NESHAP-OLD Reconsideration Status TOEM Committee RCAC Staff Tom Kuckertz Harvey Consulting Walker and Levesque Environmental Protection Agency 01.27.2006 Board Meeting
In 2004 EPA exempted the N ational Valdez Marine Terminal from E mission emission control under the National Emission Control S tandard (NESHAP) Rule for Control of for Hazardous Air Pollutants H azardous March 2004 A ir PWSRCAC Petitioned EPA to P ollutants re-consider this decision PWSRCAC maintained the for O rganic amount of HAPS emitted from the terminal was significant and L iquid warranted emission control D istribution facilities 01.27.2006 Board Meeting
NESHAP OLD Rule Reconsideration Progress • Facility Photos to Show Facility Units Involved in the Appeal • Progress Made Since Appeal was granted by EPA in April 2004 • Inquiry by Senator Lisa Murkowski • EPA Participation: Next Steps to Be Taken to Achieve Final NESHAP-OLD and Emission Control at the Ballast Water Treatment Facility • Comments and Questions 01.27.2006 Board Meeting
Facility at Issue: Ballast Water Treatment Facility 01.27.2006 Board Meeting
Issue: Should Emission Control be Installed on the 90’s Tanks At the Ballast Water Treatment Facility (BWTF)? 01.27.2006 Board Meeting
Issue: Should Emission Control be Installed on the Dissolved Air Flotation (DAF) Tanks At the Ballast Water Treatment Facility (BWTF)? 01.27.2006 Board Meeting
Issue: Should Emission Control be Installed on the Biological Treatment Tanks (BTTs) At the Ballast Water Treatment Facility (BWTF)? 01.27.2006 Board Meeting
NESHAP OLD Rule Reconsideration Progress • Facility Photos to Show Facility Units Involved in the Appeal • Progress Made Since Appeal was granted by EPA in April 2004 • Inquiry by Senator Lisa Murkowski • EPA Participation: Next Steps to Be Taken to Achieve Final NESHAP-OLD and Emission Control at the Ballast Water Treatment Facility • Comments and Questions 01.27.2006 Board Meeting
NESHAP OLD Petition Accomplishments Granted PWSRCAC’s Petition Wastewater Emission Control Returned to Federal Rule Develop Emission Standard Amend Final Rule Non-VMT Specific Rule & VMT Specific Rule 01.27.2006 Board Meeting
NESHAP OLD Petition Milestones Completed 2005 January EPA announces plans to develop a VMT-specific rule for wastewater March PWSRCAC submits BWTF emissions control costs information to EPA, prepared by Professional Eng. June Alyeska issues BTEX Fate Study Report Alyeska disputes PWSRCAC’s emission control July costs estimates, claiming they are much too low, but provides no PE certified estimates July Work slows; EPA 2004-2005 funding problematic August EPA issues preliminary Water 9 model estimates, which are significantly higher than Alyeska’s December EPA issues final Water 9 model estimates of 187 tpy at 10 mgd 01.27.2006 Board Meeting
NESHAP OLD Rule Reconsideration Progress • Facility Photos to Show Facility Units Involved in the Appeal • Progress Made Since Appeal was granted by EPA in April 2004 • Inquiry by Senator Lisa Murkowski • EPA Participation: Next Steps to Be Taken to Achieve Final NESHAP-OLD and Emission Control at the Ballast Water Treatment Facility • Comments and Questions 01.27.2006 Board Meeting
Inquiry by Senator Lisa Murkowski • To Jeffrey Holmstead EPA Assistant Administrator • Requested additional information and possible EPA engagement on changes to the NESHAP-OLD • PWSRCAC has made faulty assumptions on BWTF processes – Flow rates – Metabolizing of BTEX – Double hull tankers – Cost effectiveness of emission controls • Benefits of emission reduction questioned 01.27.2006 Board Meeting
PWSRCAC Response to Murkowski Letter • PWSRCAC Represents 18 member entities • Emphasizes that PWSRCAC has not misrepresented any of the facts • Emphasizes that EPA does not misunderstand the VMT processes • Compares VMT emissions to the California refineries • Provides detailed technical evidence in support of regulating wastewater emissions • Requests Senator’s support for clean air in Alaska 01.27.2006 Board Meeting
VMT Estimated Hazardous Air Pollutant Emissions 600 561 tpy HAPS based on EPA Water9 Model Estimate and 30 MMgal/yr permit limit in NPDES and Title V Permits 500 Historical BWTF HAPS Emissions based on EPA WATER9 predicted using Model Estimate of 187 tpy 400 Alyeska best @10MM gal/yr, prorated on case actual measurements of assumptions ballast throughput, plus 13 Tons starting in 2006, tpy other VMT HAPS 300 plus 13 tpy Historical BWTF HAPS other VMT HAPS based on EPA WATER9 Model estimate of 187 tpy @10MM gal/yr, 200 Stays above EPA's prorated on actual Major Source measurements of crude Threshold until Title V Permit oil throughput, plus 13 at least 2015 HAP Fee Basis tpy other VMT HAPS 100 123 tpy Major Source Threshold = 25 tons/year 0 75 76 79 80 83 84 87 88 91 92 95 96 99 00 03 04 07 08 11 12 15 16 19 Date (Calendar Year) Major Source Based Oil TPut Based Balst TPut Assume Based TPUT Linear (Major Source) 01.27.2006 Board Meeting
NESHAP OLD Rule Reconsideration Progress • Facility Photos to Show Facility Units Involved in the Appeal • Progress Made Since Appeal was granted by EPA in April 2004 • Inquiry by Senator Lisa Murkowski • EPA Participation: Next Steps to Be Taken to Achieve Final NESHAP-OLD and Emission Control at the Ballast Water Treatment Facility • Comments and Questions 01.27.2006 Board Meeting
NESHAP OLD Petition Milestones To Be Completed? 2005 (Continued) Response to PWSRCAC’s reconsideration request May of 80s Tanks determination as containing wastewater October EPA to evaluate emission control cost and identify possible solutions to control emissions at the terminal November EPA to draft revised NESHAP OLD rule to include emission control at the terminal December 2006 January EPA issues revised NESHAP OLD Rule for Public Comment (non-VMT specific in public comment period) 01.27.2006 Board Meeting
NESHAP OLD Rule Reconsideration Progress • Facility Photos to Show Facility Units Involved in the Appeal • Progress Made Since Appeal was granted by EPA in April 2004 • Inquiry by Senator Lisa Murkowski • EPA Participation: Next Steps to Be Taken to Achieve Final NESHAP-OLD and Emission Control at the Ballast Water Treatment Facility • Comments and Questions 01.27.2006 Board Meeting
End of Presentation 01.27.2006 Board Meeting
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