air toxic overview
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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?
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