Air Toxics Program Discussion

Clean Air Act Advisory Committee 

June 8, 2011
Overview

 History & Background

 Priority Sectors Overview

 Updates 

 Petroleum Refinery Sector Rulemakings

 Chemical Sector Rulemakings

Iron and Steel Sector Rulemakings

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

 Mercury and Air Toxics Standards for Power Plants

 Oil and Gas Sector Rulemakings

 Discussion Questions for the CAAAC

 Appendix (Air Toxics Posing Highest Risks; Other Priority Sectors)
History of Regulating Air Toxics 

 Toxic air pollutants cause or are suspected of causing cancer, birth 

defects, reproductive effects and other serious health problems (e.g., 

benzene, mercury) 

 1970 CAA air toxics provisions required EPA to list and regulate air toxics 

based on risks they posed

 In 20 years, EPA listed 8 toxics and regulated 7

 1990 Amendments changed approach

 Lists more than 180 air toxics of concern

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 Requires EPA to identify and regulate major sources of toxics – more 

than 170 different source categories

 Requires EPA to reduce emissions through technology-based 

standards (Maximum Achievable Control Technology (MACT))

 Requires EPA to evaluate the remaining risks at sources and set more 

stringent standards if necessary

 Other Toxics Provisions

 Integrated Urban Air Toxics Strategy to address smaller stationary 

sources

 Technology and fuel requirements to reduce mobile source air toxics

 Requirements for adding or delisting air toxics
Current Focus of Air Toxics Program

 Stationary sources

 Sector-based approach for priority sources

 Residual risk and technology reviews for major sources

 Priority air toxics for urban areas and reductions from area sources

 Mobile sources

 Tighter standards for new light-duty vehicles and fuels (Tier 3) and ongoing evaluation 

of renewable/alternative fuel impacts

 Implementation of recent standards (including vehicle air toxics standards (MSAT)) for 

all mobile source sectors 

 Diesel retrofit and reduced idling, including targeted EJ actions and ports/goods 

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 Diesel retrofit and reduced idling, including targeted EJ actions and ports/goods 

movement efforts

 Near-roadway information and planning tools for communities

 Lead from aviation gasoline

 Indoor air toxics

 Actions to address major sources and environments (e.g., asthma communities in 

action; indoor air quality tools for schools; international partnership to replace 

cookstoves)

 Focus on reducing radon risks

 Voluntary programs and public information

 Community Action for a Renewed Environment (CARE) grant program

 National Air Toxics Assessment

 Monitoring
Success Story: Reducing Toxic Emissions

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8

10

12

Emissions (million tons/year)

w/CAA w/o CAA

Total Emissions for All Air Toxics with and without the Clean Air Act

 Emission reductions came from on-road mobile sources and stationary sources 

0

2

4

6

1990 2005 2006 2007 2008 2009 2010 2015 2020

Emissions (million 

Source: 2005 NEI v2 and EGAS growth estimates similar to 2002 NEI forecasts. 

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Addressing Air Toxic Risks in an Era of 

Declining Budgets

The air toxics problem

 Toxic emission sources are often clustered in urban areas and areas 

already facing other air quality challenges.

 Low income, minority, and indigenous populations often bear a 

disproportionate share of the health impacts.

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EPA is targeting priority emission sources to get the 

largest risk reductions given existing resources

 Although many toxics rules have court-ordered schedules, EPA is 

prioritizing efforts based on public health concerns.

 EPA is bringing to bear a wide array of regulatory, monitoring, public 

outreach and enforcement tools.

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Tools that Improve Public Awareness 

 Emissions Monitoring

 Greater use of established remote measurement approaches (e.g., optical 

fence line monitoring, DIAL)

 Continuation of emerging remote measurement technology development

 Public Transparency

 Emission inventories (e.g., National Emissions Inventory, Toxics Release 

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Inventory)

 Rule requirements for electronic submission of compliance data

 Neighborhood Monitoring

 Community-scale Air Toxics Monitoring Grant Program

 Enforcement

 Use monitoring to identify at-risk communities and specific emissions 

sources

 Obtain injunctive relief where violations are found

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... and how we are using the tools

Reduce 

Target priority categories of emission sources

Utilize a more cost-effective “sector-based” approach to 

rulemaking

Reduce air toxics through voluntary programs

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Reduce 

pollution in 

Improve data collection and provide better information to communities

the public through monitoring and national assessments

Provide tools to help communities and other stakeholder 

participate in rulemaking.

Coordinate compliance and enforcement efforts 

towards priority sectors and areas of concern

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Air Toxics Risks Highest in Urban Areas

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2005 NATA - National Scale Assessment

Predicted County Level Carcinogenic Risk

Average Risk Level

<1 in a Million

25 - 50 in a Million

>100 in a Million

75 - 100 in a Million

50 - 75 in a Million

1 - 25 in a Million

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Combustion and Chemical Facilities Pose 

Highest Risks From Stationary Sources

80%

100%

Residential Combustion

Pulp and Paper

Power Plants

Petroleum Refining

Other

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0%

20%

40%

60%

Emissions Cancer Tox

Weighted Emissions

Noncancer Tox

Weighted Emissions

Other

Oil and Gas Production &

Distribution

Minerals (inc Cement)

Metals (Iron, Steel & NonFerrous)

Crop Production

Consumer/Commercial

Prod Mfct & Services

Chemical Manufacturing

Boiler and IC Engines
Target: Stationary Sources 

Priority Sectors

 Petroleum Refining

 Chemical Manufacturing

 Iron & Steel

 Utilities

 Oil & Gas

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 Portland Cement

Emissions from these sectors often affect lowincome and minority communities 

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The Petroleum Refinery Sector

 150 domestic refineries 

 Second largest industrial source 

of greenhouse gases (GHGs) 

Pollutant 2005 Emissions 

(tons/year)

Nitrogen oxides (NOx) 146,185

Sulfur dioxide (SO2) 247,239

Volatile organic 

compounds (VOCs) 114,852

Hazardous air 

pollutants (HAP) 14,000

Fine particulate matter 

(PM2.5) 30,333

GHGs 220 MTCO2e

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Petroleum Refinery Sector Rulemakings

 Petroleum Refinery Sector National Emissions 

Standards for Hazardous Air Pollutants (NESHAP) and 

New Source Performance Standards (NSPS)

 Proposal: December 10, 2011

 Final: November 10, 2012

 Taking an integrated approach across the sector to 

coordinate MACT and NSPS requirements that 

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currently exist in many separate rules

 Key issues

 Accurate emission data

 Scope of the rulemakings

 Options to address GHGs

 Addressing environmental justice concerns and children’s 

health

 Approach for addressing malfunctions
Integrated Sector-Based Approach:

Petroleum Refinery Sector

Emission Point Current Regulations

Boilers NSPS, MACT

Process Heaters NSPS

Flares NSPS, MACT

FCCU, Reformer, Sulfur Plant NSPS, MACT

Rulemaking 

Approach

MACT and 

NSPS amended

Process Vents MACT

Heat Exchangers MACT

Wastewater MACT, NESHAP, NSPS, CTG

Storage MACT, NESHAP, NSPS, CTG

Loading MACT, NESHAP

Equipment Leaks MACT, NSPS, NESHAP, CTG

To be amended to 

reference the Uniform 

Standards

NSPS = New Source Performance Standards; MACT = Maximum Achievable Control Technology Standard; 

NESHAP = National Emission Standards for Hazardous Air Pollutants; CTG= Control Techniques Guidelines 

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Fenceline Monitoring

 Locate passive samplers around the perimeter of each refinery

 If any concentration exceeds the action level, initiate tiered approach 

to positively identify facility contribution to risk

 If facility contribution to risk is unacceptable, initiate steps to reduce it

N

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Chemical Sector Rulemakings

 Over 550 major source facilities emitting 

15,000 tons/year (tpy) of HAP across 

entire sector

 Taking an integrated approach across the 

chemical sector to coordinate MACT and 

NSPS requirements that currently exist in 

many separate rules

 Propose consolidated set of regulations for 

HAP and VOCs from chemical plants 

Court orders require proposal for portions 

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

of this sector as early as November 2011

Pollutant Emissions (tpy)

Methanol 3,139

Hexane 3,080

Toluene 1,324

Styrene 848

Benzene 661

1,3-Butadiene 629

Xylenes 531

Ethylene glycol 464

Riskdriving 

pollutants
Iron and Steel Sector Rulemakings

 Nationwide emissions

 PM2.5: 14,210 tons

 Metal HAP: 377 tons 

 Coke oven emissions: 390 tons

 Revision of the electric arc furnace (EAF) area source 

MACT rule

Compiling data collected from the information collection request (ICR)

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

 Considering Hg emission limits with enhanced monitoring

 Plan to propose revised rule in late 2011/early 2012

 List EAFs as a major source for MACT standards

 Review NSPS for EAF and Integrated Iron & Steel

 Address remand of Integrated Iron & Steel MACT

 Evaluate Coke Oven residual risk
 Proposal published on May 3, 2011

 Comment period ends July 5, 2011

 Proposed rule would reduce emissions of heavy metals, 

including mercury, arsenic, chromium, and nickel, and acid 

gases, including hydrogen chloride and hydrogen fluoride 

Mercury and Air Toxics Standards 

for Power Plants

from new and existing coal- and oil-fired electric utility steam 

generating units (EGUs)

 90 percent reduction in mercury emissions from burned coal

 Final rule must be signed by November 16, 2011

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 Oil and Gas Sector NESHAP and NSPS

 Proposal: July 28, 2011

 Final: February 28, 2012

 Nationwide emissions

 Methane: 15.7 million tons (300 MMT CO2e) (40% of U.S. methane emissions)

 VOC emissions of 3 million tons

 HAP emissions of 130,000 tons

 NSPS improvements are being considered for several emission 

Oil and Gas Sector Rulemakings

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 NSPS improvements are being considered for several emission 

points, including:

 Completions of hydraulically fractured (“fracked”) gas wells

 Compressors

 Storage vessels

 Pneumatic devices

 Equipment leaks

 NESHAP revisions are being considered for:

 Glycol dehydrators

 Storage tanks
Discussion Questions

 What are your concerns?

 Where should we focus our efforts?

 What efforts have been most effective?

 How can we work with the CAAAC to attain 

the goals of the Air Toxics Program?

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APPENDIX

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Air Toxics with Greatest Risks Nationally

 The air toxics* with the greatest risks from inhalation include:

 Acrolein (mobile sources, combustion, open burning)

 Arsenic (combustion, non-ferrous metal production, iron and steel, incineration, mobile sources)

 Benzene (mobile sources, combustion, oil and gas production and distribution, petroleum 

refining and distribution)

 1,3-Butadiene (mobile sources, chemical manufacturing, petroleum refining and distribution)

 Chlorine (primary magnesium refining, incineration, combustion) 

 Chromium, hexavalent (electroplating, non-ferrous metal production, iron and steel, mobile 

sources)

 Coke Oven Emissions (iron and steel)

 Diesel exhaust (mobile sources)

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 Formaldehyde (mobile sources, combustion, plywood, pulp and paper, oil and gas production 

and distribution)

 Hydrogen Chloride (combustion, incineration)

 Manganese (iron and steel, non-ferrous metal production, combustion)

 Perchloroethylene (dry cleaning, solvent use)

 Polycyclic Organic Matter (POM) (mobile sources, open burning, combustion, incineration)

 The greatest risks from non-inhalation pathways occur when air toxics deposit from the air, persist 

in the environment, and contaminate food we eat. These include:

 Dioxins (backyard burning, incineration, electric utilities)

 Mercury (coal combustion, Portland cement, incineration, mining)

* Source: National Air Toxics Assessment (NATA).
Other Priority Sector Projects

Rule Proposal Promulgation

Boiler MACT/Commercial and Industrial Solid 

Waste Incinerators Reconsideration

Secondary Lead Smelting RTR NESHAP 4/29/11 (completed) 12/16/11

Compression Ignition Engines NSPS; 

Amendments

5/22/10 (completed) 6/8/11

Pulp & Paper RTR NESHAP 6/15/11 1/31/12

Chromium Electroplating and Steel Pickling 

RTR NESHAP

9/14/10 (completed) 6/30/11

Aerospace Manufacturing RTR NESHAP 8/31/11 6/29/12

Nitric Acid NSPS 9/30/11 11/15/11

Shipbuilding/Wood Furniture RTR NESHAP 9/14/10 10/31/11

Primary Lead RTR NESHAP 10/31/11

Mineral Wool Production/Wool Fiberglass RTR 

NESHAP

10/31/11 6/29/12

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Other Priority Sector Projects (continued)

Rule Proposal Promulgation

Ferroalloys RTR NESHAP 10/31/11 6/29/12

Primary Aluminum RTR NESHAP 10/31/11 6/29/12

Secondary Aluminum RTR NESHAP 1/31/11 (completed) 10/31/11

Flexible Polyurethane Foam Prod. RTR 

NESHAP

10/31/12

Acrylic and Modacrylic Fibers RTR 

NESHAP 

10/31/12

Polycarbonate Production RTR NESHAP 10/31/12

Off-Site Waste and Recovery RTR 

NESHAP

10/31/12

Phosphoric Acid RTR NESHAP 10/31/12

Phosphate Fertilizer RTR NESHAP 10/31/12

Group III Polymers and Resins RTR 

NESHAP

10/31/12

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