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Air Toxic DataAn Improved Tool for Air Emissions Data Collection

Genesee Finger Lakes ChapterJoint Meeting of the AWMA & NYWEAFebruary 14, 2017

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Overview• AWMA Annual Meeting – State Programs• Air Contaminant vs Regulated Air Pollutant• Development of the “Barlow” Spreadsheet

• Boiler example• Asphalt Plant Template

• Air Compliance and Emissions (ACE) Electronic Reporting

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AWMA Annual Meeting – June 2018Air Toxic Monitoring • The use of cheaper and more accurate sensors and public

and private entities collection of more ambient data on air toxics concentrations.

• What do the results mean and what best practices exist?• Is the general public actively involved in any part of the

process, and if so, how? New York Community Air Screen Program Introduced in April 2012 Finger Lakes Zero Waste Coalition, Inc.

Community Air Screen Program

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Screening versus Monitoring• Screening Air sampling on a limited basis Used to determine whether area has an air quality

concern Samples can be collected in places and at times

reflecting potentially higher pollutant concentrations• Monitoring Air samples collected for longer period than

screening, e.g. 6 months, 1 year Implemented after screening suggests air quality

concern Sited following specific EPA criteria

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Program Overview

• EPA funded• Participation by application process 4 page application, available on-line Applications scored using the following

considerations:• Description of community concern• proximity to known sources and

existing monitors• Prior citizen complaints

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Program Specifics• Glass-lined SUMMA canisters • EPA’s TO-15 method, 43 air toxics• Quality assurance and quality control• 1-hr sample collection• Field log & chain of custody completed

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Conveying Results and Risk

• What are our goals? Provide results and risk information in a meaningful

and transparent manner• Screening Comparison Graphs• Toxicological Trees

• What are our responsibilities? Protect the environment and enhance health, safety

and welfare of the people Minimize unwarranted concern

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Program Outcome - Communicating Results• Three levels of communication

1. Letter in plain English2. Report detail Program Sampling Analysis Interpretation Results Discussion Limitations

3. Appendices more detailed and technical Controlling Sources of Toxic Air Pollutants Uses, Sources and Potential Exposure Graphs comparing DEC air toxics network to community samples

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AWMA Annual Meeting – June 2018

State Programs• What risk assessment approaches are used to

determine when pollution control or operating limits are added to permits?

• How, and how often, are programs reviewed and updated?

• What best practices exist to optimize public health protection and regulatory efficiency

• How do states decide which pollutants are of interest?

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How do states decide which pollutants are of interest?Air contaminant vs Regulated Air Pollutant (contaminant) Regulated air pollutant or regulated air contaminant.

• (1) NOx and any VOCs;• (2) any air contaminant for which a NAAQS has been

promulgated;• (3) any air contaminant that is subject to any NSPS or

NESHAP. Air contaminant or air pollutant. A chemical, dust,

compound, fume, gas, mist, odor, smoke, vapor, pollen or any combination thereof.

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Development of Short-term & Annual Guideline Concentrations

• American Council of Governmental Industrial Hygienists (ACGIH)

• USEPA – Integrated Risk Information System (IRIS)• NYS Department of Health• NYS Department of Environmental Conservation Contaminants with Short-term health effects:• California’s OEHHA Table• ACGIH short-term and ceiling values

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NYS DEC’s (SGC/AGC) TablesShort-term and Annual Guideline Concentration

452

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190

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AGCs

TLVs NYS DOH USEPA DEC Analogy

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Toxic Substance Control Act (TSCA)• 23,000 “new chemicals” have been added to the TSCA

inventory since its first establishment in 1979.• Several thousand chemicals are currently in use, and

hundreds more are introduced to the market every year. • Due to the time and resource-intensive nature of chemical

safety testing, only a small fraction of chemicals have been evaluated for potential health effects.

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§ 212-1.3 Determination of Environmental Rating

• (a) Toxicity of the air contaminant;• (b) location of sensitive environmental

receptors;• (c) emission dispersion characteristics taking

into account relative to the surrounding buildings and terrain; and

• (d) the projected maximum cumulative impact.

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Evaluating “Unknown” Air Contaminants

• Rule out High Toxicity based on definition in 212-1• Structure Activity Relationships• Toxicity assigned a moderate classification DAR-1 suggest starting with an initial Environmental

Rating of “B” Annual actual offsite concentration < 0.1 ug/m3

Yearly actual emissions less than 100 pounds per year

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What is the “Barlow” Spreadsheet

• A method to organize emissions in one document• Components of the spreadsheet Facility wide summation of emissions Facility wide summations of predicted offsite

concentrations Access to SCCs, DEC emission statement codes and air

contaminant database

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Difference in Addressing Emissions

Application Organization

• Facility• Emission Unit -

Description Building Emission Point Emission

Source/Control Process

“Barlow” Spreadsheet

• Facility• Emission Unit - Description Process Emission Point

• Emission Source/Control

• Building

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Facility Level Page (Tab) – Boiler Example

• First, List all air contaminants at the facility. All air contaminants that are currently listed with the

State are included in the spreadsheet. The listed air contaminants will be duplicated

throughout the other tabs, Emission Unit level, Process level, etc.

Inputted data from processes will be summed on the facility page.

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Process Level Page (Tab) – Boiler Example• Input the appropriate Source Classification Code (SCC)

SCC listed on spreadsheet

• Input Process ID

• Input Annual Throughput – mm ft3, 103 gallons

• Input data based on Emission factors: lbs/gallon, lbs/ton of product, lbs/mmBtu, etc..

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Emission Point Level Page (Tab) – Boiler Example• Enter processes associated with emission point

• Spreadsheet allows for air dispersion modeling data to be inputted as maximum one-hour and annual concentrations.

• SGC and AGCs are built into the spreadsheet and offsite concentration to SGC/AGC are shown.

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Emission Unit Level Page (Tab) – Boiler Example• Data from the maximum emissions of the processes are

summed to the Emission Unit level.

• Data from the maximum concentrations of processes are summed to the Emission Unit level.

• All Emission Units are summed at the Facility Level

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Asphalt Plant Example

• Standardized input screen• Ton per year cap

• Emission factors • Based on batch or drum plants• Fuel• Silo storage • Truck loadout• Hot oil heater

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Air Compliance and Emissions (ACE) Electronic Reporting

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How to Get Enrolled in ACE• http://www.dec.ny.gov/chemical/54266.html

• To use ACE, an Application for Electronic Reporting System must be completed, signed and notarized.

• Once the application has been approved, the account holder will be emailed a statement of acceptance, specific information about their ACE account and user manuals. Responsible Official (RO) Emission Statement Editor (ESE) Emission Statement Reviewer (ESR)

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Benefits of ACE to End-Users• NYSDEC anticipates ACE to save time and resources for

permittees and states while increasing data accuracy and improving compliance.

• Reduce transcription errors.• The ability to upload previous year’s submission and only

edit data where needed.• Report standardization • Imbedded QA checks

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In Summary• New chemicals are being introduced into the marketplace

annually.• “Lists are only good as of yesterday.”• NYSDEC and the regulated community need to work

together to identify and address the emissions of these “new” air contaminants on the environment and the public.

• A conservative approach is needed to evaluate the potential adverse effects of these contaminants until more data is available.

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Thank You• Steve DeSantis• Research Scientist• 625 Broadway, Albany, NY• steve.desantis@dec.ny.gov• 518-402-8402

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