SLIDE 1
Tracking Michigan Air Toxics Program Applicability Using MON Operating Scenarios
MCC Annual Conference October 17, 2017 Steve Zervas, Managing Consultant David Dempsey, Managing Consultant
Tracking Michigan Air Toxics Program Applicability Using MON - - PowerPoint PPT Presentation
Tracking Michigan Air Toxics Program Applicability Using MON - - PowerPoint PPT Presentation
Tracking Michigan Air Toxics Program Applicability Using MON Operating Scenarios MCC Annual Conference October 17, 2017 Steve Zervas, Managing Consultant David Dempsey, Managing Consultant Meaningful Change Exemption for Air Toxics
SLIDE 2
SLIDE 3
Background
˃ MDEQ introduced the terms “Meaningful
Change” and “Meaningful Increase” with its PTI exemption rules published in 1992.
˃ The concepts for determining whether a change
- r increase is meaningful was presented as
guidance in 1993.
˃ The terms were defined in the regulations in
December 2016.
˃ Written guidance on implementing the concepts
was published in May 2017.
SLIDE 4
What does the Meaningful Change Exemption do?
˃ Allows process changes without permitting ˃ Based on evaluation of baseline Toxic Air
Contaminant (TAC) emissions and post-change TAC emissions
˃ Relies on a concept called the Hazard Potential ˃ Baseline established using potential emissions
included in an approved application dated after April 17, 1992
SLIDE 5
Hazard Potential
Two Hazard Potentials are required to make a Meaningful Change determination – one for carcinogens and another for non-carcinogens. The Hazard Potential is Calculated as follows: Hazard Potential = PTE (lb/hr) / IRSL or Adjusted Annual ITSL The adjusted annual ITSL is the ITSL adjusted to an annual averaging time. To convert from: 1-Hr to Annual: multiply ITSL x 0.10 8-Hr to Annual: multiply ITSL x 0.11 24-Hr to Annual: multiply ITSL x 0.17
SLIDE 6
Meaningful Change
˃ A change that increases Hazard Potential more
than 10% is a Meaningful Change.
˃ To determine the increase, compare the baseline
carcinogenic Hazard Potential with the post- change carcinogenic Hazard Potential. Likewise for the non-carcinogenic Hazard Potentials.
˃ If there is no baseline Hazard Potential, the post-
change Hazard Potential (of the same type) represents more than a 10 percent increase.
SLIDE 7
Seven Step Process
1.
Identify the TACs for both the existing permitted emission unit and the emission unit after the proposed change.
2.
Determine the hourly potential to emit (PTE) in pounds per hour for each TAC. PTE is defined in Rule 116(m).
3.
Identify all screening levels (SLs) for each TAC identified in Step 1. Some TACs have both an ITSL and an IRSL – both must be used.
4.
Convert each non-annual ITSL to adjusted annual ITSL.
5.
Calculate both a carcinogenic Hazard Potential (HP) and a non- carcinogenic HP for each SL. HP = (hourly PTE) / (IRSL or adjusted annual ITSL)
6.
Find the highest HP for non-cancer (based on ITSLs) and the highest HP for cancer (based on IRSLs) for both the existing operation and post-modification.
7.
Determine the percent change in each HP - an increase of more than 10% in either HP is “meaningful”.
SLIDE 8
Other Considerations
˃
Changes cannot involve the installation or reconstruction of an Emission Unit
˃
Changes cannot result in emissions greater than an existing permit limit
˃
Some Meaningful Changes may be exempt – Rule 285(2)(c)(iii)
˃
Meaningful Increase:
- MDEQ Policy: Emissions increases of greater than 10% are not meaningful if they
don’t cause an increase in the Hazard Potential of more than 10%
- MDEQ Rule: Meaningful Increase means an increase of 10% or more of an
individual TAC (e.g., of the same TAC, or any new TAC not in the baseline)
˃
Installation of control equipment may utilize this approach
˃
If a proposed change involves a TAC without a SL, it must be included – use regulatory guidance to develop an appropriate SL.
˃
Maintain records for each Meaningful Change evaluation performed
SLIDE 9
Example 1
A facility obtained a permit in 1999 that included a 10 lb/hr emission limit for Compound A. No changes have occurred at the facility since then. The proposed change will increase Compound A to 12 lb/hr. Since the original permit was obtained, the ITSL for Compound A has increased from 1,200 µg/m3 (annual) to 5,000 µg/m3 (annual).
TAC PTE (lb/hr) IRSL (µg/m3) ITSL (µg/m3) Averaging Period Adjusted Annual ITSL Hazard Potential Baseline: Compound A
10
- 1,200
Annual
- 0.083
Proposed: Compound A
12
- 5,000
Annual
- 0.002
Evaluation: Even though the Hazard Potential decreases, this project cannot be exempt because the new emission rate will exceed an existing permit limit.
SLIDE 10
Example 2
A facility obtained a permit in 2010 that included a carcinogen and two non-
- carcinogens. The proposed change includes 3 carcinogens and 17 non-
carcinogens.
TAC PTE (lb/hr) IRSL (µg/m3) ITSL (µg/m3) Averaging Period Adjusted Annual ITSL Hazard Potential Baseline: Carc A
1.1 1.2
- Annual
- 0.917
Non-Carc A
0.55
- 6,000
24-Hr 1,020 0.00054
Non-Carc B
16.2
- 17
1-Hr 1.7 9.53
Proposed (only the worst-case listed here): Carc B
0.6 0.8
- Annual
- 0.75
Non-Carc G
12
- 10.5
8-Hr 1.16 10.34 Evaluation: Carcinogenic HP decreases from 0.917 to 0.75 – not Meaningful Change. Non-Carcinogenic HP increases from 9.53 to 10.34 = 8.5% increase – not Meaningful Change.
SLIDE 11
Example 3
A facility obtained a permit in 2007 that included one carcinogen. The proposed change includes 2 non-carcinogens.
TAC PTE (lb/hr) IRSL (µg/m3) ITSL (µg/m3) Averaging Period Adjusted Annual ITSL Hazard Potential Baseline: Carc A
65 1.2
- Annual
- 54.17
Proposed: Non-Carc X
15
- 1,000
24-Hr 170 0.088
Non-Carc Y
35
- 5,000
8-Hr 550 0.064 Evaluation: There is no baseline non-carcinogenic Hazard Potential. Therefore, no Meaningful Change calculation can be made. This project cannot be exempt.
SLIDE 12
Operating Scenario Records – The MON and TAC Additions
SLIDE 13
MON Summary
˃ 40 CFR 63, Subpart FFFF - Miscellaneous
Organic NESHAP
˃ EPA’s catch-all rule for chemical
manufacturing sources not subject to another NESHAP
˃ Intended to be flexible – cover many
different types of chemical processes
More site-specific applicability determinations
than typical MACTs ˃ Contains detailed operating scenario and
process change recordkeeping and reporting requirements
SLIDE 14
Operating Scenarios
˃ MON Final Rule Preamble
…Our position is that submitting operating scenarios is critical to enforcement of the final rule, as they provide much of the information required to demonstrate compliance. Information in operating scenarios also is the cornerstone of the management of change strategy that was developed to address the constantly changing processing environment associated with batch processors. Although this management of change flexibility is optional at the discretion of the regulatory authority, 40 CFR part 63, subpart FFFF, provides the framework for implementing the strategy.
DD2
SLIDE 15
Slide 14 DD2 in other words, the MON provides an example of a well-described management of change procedure for evalating facility changes that could be applied for NSR.
David Dempsey, 7/22/2015
SLIDE 16
MON Operating Scenario Records
˃ Process/equipment description ˃ Identify process vents and associated
emission episodes
˃ Identify support operation
Wastewater, storage tanks, transfer
racks ˃ Calculations and engineering
analyses required to demonstrate compliance
SLIDE 17
MON Operating Scenario Records
˃ Applicable control requirements,
including level of control
˃ Control device details
Description Identify all equipment routed Description of operating conditions Description of testing conditions
Monitoring requirements Monitoring levels that assure
compliance
SLIDE 18
Your Operating Scenario?
˃ For each process line -
What products do you manufacture? Are there multiple formulations for a
product? Different solvents used?
Different TAC composition
˃ Documentation needed for each
- perating scenario will vary
Is one product clearly the worst case HP? How many products do you need to have
the HP (i.e., what is reasonable)
SLIDE 19
Operating Scenario Baseline Records for TAC
˃ Have records by process and product ˃ Identify each air toxic contaminant ˃ For each air toxic contaminant
IRSL or adjusted annual ITSL baseline PTE established by either
♦ the permit limits after April 17, 1992 ♦ the permit application
Hazard Potential (HP)
♦ Carcinogens ♦ Non-Carcinogen
Assumptions that affect PTE and HP
SLIDE 20
Operating Scenario Project Records for TAC
˃ Have records by process and product ˃ Identify each TAC affected and each new
TAC
˃ For each TAC
IRSL or adjusted annual ITSL PTE Hazard Potential (HP) for each TAC
˃ Compare max HP to baseline
Carcinogens Non-Carcinogens
SLIDE 21
Watch Out!!
˃ Accurate calculation of lb/hr emissions
Not average annualized
˃ Have records by process and product
Products with TAC not worst-case for
permitting purposes
Tracking multiple products with TAC
˃ TAC not previously used ˃ Changes in screening levels ˃ Do you have records of past applications?
SLIDE 22
Key Baseline Records
˃ Have records by process and product ˃ Identify each air toxic contaminant ˃ For each air toxic contaminant
IRSL or adjusted annual ITSL baseline PTE established by either
♦ the permit limits established after April 17, 1992 ♦ the permit application or facility records
Hazard Potential (HP)
SLIDE 23