Workshop T Regulatory Whirlwind: Priceless Insights on the Numerous U.S. EPA’s MACT Standards for Hazardous Air Pollutants … a Flurry of Risk and Technology Reviews Tuesday, March 24, 2020 3:30 p.m. to 4:45 p.m.
Biographical Information Joanne Reinhold, Sr. Environmental Manager GE Aviation 1 Neumann Way, Cincinnati, OH 45215 513-638-2333 joanne.reinhold@ge.com Joanne is the Sr. Environmental Manager for the GE Aviation plant in Evendale, OH. At GE Aviation, Joanne is responsible for regulatory compliance for the environmental programs, including air permitting, water programs, waste management, and remedial programs. Joanne has been with GE for approximately 9 years. Prior to joining GE, Joanne worked as an engineering consultant for various industrial companies specializing in air compliance and permitting. Joanne is a graduate of the University of Cincinnati with a B.S. In Chemical Engineering. DJ Wheeler, Managing Consultant Trinity Consultants 110 Polaris Parkway, Suite 200, Westerville, Ohio 43082 614.433.0733 Fax: 614.433.0734 dwheeler@trinityconsultants.com Mr. Wheeler provides air quality permitting and compliance services for industries such as oil and gas, metallurgical coke production, secondary aluminum recycling, petroleum refineries, steel mini-mills, and gas-fired electricity generating units. He has provided specialized stack testing and CEMS support to numerous clients including overseeing performance tests, coordinating RATAs, reviewing test reports, and auditing CEMS data. Mr. Wheeler currently operates as a Managing Consultant in Trinity’s Columbus, Ohio office. He received a Bachelor’s degree in chemical engineering from the University of Michigan.
MEC Workshop T U.S. EPA Risk and Technology Reviews for Hazardous Air Pollutants DJ Wheeler –Trinity Consultants, Inc. Joanne Reinhold – GE Aviation Cincinnati, OH –March 24, 2020
Status of EPA NESHAP RTRs ˃ EPA required to conduct RTR periodically per the Clean Air Act ˃ RTR deadline has passed for several NESHAP rules ˃ EPA could, at any time, elect to move forward with RTR rulemaking, or be forced to do so by court order Such as the citizen suit filed in April 2015 for failure to complete RTR for several NESHAPs ˃ EPA has put out 20 rule proposals in 2019 Most with no changes or minor updates All rule proposals update startup, shutdown, and malfunction language ♦ Maintenance vents are now subject to emission standards. ♦ EPA proposed work practices for maintenance vents in some cases. Many include updates for electronic reporting
Regulatory Deadlines Not Just an Industry Headache! ˃ California Communities Against Toxics v. E. Scott Pruitt “[EPA’s] justifications for its inability to meet their timeline are too vague; citing other obligations but failing to describe what they are, what type of resources they consume, and whether they could be delayed to prioritize the RTR rulemakings at issue.” ˃ Blue Ridge Environmental Defense League v. Scott Pruitt “…the Clean Air Act makes clear that Congress contemplated that the EPA could promulgate dozens of air toxics rules in a condensed amount of time.” ˃ Community In ‐ Power and Development Association, Inc. v. E. Scott Pruitt “[EPA] must at least try to make a persuasive claim that it is currently so cash strapped that it cannot possibly start the mandated reviews…”
Source Category Latest Action Date Status Misc. Organic NESHAP (MON) 12/17/2019 Proposed Organic Liquids Distribution (OLD MACT) 10/21/2019 Proposed Ethylene Production 10/9/2019 Proposed Taconite Iron Ore Processing 9/25/2019 Proposed Paper and Other Web Coating 9/19/2019 Proposed Lime Manufacturing Plants 9/16/2019 Proposed Cellulose Products Manufacturing 9/9/2019 Proposed Plywood and Composite Wood Products Manufacture 9/6/2019 Proposed Miscellaneous Coating Manufacturing (MCM) 9/4/2019 Proposed Site Remediation 9/3/2019 Proposed Automobiles and Light‐Duty Trucks, Miscellaneous Metal Parts, Plastic Parts Coatings 11/1/2019 Proposed Integrated Iron and Steel Manufacturing 8/16/2019 Proposed Iron and Steel Foundries 10/16/2019 Proposed 10/30/2019 Rubber Tire Manufacturing Proposed Municipal Solid Waste Landfills 2/25/2020 Final Solvent Extraction for Vegetable Oil Production 2/25/2020 Final Surface Coating of Metal Cans and Metal Coil 2/25/2020 Final Boat Manufacturing and Reinforced Plastics Composites Production 2/25/2020 Final Engine Test Cells/Stands 5/8/2019 Proposed Asphalt Processing and Asphalt Roofing Manufacturing 1/30/2020 Final Stationary Combustion Turbines 1/31/2020 Final Hydrochloric Acid Production (HCl MACT) 2/4/2019 Proposed
Remaining RTRs EPA has yet to complete the RTR for the following sources: ˃ Consent Decree or Court Ordered Source Category Date for Signature of Final Rule Mercury Emissions from Mercury Cell Chlor‐Alkali Plants 10/1/2021 Semiconductor Manufacturing 10/1/2021 Generic MACT II ‐ Cyanide Chemicals Manufacturing 10/1/2021 Generic MACT II ‐ Spandex Production 10/1/2021 Generic MACT II ‐ Carbon Black Production 10/1/2021 Primary Copper Smelting 10/1/2021 Flexible Polyurethane Foam Fabrication Operations 10/1/2021 Refractory Products Manufacturing 10/1/2021 Primary Magnesium Refining 10/1/2021
14 12 10 Frequency 8 6 4 2 0 30 60 90 120 150 180 210 240 270 300 330 360 390 420 450 480 510 540 570 600 630 660 690 720 750 780 810 840 870 900 930 960 990 1020 More Days from Proposed Rule to Final Publication The graph shows the days taken for the final publication of a rule from the day it was proposed. The average time for a rule to be finalized is about 300 days from the publication of the proposed rule.
All RTR Proposals SSM Revisions: Comply At All Times ˃ Removal of startup, shutdown and malfunction (SSM) blanket exemptions from emission control standards. ˃ Sources are expected to comply with emission limits and work practice standards during all emission generating periods, including startup / shutdown. ˃ Work Practice Standards for Malfunctions and Maintenance.
All RTR Proposals SSM Revisions: Comply At All Times ˃ The requirement for SSM Plans are completely removed, along with associated SSM recordkeeping and reporting ˃ Detailed records for events associated with each failure to meet an applicable standard – including impacted equipment & HAP emitted, estimation methodology
Malfunction Records and Enforcement Discretion “ The EPA is also proposing to add…a requirement that sources keep records that include a list of the affected source or equipment and actions taken to minimize emissions, an estimate of the quantity of each regulated pollutant emitted over the standard for which the source failed to meet the standard, and a description of the method used to estimate the emissions. Examples of such methods would include product loss calculations, mass balance calculations, measurements when available, or engineering judgment based on known process parameters. The EPA is proposing to require that sources keep records of this information to ensure that there is adequate information to allow the EPA to determine the severity of any failure to meet a standard, and to provide data that may document how the source met the general duty to minimize emissions when the source has failed to meet an applicable standard. “ [84 FR 56320 ‐ 56321]
All RTR Proposals Electronic Reporting (CEDRI) ˃ US EPA is incorporating requirements for electronic data submittal through US EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) into all recent regulatory actions. ˃ Such reporting requirements thus far have included: Submittal of NESHAP Performance Test Reports Submittal of Fenceline Monitoring Reports Semiannual NESHAP Initial and Semi-Annual Compliance Reports ˃ All RTR amendments, across all source categories, are incorporating some level of CEDRI reporting, and NESHAP regulated sources can expect to eventually use CEDRI for all US EPA reporting submittals.
MON RTR Proposal
MON RTR Proposal Overview ˃ Removal of SSM Provisions ˃ Addition of work practice standards for periods of SSM Certain “Subset” of Flares – EO, olefins, polyolefins PRDs Maintenance Vents ˃ Clarification of provisions for certain vent control bypasses Closed vent systems containing bypass lines Flares connected to fuel gas systems ˃ Equipment Leaks – Lower thresholds ˃ Heat Exchange Systems – Modified El Paso Method
MON RTR Proposal Overview ˃ Monitoring and operational requirements for flares used as APCDs that control: Ethylene oxide emissions Olefins production and polyolefins production; Allow option for flares outside of this category to “opt in” in lieu of compliance with current flare standards. ˃ Electronic reporting of performance test results and reports, performance evaluation reports, and compliance reports
MON RTR Proposal Overview ˃ Specific Requirements for MCPUs with ethylene oxide (EO) LDAR Process Vents Storage Tanks Fuel Gas Systems Scrubber Monitoring
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