Risk and Technology Review Regulations and Technology Needs Presentation for ICAC Roundtable Meeting Brian Shrager, EPA Sector Policies and Programs Division December 3, 2015
Overview Risk and Technology Review (RTR) Background 2015 RTR Program Achievements RTR Program Highlights Other RTR Issues 2
Risk and Technology Review Background Residual risk and technology review (RTR) required within 8 years of promulgation of MACT standards Analysis of residual risk includes 2 steps 1. Determine if risk is acceptable considering health info 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 noncancer) 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 We also consider previously unregulated processes and HAP, and we make technical corrections 3
2015 RTR Program Achievements Issued 1 proposal and 10 final rules Off-Site Waste Manufacturing Operations, Published 3/18/15 Ferroalloys, Published 6/30/15 Mineral Wool, Published 7/29/15 Wool Fiberglass, Published 7/29/15 Phosphoric Acid Production, Published 8/19/15 Phosphate Fertilizer Manufacturing, Published 8/19/15 Secondary Aluminum, Published 9/18/15 Primary Aluminum, Published 10/15/15 Petroleum Refineries, Published 12/1/15 Aerospace, Proposal Published 02/17/15; Final Signed 11/19/15 4
RTR Highlights and Technology Needs Ferroalloys: Requires capture and control of fugitive emissions from multiple processes and requires use of digital cameras to continuously monitor opacity Technology needs include extensive fugitive emissions capture systems and associated PM controls, and digital camera opacity monitoring systems Wool Fiberglass: Includes standards for hexavalent chromium (Cr+6) and resulted in the addition of a new area source rule to ensure that Cr+6 is regulated at facilities not subject to the major source rule Primary technology projected for Cr+6 control is more frequent furnace rebuilding, although industry is evaluating various add-on control systems that could be used Petroleum Refineries: First RTR rule to require fenceline monitoring (of benzene); also includes measures to reduce emissions from flares, pressure relief devices, storage tanks, and delayed coking Technology needs include fenceline monitoring systems, PRD wireless monitors, flare instrumentation (Btu analyzers, Hydrogen Analyzers, etc...), compressors and other vacuum generating equipment for delayed cokers 5
Upcoming RTR Schedule Rule Proposal Date Final Rule Date Publicly Owned Treatment Works 12/8/16 a 10/16/17 a Portland Cement 6/15/17 a 6/15/18 a Large Municipal Waste Combustors TBD TBD Nutritional Yeast Manufacturing TBD b TBD b Pulp and Paper Combustion Sources TBD b TBD b Reconsiderations-Several Categories c TBD TBD a Date established by consent decree b Date to be determined by a U.S. District Court c Includes secondary lead, ferroalloys, polymers and resins III, phosphate fertilizer and wool fiberglass. Reconsiderations are limited to specific issues, and the rules remain in place during reconsideration. 6
Other RTR Issues Deadline suit for 20 additional source categories Negotiations ongoing Categories include Integrated Iron and Steel, Multiple Coatings Rules (Auto and Light Duty Truck, Misc. Metal Parts, Plastic Pasts, Metal Can, Metal Coil, Paper and Other Web), Hydrochloric Acid Production, Engine Test Cells/Stands, Asphalt Processing and Roofing, Cellulose Products, Ethylene Processes, Site Remediation, Vegetable Oil, Turbines, Reinforced Plastics and Composites, Organic Liquids Distribution, Misc. Organics NESHAP (aka the MON), Landfills, and Boat Manufacturing Ongoing litigation activities on several rules including multiple chemical sector rules, secondary lead, and ferroalloys The DC Circuit upheld the Chromium Electroplating RTR against challenges from both industry and environmental groups. 7
Questions? For more information, contact: Brian Shrager Sector Policies and Programs Division (919) 541-7689 shrager.brian@epa.gov 8