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Indiana Steel Environmental Group January 11, 2012

Indiana Steel Environmental Group January 11, 2012. Thomas W. Easterly, P.E., BCEE, QEP Commissioner IN Department of Environmental Management. IDEM’s Mission. We Protect Hoosiers and Our Environment

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Indiana Steel Environmental Group January 11, 2012

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  1. Indiana Steel Environmental GroupJanuary 11, 2012 Thomas W. Easterly, P.E., BCEE, QEP Commissioner IN Department of Environmental Management

  2. IDEM’s Mission We Protect Hoosiers and Our Environment IDEM’s mission is to implement federal and state regulations to protect human health and the environment while allowing the environmentally sound operations of industrial, agricultural, commercial and government activities vital to a prosperous economy.

  3. How Does IDEM Protect Hoosiers and Our Environment? • Develop regulations and issue permits to restrict discharges to the environment to safe levels. • Inspect and monitor permitted facilities to ensure compliance with the permits.

  4. How Does IDEM Protect Hoosiers and Our Environment? • Use compliance assistance and/or enforcement when people exceed their permit levels or violate regulations. • Educate people on their environmental responsibilities.

  5. 25 Years of Progress http://www.in.gov/idem/files/state_of_environment_2011.pdf

  6. REMARKABLE AND CURIOUS TIMES • Power plants are getting cleaner and cleaner. • Air quality is getting better and better. • The economy is on its back. • Worldwide debate over the future of energy policy. • Increasing restrictions on the mining and burning of coal and the disposal of coal ash. • An avalanche of new action directly against power generation in general and coal-fired generation, in particular.

  7. UNPRECEDENTED FEDERAL INITIATIVES Clean Air Act • CAIR (Clean Air Interstate Rule)/Transport rule/CSAPR (Cross State Air Pollution Rule) • NAAQS revisions—SO2, NOx, Ozone, PM2.5 • Mercury / HAPS (Hazardous Air Pollutants) • Greenhouse Gasses including CO2

  8. UNPRECEDENTED FEDERAL INITIATIVES Clean Water Act • Intake structures (316(b)) • Effluent guidelines Resource Conservation and Recovery Act (RCRA) • Coal combustion residuals (CCR)

  9. Protection of Downwind States • The concept of the series of air transport rules: • Clean Air Interstate Rule (CAIR) • Transport Rule • Cross States Air Pollution Rule (CSPAR) is that emissions in some states were interfering with the attainment of air quality standards in other states.

  10. Protection of Downwind States • In 2005 a number of Counties including three in Indiana did not meet all ozone and PM2.5 air quality standards. U.S. EPA projected that over 100 counties would still not meet standards by 2012. • By the end of 2010 air quality in Indiana and the rest of the country had improved to meet the Ozone and PM2.5 air quality standards addressed by CSAPR (except for two areas impacted by local sources).

  11. Protection of Downwind States

  12. Protection of Downwind States • Modeled projections by some groups indicate that all areas of the country impacted by transport may achieve the Ozone and PM standards without the emission reductions being required by CSAPR—actually happened in 2010. • The use of the 2005 as the base year instead of a more recent year and U.S.EPA’s triple weighting of the base year are bad for Indiana.

  13. CAIR/Transport Rule/CSAPR IDEM expected to meet the Transport Rule Statewide caps for 2012 without additional controls, CSAPR reduced those caps by 29%--not currently achievable. IDEM expected that we would need one current project completed and another source controlled to meet the 2014 caps. CSAPR reduced the caps by 20%. CSAPR annual cost estimated to be $2.4 billion.

  14. CAIR/Transport Rule/CSAPR • The State of Indiana has filed three actions to respond to CSAPR: • A petition to reconsider the rule with U.S. EPA. • A petition for judicial review of the rule with the DC Court of Appeals. • A request for a stay of the rule with the DC Court of Appeals. • We are also working with LA, OH, TX and WV to advocate reconsideration of the rule.

  15. CAIR/Transport Rule/CSAPR • U.S. EPA is implementing CSAPR through a Federal Implementation Plan (FIP) before allowing the States to implement the rule. • The State has no role in CSAPR unless we modify our State Implementation Plan (SIP). • U.S. EPA is moving to approve our requests to redesignate the State of Indiana to attainment for PM2.5 now that CSAPR is in effect. • This rule will also allow U.S. EPA to approve our BART SIP submission.

  16. CAIR/Transport Rule/CSAPR • Success to Date: On December 30, 2011, the DC Circuit Court of Appeals issued a Stay of CSAPR and indicted that a hearing on the merits of the appeals would likely be held in April. • Cost of Success: U.S. EPA placed a hold on the PM2.5 attainment designation for the Indianapolis Area which had been sent to the Federal Register, but not published.

  17. NAAQS Revisions At the end of 2009, all of Indiana met every currently effective NAAQS for the first time since NAAQS were established in the 1970’s. • New 75 ppb 1 hour SO2 Air Quality Standard (2010). • New 100 ppb short term NOx Air Quality Standard (2010). • U.S. EPA reconsideration of 0.075 ppm ozone Air Quality Standard. • U.S. EPA review of the 15 microgram/cubic meter annual PM2.5 Air Quality Standard.

  18. 1-Hour Sulfur Dioxide (SO2) – Maximum 1-Hour Design Value Trends

  19. Indiana Preliminary Designation Recommendations SO2 1-Hour Standard June 6, 2010: U.S. EPA Announced A New SO2 1-Hour Standard Set At 75 ppb

  20. IDEM Steel Related SO2 Actions • All Steel Mills (including Minis) are in areas that will be designated unclassifiable for SO2. • U.S. EPA is requiring modeled demonstrations of attainment for all unclassifiable areas and the establishment of SO2 limits for any source with more than 100 tons per year of actual emissions. • IDEM staff is working with the mills and their consultant to produce this modeling demonstration of attainment.

  21. IDEM Steel Related SO2 Actions • We plan to publish a second notice SO2 emission regulation this spring. • We expect the APCB to preliminarily adopt the proposed SO2 emission regulation this summer. • We expect to publish the third notice in this fall. • We expect the APCB to final adopt the SO2 emissions regulations in the spring of 2013. • Lake and Porter will likely not be successfully modeled on the schedule for the rest of the state.

  22. IDEM Steel Related SO2 Actions • SO2 Air Quality Modeling in Lake and Porter Counties currently predicts SO2 concentrations that are more than 40 times actual measured SO2 concentrations. • We are not the only State where the model is grossly over-predicting monitored concentrations and we are working with U.S. EPA to find a solution to this issue.

  23. NAAQS REVISIONS - OZONE • Administrator Jackson stated that the current 0.075 ppm (8 hour average)ozone standard did not protect public health and would be reconsidered. • On January 19, 2010 U.S. EPA proposed a new standard (0.060 – 0.070 ppm). • Good news: On September 2, 2011, President Obama cancelled the reconsideration—next ozone standard revision will be on the normal schedule (2013).

  24. Ozone – Maximum Design Value Trends

  25. March 15, 2010: U.S. EPA Announced It Would Reconsider The Annual PM2.5 Standard Within ARange Of 11-14 µg/m3 PM2.5 Annual Design Values (3-yr Average) Based on 2008-2010 Monitoring Data Standard at 13 µg/m3

  26. Fine Particle (PM2.5) – Maximum Annual Design Value Trends

  27. MERCURY MACT (NESHAP) Proposal Published: May 3, 2011 Final Deadline: Currently December 16, 2011 • Annual rule cost $10.9 billion. • Annual rule HAP benefit $5,000 to $6,000,000 (0.00209 IQ points per exposed person or 510.8 IQ points per year in US out of 31 billion IQ points) • Rule cost is between $1,211 and $2,180,000 per $1 of HAP benefit. • Estimated annual co-benefits $53 to $140 billion.

  28. MERCURY MACT (NESHAP) • HAPS: Hg, HCL, PM, THC, Dioxins / Furans • Rule requires about 90% reduction in mercury emissions. • No MACT trading (except units at a single site). • Mercury emissions in Indiana have decreased by approximately 20% over the past 14 years, but measured mercury deposition has decreased by only 7% and there is no apparent change in mercury fish concentrations in Indiana.

  29. CO2 (Green House Gasses) The National Academy of Sciences report, “America’s Climate Choices” recommends that actions be taken now to start reducing U.S. greenhouse gas emissions to levels between 50% and 80% below 1990 levels. • Achieving an 80% reduction from 1990 levels would require a 81.4% reduction from 2009 levels. • If we converted all U.S. fossil fuel use from coal and oil to natural gas, we would achieve a 23.9% reduction from 2009 levels.

  30. CO2 (Green House Gasses) • The remaining emissions would need to be reduced by 73.8% to reach the 80% target. • Apparent choices are: • Energy conservation. • Increasing non-hydro renewable energy sources from the current 5.5% market share. • Carbon sequestration. • Nuclear electricity. • Is it possible to achieve the additional 73.8% reduction?

  31. Clean Water Act – (316(b)) • 316(b) is a section of the Clean Water Act designed to reduce the damage to aquatic organisms from impingement on the intake structures and entrainment in the water passing through a facility. • Factors to be considered in a 316(b) assessment: • Is through screen velocity sufficiently low to allow fish to escape? • What is the mortality rate of aquatic life impinged/entrained? • Has there been a sufficient reduction in the amount of aquatic life impinged/entrained? • Has there been a sufficient reduction in the mortality of aquatic life impinged/entrained?

  32. Clean Water Act – (316(b)) Proposed: April 20, 2011 Good news: Does not mandate retrofitting closed-cycle cooling to address entrainment at all facilities covered by the rule. Bad news: Inflexible one-size-fits-all approach to minimizing impacts due to impingement of aquatic organisms by cooling water systems.

  33. CLEAN WATER ACT – EFFLUENT GUIDELINES (technology based effluent limits) • Notice of plan availability: Preliminary 2010 Effluent Guidelines Program PlanDecember 28, 2009 (74 Fed. Reg. 68599) • Request for information : Questionnaire for Steam Electric Power Generating Effluent Guidelines March 9, 2010 (75 Fed. Reg. 10791) Highlights: • “high levels” of toxic weighted pollutants • Caused by air pollution control systems • Various wastewater treatment systems under investigation

  34. Coal Combustion Residuals (CCR) Proposed rule: June 21, 2010 (75 Fed. Reg. 35127) • Beville amendment and actual waste characteristics have historically exempted CCR from Subtitle C (hazardous waste) regulation . • December 2008 coal ash spill in Tennessee has caused that exemption to be reviewed • Options being considered include: - phase out all surface impoundments in favor of landfills. - allow surface impoundments, but with stricter controls.

  35. Coal Combustion Residuals IDEM data indicates that CCR do not exhibit hazardous characteristics, therefore, they should not be regulated under Subtitle C. IDEM believes that U.S. EPA should develop reasonable minimum national management standards for surface impoundments and landfills under Subtitle D. Due to volume of public comments, U.S. EPA will not publish a final rule until sometime in 2012.

  36. IDEM 2011-2012 Goals and Challenges

  37. 2011-2012 IDEM Major Goals • Complete Antidegradation Rulemaking Process. • WPCB Preliminary Adoption September 19, 2011. • Third Notice Comment Period December 7 to December 30, 2011. • Final Adoption consideration by WPCB in 2012. • Obtain U.S. EPA approval of attainment designations for PM2.5 for all of Indiana: • Evansville and Cincinnati are Final and effective. • NW Indiana is Final and effective 2/6/2012. • Indianapolis has been signed and sent to the Federal Register, but is currently being held (CSAPR).

  38. 2011-2012 IDEM Major Goals • Complete CAFO/CFO Rulemaking Process. • Done Final Adoption November 9, 2011. • Adopt RISC Closure Guidance as an NPD. • Released for public comment May 6, 2011. • Public Comment on Revised NPD started 1/6/12. • Plan to present to SWMB February 21, 2012. • Reissue NPDES General Permits Administratively and address antidegradation requirements.

  39. 2011--2012 IDEM Challenges • Attainment and nonattainment designations for new SO2 Standard and 0.075 Ozone Standard. • Complete implementation of major IT initiatives: Virtual File Cabinet, Digital Inspector, TEMPO. • Respond to U.S. EPA’s Cross States Air Pollution Rule (CSAPR) which replaced the Transport Rule.

  40. 2011--2012 IDEM Challenges • Other possible U.S. EPA decisions such as 316(b) cooling water intakes, no Coal Combustion Waste decision expected in 2011. • Develop and implement plan for seamless implementation of water program responsibilities currently assigned to: IDEM, ISDH, IDNR, IDHS, and ISDA.

  41. Environmental Quality Service Council IDEM Cost of Service and Revenues Thomas W. Easterly, P.E., BCEE, QEP Commissioner August 4, 2011

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