Moving Towards Multi-Air Pollutant

Reduction Strategies in Major U.S.

Industry Sectors

A Report to the U.S. EPA’s

Clean Air Act Advisory Committee

November 17, 2011

Elineth Torres 

U.S. EPA Office of Air Quality Planning and Standards

and

Keith Mason 

U.S. EPA Office of Policy Analysis and Review
The Challenge

• Most U.S. industrial sectors are subject to numerous Clean 

Air Act regulations simultaneously

 Reductions in criteria air pollutants (e.g. SO2, NOx) and hazardous air 

pollutants (e.g. benzene) can be required from the same emission 

sources within an industrial facility

• Clean Air and Clean Energy Goals are merging 

 Environmental technology investments and compliance strategies 

must address both conventional air pollution as well as greenhouse 

gas emissions and energy efficiency

• Optimizing public health and environmental outcomes in 

challenging economic times requires innovation

 Innovative environmental policies are complicated to implement given 

the significant investments made to develop and maintain our current 

system of environmental regulations

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EPA’s Progress towards a 

Multi-pollutant Sector Approach

• Since 2004, the EPA has invested in a more integrated multipollutant approach

 Working with stakeholders to understand and establish priorities

 Improving emission inventories

 Integrating criteria air pollutants, hazardous air pollutants and 

greenhouse gases emissions and control databases

 Grouping air rules by industrial sectors

 Conducting comprehensive review of multiple rules

 Harmonizing regulatory schedules

 Developing integrated approaches for industrial sectors

• Cement, Oil and Gas, Refineries, Chemical Manufacturing 

 Reorganizing into sector teams to better serve the mission of 

protecting human health and the environment 

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The CAAAC Work Group

• Purpose

 Provide the EPA with information, advice and recommendations 

regarding the development and implementation of an air pollution 

stationary source multi-pollutant approach

• Approach

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 Work group meetings, teleconferences, sector Roundtables, and 

report discussions and drafting

• Outcomes

 Diverse group of Stakeholders informed; variety of perspectives 

reflected in the Report’s conclusions and recommendations

 Opportunity Areas identified
Sector Roundtable Discussions

• WG conducted two 1-day roundtable discussions to 

explore the attributes and investigate the opportunities 

and challenges of moving towards a multi-pollutant 

system of air pollution regulation at stationary sources

 Iron and Steel

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- U.S. Steel, Arcelor Mittal, Nucor, American Iron and Steel 

Institute

 Chemical Manufacturing

- 3M, Flint Hills Resources, American Chemistry Council
Roundtable Topics

• Overarching questions included:

 How might a sector-based, multi-pollutant strategy optimize the reduction 

of air pollution for the sector?

 What might optimization look like when considered in terms of emissions 

reduction, risk and impacts reduction, environmental justice, cost reduction, 

certainty, and operational and compliance flexibility?

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• Topic areas included:

1. Timing and sequencing of regulations and requirements

2. Source definition and scope of applicable requirements

3. Monitoring and data

4. Reporting and record keeping

5. Emissions control technology and approaches

6. Energy use and efficiency improvement

7. Community-focused strategies
Work Group Conclusions

1. Time is right to take a more rigorous look at opportunities to 

align and optimize across air regulations

2. Multi-pollutant approaches promise benefits in many 

sectors, although the challenges are real

3. The availability and nature of opportunities to advance 

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multi-pollutant approaches vary substantially across sectors

4. An incremental approach to exploring and implementing 

new sector-based, multi-pollutant approaches is underway 

and should continue within the confines of the Clean Air Act
Recommendations for EPA

1. Expand efforts to advance multi-pollutant clean air 

approaches within sectors, when such approaches can be 

anticipated to provide the intended health, environment, and 

cost-reduction benefits despite the anticipated challenges. 

Each effort should include consideration of criteria pollutant, 

hazardous air pollutant, and greenhouse gas emissions.

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2. Establish a clear and transparent process for considering 

and advancing multi-pollutant clean air approaches within 

sectors.

3. Expand engagement with community residents, grassroots 

and EJ organizations, and develop approaches to reduce 

facility-specific and cumulative risks and impacts.
Recommendations for EPA

4. Identify and quantify air pollution co-benefits and trade-offs 

associated with multi-pollutant regulatory approaches.

5. Work with stakeholders to explore opportunities to simplify 

industrial source category definitions to advance multipollutant reduction strategies.

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6. Explore, develop, and test integrated approaches to multipollutant monitoring, record keeping, and reporting that 

harness new monitoring and information technologies.

7. Disseminate information about tools and resources 

available to improve implementation of clean air regulatory 

programs (permitting innovation, timely rule implementation 

guidance, etc.).
Additional Report Contents

• Background on the U.S. EPA air multi-pollutant, sectorbased activities

• Detailed discussion of seven opportunity areas with 

potential benefits and challenges and examples and 

observations

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• Appendices:

 Work Group Charter and Membership

 CAA Requirements and Opportunities for an Integrated Approach

 Integrated Multi-pollutant Sector-based Approach for the Cement 

Manufacturing Industry

 Types of Industrial Sectors Addressed by Air Regulations

 Petroleum Refinery Sector Regulatory Summary
Any Questions?

Thanks!

Elineth Torres

Torres.Elineth@epa.gov

919-541-4347

Keith Mason

Mason.Keith@epa.gov

202-564-1678
Discussion Questions

1. What do you see as the most promising benefits of pursuing 

sector-based, multi-pollutant strategies?

2. What do you see as the one or two biggest challenges to 

expanding the use of sector-based, multi-pollutant 

strategies?

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3. Do you see any near-term opportunities to advance multipollutant, sector-based approaches?

4. Are there any of the work group's recommendations that 

you would like to highlight as being particularly important for 

advancing sector-based, multi-pollutant strategies?

5. Do you have suggestions on the work group process that 

could assist future Committee efforts?