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Paul Koval December 6, 2011 Air Toxic Overview
Air Toxics Overview • Ohio Air Toxic Update • Project updates • East Liverpool • National Air Toxic Assessment (NATA) Overview • ATU Updates
Summary of Risk Management Decisions • Ohio EPA determined that S.H. Bell is the major source contributing to elevated Mn concentrations. • Director issued 2 sets of Findings & Orders requiring immediate control measures: • enclosing some storage piles and screening operations, tarping trucks, paving roads, and using water trucks, sweepers and other means to minimize dust.
NATA Overview High Risk Sources NATA (the National Air Toxics Assessment) is a prioritization tool used to identify geographic areas, pollutants and emission sources that should be evaluated further to gain a better understanding of health risks posed by air toxics. NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to specific individuals. This is because NATA uses models to estimate risks. U.S. EPA has provided Ohio EPA with a list of Ohio’s “High Risk Point Sources” [HRPS], derived from the most recent NATA study. This list contained 147 facilities.
NATA OverviewHigh Risk Sources Facilities were classified as high risk sources when there is a risk of greater than 10 in a million (1 x 10-5) or a hazard index (HI) greater than 1. Ohio EPA discovered many errors within the list. Problems ranged from incomplete and inaccurate emission inventories, mischaracterization of chromium emissions, and many facilities being out-of-business. DAPC investigated the accuracy of the Ohio list.
HRPS Project Method U.S. EPA clarified the risk that results in activity by Region V. In general, action is necessary when cancer risks are greater than 100 in a million (1 x 10-4) and / or the non-cancer hazard index is greater than five (5.0). STEPS: The initial list of 147 HRPS was first narrowed down to the facilities that met these criteria. Secondly, staff determined if a listed facility is still operating. If facility is operating, then we examined NATA data to investigate source of emission(s) data.
HRPS Project Method Cont. • Compared NATA emissions data to TRI 2005 data • Compare NATA emissions data to most current Stars 2 data, or, if not available, compared to TRI 2009 data. • In the case of chromium emissions, we contacted you (DO/LAAs) to determine if Cr compound(s) have been correctly identified, if emission data appears correct, and if there have been any changes to the facility’s emission profile. • Facilities were then placed in one of three categories: high risk point source, low risk point source, and shut down.
Results From the 147 facilities on the original list, 32 facilities were considered above the U.S. EPA action level. Of these 32 facilities, 4 facilities closed. 16 facilities were re-categorized in the low risk point source category (below action levels). 8 facilities remained in the high risk point source category. We are still awaiting verification of 4 facility’s status.
Low Risk Point SourcesSummary The majority of these facilities were on the original list due to Cr+6 emissions. However, upon verification, most of the facilities did not use Cr+6 in their production processes, but used Cr+3. This discovery caused their re-categorization in the low risk point source category. Reduced production levels since 2005 and / or over-estimation of emissions in the 2005 TRI also caused facilities to be moved to the LRPS category.
ATU MACT Information MACT Position: not scheduled to be filled yet, on docket to be examined for future hiring. ATU assisting with filing and distributing Initial Notification and compliance information to Feds and DO/LAAs. Specific engineering questions should now be directed to Permitting Section contact in CO working on the source category.
ATU GACT Information GACT Delegation of Authority: Ohio EPA has not applied for or received delegation of authority for the Area Source MACTs (GACTs). Questions need to be directed to U.S. EPA contact for the rule.
ATU GACT Information • All paperwork needs to be sent to U.S. EPA. • Each DO/LAA can keep copy of paperwork if desired, but not required. • No T & C’s put in Permits, just notification that area source GACT may apply to source by U.S. EPA. • No inspection of GACT requirements to be conducted during site visits.
Asbestos Update 1 5-year Rule Review: Asbestos rules undergoing rule review currently. The following rules needed changes. OAC 3745-20-01(B), Definitions and incorporation by reference and OAC 3745-20-05(A), Standard for asbestos waste handling. The definitions of "Facility"; "Friable asbestos material"; and the addition of new definition "Residential exempt structure", for clarification purposes only.
Asbestos Update 2 The amendment to 3745-20-05(A) will allow only Category I non-friable ACM that is not RACM to go to a CD&D landfill. The amendment will make this rule consistent with the federal asbestos NESHAP regulations at 40 CFR Part 61.154(b). Clarifying changes were made regarding referenced items in rules 3745-20-07; 08; 09; 12; 13; and 15. The DAPC has reviewed asbestos emission control rules in OAC rules 3745-20-02; 03; 04, 06, 10, 11 and 14 and found them to be necessary but without need for changes:
Asbestos Update 3 DAPC’s “interested parties” comment period began October 7th , 2011 for the first 30-day review. Comments were addressed and a responsive summary prepared. A copy of the summary can be obtained on our web-site. The public hearing on these rule changes will be conducted on Monday, January 9th , 2012 at 10:00 AM.
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