State’s rule requiring paving, and a technical analysis demonstrating that the cost of paving these specifically identified roads at ASARCO was economically unreasonable compared to other methods of dust control.  The EPA found that the alternate particulate control plan provided for more reductions than paving would provide. Instead of paving, ASARCO is required to use the following as alternate particulate control methods for the slag haul road and other applicable unpaved roads: (1) Continuous wetting using an automatic sprinkler system, or (2) daily watering and twice weekly application of a chemical oil spray. ASARCO must maintain a log record for a two-year period showing the amount of water and chemical applied daily for unpaved roads not maintained in a continuously wetted condition.  The EPA approved the revision on September 15, 1994 at 59 FR 47261.

Federal Register Actions:

EPA Action Federal Register Date Federal Register Citation
Proposed approval of attainment plan 10/08/1993 58 FR 52467
Final approval of attainment plan 01/18/1994 59 FR 02532
Proposed rule:  Site Specific Particulate Control Plan for ASARCO, El Paso 09/15/1994 59 FR 47288
Direct final rule:  Site Specific Particulate Control Plan for ASARCO, El Paso 09/15/1994 59 FR 47261

EPA Region 6 Contact:

     Bill Deese at 214-665-7253 or


This SIP Citation Was Last Modified on: 08/14/2003