EPA Clean Air Act training in Detroit #EJEPADET


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Clean Air Act, Health Effects and Rule Overview
Training for Environmental Justice advocates held in Detroit April 25-26, 2014
Presentation and discussion - EPA / MDEQ / Community EJ advocates

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  • Key Points
    Particles come from a variety of sources –
    Some particles come from natural sources. But the vast majority of particles are produced by human activities – from cars, trucks and other vehicles, to industry, power plants – and even wood stoves.
    Fine particles can be emitted directly into the air, such as diesel particles from motor vehicles,
    But the majority of fine particles are formed by gases in the atmosphere.
    For example, sulfur dioxide emissions from power plants and industrial facilities transform in the air to become particles known as sulfates.
    The chemical composition of particles depends on the location of the source, the time of year, temperature and weather.
    Additional Info ___________________________________________________________
    Other examples of fine particles emitted directly into the air: iron oxides from iron and steel mills and elemental carbon (soot) from wood burning.
    Other examples of fine particles formed by chemical reactions:
    Fine particles known as nitrates form in the atmosphere by chemical reactions involving nitrogen oxide emissions from power plants, automobiles and other sources that burn fossil fuels.
    And particles known as “secondary organic particles” come from reactions between nitrogen oxide emissions and volatile organic compounds emitted by industrial operations and motor vehicles.
  • Primary – what does this mean?
    Each day SO2 monitor taking hourly readings, for each day you determine the highest hourly value
    So over one year, you get a data set of 365 highest daily values
    These 365 values are ranked from highest to lowest
    The fifth highest value is approximately the 99th percentile value
    Take 99th percentile reading (fifth highest SO2 reading) for each of three consecutive years and then average them
    If the value you end up with is less than 75 ppb, the monitor would be judged to be meeting the standard
    Secondary standard has not changed since 1971
    Laura already touched on health effects of SO2 but want to take second draw attention to really startling prevalence of asthma in Detroit area
    2008 study done by Mich Dept of Comm Health
    Asthma among adults in Detroit was 50% higher than the statewide average
    Asthma among children covered by Medicaid in Detroit (special focus of MDCH); 10% higher chance of persistent asthma and 50% more likely to visit the emergency department as a result of asthma, than their statewide counterparts
    Rates of asthma hospitalization in Detroit (for both children and adults) were found to be three times higher than that of Michigan as a whole
    Rates of asthma death over two times higher compared to overall state numbers
    Like Laura already talked about
    SO2 + water molecules in atmosphere = sulfuric acid (acid rain)
  • Total SO2 emissions from major sources in Wayne County
    This was info USEPA and MDEQ used in deciding boundaries for nonattainment area (primarily SO2 emissions data from 2008)
    Notice as pointed out by Laura, largest emitters are power generating plants (DTE) that burn coal
    DTE Monroe largest SO2 emitter, is actually outside final nonattainment area, justified this decision based on recently installed emission control tech & distance form violation monitor
  • Map of SO2 emission sources and SO2 monitors in Detroit
    Violating monitor (red diamond) located at Southwestern High School, monitor showed 90ppb (data from 2009-2011) in violation of 2010 primary standard
    Grey dots (small and large) are SO2 emitters
  • Map of final nonattainment area, area designation effective 10/4/2013
  • Now question is what to do about nonattainment in Wayne County?
    As of now, Michigan has not submitted a SIP for 2010 SO2 standard
    If still in nonattainment by deadline (10/4/18), state has 12 months to submit revised SIP that proves can reach SO2 attainment within following 5 years (5 years after USEPA determined still weren’t in attainment)
    If a state fails to submit an approvable plan or if EPA disapproves a plan, EPA is required to develop a federal implementation plan (FIP)
  • Several common themes emerged from stakeholder outreach:
    -Broad agreement that opportunities exist to lower the carbon intensity of power generation through a wide range of measures
    -States need more than one year to develop and submit plans
    -More time necessary due to legislative/regulatory schedule in many states
    -Additional time would allow and promote multi-state programs and cooperation
    -Multiple opinions about how broader measures taken throughout the electric system could factor into programs
    -General support for giving states flexibility
    -Recognize existing programs and the progress achieved
    -Allow compliance options that permit the use of approaches that are outside the power plan “fence line” (e.g., demand-side management)
    -Acknowledge leadership for prior GHG activities in states
    -Potential hurdles or concerns identified by stakeholders:
    -Views vary regarding form of the goal
    -Rate-based: States must stay below a tons of CO2 per megawatt hour limit
    -Mass-based: States must stay below a total tons of CO2 emitted per year limit
    -Many states have already achieved greenhouse gas reductions and have exceeded the President’s goal
    -Some suggest that EPA can legally only base the reduction goal on measures “within the fenceline”
    -This would eliminate EPA’s ability to count reductions achieved away from the power plant (e.g., demand-side management programs)
    -Concerns that rulemaking will have a negative impact on jobs and ratepayers
    -Concern that ratepayers will have to pay for stranded assets
    -Concerns regarding maintaining the reliability of the electric power system
  • EPA Clean Air Act training in Detroit #EJEPADET

    1. 1. Clean Air Act, Health Effects and Rule Overview Laura McKelvey and Stephanie Karisny
    2. 2. Titles of the Clean Air Act • Title I—National Ambient Air Quality Standards, Hazardous Air Pollutants – SIP, NSR and Technology Standards • Title II—Mobile Sources • Title III— Emergency Powers and Tribal Authority, Public Involvement • Title IV—Acid Deposition • Title V—Operating Permits • Title VI—Stratospheric Ozone
    3. 3. A Brief Overview of the CAA • The U.S. Environmental Protection Agency was created in 1970; the Clean Air Act (CAA) was passed in 1970; amendments were passed in 1990 • The goal of the Clean Air Act was to give the federal government the authority to address air pollution in the United States • Since the inception of the Clean Air Act (in 1970): – There has been a 50% decrease in the criteria pollutants; criteria pollutants include particulate matter (PM), ground-level ozone, carbon monoxide, sulfur oxides, nitrogen oxides and lead – Air toxics from large industrial plants have been reduced by 70% – New cars are more than 90% cleaner – Production of ozone-depleting chemicals has ceased
    4. 4. Air Quality Management Process Implement Control Strategies Evaluate Air Quality - Air Quality Assessments •Emissions Inventory Data •Ambient Air Monitoring Data Choose Control Strategies -Voluntary programs / Outreach -Some strategies may be regulatory Determine Necessary Emissions Reductions Set Air Quality Goals
    5. 5. NAAQS • National Ambient Air Quality Standards (NAAQS) – Primary standard set to protect public health – Secondary standard set to protect public and welfare • State Implementation Plans – State plans to attain or maintain the NAAQS • New Source Review and Prevention of Significant Deterioration (PSD) permits are part of the SIPs • Title V Permits takes all the requirements from SIPs, technology standards, new source performance standards, etc. and combine them in one permit
    6. 6. Setting Air Quality Goals for Commonly Found “Criteria” Pollutants • EPA sets limits for the amount (concentration) of pollutant that can be in the air for six commonly found pollutants: – Particulate Matter (PM) – Ground Level Ozone (O3) – Carbon Monoxide (CO) – Sulfur Oxides (SOx) – Nitrogen Oxides (NOx) – Lead (Pb) • These six pollutants are generally referred to as “criteria pollutants” • These limits are called National Ambient Air Quality Standards (NAAQS) • There are two types of NAAQS: – Primary standards are set at a level to protect public health – Secondary standards are set at a level to protect ecosystems, the environment and other values
    7. 7. EPA’s Role in Setting Air Quality Goals • NAAQS set national levels for acceptable concentrations of these six pollutants in outdoor air • EPA determines/designates all areas in the country as: – Clean or in “attainment” – Dirty (above the standard) or contributing to dirty air in a nearby location or “nonattainment” or – Not having enough information to determine the air quality status “unclassifiable” • The CAA sets dates by which these pollution levels must be reached • EPA provides guidance to the states on how to address air quality and reviews and approves (where appropriate) state air plans • EPA and oversees implementation of plans and can enforce state requirements where necessary • State plan for cleaning the air or keeping it clean to meet the national standards for these six “criteria pollutants” is called a State Implementation Plan (SIP) • The criteria pollutants are also regulated through New Source Performance Standards (issued by EPA) which apply to certain new air pollution sources and SIPs and Permit requirements for sources must at least be as stringent as the NSPS but States can be more stringent then the NSPS
    8. 8. Ground-level Ozone is • Primary component of smog • Sometimes called “bad ozone” to distinguish it from “good ozone” – Both types of ozone have the same chemical composition (O3) – “Good ozone” occurs naturally in the upper portions of the earth’s atmosphere and forms a layer that protects life on earth from the sun's harmful rays – “Bad ozone” at ground level is harmful to breathe
    9. 9. • Not emitted directly into air; forms when emissions of nitrogen oxides (NOx) and volatile organic compounds (VOCs) “cook” in sun – Emissions from industrial facilities, electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents are major man-made sources of NOx and VOCs • Mainly a summertime pollutant, because sunlight and hot weather accelerate its formation • Ozone levels can be high in both urban and rural areas, often due to transport of ozone, or the NOx and VOC emissions that form ozone Ground-level Ozone (cont.)
    10. 10. • Ozone can penetrate deep into the lungs and can: – Make it more difficult for people working or playing outside to breathe as deeply and vigorously as normal – Irritate the airways, causing: coughing, sore or scratchy throat, pain when taking a deep breath, and shortness of breath – Increase asthma attacks and use of asthma medication – Inflame and damage the lining of the lung by injuring the cells that line the air spaces in the lung – Increase susceptibility to respiratory infection – Aggravate chronic lung diseases such as asthma, emphysema and bronchitis Ozone and Health • Repeated exposure may cause permanent changes in the lung, leading to long-term health effects and a lower quality of life
    11. 11. Ozone Health Impacts: “ Pyramid of Effects” Susceptible and vulnerable groups include – People with lung disease such as asthma – Children – Older adults – People who are more likely to be exposed, such as outdoor workers Proportion of Population AffectedProportion of Population Affected Severity of Effects A large number of scientific studies have linked ozone exposure to serious health outcomes such as emergency department visits, hospitalizations for respiratory causes, and mortality
    12. 12. Particulate Matter: What is It? A complex mixture of extremely small particles and liquid droplets
    13. 13. Fine Particles Combustion, gases to particles Sulfates/acids Nitrate Ammonium Organics Carbon Metals Water Sources: Coal, oil, gasoline, diesel, wood combustion Transformation of SOx, NOx, organic gases including biogenics High temperature industrial processes (smelters, steel mills) Forest fires Exposure/Lifetime: Lifetime days to weeks, regional distribution over urban scale to 1000s of km Inhalable Coarse Particles Crushing, grinding, dust Resuspended dusts (soil, street dust) Coal/oil fly ash Aluminum, silica, iron-oxides Tire and brake wear Inhalable Biological Materials (e.g., from soils, plant fragments) Sources: Resuspension of dust tracked onto roads Suspension from disturbed soil (farms, mines, unpaved roads) Construction/demolition Industrial fugitives Biological sources Exposure/Lifetime: Coarse fraction (2.5-10) lifetime of hours to days, distribution up to 100s km PM Components: fine and coarse
    14. 14. • Larger particles (> PM10) deposit in the upper respiratory tract • Smaller, inhalable particles (≤ PM10) penetrate deep into the lungs • Both coarse PM10-2.5 and fine PM2.5 can penetrate to lower lung • Deposited particles may accumulate, react, be cleared or absorbed Particulate Matter
    15. 15. Heath Effects of Particle Pollution • Particles can cause both respiratory and cardio-vascular health problems, including: – Aggravated asthma – Increases in respiratory symptoms like coughing and difficult or painful breathing – Chronic bronchitis – Decreased lung function – Changes in heart rate and heart rate variability – Cardiac arrhythmias – Heart attacks – Premature death • Types of studies: – Epidemiology/Field – Controlled human exposure – Animal
    16. 16. lung function changes, immunecell responses, heart rateor heart ratevariability responses Asthmaattacks, medication use, symptoms Doctor visits Hospital Admissions Death PM Health Impacts: “Pyramid of Effects”PM Health Impacts: “Pyramid of Effects” Some groups are at greater risk • People with heart or lung diseases – Diseases make them vulnerable – May include people with diabetes • Older adults – May have undiagnosed disease • Children – Bodies still developing
    17. 17. Sulfur Dioxide Health Effects • Short-term exposures to SO2, ranging from 5 minutes to 24 hours • Respiratory effects including: – bronchoconstriction – increased asthma symptoms • These effects are particularly important for asthmatics while exercising or playing. • Short-term exposure result in: – increased visits to emergency departments and hospital admissions for respiratory illnesses – particularly in at-risk populations including children, the elderly, and asthmatics • Emissions that lead to high concentrations of SO2 generally also lead to the formation of other Sox. • SOx can react with other compounds in the atmosphere to form small particles or PM2.5 discussed earlier. • These particles penetrate deeply into sensitive parts of the lungs and can cause or worsen respiratory disease, such as emphysema and bronchitis, and can aggravate existing heart disease, leading to increased hospital admissions and premature death. • EPA’s NAAQS for particulate matter (PM) are designed to provide protection against these health effects.
    18. 18. Current National Ambient Air Quality Standards (NAAQS) as of March 2014 Pollutant Primary/ Secondary Averaging Time Level Form CO primary 8-hour 9 ppm Not to be exceeded more than once per year 1-hour 35 ppm Lead primary and secondary Rolling 3 month average 0.15 μg/m3 Not to be exceeded NO2 primary and secondary Annual 53 ppb Annual mean primary 1-hour 100 ppb 98th percentile of 1-hour daily maximum concentrations, averaged over 3 years O3 primary and secondary 8-hour 0.075 ppm Annual fourth-highest daily maximum 8-hr concentration, averaged over 3 years PM2.5 primary Annual 12.0 μg/m3 annual mean, averaged over 3 years secondary 15.0 μg/m3 primary and secondary 24-hour 35 μg/m3 98th percentile, averaged over 3 years PM10 primary and secondary 24-hour 150 μg/m3 Not to be exceeded more than once per year on average over 3 years SO2 primary 1-hour 75 ppb 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years secondary 3-hour 0.5 ppm Not to be exceeded more than once per year Primary (health-based) and secondary (welfare-based) standards. Units of measure are parts per million (ppm), parts per billion (ppb) or micrograms per cubic meter of air (μg/m3 ). For more information about the standards, visit http://www.epa.gov/ttn/naaqs/.
    19. 19. “Everything is connected” Permits MonitoringPlanning & Analysis Statutory Authority Resources: FTEs & $$ $ Compliance & Enforcement Rules & Regulations Emissions Inventory What is a SIP?
    20. 20. What is a SIP? • Most air pollution control regulations in the US are found in SIPs (State Implementation Plans) • States and have great leeway in developing SIPs • Implementation plans include information to understand and track air quality like: – Emissions inventories (what sources are in the area) – Air quality monitoring – Modeling to show how the plan will achieve or maintain good air quality • Control strategies for all the sources of pollution in an area which can include – Voluntary programs to improve air quality, for example, • Build High Occupancy Vehicle Lanes • Cash for clunkers – Regulatory programs, for example • Impose limits on bus idling • Require sources to install air pollution control equipment – Permit programs for new and modified sources • Development of these components generally takes 3-4 years • CAA requires an area move to attainment with in 5-7 years.
    21. 21. SIPs Must Meet Minimum Requirements • The Clean Air Act has many requirements for SIPs, including a requirement that non-attainment areas come into attainment as soon as possible • SIPs must have: – Enforceable emission limits and control measures – An air monitoring program – Permit programs to control construction and modification of new stationary sources – Measures to prevent one State from significantly contributing to nonattainment in another State • SIPs are submitted to EPA for approval – EPA must publish notice before approving a SIP (typically found in the Federal Register) and must give the public an opportunity to request public hearing and at least a 30-day comment period
    22. 22. Implementing Control Strategies • Pre-construction and operating permits help with compliance and enforcement of the SIP – Permits contain requirements and become enforcement tools – Before a permit is issued, the public can request a public hearing and make comments on the draft permit • Progress can be tracked through – Ambient monitoring – Reporting requirements contained in permits and regulations • Enforcement is essential
    23. 23. SIP Process and Roles Opportunities for Input SIP is now federally enforceable Meet w/State SIP development team, join SIP stakeholder group, get on mailing list Work w/Regional Office to provide input and community or tribal perspective Attend and speak at public hearing, submit written comments Work w/Regional Office to review and provide input Attend and speak at public hearing, submit written comments Work w/EPA and State to ensure controls are in place and working State / local agencies start to develop SIP State holds public hearing and comment period State revises SIP to respond to public comment State adopts & officially submits SIP to EPA Regional Office EPA performs completeness review (EPA has 6 months) EPA publishes proposed notice in Federal Register EPA holds public comment period EPA publishes final action responding to public comment State modifies SIP based on EPA comments State drafts SIP and submits to EPA for informal review The State Implementation Plan Process
    24. 24. Stephanie Karisny Staff Attorney Great Lakes Environmental Law Center
    25. 25. • National Ambient Air Quality Standard (NAAQS) for SO2 – Primary standard: Protection of human health including "sensitive" populations such as asthmatics, children, and the elderly • One-hour standard, 75 parts per billion (ppb) • Calculated as the three-year average of the 99th percentile of the annual distribution of daily maximum 1-hour average concentrations – Secondary standard: Protection against environmental and property damage - e.g., protection against decreased visibility, damage to animals, crops, vegetation, buildings • Three-hour standard, 0.5 parts per million (ppm) • Not to be exceeded more than once per calendar year
    26. 26. • Wayne is the only county in Michigan that is a designated nonattainment area for SO2 under the 2010 standard – “The area bounded on the east by the Michigan-Ontario border, on the south by the Wayne County- Monroe County border, on the west by Interstate 75 north to Southfield Road, Southfield Road to Interstate 94, and Interstate 94 north to Michigan Avenue, and on the north by Michigan Avenue to Woodward Avenue and a line on Woodward Avenue extended to the Michigan-Ontario border”
    27. 27. • States are primarily responsible for ensuring attainment and maintenance of NAAQS once EPA has established them • State needs to create a State Implementation Plan (SIP) that provides for the attainment and maintenance of NAAQS through control programs directed at sources of SO2 • SIP goes through public participation process (state level) • USEPA has final say, approves or disapproves SIP (also public participation) • SIPs due to USEPA by April 6, 2015 • NAAQS for SO2 must be met by October 4, 2018
    28. 28. • General Nonattainment SIP Requirements: – Section 172 of the Clean Air Act (CAA) addresses the general requirements for areas designated as nonattainment – States with nonattainment areas must submit a SIP that shows the affected area will attain the standard by the applicable attainment date (10/4/2018) – SIP must demonstrate that area will attain the standard as expeditiously as practicable, and provide for the implementation of all reasonably available control measures (RACM) including reductions in emissions from existing sources through adoption of additional control technologies
    29. 29. • What kinds of SO2 control options are available? – Switch to low-sulfur fuel (low sulfur coal) – Implement flue gas desulfurization control technology • Dry FGD technologies • Wet FGD technologies
    30. 30. Overview • Section 112 of the Clean Air Act – Overview – Emission standards – MACT program – Risk and technology review (RTR) • Available Resources • Status Updates on Rules
    31. 31. Section 112 of the Clean Air Act Overview • Establishes requirements for setting national emission standards for hazardous air pollutants (NESHAP) • A hazardous air pollutant is defined as “any air pollutant listed pursuant to subsection (b) of this section [CAA section 112]” – There are currently 189 pollutants on the HAP list (the complete list is available online at: http://www.epa.gov/ttn/atw/overview.html) • Stationary sources are broken down into two categories: major and area – A major source “means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants” – An area source “means any stationary source of hazardous air pollutants that is not a major source”
    32. 32. Regulation of Toxic Pollutants • The Clean Air Act listed 189 (now 183) toxic air pollutants (that may cause cancer or serious health problems) • There are literally thousands of sources of toxic air pollutants (also called hazardous air pollutants or HAPs) • Sources range from gigantic oil refineries to the dry cleaner on the corner, as well as mobile sources (cars, trucks, planes, trains) • Clean Air Act requires EPA to set standards for specific source types
    33. 33. Section 112 of the Clean Air Act Emission Standards • Per section 112(d), “the Administrator shall promulgate regulations establishing emission standards for each category or subcategory of major sources and area sources of hazardous air pollutants listed for regulation pursuant to subsection (c) of this section in accordance with the schedules provided in subsection (c) and (e) of this section” • Emission standards “require the maximum degree of reduction in emissions of the hazardous air pollutants…the maximum degree of reduction in emissions that is deemed achievable for new sources in a category or subcategory shall not be less stringent than the emission control that is achieved in practice by the best controlled similar source, as determined by the Administrator” – The above is speaking to the maximum achievable control technology or MACT program
    34. 34. Section 112 of the Clean Air Act MACT Program • Under the MACT program emission limits for existing sources are established by: – Examining “the average emission limitation achieved by the best performing 12 percent of the existing sources (for which the Administrator has emissions information)… or by examining “the average emission limitation achieved by the best performing 5 sources (for which the Administrator has or could reasonably obtain emission information) in the category or subcategory for categories or subcategories with fewer than 30 sources) • For area sources the Administrator may “elect to promulgate standards or requirements applicable to sources in such categories or subcategories which provide for the use of generally available control technologies or management practices by such sources to reduce emissions of hazardous air pollutants”
    35. 35. Section 112 of the Clean Air Act Risk and Technology Review (RTR) • Residual risk review and technology review required within 8 years of promulgation of MACT standards • 2-step risk analysis 1. Determine if risk is acceptable considering health information only, and if not acceptable, tighten standards so risks are acceptable 2. Determine if standards provide an ample margin of safety, which considers health info, costs and feasibility • Risk review includes inhalation risk assessment (cancer and non- cancer) and screens to assess multipathway, whole facility, acute and environmental risks – Can perform refined multipathway assessments in limited cases if screens show potential multipathway human health risk • Technology review takes into account new developments in practices, processes and control technologies considering cost and feasibility • We also consider previously unregulated processes and HAP, and we make technical corrections
    36. 36. Available Resources • Overview of section 112 (this includes the list of HAPs): http://www.epa.gov/ttn/atw/overview.html • For further explanation of major and area sources and a list of source categories please visit: http://www.epa.gov/ttn/atw/pollsour.html • For a listing of all of the NESHAP/MACT final rules please visit: http://www.epa.gov/ttn/atw/mactfnlalph.html • For an overview of the risk and technology review program please visit: http://www.epa.gov/ttn/atw/rrisk/rtrpg.html • Plain English guide to Clean Air Act: http://www.epa.gov/air/caa/peg/ • State, local, tribal and federal partnerships: http://www.epa.gov/ttn/atw/stprogs.html
    37. 37. Status Updates on Rules Startup Shutdown and Malfunctions • Historically, EPA’s air pollution rules require compliance with standards at all times, but most rules allowed an exemption of the standard if it occurred during a malfunction or during periods of startup or shutdown • In 2008, the D.C. Circuit Court ruled that such exemptions were not permitted • EPA is addressing the court decision in its rules by removing the exemption for malfunctions; for start up and shutdown provisions, EPA considers whether it is viable for sources to comply at all times, or whether a separate provision is necessary to address start up and shutdown
    38. 38. Status Update on Rules (cont.) Steel Sector • Steel mills are regulated under three different rulemakings • Electric Arc Furnaces (EAF) – steel from recycled steel scrap – 88 facilities; mostly area sources (80 facilities) – 5 major stand-alone; 3 major co-located at integrated iron and steel facilities – Rule promulgated in 2007, included standards for mercury and PM limits • Integrated Iron and Steel Plants – steel from taconite ore, coke – 16 facilities: 4 with sinter plants, 3 with EAF – 5 facilities with co-located coke plants – MACT rule promulgated in 2003, included PM and opacity limits • Coke Plants – produces coke, a high-energy fuel used in steel production – 19 facilities; 5 co-located at integrated iron and steel facilities – Most have multiple coke oven batteries – MACT rules were promulgated in 1993 and 2003 for various plant processes – RTR will be conducted for pushing, quenching and battery stacks – Coke oven rules include requirements for opacity and PM
    39. 39. Status Update on Rules (cont.) 43 Pollutant Limit PM 27 milligrams per dry standard cubic meter (dscm) Opacity 10 percent Cadmium 0.040 milligrams per dscm Lead 0.44 milligrams per dscm Mercury 0.080 milligrams per dscm or 15 percent of the potential mercury emission concentration, whichever is less stringent Sulfur dioxide 29 parts per million by volume (ppmv) or 25 percent of the potential sulfur dioxide emission concentration, whichever is less stringent Hydrogen chloride 29 ppmv or 5 percent of the potential hydrogen chloride emission, whichever is less stringent Dioxins/furans If facility uses ESP: 60 nanograms per dscm If no ESP: 30 nanograms per dscm Nitrogen oxides 205 ppmv (mass burn waterwall) Carbon monoxide 100 ppmv (mass burn waterwall) Federal plan emission limits for large MWCs constructed on or before 9/20/1994 (40 CFR Part 62 Subpart FFF) Existing Large Municipal Waste Combustors
    40. 40. Status Update on Rules (cont.) Carbon Pollution Standards for Existing and Modified Power Plants • The President in his directive to EPA under the Climate Action Plan stated that the agency should: – Set flexible carbon pollution standards, regulations or guidelines, as appropriate, for power plants under section 111 of the Clean Air Act – Focus on these elements when developing the standards: • Stakeholder engagement on program design – States – Leaders in the power sector – Labor leaders – Non-governmental organizations – Tribal officials – Members of the public • Flexibilities in program design – Market-based instruments, performance standards, others • Costs – Tailor regulations and guidelines to reduce costs • Continued importance of relying on a range of energy sources • Other regulations that affect the power sector
    41. 41. Status Update on Rules (cont.) Carbon Pollution Standards for Existing and Modified Power Plants • EPA’s Task: – Develop carbon pollution standards, regulations or guidelines, as appropriate, for: • New power plants • Modified and reconstructed power plants • Existing power plants • Per the President’s Directive, EPA will issue proposed carbon pollution standards, regulations or guidelines, as appropriate, for modified, reconstructed and existing power plants, by no later than June 2014 – EPA will issue final standards, regulations or guidelines as appropriate by no later than June 2015 – EPA will include in the guidelines addressing existing power plants a requirement that States submit to EPA the implementation plans by no later than June 2016
    42. 42. Status Update on Rules (cont.) Carbon Pollution Standards for Existing and Modified Power Plants • EPA has been conducting a robust stakeholder engagement process – Participated in meetings with over 300 utility, labor and environmental groups since June 2013 – Developed video webinar about the Climate Action Plan and CAA section 111(d); this video has been viewed more than 3,800 times – Held 11 public listening sessions around the country • 3,300 people attended • More than 1,600 people offered oral statements • Engagement process has given EPA several key insights and takeaway messages
    43. 43. Petroleum Refinery Sector Risk and Technology Review Presentation to the U.S. EPA Science Advisory Board July 19, 2013
    44. 44. Developing Exposure Estimates • We use the EPA Human Exposure Model (HEM) risk modeling system to estimate exposure, which contains: – AERMOD dispersion model (EPA’s approved local-scale model) – 2010 Census data at census block resolution (about 10 households) – Terrain elevation data – Meteorological data • Uses historical (2011) data from weather stations nationwide • Exposure estimates are conservative – We assume that there is a person at the centroid of census block who is continually exposed for 70 years • If the highest concentration is at residence closer to the facility than the centroid, we use that concentration as our exposure estimate – This reflects the Clean Air Act mandate to assess risks to the ‘individual most exposed’
    45. 45. Inhalation Risk Outputs • Chronic – Cancer: Maximum Individual Risk (MIR) – highest cancer risk (in a million) at a location where people live (census block centroid or nearest residence) – Noncancer: Hazard Index (HI) – highest noncancer risk at a location where people live (census block centroid or nearest residence) – Annual cancer incidence (cases/year) – Cancer risk bin distributions (>100 in a million, 10 in a million…) – Source category and facility wide risks – Process level risk contributions • Acute – Maximum off-site impact: pollutant-specific highest 1-hour Hazard Quotient (HQ) outside estimated facility fenceline • Default factor of 10x time the annual emissions rate unless source category specific information is provided • Can be refined with site-specific boundary conditions
    46. 46. Development of Emission Inventories • The purpose of the risk and technology review is to evaluate the MACT standards to determine if: – It is necessary to tighten the standards to protect human health and the environment with an “ample margin of safety” – There are advancements in practices, processes or technologies that warrant tightening the standards • Risk and technology review requires emission inventory data • Emission inventories are developed to satisfy state requirements – EPA provides guidance in the form of AP-42 emission factors, but does not mandate their use – Inventories are not consistent among states – Speciation and completeness of data for air toxic pollutants vary – EPA houses state inventories in the Emission Inventory System (EIS)
    47. 47. Refinery Emissions Inventory • EPA was petitioned in 2008 under the Data Quality Act to improve emission factors from refineries – In response, EPA developed a refinery emissions estimation protocol, which was put through two rounds of public notice and comment in 2010 • http://www.epa.gov/ttn/chief/efpac/protocol/index.htm • Refinery Emissions Estimation Protocol – Provides consistent set of methods for estimating emissions (criteria pollutants and air toxics) – Requires speciation of air toxic pollutants – Describes what refinery emission sources should have pollutant emission estimates – No new sampling is required – Ranking of methodologies depending on available data – More detailed and comprehensive than AP-42 emission factors • 2011 Refinery ICR required refiners to use the Refinery Emissions Estimation Protocol to develop their inventory • Refinery inventory submitted in response to the ICR will be used to perform the risk and technology review of the MACT standards
    48. 48. Air Toxics Emissions From Refineries
    49. 49. Refinery Emission Sources • Point sources (vents or stacks) – Emissions generally well understood and well characterized, and some test data available where pollutants were directly measured – Examples include vents at catalytic cracking, fluid coking, delayed coking, catalytic reforming, sulfur recovery, hydrogen plants – As part of risk and technology review, EPA is amending rules to require electronic submission of performance test data; will be used to periodically update emission factors • Flares – Destruction of pollutants in an open flame – Difficult to directly measure pollutants – Flare studies available to develop correlations for parameters that affect flare destruction efficiencies (2012 peer review) – September 2012 NSPS flare amendments will require all flares to eventually have monitors to measure waste gas flow – Flare operational requirements ensure good combustion and provide information (waste gas composition and flare destruction efficiency) that can be used to estimate emissions from flares • Fugitive emission sources – Tend to be open sources or not emitted through a stack or vent, thus difficult to directly measure pollutants – Examples include equipment leaks and pressure relief devices, tanks and transfer operations and wastewater handling and treatment – Emission models and estimates are used to predict pollutant emissions – An emission standard at the fenceline can help ensure fugitive emission standards are being met
    50. 50. Fenceline Monitoring • Fugitive emission sources may not be well characterized in the inventories but are likely significant contributors to overall emissions • Fugitives from process piping • Wastewater sources • Pressure relief events • Tanks • Highest concentrations of these fugitive emission sources outside the facility likely occur by the property boundary near ground level • Air monitoring at the property boundary can provide a direct measure of the annual average concentrations of air toxics directly surrounding the refinery • Benzene is a refinery risk driver and also primarily emitted from fugitive sources; 85% of benzene emissions from refineries is from fugitive, ground-level sources, so reducing emissions of benzene from fugitive sources will reduce emissions of other toxic pollutants • Perimeter or fenceline monitoring provides an indicator of the level of emissions at refineries and is a way to ground-truth fugitive emission estimates
    51. 51. Low-cost sensor networks Low-cost sensor networks Different technologies and approaches to detect and measure pollutants over extended areas and time Mobile inspection systems Mobile inspection systems Monitoring for Assessment of Fugitives Leak detection power and feasibility of widespread deployment Analyticalpowerandimplementationcost Current open- path and auto GC systems Current open- path and auto GC systems Lower cost optical systems Lower cost optical systems
    52. 52. 0.2 0.5 2 5 10 (µm)0.2 0.5 2 5 10 (µm) UV DOAS FTIRTDL FLIR UV Diff. Optical Absorption Spectroscopy Tunable Diode Laser (scanning) Forward-Looking InfraRed (leak imaging) Fourier Transform InfraRed (scanning) Open-path optical systems Open-path optical systems Open-Path Instruments
    53. 53. N Low-Cost Sensors Can Provide 24-7 Observation & Enable New Regulatory Approaches Facility fenceline monitoringPassive sampling Low-cost sensor networks Low-cost sensor networks • Locate passive samplers around the perimeter of each refinery • Calculate annual average concentration • If rolling average concentration exceeds benzene concentration standard (the action level), initiate tiered approach to positively identify facility contribution and conduct corrective action to reduce emissions
    54. 54. Developments in Lower-Cost Time-Resolved Monitoring to Support Time-Integrated Passive Sampler Fenceline Measurements Mobile inspection systems Mobile inspection systems SECONDARY MIRROR PRIMARY MIRROR SEALED UV WINDOW BEAM SPLITTER DETECTORS FOCUSING LENS Lower cost open-path optical systems Lower cost open-path optical systems Deep UV optical sensor Drive-by leak inspection Drop-in-place sensor packages Prototype PID sensor package (pres. temp. , RH., VOC) Combining senor and wind data Combining senor and wind data New leak-location algorithms Low-cost stand-alone sensors Low-cost stand-alone sensors
    55. 55. Wind April 2013 passive sampler and GMAP demo with a cooperating refinery Mobile inspection detected benzene leak at location of the highest passive sampler reading Passive sampler Geospatial measurement (GMAP) mobile benzene survey Passive sampler fenceline and mobile inspection demonstration