Gap Filling HAPs. For Point Sources in the 2008 National Emissions Inventory

Transcription

1 Gap Filling HAPs and other HAP additions by EPA For Point Sources in the 2008 National Emissions Inventory 1

2 Pollutants Included in the NEI Criteria Pollutants/Precursors (CAPs) Required To Be Reported By the Air Emissions Reporting Rule Sulfur dioxide (SO2) Nitrogen Oxides (NOX) Volatile Organic Compounds (VOC) Carbon Monoxide(CO) Primary PM 2.5 and PM 10 (and filterable and condensible components, as applicable) Ammonia (NH3) Lead and Lead Compounds Hazardous Air Pollutants (HAPs) encouraged to be submitted voluntarily 187 pollutants/pollutant groups on current list ( rig189.html) benzene, toluene, xylenes, ethyl benzene, acrolein, formaldehyde, acetaldehyde, vinyl chloride, carbon tetrachloride, other HAP VOC mercury, arsenic, chromium, manganese, nickel, cadmium, selenium, beryllium, lead, other metals hydrochloric acid, hydrogen fluoride, hydrogen cyanide, and other acid gases tetrachloroethylene, methylene chloride, methyl chloroform and other HAP Glycol Ethers, Polycylic Organic Matter and other groups 2

3 HAPs Reported Voluntarily by Most States differing levels of completeness * Number of HAPs reported Point Source Data Category Agency Type Reporting HAPs (#) Min Max state local tribe Mercury (Hg) reporting by S/L/T: 41 states 13 local 2 tribes * Local Agencies in NV reported HAPs but NV state agency did not 3

4 Objectives for adding HAPs Complete, integrated inventory for HAPs and CAPs Focus on high risk HAP/facilities and mercury (Hg) Use automated approaches for other sources 4

5 HAP DATA USED IN INVENTORY NEI 2011 DATA SOURCE Chromium split MATS HOW IT WAS USED Contains hexavalent and trivalent chromium computed from S/L/T unspeciated chromiu Inventory developed as a result of data request was incorporated into NEI 2008 EPA Airports, Rail Sources and emissions used in nonroad source sector 2008 Offshore platforms 2008 EPA Rule data Nevada gold mines Sources and emissions added as a new sector in the inventory Emission Factors applied to: Electric Arc Furnaces, Hg chloralkali, Municipal waste combusters, ICI boilers. Test data collected by NV under the Nevada Mercury Control 2008 EPA Coke ovens Emission factors applied to facilities in 4 states. TRI 2,636 facilities. 40,000 tons total (9%) 2005 NATA 8 facilities in 10 states Emission factors from Webfire applied: 92 HAPS added; 8500 tons mass; 21,286 facilities have at least 1 HAP Webfire added from this process 5

6 Summary EPA HAP data used for all States in point data category Nearly 200,000 tons HAPs from EPA (vast majority was HCl from MATS data) 32% of total point HAP is from MATS 13 % of total point HAP is from other EPA augmentation Range of EPA HAP mass ranged from 9% to 100% of state HAP 6

7 Proportion of EPA HAPs by Region 160,000 Point Source HAPs Emissions by Region 140, , ,000 80,000 60,000 40,000 20,000 Tribe EPA REGION OR TRIBE 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percent of Point Source HAPs from EPA ALL EPA data sets Tribe EPA REGION OR TRIBE 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percent of Point Source HAPs from EPA datasets other than MATS Tribe EPA REGION OR TRIBE 7

8 Using the NEI to Conduct Residual Risk Assessments The Pulp and Paper Industry Experience 2012 International Emission Inventory Conference Session 10: Air Toxics August 16, 2012 Katie Hanks, RTI International Ann Crapo, NCASI John Pinkerton, NCASI

9 NEI 2005 Initially used to estimate Risk Elevated Risk Caused By: Pre-MACT emissions estimates Receptors on mill property Fugitive area sources that should have been coded as point sources with appropriate release parameters (e.g., stack height, exit gas velocity) Total source emissions reported to multiple vents instead of apportioned to individual vents Consolidated emission releases reported from a single point or only a few points Emissions from multiple sources sharing the same set of latitudinal and longitudinal co-ordinates Double reporting: source emissions reported as compound groups (cresols, xylenes, POM, etc) and also reported as individual pollutant 2012 International Emission Inventory Conference 9

10 Source Type and Release Parameters Point source (plume) stack diameter and height exit gas velocity, flow and temperature Area source (fugitive) quiescent surface length, width, and angle release height No SCC-, MACT-, or SIC-match defaults for point & area sources Parameter Point Source Area Source (02 06) (01) Stack height (ft) Stack temperature ( o F) Stack diameter (ft) Stack velocity (ft/sec) Stack flow (cu ft/sec) International Emission Inventory Conference 10

11 Improperly Located Process Equipment White Liquor Clarifier Mill 2012 International Emission Inventory Conference 11

12 Co located Sources: the One Point Mill Coordinates on emission points Coordinates for all emission points in one location 2012 International Emission Inventory Conference 12

13 Pollutant Issues in Inventory Hexachlorocyclopentadiene (HCCPD) Emission factors mostly non-detect Hexachloroethane (HCE) Emission factor review Additional testing by NCASI following RTR proposal Speciation required for: Chromium and Hexavalent Chromium Mercury Polycyclic Organic Matter Duplicate pollutant coding issues Case-by-case review 2012 International Emission Inventory Conference 13

14 Information Collection Request (ICR) Three-part ICR gathering data useful for 2 NESHAP RTRs and NSPS review Pre-populated inventories distributed 2/2011. Based on 2005 NATA NEI Spreadsheets with revision columns NEI updates were due 6/2011. Spreadsheets were QA d for completeness Mills contacted with follow-up questions ERG assembled into compiled file Intensive QA and standardization of compiled inventory 2012 International Emission Inventory Conference 14

15 Developing a Post MACT Inventory 2005 NEI updated with ICR data Detailed stack-by-stack information Emissions allocated to individual release points Unlike TRI which contains aggregated facility totals Stack parameters and geographic coordinates MACT codes, SCCs, and emission process groupings used to categorize emission sources Several HAP estimated per emission release point 2012 International Emission Inventory Conference 15

16 Pulp &Paper Post ICR Inventory Numbers 171 HAP major source mill locations (some with multiple NEI IDs) 130,000 records (rows) including non-hap 105,000 HAP records Average records per mill: HAP (some grouped) 214 HAP with groups speciated (e.g., POM) The nationwide HAP total in the inventory increased by about 5,000 tons/year (tpy) as a result of the ICR 225 SCCs 2012 International Emission Inventory Conference 16

17 SUMMARY Substantial effort required to inventory HAP from numerous P&P process types Pre-MACT versions of the NEI inadequate for RTR 2005 NEI with extensive revisions through ICR used 5-year iterative, collaborative effort between EPA, industry, and consultants Beneficial to improve data quality for facilityspecific risk assessments across entire industry Sharing of intermediate modeling results key to targeted review of emissions inventory data 2012 International Emission Inventory Conference 17