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Area Source NESHAP Implementation in Iowa A review of the latest federal air toxics regulations affecting many small businesses 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. Why Area Source NESHAP? The federal Clean Air Act (CAA) requires EPA to: • Reduce public’s 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 (EPA’s “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) 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 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 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 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 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 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 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. 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) 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) 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 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 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) 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 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 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 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 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 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 < 20,000 gallons/day to avoid classification as bulk terminals • Some bulk plants may not yet have submerged fill on loading racks 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 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 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 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 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 Aluminum, Copper & Other Nonferrous Foundries: 6Z NESHAP • Applies only to foundries with > 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 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 What Now? • Visit the new DNR NESHAP website at www.iowadnr.gov/air/prof/NESHAP/ • Visit EPA’s 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 NESHAP Contact Information • Iowa Department of Natural Resources ▫ Christine Paulson - DNR Air Quality Bureau [email protected] or 515-242-5154 • Technical air assistance for small businesses ▫ Dan Nickey – UNI, Iowa Waste Reduction Center [email protected] or 319-273-6588 Thank you!