Air Toxics Regulatory Update

National Tribal Forum June 14, 2011

Overview

► Regulatory Updates ► Mercury and Air Toxics Standards► Boiler MACT/CISWI Reconsideration► Oil and Gas Sector Rulemakings► Stationary Engines NESHAP Reconsideration and NSPS

Amendments► Petroleum Refinery Sector Rulemakings► Chemical Sector Rulemakings

► Other Notable Regulatory Efforts► Upcoming Regulations► Pulp & Paper RTR Proposal Update

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REGULATORY UPDATES

Timeline for the Mercury and Air Toxics Standards

MILESTONE DATE

Proposal Published in Federal Register May 3, 2011

Public Hearings – Philadelphia & Chicago May 24, 2011

Public Hearing – Atlanta, GA May 26, 2011

Comment Period Ends July 5, 2011

Final Rule Signed November 16, 2011

Boiler MACT and CISWI Reconsideration

► Issues identified by EPA ► Full load stack test requirement for carbon monoxide coupled with

continuous oxygen monitoring ► Dioxin emission limit and testing requirements► Data considered in setting emission limits may not fully reflect

comments received► Setting PM standards under GACT for existing oil-fired boilers

► Issues identified by Industry► Dioxin and CO limits ► New source limits and HAP testing ► PM limits for some biomass boilers

► EPA issued a stay on May 18, 2011► We are moving forward expeditiously on the reconsideration

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Oil and Gas Sector Rulemakings

► Oil and GAS NESHAP and NSPS► Proposal: July 28, 2011► Final: February 28, 2012

► Nationwide emissions► HAP emissions of 130,000 tons► VOC emissions of 3 million tons► Methane emissions of 15.7 million tons (300 MMT CO2e)

► 40% of all U.S. methane emissions

► NESHAP revisions being considered

► NSPS improvements being considered for several emission points

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Stationary Engine NESHAP Reconsideration and NSPS AmendmentsExisting Engines► March 9, 2011 direct final/parallel proposal to address NESHAP

monitoring requirements for engines complying with the 2004 NESHAP

► Reconsideration of 2010 NESHAP amendments in Summer/Fall 2011► Monitoring requirements► Emission limits► GACT analysis for area source engines

New Engines► Final NSPS amendments in June 2011

Existing and New Engines► Propose requirements for engines used for back-up power (address

peak shaving and emergency demand response)7

Petroleum Refinery Sector Rulemakings► Petroleum Refinery Sector NESHAP and NSPS

► Proposal: December 10, 2011► Final: November 10, 2012

► Taking an integrated approach across the refinery sector to coordinate MACT and NSPS requirements that currently exist in many separate rules

► Key issues► Accurate emission data► Scope of the rulemakings► Options to address GHGs► Addressing environmental justice concerns and children’s health► Approach for addressing malfunctions

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Chemical Sector Rulemakings

► Taking an integrated approach across the chemical sector to coordinate MACT and NSPS requirements that currently exist in many separate rules

► Propose consolidated set of regulations for HAP and VOC from chemical plants ► Rules will reference new uniform standards► Perform risk and technology review (RTR) for six MACT (three

are under consent decree, three have statutory deadlines)► Also perform technology review for the Hazardous Organic

Chemicals NESHAP (HON), the largest chemical industry MACT

► Currently under court orders that require proposal for portions of this sector as early as Nov. 2011

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Other Notable Regulatory Efforts

► EGU GHG NSPS

► Iron and Steel Sector NESHAP

► Startup, Shutdown, and Malfunction Rule

► PVC and Copolymer Production NESHAP

► Cement Reconsideration

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Upcoming RegulationsRule Proposal PromulgationSecondary Lead Smelting RTR NESHAP 4/29/11 (completed) 12/16/11

Compression Ignition Engines NSPS; Amendments

5/22/10 (completed) 6/8/11

Pulp & Paper RTR NESHAP 6/15/11 1/31/12

Chromium Electroplating and Steel Pickling RTR NESHAP

9/14/10 (completed) 6/30/11

Aerospace Manufacturing RTR NESHAP 8/31/11 6/29/12

Nitric Acid NSPS 9/30/11 11/15/11

Shipbuilding/Wood Furniture RTR NESHAP 9/14/10 10/31/11

Primary Lead RTR NESHAP 10/31/11

Mineral Wool Production/Wool Fiberglass RTR NESHAP

10/31/11 6/29/12

Ferroalloys RTR NESHAP 10/31/11 6/29/12

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Upcoming Regulations (continued)

Rule Proposal PromulgationPrimary Aluminum RTR NESHAP 10/31/11 6/29/12

Secondary Aluminum RTR NESHAP 1/31/11 (completed) 10/31/11

Flexible Polyurethane Foam Prod. RTR NESHAP

10/31/12

Acrylic and Modacrylic Fibers RTR NESHAP

10/31/12

Polycarbonate Production RTR NESHAP 10/31/12

Off-Site Waste and Recovery RTR NESHAP

10/31/12

Phosphoric Acid RTR NESHAP 10/31/12

Phosphate Fertilizer RTR NESHAP 10/31/12

Group III Polymers and Resins RTR NESHAP

10/31/12

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PULP & PAPER RTR PROPOSAL UPDATE

Logs

Debarking Drum

Chipper & Screens

Chips

Dig

este

r

Pulp & Black Liquor

Washers

Evaporators

Recovery Boiler

Caustic Plant

Lime: CaO

Lime Kiln

Lime Mud: CaCO3

Green Liquor:Na2S, Na2CO3 Strong

Black Liquor

Weak Black Liquor

Wash Water

Pulp

Screens

Brown Pulp

Storage

Bleached Pulp

Storage

Bleach Plant

Wash Water

MACT 1 NSPSMACT 2 Power Boiler

BarkSteam

Boiler MACT

White Liquor:Na2S, NaOH

Paper

Paper Machine

Refiners

Additives

Paper Making Slurry

To Converting

Waste Water Treatment

Primary Clarifier

ASB To RiverWater From Process

Secondary Clarifier

Sludge Sludge Sludge

MACT 3 (bleached product)

(unbleached

product)

OilCoal

KRAFT PROCESS

Screens & Cleaners

Pulp & Paper Air Emissions

Digester Blow Tank & Accumulator

Washers & Screens

Lime Kiln

Slaker Dissolving Tank

Turpentine Recovery

Recovery Boiler

Multiple Effect Evaporators

Combination Fuel Boiler

Wood Chips

Pulp to the paper mill

Gaseous Organic HAP VOCHAP metalsPM HClSO2 ChlorineNOx HFCO CO2

Gaseous Organic HAP VOCHAP metalsPM HClSO2 TRSNOx

CO CO2

Gaseous Organic HAP VOCHAP metalsPM HClSO2 TRSNOx

CO CO2

Gaseous Organic HAP VOCTRS

Gaseous Organic HAP VOCTRS

Gaseous Organic HAP VOCTRS

Gaseous Organic HAP VOCTRS

Wastewater Treatment

Gaseous Organic HAP VOCTRS

Bleach Plant

HClChlorineChloroform

Gaseous Organic HAP VOCTRS

Gaseous Organic HAP VOCTRSPM

Gaseous Organic HAP VOC

Pulp & Paper MACTChemical Combustion MACTBoiler MACTNSPS

Pulp & Paper Sector in Perspective

► About 350 Pulp & Paper Mills► 200 major sources subject to MACT, typically

Integrated Pulp & Paper► 150 area sources, paper only

► $115 billion in sales; 400K direct jobs

► 79 million tons paper produced 2008, 18% decrease from 1999 peak

► China eclipsed U.S. as largest paper producer in 2008; U.S. still largest in pulp production

► Energy subsidies for biomass energy (burning ‘black liquor’) have become an important factor in net income/profit

Pollutant2005

Emissions (TPY)

(includes boilers)

To Compare:Refineries

HAP 57,000 14,000

VOCs 82,000 115,000

NOx 69,000 146,000

PM2.5 50,000 30,000

SO2 332,000* 247,000

CO 135,000 138,000

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* Boiler MACT Rule (co-benefit) projected to reduce SO2

by over 100,000 TPY with scrubber controls.

Pulping Sources in Category

► Main Pulping Sources: Digesters, Evaporators, (Some Facilities) Turpentine Recovery, Steam Strippers► Low volume high concentration

(LVHC) emission sources► MACT controls – combustion device

► Secondary Pulping: Washers, Screens, Liquor Storage► High volume low concentration

(HVLC) emission sources► MACT controls – combustion

device, clean condensate alternative or waste water treatment

► Mechanical Pulping Sources:► No MACT limits

► Bleaching► MACT controls – scrubber, total

chlorine free (TCF)

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Evaporator: Concentrates Black Liquor

Example Pulp & Paper Processing Equipment

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Turpentine Recovery

Causticizing Equipment

Digester Blow Tank

Papermaking Sources in Category

► Paper Machines► No MACT limits► An alternative compliance tool

for HVLC control under clean condensate alternative

► Waste Water Treatment► No MACT limits► An alternative compliance tool

for HVLC control using biological treatment (activated sludge)

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Paper Machines

► The CAA requires that we review MACT standards, considering advances in practices, processes, and control technologies.

► This allows us to tighten existing MACT standards with cost-effective controls.

► For the Technology Review, we also assess MACT to:► address significant unregulated emission points► require consistent monitoring and electronic compliance reporting► fix administrative requirements that are duplicative or inconsistent

What is Involved in the Technology Review?

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► Decision process for residual risk

► If maximum individual cancer risk (MIR) is less than 1 in 1 million and there are no other health impacts, then no further assessment is needed

► If MIR is greater than 100 in 1 million or other significant health impacts are identified, risks are “unacceptable” and must be reduced (this is not a bright line; uncertainties and other health factors need to be considered in this decision)

► If MIR is between 1 and 100 in 1 million, we tighten the standards if cost-effective controls are available to provide an “ample margin of safety”

► Also consider cost-effective controls to address other endpoints, including noncancer effects, population risks, and environmental impacts

► Consider facility-wide risks and demographic analyses to:► make acceptability and ample margin of safety determinations

► identify other source categories for priority review and regulatory action, as appropriate

What is Involved in the Risk Review?

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For More Information

► Amy Vasu► 919-541-0107► Vasu.amy@epa.gov

► OAR Policy & Guidance Information► www.epa.gov/ttn/oarpg

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