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State Implementation of Risk-Based MACT Exemptions Region 4 Permit Managers Meeting

State Implementation of Risk-Based MACT Exemptions Region 4 Permit Managers Meeting. Rhonda B. Thompson, P.E., Director Engineering Services Division SC DHEC - Bureau of Air Quality. Presentation Overview. Boiler MACT Health-Based Compliance Alternative (HBCA)

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State Implementation of Risk-Based MACT Exemptions Region 4 Permit Managers Meeting

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  1. State Implementation of Risk-Based MACT ExemptionsRegion 4 Permit Managers Meeting Rhonda B. Thompson, P.E., Director Engineering Services Division SC DHEC - Bureau of Air Quality

  2. Presentation Overview • Boiler MACT Health-Based Compliance Alternative (HBCA) • Plywood MACT Low-risk Subcategory • Ongoing Litigation • Other Related Issue

  3. Boiler MACT HBCA • 144 facilities subject to Boiler MACT • 42 facilities have solid-fuel fired boiler • 16 facilities submitted HBCA demonstrations • 19 wood-fired boilers • 4 coal-fired boilers • 28 mixed fuel-fired boilers • 17 boiler demonstrations for Mn (TSM) • 37 boiler demonstrations for HCl • 14 used stack testing, 2 used fuel analysis

  4. Health-based Compliance Alternative (HBCA) • States not required to review HBCA demonstrations (optional) • SC will review HBCA demonstrations before incorporating into TV permit • Uncomfortable incorporating HBCA limits into TV without some level of review • TV regulations require states to set forth the “legal and factual basis” for permit conditions (§70.7(a)(5)) • Expecting some challenges of HBCA permit conditions • EPA only reviewing 1 HBCA – Clemson University

  5. HBCA Preview Procedures • 13 facilities used look-up tables • 3 facilities submitted a site-specific risk assessment (EPA’s Air Toxics Risk Assessment Reference Library, Volume 2; AERMOD modeling) • Stack Testing group reviewing test protocols and results • Air Toxics group reviewing modeling and risk equations • Permitting group will incorporate HBCA conditions into TV

  6. HBCA Review Procedures • E-mail to facilities February 14, 2007 • Complete HBCA reviews by March 30, 2007 • Notify facilities of approvals or problems • Discuss possible monitoring parameters for TV permit • Compliance extension requests expected if controls are needed

  7. Most Common Problems Found • Test protocols not submitted prior to testing or fuel analysis – testing not done correctly • Protocol required by state regulations, not by Appendix A • Facilities not testing at maximum worst-case scenario, as low as 20% capacity • Testing shows emissions not linear with production • Facilities not including all HCl/Cl2 or Mn emitting sources on-site (e.g., oil-fired units, small solid-fired units)

  8. Most Common Problems Found • Facilities waiting to hear from State/EPA before purchasing compliant fuels or ordering control devices – may ask for extensions • Public facilities (universities, etc.) not considering on-site residents (dorms) as most exposed individuals • No soot blowing, grate cleaning done during stack test (part of normal operation) • Facilities needing to retest quickly, before compliance date

  9. Incorporating HBCA in TV Permits • Major modification to TV permit • Public notice required • Most will be incorporated at permit renewal

  10. Plywood Low-risk Subcategory • 25 facilities subject to Plywood MACT • MDF, OSB, Plywood, Particleboard facilities more likely to submit demonstrations • 1 Preliminary demonstration submitted, used by EPA as the template

  11. Plywood Low-risk Subcategory Review Procedures • EPA will review all low-risk demonstrations • SC will also review demonstrations, will notify EPA of any issues/concerns • SC more familiar with facility processes • Same review procedures as Boiler MACT HBCA

  12. Plywood Low-risk Subcategory Common Questions • Facilities required to maintain test conditions after demonstration approved? • Example: Temporary hoods and stacks installed to determine concentration and conduct modeling • Can facility request Routine Control Device Maintenance Exemption (RCDME) after they risk-out?

  13. Ongoing Litigation • HBCA and risk-based exemptions being challenged by environmental groups, states • Boiler MACT hearings started • EPA’s petition to DC Circuit to vacate and remand parts of the Boiler and Plywood MACT standards • Response to vacatur of Brick and Clay MACT • EPA requesting the HBCA and risk-based exemption litigation cases continue separately

  14. Other Plywood MACT Issue • Routine Control Device Maintenance Exemption (RCDME) – §63.2251 • Allows processes to run uncontrolled during routine maintenance (0.5 - 3% of reporting period) • States have discretion to approve/disapprove • SC disapproved request for a new facility • Can’t meet State VOC LAER rules without control device • Decision was appealed (may go to administrative law court hearing) • Basis: Can State rules be more stringent than Federal??

  15. Questions? Elizabeth Basil – Air Toxics Manager (803)898-4126 basilej@dhec.sc.gov Rhonda Thompson - Permit Director (803) 898-4391 thompsrb@dhec.sc.gov

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