NESHAP-OLD Reconsideration Status TOEM Committee RCAC Staff Tom - - PowerPoint PPT Presentation

01.27.2006 Board Meeting

NESHAP-OLD Reconsideration Status

TOEM Committee RCAC Staff Tom Kuckertz Harvey Consulting Walker and Levesque Environmental Protection Agency

01.27.2006 Board Meeting

National Emission Standard

for

Hazardous Air Pollutants

for

Organic Liquid Distribution facilities

In 2004 EPA exempted the Valdez Marine Terminal from emission control under the National Emission Control (NESHAP) Rule for Control of Hazardous Air Pollutants March 2004 PWSRCAC Petitioned EPA to re-consider this decision PWSRCAC maintained the amount of HAPS emitted from the terminal was significant and warranted emission control

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 July Alyeska disputes PWSRCAC’s emission control 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

• f 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

100 200 300 400 500 600 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) Tons Major Source Based Oil TPut Based Balst TPut Assume Based TPUT Linear (Major Source) Major Source Threshold = 25 tons/year Historical BWTF HAPS based on EPA WATER9 Model estimate of 187 tpy @10MM gal/yr, prorated on actual measurements of crude

• il throughput, plus 13

tpy other VMT HAPS Historical BWTF HAPS based on EPA WATER9 Model Estimate of 187 tpy @10MM gal/yr, prorated on actual measurements of ballast throughput, plus 13 tpy other VMT HAPS Emissions predicted using Alyeska best case assumptions starting in 2006, plus 13 tpy

• ther VMT HAPS

Stays above EPA's Major Source Threshold until at least 2015 561 tpy HAPS based on EPA Water9 Model Estimate and 30 MMgal/yr permit limit in NPDES and Title V Permits Title V Permit HAP Fee Basis 123 tpy

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) May Response to PWSRCAC’s reconsideration request

• f 80s Tanks determination as containing

wastewater October EPA to evaluate emission control cost and identify possible solutions to control emissions at the terminal November December EPA to draft revised NESHAP OLD rule to include emission control at the terminal

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