Paul KovalDecember 6, 2011

Air Toxic Overview

• Ohio Air Toxic Update

• Project updates– East Liverpool– National Air Toxic Assessment (NATA)

Overview– ATU Updates

Air Toxics Overview

Total Cancer Risk Estimates Volatile Organic Compounds (VOCs)

Total Cancer Risk Estimates Volatile Organic Compounds (VOCs)

Butler (00 - 1

0)

Cuyahoga-St. Theo.(06-10)

Cuyahoga-F.S. #11 (04 - 10)

Cuyahoga-F.S. #22 (04 - 10)

Jefferson (04 - 1

0)0

2

4

6

8

10

12

14

16

18

20

Average Total Risk Per County (2000 - 2010)

County

Risk

(10

E -0

5)

Current Sites

Total Cancer Risk Estimates Volatile Organic Compounds (VOCs)

Butler

Cuyahoga-St. Theo.

Cuyahoga-F.S. #11

Cuyahoga-F.S. #22

Jefferson

0

2

4

6

8

10

12

14

16

18

20

Average Total Risk Per County (2000 - 2010)

Updated Average (00-10)Reported (00-09)

Current Sites

County

Jefferson County Average Risk

2004 2005 2006 2007 2008 2009 20100

5

10

15

20

25

30

35

Jefferson County Average Risk (04-10)

Year

Risk

(10

E -0

5)

Total Cancer Risk Estimates Heavy Metals

Butler/O

hio Bell

Columbiana/M

arylan

d Ave

Columbiana/P

ort Authorit

y

Columbiana /

Wate

r Plan

t

Cuyahoga/

Ferro

"A"&

B

Cuyahoga

/Asphalt

Plant A

Cuyahoga

/St. T

heodosiu

s Church

Cuyahoga/

Fire "

4A", "4B"

Frankli

n/Ann, W

oodrow

Fulto

n

Loga

n/Bell

efontai

ne

Ottawa/B

rush

Well

man 32

Washingto

n/Care

er Cen

ter0

5

10

15

20

25

30

35Average Total Non-Cancer Risk

Reported (00-09) Updated (00-10)

Haz

ard

Inde

x

County

East Liverpool/ Heavy Metals

• 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.

Summary of Risk Management Decisions

2004 2005 2006 2007 2008 2009 2010 20110.00

0.50

1.00

1.50

2.00

2.50

East Liverpool Annual Average Manganese Con-centrations

Note: 2011 values represent January through JulyCo

ncen

trati

on- µ

g/m

³

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 Overview

NATA Overview

High 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.

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

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.

• 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.

Results

Results Cont.

SHUTDOWN

GE LIGHTING INC.

TRW INC VALVE DIV

TRI PALM INTERNATIONAL LLC

FAURECIA EXHAUST SYS INC TROY FACILITY

LRPS

WHEMCO-OHIO FOUNDRY INC ENERFAB CORP

EVERTZ TECHNOLOGY SERVICES XTEK, INC.

AK STEEL-COSHOCTON WORKS

MODERN WELDING CO OF OHIO INC

ALCON INDS INCREPUBLIC ENGINEERED PRODUCTS, INC

AMERICAN SPRING WIRE CORP.

BWX TECHNOLOGIES INC

ISG CLEVELAND INC. ERAMET MARIETTA, INC.

FMC FOODTECH STEIN-DSI GLOBE METALLURGICAL INC.

CRANE PERFORMANCE SIDING LLC - NORTH

PREMIUM BUILDING PRODUCTS

HRPS

PENTAIR PUMP INC

VON ROLL AMERICA INC

Quaker City Castings

A-BRITE PLATING CO

PLASTIC PLATERS INC

COLUMBUS STEEL CASTINGS

BARIUM & CHEMICALS INC

SAFETY-KLEEN SYSTEMS INC

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.

Comments / Questions

• Comments / Easy questions?