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Residual Risk for HAPs

Residual Risk for HAPs. Air Quality Issues Workshop AWMA Allegheny Section 5/23/06 Doug Krings Bayer Material Science. Residual Risk. Residual Risk 101 Rulemaking status, timelines Practical responses. Residual Risk 101. What the @#!& is this guy talking about?

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Residual Risk for HAPs

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  1. Residual Risk for HAPs Air Quality Issues Workshop AWMA Allegheny Section 5/23/06 Doug Krings Bayer Material Science

  2. Residual Risk • Residual Risk 101 • Rulemaking status, timelines • Practical responses

  3. Residual Risk 101 • What the @#!& is this guy talking about? • Congressional mandate - §112(f)

  4. §112(f)(2)(A) 8 years … the Administrator shall, within 8 years after promulgation of standards for each category … promulgate standards for such category or subcategory if promulgation of such standards is required in order to provide an ample margin of safety to protect public health … or to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect. Emission standards promulgated under this subsection shall provide an ample margin of safety to protect public health … unless the Administrator determines that a more stringent standard is necessary to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect. If standards promulgated pursuant to subsection (d) and applicable to a category or subcategory of sources emitting a pollutant (or pollutants) classified as a known, probable or possible human carcinogen do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a source in the category or subcategory to less than one in one million, the Administrator shall promulgate standards under this subsection for such source category. known, probable or possible human carcinogen one in one million

  5. Residual Risk 101 • What the @#!& is this guy talking about? • Congressional mandate - §112(f) • EPA methodology • Perform screening analysis • Any one source > 10-6 cancer risk or 1.0 HI • Develop candidate technology list • Determine which technology provides AMOS

  6. Residual Risk 101 • AMOS and the benzene 2-step • Benzene (Part 60) NESHAP • Vinyl Chloride decision • Endorsed by Congress in 1990 amendments • Benzene 2 step • EPA selects a safe level • EPA examines the costs and determines if additional controls are warranted

  7. 10-6 10-4 Residual Risk 101 Ample Margin of Safety - consideration of costs, technical feasibility and other factors Risk - Action needed to reduce risks Generally considered “Safe”

  8. A short side trip • Air toxics in perspective • Congress’ bright line – 1 in a million • 1 in 3 Americans will contract cancer 333,000 in a million

  9. A short side trip National avg. cancer risk from air toxics 44 in 1 million Major sources are not, at least on a national scale, major drivers of risk Source: 1999 NATA

  10. Final rules Coke ovens Dry cleaning Ethylene Oxide Sterilizers Magnetic Tape Gasoline Distribution Industrial Cooling Towers 7/14/05, compliance date 12/21/05, proposal date 4/7/06, NFA 4/7/06, NFA 4/6/06, NFA 4/7/06, NFA Rulemaking status, timelines

  11. Rulemaking status, timelines • HON RR Rule • Proposal • Early April ’06 • No wait, Early May • Maybe late May, early June • Before AWMA (New Orleans)? • Final 12/16/06

  12. HON RR Rule • Proposal will take comment on: • NFA • Specific technologies addressing: • Fugitive emissions • Tank emissions • Process Vent emissions • Subcategorization

  13. HON RR Rule • NFA • Post MACT cancer incidence - 0.14 • Post RR cancer incidence – 0.13 • Additional costs $15 – 20 MM/yr

  14. HON RR Rule • Specific technologies • Fugitive emissions – increase monitoring frequency – e.g. valves, quarterly →monthly • Tanks - > 5 TPY HAP • Process Vents – TRE cutoff 4

  15. HON RR Rule • Subcategorization • Low risk sources form subcategory • Subcategory not regulated • Who’s in the low risk subcategory

  16. Practical Responses • Risk assessment • Oh no!, 189 HAPs, a years worth of met data, somebody who can run ISC, no AERMOD. We’re talking a quarter mil… • Whoa, maybe …. but probably not • Risk assessment - under $1000

  17. Practical Responses • Tiered risk assessment • EPA accepts/promotes • See http://www.epa.gov/ttn/fera/risk_atra_vol2.html • Tiered • Tier 1 - Very simple, very very conservative • Tier 2 – More complex, somewhat conservative • Tier 3 – Skies the limit

  18. Emission estimates Ambient concentrations Modeling parameters Health effects data Risk estimates Receptor parameters Practical Responses

  19. Emission estimates Ambient concentrations Modeling parameters Health effects data Risk estimates Receptor parameters Practical Responses • Tier 1 • TRI data • Screen3 model • An hour later • Results

  20. Emission estimates Ambient concentrations Modeling parameters Health effects data Risk estimates Receptor parameters Practical Responses • Tier 2 • TRI data • Aermod (ISC) model • Days later • Results

  21. Emission estimates Ambient concentrations Modeling parameters Health effects data Risk estimates Receptor parameters Practical Responses • Tier 3 • TRI data • Aermod (your favorite) model • Better (not IRIS) data • Activity based exposures • Months later • Results

  22. Practical Responses • Advice • Do a tier 1 before you have a final RR rule • Spreadsheet based tools • 90 day clock

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