Department of Environmental Quality Methyl Bromide Log Fumigation - - PowerPoint PPT Presentation

Department of Environmental Quality

Rules Adoption for the Control of Emissions from Log Fumigation Operations Rule Amendment to Toxic Air Pollutant Guidelines

Bradley Nelson, Division of Air Quality May 8, 2019

Methyl Bromide Log Fumigation Operations

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Log export to Chinese markets requires:

• Debarking; or
• Fumigation with methyl bromide.

The Montreal Protocol banned the use of methyl bromide due to its ozone- depleting properties.

• Quarantine and pre-shipment (QPS) treatment was exempted by the

EPA’s rulemaking authority in 2003.

In 2018, NC experienced an increase in permit applications/inquiries from entities interested in using methyl bromide for fumigation of whole logs with bark.

Methyl Bromide Log Fumigation Operations

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Fumigation Process:

• Logs are placed in a shipping container
• Fumigant applied to logs inside container
• Left for residence time of ~36-72 hours.

Aeration Process:

• Doors are opened to vent to atmosphere.

Fumigators must follow instructions on the label:

• Buffer zones
• Buffer zone entry restrictions
• Respirator requirements
• Work time restrictions

Methyl Bromide Log Fumigation Operations

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NC has 5 log fumigation facilities with Synthetic Minor permits.

Current Permit Requirements:

• Report 100% usage as emissions
• Reporting conditions
• Less than 10 tons per year limit to avoid major source

classification.

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DAQ’s concerns:

• 1. Methyl Bromide is a Hazardous Air Pollutant (HAP).
• 2. The potential for acute (short-term) & chronic (long-term) exposures:
• Methyl bromide is highly toxic and studies in humans indicate the lung may

be severely injured by the acute inhalation exposures.

• Acute and chronic inhalation of methyl bromide can lead to neurological

effects in humans.

• 3. There are no federal or state air quality regulations to protect the public

from these emissions.

• 4. Unlike many past agricultural uses, log fumigation facilities are

comparable to an industrial point source, where large quantities of HAP are used and emitted in one spot on a year round basis.

Methyl Bromide Log Fumigation Operations

Methyl Bromide Rule Options

Log Fumigation Regulatory Options Considered:

• 90% capture and control of methyl bromide during the aeration

process

• Adding Acceptable Ambient Level (AAL) for methyl bromide

and require modeling to demonstrate compliance

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Secretaries’ Science Advisory Board (SAB): October 22, 2018

• Presented Methyl Bromide Draft Report
• Board accepted the general report with follow-up items

December 3, 2018

• Reported levels from other states
• DHHS discussed occupational exposure levels

Methyl Bromide Log Fumigation Operations

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Methyl Bromide Log Fumigation Operations

Secretaries’ Science Advisory Board (SAB): February 4, 2019

• AAL range finalized and reports released for public comment

April 1, 2019

• SAB approved the AAL range and DAQ recommendation report pending

minor edits

April 12, 2019

• Final report released

Methyl Bromide Log Fumigation Operations

Secretaries’ Science Advisory Board Recommendation:

• Acceptable Ambient Level (AAL) Range for Methyl Bromide
• 0.005 mg/m3 Upper-bound AAL
• 0.002 mg/m3 Lower-bound AAL
• 24-hour Averaging Time

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AQC / EMC : August 15, 2018

• Methyl Bromide Rulemaking Concept information item

presented to the EMC November 7, 2018

• Temporary Draft Rules to AQC
• AQC voted to end temporary rulemaking process
• AQC directed the division to pursue permanent rulemaking to

proceed through the SAB’s AAL review process

• Request for range of risk values for AAL

Methyl Bromide Log Fumigation Operations

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AQC / EMC : January 10, 2019

• Continued Discussion of AAL
• Presented Informational Items
• Presented responses for follow up items to the EMC

May 8-9, 2019

• Draft Rules To AQC
• Request 30-day waiver to go to EMC and proceed to public hearing

Methyl Bromide Log Fumigation Operations

Proposed Rule Adoption and Amendment

Applicability

This rule would:

• Establish emission control requirements for HAP and TAP

from log fumigation operations.

• Define terms used in the log fumigation operations.
• Apply to new, existing, and modified bulk, chamber, and

container log fumigation operations that use a HAP or TAP as a fumigant.

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Proposed Rule Adoption and Amendment

Emission Control Requirements

Rule Based on Acceptable Ambient Level Approach

• Add methyl bromide to Toxic Air Pollutant Guidelines list in

15A NCAC 02D .1104

• Follow procedures in:
• 15A NCAC 02D .1106, Determination of Ambient Air

Concentration;

• 15A NCAC 02Q .0709, Demonstrations; and
• 15A NCAC 02Q .0710, Public Notice and Opportunity for

Public Hearing.

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Proposed Rule Adoption and Amendment

Monitoring, Recordkeeping and Reporting

• Comply with 15A NCAC 02D .0600 Monitoring, Recordkeeping

and Reporting

• 15 day initial notification
• Quarterly reporting:
• Source information,
• Toxic Air Pollutant usage,
• Monitoring summary

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Proposed Rule Adoption and Amendment

Compliance Schedule

• Existing Sources:
• Compliance within 60 days from effective date; or
• Approved alternate schedule
• New or Modified Sources:
• Compliance upon startup

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Net Present Value

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Potential Outcome – Debark Logs for Export Costs/ Benefits Year 2019 Year 2020 Private Sector Costs $3,485,860 $593,110 State/ Local Government Costs $1,600 $0 Local Community Benefits See Note See Note Private Sector Benefits $1,233,600 $1,232,000 Total Impact(+Cost – Savings) $2,253,860

• $638,890

NPV of Quantified Impacts $1,548,380 Substantial Impact Analysis $4,721,060

Note: The DAQ was unable to quantify the health benefits for local communities associated with the proposed rule.

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Potential Outcome – Control Technology Costs/ Benefits Year 2019 Year 2020 Private Sector Costs $1,301,433 $1,063,197 State/ Local Government Costs $15,642 $6,953 Local Community Benefits See Note See Note Private Sector Benefits $160,524 $0 Total Impact(+Cost – Savings) $1,156,551 $1,070,150 NPV of Quantified Impacts $2,015,599 Substantial Impact Analysis $1,477,599

Net Present Value

Note: The DAQ was unable to quantify the health benefits for local communities associated with the proposed rule.

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Potential Outcome – Log Fumigator Moves Out of NC Costs/ Benefits Year 2019 Year 2020 Private Sector Costs $1,475,679 $1,475,679 State/ Local Government Costs $1,600 $0 Local Community Cost $1,468,165 $0 Private Sector Benefits $637,774 $636,174 Total Impact(+Cost – Savings) $2,307,670 $839,505 NPV of Quantified Impacts $2,889,957 Substantial Impact Analysis $3,583,218

Net Present Value

Note: The DAQ was unable to quantify the health benefits for local communities associated with the proposed rule.

Methyl Bromide Log Fumigation Operations

• DAQ requests approval of the AAL for Methyl Bromide.
• DAQ requests a 30-day waiver to go to EMC and proceed to

public hearing on the proposed adoption of 15A NCAC 02D .0546, the amendment of 15A NCAC 02D .1104, and the associated fiscal note.

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Questions?

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