EPA s Information Collection Request ICR Programs

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Subjects. Foundation about the Brick MACT decisionWhat is EPA\'s 114 authority?What ICRs were issued in 2009/10?Issues emerging structure complex and comprehensively appropriate testing programWhat is in store?. Noteworthy March 13 occasions. 1733 - Joseph Priestley conceived (recollect science class?)1781 - Uranus discovered1894 - first open strip tease (Paris, of course)1930 - Pluto found (odd, that)1939 - Neil Se

Presentation Transcript

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EPA's Information Collection Request (ICR) Programs Lessons gained from a Brick up side the head

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Topics Background about the Brick MACT choice What is EPA's 114 expert? What ICRs were issued in 2009/10? Issues emerging structure complex and comprehensively material testing program What is in store?

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Historic March 13 occasions 1733 - Joseph Priestley conceived (recollect science class?) 1781 - Uranus found 1894 - first open strip bother (Paris, obviously) 1930 - Pluto found (odd, that) 1939 - Neil Sedaka conceived (The Dreamer) 2007 – Court strikes down Brick MACT

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What did EPA attempt to do with the Brick MACT run the show? EPA distributed last govern for block and basic mud items in May 2003: Based on control innovation considered all the more extensively achievable (however less stringent) than that utilized by best controlled sources Allowed elbowroom for fluctuation among comparable sources paying little respect to execution Included no emanations decreases for a few sources in characterizing the floor Prescribed work rehearse guidelines (clean coals) rather than outflows limits

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What was not to like? Sierra Club said that Agency had not accommodated with the Act and the Court concurred that EPA: Must consider controls accomplished by best performing offices Must take a gander at scope of discharges accomplished by as well as can be expected not abstain from setting limits for HAPs not controlled with innovation Can consider work rehearse benchmarks just if testing mechanically and financially impracticable

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How does Brick choice influence different principles? Some re-proposition to address Brick issues Medical waste incinerators Stationary motors Portland concrete plants Some remands in 2009 Plywood and composite wood items man. Expansive city squander combustors Boilers and CISWI (quite Brick choice) Sierra Club appeal to change 34 existing MACT rules (more on the rundown later)

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What to do? EPA should gather more discharges information to: Define the MACT floors Set numerical outflows limits EPA must address all HAPs 187 dangerous air poisons on CAA list Look for least emanations levels Need information for surrogates, if to be utilized

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How would we do that? Utilize Clean Air Act area 114 specialist: To help with creating rules, EPA may require sources on a one-time or consistent premise to test emanations and gather operational information in way endorsed by the office and make reports. In this way, we issue Information Collection Requests , ICRs

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What do ICRs incorporate? Review - foundation data Facility estimate, area, possession, allow Operations configuration, fuel and sustain stock, control measures Reported emanations and decreases Testing prerequisites (for some ICRs ) Pollutants and surrogates Stack fumes, fuel, and crude materials Methods and systems Reporting necessities (ERT required) Deadline dates

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Testing for what? How would we figure out which 187 HAPs to gauge? Some apply to particular industry (e.g., coke broiler emanations, pesticides) Survey data can dispose of Some can be assembled and spoken to by reasonable number of related segments (e.g., select PAHs, POMs, D/Fs)

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How low would you be able to go? Outflows levels required for basic leadership Act focuses to least emanating 12 percent as MACT, additionally indicates HAP list in aggregate Not effortlessly controlled by approach Experiences with industry Most strategies are intended for consistence testing, not for measuring last particle Equipment outline (instrumental techniques) Sample estimate related (trial number and span) Calibration principles

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Recently issued ICRs with testing – a few illustrations Electric Utility Steam Generating Units Nitric Acid plants Brick and Tile fabricating Phosphate compost, phosphoric corrosive, and essential phosphorous Primary and Secondary aluminum Other strong waste incinerators

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So, how have those ICRs worked out for you, EPA? Needed to give a few illuminations to address specialized issues in a few territories Multiple natural HAPs estimations and scientific issues Handling strategy location level detailing issues Short rundown of endorsed test techniques prompted to demands for choices Produced various FAQ reports (e.g., GD 51, 51A-G), and endless messages for each ICR issued

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What are the real testing issues? VOST and Semi-VOST examining and investigations Grouping strategies for concurrent testing (frequently site-particular confinements) PM/PM 2.5 , Hg and different metals Organic – PAHs, POMs, THC, CH 4 , CO, CH 2 O, D/F Acid gasses – HCl, HF, SO 2 , NO Using the ERT

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How is this work playing out in EPA? OAQPS and ORD asset concerns Stretched staff 1970-85: 30 + source testing staff and numerous testing temporary workers Today: <12 source testing staff and for all intents and purposes no testing contractual workers Sharp expectation to absorb information OAQPS staff less acquainted with a few strategies, discovery capacities, options ICRs are coming rapidly each with particular and differed needs

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What to expect for next couple of years?

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What enormous hitters with ICRs would it be advisable for you to hope to see? Petroleum refineries Polymers and Resins Iron and steel, ferroalloys Chemical creation and dispersion Other sources to-be-named-later