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Region 5 Enforcement Approach

Region 5 Enforcement Approach. NACAA Enforcement and Compliance Workshop. George Czerniak June 13, 2007. TARGETED INVESTIGATIONS. Don’t Try for Broad Coverage Don’t Affirm Compliance High Likelihood of Violation Where Correction Will Result in Significant Emission Reduction

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Region 5 Enforcement Approach

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  1. Region 5 Enforcement Approach NACAA Enforcement and Compliance Workshop George Czerniak June 13, 2007

  2. TARGETED INVESTIGATIONS • Don’t Try for Broad Coverage • Don’t Affirm Compliance • High Likelihood of Violation Where Correction Will Result in Significant Emission Reduction • Focus on Company, Sector, Rule

  3. CASE DISTRIBUTION

  4. CASE DISTRIBUTION

  5. CASE DISTRIBUTION

  6. ENVIRONMENTAL BENEFIT FROM FY 2006 CAA SETTLEMENTS • Primary Environmental Benefit • Emission Reductions (142,942,912 lbs/yr) • 98,828,033 lbs/yr Sulfur Dioxide • 13,628,951 lbs/yr Nitrogen Oxides • 10,468,625 lbs/yr Volatile Organic Compounds • 9,574,790 lbs/yr Carbon Monoxide • 6,946,758 lbs/yr Carbon Dioxide • 2,326,870 lbs/yr PM10/Particulate Matter • 1,158,218 lbs/yr Hazardous Air Pollutants • 8,588 lbs/yr Chlorofluorocarbons • 2,079 lbs/yr Lead • Federal Penalties Assessed - $4,512,447

  7. PORTION OF ENVIRONMENTAL BENEFIT IN SUPPLEMENTAL ENVIRONMENTAL PROJECTS • SEP Emission Reductions (11,667,767 lbs/yr) • 6,946,758 lbs/yr Carbon Dioxide • 4,071,210 lbs/yr Carbon Monoxide • 240,033 lbs/yr Sulfur Dioxide • 233,398 lbs/yr Hazardous Air Pollutants • 130,748 lbs/yr PM10/Particulate Matter • 26,951 lbs/yr Nitrogen Oxides • 15,425 lbs/yr Volatile Organic Compounds • 2,079 lbs/yr Lead • 1,165 lbs/yr Chlorofluorocarbons

  8. TARGETING APPROACH Theory of Violation Develop Expertise Work Through Company, Sector, Rule

  9. TARGETING EXAMPLES

  10. ACID PRODUCTION THEORY: NSR

  11. ACID PRODUCTION PLANT DIAGRAM

  12. ACID PRODUCTION • Remedy • Sulfuric Acid Plants • Wet Gas Scrubber • Double Contact Double Absorption System Capable of Meeting an Emissions Limit of 1.5 lbs/ton • Mist Elimination System Capable of Meeting Sulfuric Acid Mist Emission Rates of 0.15 lbs/ton or less

  13. ACID PRODUCTION • Remedy (cont.) • Nitric Acid Plants • Selective Catalytic Reduction (SCR) • Non-Selective Catalytic Reduction (NSCR), and/or • Extended Absorption System • Capable of Meeting NOx Emission Limits in the Range of 0.3 to 0.6 lbs/ton

  14. ACID PRODUCTION • Potential Environmental Results • 120,000 TPY of SO2 • 30,000 TPY of NOx • Current Status • Two (2) Settlements • 6 Sulfuric Acid Plants • 1 Nitric Acid Plant • Reductions: • 19,000 TPY SO2 • 200 TPY NOx • Sulfuric Acid Mist Reductions • Settlement discussions continue with others

  15. PETROLEUM COKE THEORY: NSR

  16. PETROLEUM COKE • Affected Sectors • Cement • Iron and Steel • Coal Fired Boilers • Calcining • Remedy • SO2 (Scrubbers) • NOx (SCR and SNCR) Controls • Potential National Environmental Results • 160,000 TPY SO2 and NOx Reductions • Current Status • One Global Negotiation in Progress, One On-going Case, Two Investigations

  17. FLARING THEORY: LESS SCRUTINY FOCUS ON OPACITY

  18. FLARING • Proper Operation • Pilot flame must be present • Sufficiently low exit velocity • Smokeless operation • Steam or air commensurate with organics • Heat Content > (300 BTU/scf)

  19. FLARING • Regulations • MACT • General provisions 63.11(b) • Polymers & Resins, HON, Pharmaceuticals, Refineries, etc. • NSPS • General Provisions 60.18(b) • SOCMI, Polymers, Refineries, etc. • SIP • State VOC reduction requirements • State permit requirements (e.g. 300 BTU)

  20. FLARING • Violations • Heat Content lower than 300 BTU/scf (63.11(b), 60.18(b)) • Failure to use good air pollution control practices by steam addition in excess of design parameters (63.6(e), 60.11(d)) • Specified by API and Flare Manufacturer • Typically near 1 lb steam/1 lb gas • Destruction Efficiency Specified in SIP (95%)

  21. FLARING • Remedy • Heat Content (BTU/scf) Instrument • Steam Addition Control Valve • Natural Gas Addition Control Valve • PLC So Heat Content Dictates Steam and Natural Gas Addition Rates • Potential Environmental Benefits • Increase In Destruction Efficiency at the Flare • Less VOC and HAPs Emissions

  22. FLARING • Current Status • Batch Chemical Plant in SW Ohio • 300 BTU/scf and oversteaming violations • NOV issued • > 560 TPY excess emissions • Batch Chemical Plant in NW Ohio • 300 BTU/scf and oversteaming violations • NOV issued • ~ 12 TPY excess emissions • Batch Chemical Plant in SE Ohio • $675,000 instrument upgrade for two flares in response to an information request • < 5 TPY excess emissions

  23. CEM THEORY: WRONG PERCEPTIONS

  24. CEM

  25. CEM

  26. CEM

  27. CEM

  28. CEM • Remedy • Continuous compliance • Fixing causes of excess emissions/CEMS downtime so they don't happen again • Injunctive relief (redesigned/new control technology to replace old/underdesigned controls) • SEPS • Current Status • Seven Notices/Findings of Violation • ~ 100 Facilities Being Reviewed

  29. QUESTIONS

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