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Louisville’s STAR Strategic Toxic Air Reduction

Louisville’s STAR Strategic Toxic Air Reduction. Presented by Lauren Anderson May 21, 2013. Regulations. General Chapter 5 STAR 1.02 5.00 5.20 1.06 5.01 5.21 2.08 5.11 5.22 5.12 5.23 Adopted June 15, 2011 Adopted July 20, 2011. Who is regulated?.

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Louisville’s STAR Strategic Toxic Air Reduction

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  1. Louisville’s STAR Strategic Toxic Air Reduction Presented by Lauren Anderson May 21, 2013

  2. Regulations General Chapter 5 STAR 1.025.005.20 1.06 5.015.21 2.08 5.115.22 5.125.23 Adopted June 15, 2011 Adopted July 20, 2011

  3. Who is regulated? Group 1 stationary sources • Major, Title V; 2.16; 5.00 s. 1.16 Group 2 stationary sources • “Synthetic minors,” FEDOOPs; 2.17, 5.00 s. 1.17

  4. What is regulated? • Each process or process equipment at a Group 1 or Group 2 stationary source • Toxic air contaminants (TACs) – 5.00 s. 1.24 “Toxic air contaminant” means any air contaminant for which there is no national ambient air quality standard and that is, or may become, harmful to public health or the environment when present in sufficient quantities and duration in the ambient air.

  5. TACs Regulation 5.23: Category 1 TAC – compounds monitored in the 2000-2001 WLATS at concentrations representative of a cancer risk >1x10-6 or HQ > 1.0 Category 2 TAC – compounds with 2002 Jefferson County TRI-reported air emissions with a RSEI score >/= 500 Categories 3 and 4 – the rest of the HAPs (CAA s. 112(b) and (k))

  6. Regulation 5.22:Determining the Maximum Ambient Concentration Section 1.1 – The maximum ambient concentration of a TAC … shall be used to determine compliance with the ambient goals for environmental acceptability (EA goals) established in Regulation 5.21

  7. Regulation 5.22 cont. Tier 4 modeling using an EPA-approved dispersion model Section 1.3.4 – The output of these highly complex models is the MAC for the identified averaging time, which is set within the model depending on the averaging time of the BAC for the specific TAC. • Detailed dispersion modeling parameters are required.

  8. Regulation 5.20 s. 3 Determining the BACc BACc = 1 x 10-6/URE Where: BACc = a concentration representative of an additional lifetime cancer risk of 1 in 1,000,000, in units of µg/m3 URE = the upper-bound excess lifetime cancer risk estimated to result from continuous exposure to an agent at a concentration of 1 µg/m3 in air, in units of (µg/m3)-1. The URE shall be determined according to the methodology in section 3.3.

  9. Regulation 5.20 cont. Section 3.3 - Determining the URE In order of preference: • EPA’s IRIS • CARB • Michigan • Case-by-case risk assessment If none of the above, the default BACc = 0.0004 µg/m3 Averaging period for all BACc values: annual

  10. Regulation 5.20 cont. Section 4: Determining the BACnc From 5.00 s. 1.2.2: The BAC for the noncarcinogenic effects of a TAC is the concentration of a TAC at or below which no adverse health effects are expected. The BACnc represents a Hazard Quotient of 1.0.

  11. Regulation 5.20 cont. Section 4: Determining the BACnc In order of preference: • A reference concentration from EPA’s IRIS • A reference exposure level from CARB • An oral reference dose from IRIS • An initial threshold screening level from Michigan • An occupational exposure level from NIOSH • An inhalation NOAEL or LOAEL • An oral NOAEL or LOAEL

  12. Regulation 5.20 cont. Section 4: Determining the BACnc cont. • An inhalation LC50 • An oral LD50 If none of the above, the default value = 0.04 µg/m3 5.20 ss. 4.1-4.10; 4.11

  13. Regulation 5.21Environmental Acceptability for TACs Emissions of a TAC are EA if the emissions are: • de minimis, or • If the MAC of the TAC </= the BAC. Which can be established by: • Uncontrolled PTE, • An emission standard, or • An alternative measure. 5.21 ss. 2, 4.2

  14. Regulation 5.21 cont. “Emission standard” is defined in Regulation 1.02 as: “a requirement that is contained in a federal, state, or local law or regulation, District permit, or Board Order, or is otherwise legally enforceable that limits the quantity, rate, concentration, or opacity of the emission of an air contaminant on a continuous basis, including an requirement related to the operation or maintenance of a process or process equipment to assure continuous emission reduction, and any design, equipment, work practice, or operational standard.”

  15. Regulation 5.21 cont. Section 4.2.3 – an alternative measure may include: • Controlled PTE • Acutal emissions • Limited emissions, or • Throughput or production rate. 4.3 “An alternative measure that demonstrates EA shall be established as a new emission standard and incorporated in the permit for the process or process equipment.”

  16. Regulation 5.22 Changes: • Intermittent emissions - s. 1.2 • Preference for AERMOD in Tier 4 modeling – s. 5.1.1 • Can use ISC3 or other model on a case-by-case basis with approval by the District

  17. Regulation 5.20 Section 2: A TAC shall be determined to be a carcinogen for purposes of determining the BACc if: • EPA, California, or Michigan has developed a URE; • It is designated as known or reasonably anticipated to be a human carcinogen by NTP; • It is designated as carcinogenic or probably carcinogenic to humans by IARC; • It is designated as a carcinogen by ATSDR; or • The District determines that it is a carcinogen. 5.20 s. 2.1

  18. Regulation 5.20 cont. 2.3       Notwithstanding any provision of section 2.1, the Board may determine, through rulemaking pursuant to Regulation 1.08, that a TAC is not a carcinogen for the purpose of determining the BACc. New recommended language: 2.3.1          In making a determination pursuant to section 2.3, the Board shall rely upon a determination by one of the sources listed in sections 2.1 or 3.3 that a TAC is not a carcinogen for purposes of determining the BACc under the STAR Program. This provision does not limit the Board’s statutory authority under KRS Chapter 77 to grant a variance.

  19. Regulation 5.20 cont. • 2.3.2          In making a determination pursuant to section 2.3, conclusions regarding carcinogenicity in humans or experimental animals shall be based on relevant peer-reviewed scientific evidence, including dose response, route of exposure, chemical structure, metabolism, pharmokinetics, sensitive sub populations, genetic effects, and other data relating to mechanism of action or factors that may be unique to a given substance, traditional cancer epidemiology studies, data from clinical studies, or data derived from the study of tissues exposed to the TAC.

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