Area Source NESHAP Implementation in Iowa

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Area Source NESHAP Implementation in Iowa

• A review of the latest federal air toxics
  regulations affecting many small businesses

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Definitions

• NESHAP National Emission Standards for
  Hazardous Air Pollutants
• Found in 40 CFR Part 63
• DNR adoption in 567 IAC Chapter 23
• Area Sources Facilities or installations that
  have the potential to emit less than 10 tons per
  year of any single hazardous air pollutant (HAP)
  or 25 tons per year of any combination of HAP
  (not major sources)
• Area sources are of concern because although
  generally
• small in size, they are large in number and
  collectively,
• area sources may pose health risks.

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Why Area Source NESHAP?

• The federal Clean Air Act (CAA) requires EPA to
• Reduce publics exposure to HAP, sometimes called
  air toxics, that are known or suspected to
  cause cancer or other serious health effects
• Identify and list at least 30 HAP that pose the
  greatest risk in urban areas (EPA
  identified/listed 33)
• Identify and list area source categories
  (industries or operations) that represent 90 of
  the 33 urban HAP emissions (EPAs urban air
  toxics strategy)
• Set standards for the listed area source
  categories
• Ensure that area sources meet, at a minimum,
  Generally Available Control Technology (GACT)

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Background

• Pre-2005 15 NESHAP issued e.g. Dry Cleaners,
  Halogenated Solvent Cleaners, and Chromium
  Electroplaters
•  2006-2007 10 NESHAP issued e.g. Clay
  Ceramic Products, Lead Acid Battery, Wood
  Preserving and Hospital EtO Sterilizers
• January 2008-now 9 NESHAP issued, so far - More
  small businesses and previously unregulated
  facilities impacted

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Overall Challenges

• Estimate 3000-5000 facilities in Iowa could be
  impacted by area source NESHAP
• Several NESHAP issued at or near the same time
• No additional funding from EPA
• Limited staff and resources
• Some facilities may be subject to more than one
  NESHAP

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Facing the Challenges

• NESHAP Implementation Group
• Formed in March 2008
• Cooperative effort among DNR Air Quality
  Bureau, University of Northern Iowa IAEAP, Iowa
  Department of Economic Development Small
  Business Liaison, Linn Polk County Local Air
  Programs
• Developing outreach strategies
• Working with impacted stakeholders

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Facing the Challenges

• Implementation Approaches
• DNR vs. EPA implementation
• Developing outreach and compliance assistance
  strategies specific to each NESHAP
• Identifying affected facilities
• Presentations workshops
• Fact sheets other outreach materials
• Website (for easier access)
• Guides
• Listserv and newsletters
• Streamlined permits registration forms

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Standards for Stationary Internal Combustion
Engines

• One NESHAP Two New Source Performance Standards
  (NSPS) for stationary Compression Ignition (CI)
  and Spark Ignition (SI) engines
• HAP emissions from engines include formaldehyde
  benzene
• All sizes of engines covered (no deminimus level)
• NESHAP does not impact existing engines at
• this time

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Stationary Internal Combustion Engines

• Affects owners and operators of stationary
  engines manufactured after certain trigger dates
• 2006 for CI engines 2008 for SI engines
• NESHAP Requirements include
• Manufacturer certification to meet emission
  standards (some exceptions)
• Use of low sulfur fuel
• Non-resettable hour meter

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Stationary Internal Combustion Engines
Challenges?

• Stationary engines are used at many different
  types of facilities (no specific industry sector)
• Regulations are lengthy, complex and confusing
• Hundreds if not thousands of new engines will be
  installed over the years
• Portable engines Some are considered to be
  nonroad and are not subject to NSPS-NESHAP
• EPA has proposed standards for existing engines
  that may pose very stringent requirements in the
  next few years.

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Stationary Internal Combustion Engines
Addressing Challenges

• Developed engine registration form for smaller
  engines
• Working with engine distributors, municipal
  utility associations and other stakeholders
• Developed listserv articles and Frequently Asked
  Questions document (on website)

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Surface Coating NESHAP Subpart 6H

• Sets standards for three source categories to
• control HAP emissions from
• Paint stripping (methylene chloride (MeCl))
• Surface coating of motor vehicle/mobile equipment
  (Target HAP)
• Miscellaneous surface coating (Target HAP)
• Applies only if spray apply coatings that contain
  the Target HAP Lead, Manganese (Mn), Nickel
  (Ni), Cadmium (Cd) or Chromium (Cr)

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6H NESHAP Who is Impacted?

• Manufacturers who spray apply coatings to metal
  or plastic (wood and other materials are not
  covered)
• Estimate 100-150 Iowa facilities
• Autobody shops and other mobile equipment
  refinishers/manufacturers (e.g. trailer mfg)
• Estimate 1000-2000 Iowa facilities

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6H NESHAP Requirements?

• Specific equipment and management practices
  required for
• Paint booth exhaust systems
• Spray booths/prep stations
• Spray guns
• Spray gun cleaning operations
• Painter training

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6H NESHAP Challenges?

• Many autobody shops need assistance with NESHAP
  and other air quality requirements
• HAP-free coatings for autobody operations are not
  yet readily available
• Painter training not yet widely available
• All autobody/mobile source operations are
  affected, even if Target HAP-free, unless they
  request and receive an exemption from the
  Administrator (DNR)

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6H NESHAP Addressing Challenges

• Streamlined permitting DNR revised
  permit-by-rule (PBR) to include 6H questions
• Outreach materials
• UNI-DNR workshops over 700 attendees
• Partnering with stakeholders on training and
  outreach

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Metal Fabrication Finishing NESHAP Subpart 6X

• Sets standards for nine source categories under
  12 SIC codes (Standard Industrial Classification)
• Must be more than 50 of the production at the
  facility to be an affected source
• Regulates emissions of Lead, Mn, Ni, Cd, and Cr
• Applies to five types of manufacturing activities
  at covered facilities
• Applies only to facilities with potential to emit
  MFHAP or that use materials that contain MFHAP

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6X NESHAP

• Challenges
• Applicability issues with SIC and determining
  primary production activity
• Standards management practices are complex
  (e.g. welding and painting)
• Addressing the Challenges
• Streamlined permitting - PBR
• Outreach Materials

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Gasoline NESHAP Subpart 6B Subpart 6C

• Sets standards for gasoline source categories to
  control benzene emissions
• Bulk gasoline distribution (6B)
• Gasoline Dispensing Facilities GDF (6C)
• Gasoline includes ethanol blends up to E85
• Oil, diesel and other fuels are not covered

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6B NESHAP

• Affects Bulk Gasoline Sources
• Gasoline terminals
• Pipeline breakout and pumping station
• Gasoline bulk plants
• Requirements
• Must use submerged fill
• Minimize gasoline vapor releases
• Monthly leak inspections
• Larger terminals - install emissions control

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6B NESHAP Challenges?

• Most bulk plant owners/operators are unfamiliar
  with air quality regulations (most bulk plants
  are unpermitted)
• Many bulk plants are located in rural areas, some
  are unmanned
• Nearly all bulk plants need a throughput limit
• lt 20,000 gallons/day to avoid classification as
  bulk terminals
• Some bulk plants may not yet have submerged fill
  on loading racks

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6B NESHAP Addressing Challenges

• Developing a streamlined permit template for bulk
  plants
• UNI developing a compliance calendar
• Working with Petroleum Marketers and Convenience
  Stores of Iowa (PMCI) and Agribusiness
  Association of Iowa (AAI) on tool development and
  roll-out
• Permitting assistance and compliance workshops
  scheduled for winter 2010

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6C NESHAP

• Affects GDF - Commercial gas stations (estimate
  3000 facilities) other installations
• Requirements
• Small GDF Best management practices (BMP) for
  gasoline vapor and spills.
• Medium GDF BMP and submerged fill
• Large GDF BMP, submerged fill, vapor balance
  systems (Stage 1) and initial/periodic vapor
  testing

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6C NESHAP

• Challenges
• Implementation at Large GDF
• Addressing the Challenges
• Two formal meetings with interested stakeholders
• Working closely with underground storage tank
  (UST) interests (DNR, PMCI, consultants and
  insurers) to disseminate NESHAP compliance and
  inspection information
• EPA intends to issue 6C amendments in fall 2009
  to clarify definitions and applicability

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Plating Polishing NESHAP Subpart 6W

• Applies to area sources with these operations
• Electroplating
• Electroless or non-electrolytic coating
• Other non-electrolytic metal coating
• Dry mechanical polishing after plating
• Electroforming
• Eletropolishing
• Only operations that emit or use materials that
  contain Lead, Mn, Ni, Cd and Cr
• Outreach beginning to take place

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Iron Steel Foundries 5Z NESHAP

• Comply with scrap management and binder
  formulation requirements to reduce HAP
• Opacity limit on fugitive emissions
• Large foundries - PM and opacity limits

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Aluminum, Copper Other Nonferrous Foundries
6Z NESHAP

• Applies only to foundries with gt 600 tons per
  year melted (smaller foundries are automatically
  exempt)
• Does not apply to die-casters (e.g. aluminum or
  zinc die-casters)
• Requirements
• Foundries must comply with management practices
• Large copper and nonferrous foundries must meet
  PM emission standards

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The Future of NESHAP

• EPA is under an October 15, 2009, deadline to
  issue NESHAP for 15 additional area source
  categories, including
• Chemical Manufacturing
• Paint and Allied Products
• Prepared Feed Manufacturing
• Pharmaceutical Production (not yet proposed)
•  
• EPA is under July 15, 2010, deadline to issue
  NESHAP for industrial, institutional and
  commercial boilers

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What Now?

• Visit the new DNR NESHAP website at
  www.iowadnr.gov/air/prof/NESHAP/
• Visit EPAs area source websites at
  http//www.epa.gov/ttn/atw/area/compilation.html
  and http//www.epa.gov/ttn/atw/area/arearules.html
  
• Sign up for EPA and DNR air quality listserv
• Contact DNR or UNI with questions

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NESHAP Contact Information

• Iowa Department of Natural Resources
• Christine Paulson - DNR Air Quality
  Bureauchristine.paulson_at_dnr.iowa.gov or
  515-242-5154
• Technical air assistance for small businesses
• Dan Nickey UNI, Iowa Waste Reduction Center
  daniel.nickey_at_uni.edu or 319-273-6588

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Questions?
Thank you!