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The 2007 STAR

The 2007 STAR. Jon Trout Assistant Director. W est J efferson C ounty C ommunity T ask F orce. 1996-2000 - Task Force studied and discussed air pollution – 1 st step – monitoring 2000 - Task Force adopted monitoring Quality Assurance Project Plan (QAPP)

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The 2007 STAR

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  1. The 2007 STAR Jon Trout Assistant Director

  2. West Jefferson County Community Task Force • 1996-2000 - Task Force studied and discussed air pollution – 1st step – monitoring • 2000 - Task Force adopted monitoring Quality Assurance Project Plan (QAPP) • April 2000 - April 2001 – Monitoring • 2001-2002 – Sample analysis Risk assessment work plan • 2002-2003 – Risk management plan Risk assessment report

  3. http://www.louisvilleky.gov/APCD/STAR/

  4. Compliance Dates Category 1 and 2 TACS • Existing sources (extension allowed) • Title V – 2008 (+ 6 months) / 2010 (+ 1 Yr) • FEDOOP – 2010 (+ 1 Yr) / 2011 (+ 1 Yr) • Minor, Area, Non-road Mobile, and Mobile sources • 2012

  5. What is Acceptable? • Carcinogens – Cancer Risk Goals • 1 x 10-6 – single process/single TAC • 3.8 x 10-6 – new processes/all TACs/ single company • 7.5 x 10-6 – all processes/all TACs/ single company • 10 x 10-6 – all processes/all TACs/ multiple companies

  6. What is Acceptable? • Noncancer risk – Hazard Quotient (HQ) Goals • 1.0 HQ – single process/single TAC • 1.0HQ – new processes/single TAC/ single company • 1.0HQ – all processes/single TAC/ single company • 1.0 HQ – all processes/single TAC/ multiple companies

  7. Modification of Goal • Cancer risk • Up to 7.5 x 10-6 • Public Review, District Approval • T-BAT (Best Available Technology for Toxics) • 7.5 to 25 x 10-6 • Public Review, District Approval • T-BAT, Land use and demographic factors • 26 to 100 x 10-6 • Public Hearing Required, District Approval • T-BAT, Land use and demographic factors

  8. Modification of Goal • Noncancer risk • Greater than 1.0 • Public Review, District Approval • T-BAT, Land use and demographic factors • TOSHI (Target organ-specific hazard index)

  9. Unintended Emissions • Reg 1.07 Excess Emissions During Startups, Shutdowns, and Malfunctions • General duty to comply at ALL times, including S/S/M • Excess emissions are violations • Removed emergency/affirmative defense • Enforcement factors, enforcement discretion • Increased details reported • Reg 1.20 Malfunction Prevention Programs • Enhanced Leak Detection and Repair (LDAR) Programs (To be reproposed) • Enhancements: Components monitored, Frequency, Leak definition, Time to repair, Third-party audit

  10. STAR Program ImplementationDue to Date • Stack info Category 1 & 2 TACs (TV) • Enhanced emission inventory Cat. 1 & 2 (TV) • EA demonstration Cat. 1 (TV) • Enhanced emission inventory Cat. 1 (F) • Stack info Cat. 1 (F) • Compliance plan Cat. 1 (TV)

  11. Allied Drum ASRC BAE Brown Forman DuPont Perf. Elast. Hexion Specialty Kosmos Cement Oxy Vinyls PolyOne Rohm & Haas Sam Meyer Zeon Environmental Acceptability Not Demonstrated

  12. Post-Adoption Activities • STAR Implementation Advisory Group • Review overall implementation and progress of STAR Program • Forum for discussion of issues, revisions to regulations

  13. Post-Adoption ActivitiesSTAR Regulation Changes • Group 1 – Adopted • Treatment of 5 years of met data for modeling • Enhanced public participation opportunities • All natural gas combustion treated as de minimis • Timeframe for: Re-evaluation of T-BAT Implementation of revised T-BAT • Group 2 – Adopted • No cap for modification of noncancer environmental acceptability (EA) goal, all must show protection of public health with an adequate margin of safety • Target-organ-specific hazard index (TOSHI) for modification of noncancer EA goal • District approval of modifications of cancer EA goal for 26 to 100 x 10-6 • Industrial property factor increased from 4.2 to 10 • Group 3 – Drafted and reviewed by STAR IAG, to Board Strategy Cmte. • Allow credit for less than 10% intermittent operation for emergency generators • and other sources

  14. Post-Adoption Activities • STAR 5.30 Stakeholder Group • Develop Report and Plan of Action to assess and address minor, area, non-road mobile, and mobile sources • Presented to Board September 19, 2007 • Complete implementation by December 31, 2012 • Committees • Health/Risk • Area and Minor Source • Mobile and Non-Road Mobile Source • Report and Plan of Action • 35 Recommendations • Major focus on diesel particulate reductions • http://www.louisvilleky.gov/APCD/STAR/Reg530Report.htm

  15. Strategic Toxic Air Reduction Regulation 5.30 Stakeholder Group Report and Plan of Action September 19, 2007

  16. Cancer Risk Goals

  17. WLATS Study 24th Quarter 2001 through 2005 • 6 of original 12 monitoring sites • Monitoring for only TO-15 VOCs • Of original 17 carcinogens > 10-6 5 are not monitored Formaldehyde 4 metals

  18. WLATS Study 2 ResultsHighest single-year risk (2002 – 2005) • Carcinogens with risk greater than 10-6 (compared to Study 1) • Acrylonitrile . . . . . . . 124 (130) • Benzene . . . . . . . . . . 21 (32) • Bromoform . . . . . . . . < 1 (13) • 1,3-Butadiene . . . . . . 1370 (500) • Carbon tetrachloride . . . 12 (14) • Chloroform . . . . . . . 45 (77) • 1,4-Dichlorobenzene. . . . < 1 (19)

  19. WLATS Study 2 Results (Con’t)Highest single-year risk (2002 – 2005) • Carcinogens with risk greater than 10-6 (compared to Study 1) • Ethyl acrylate . . . . . . . 6 (33) • Methylene chloride . . . < 1 (17) • Perchloroethylene . . . . . 3 (39) • Trichloroethylene . . . . . < 1 (16) • Vinyl chloride . . . . . . . . 8 (5)

  20. WLATS Study 2 Results (Con’t)Highest single-year risk (2002 – 2005) • Chloroprene • Hazard Quotient . . . . . . 59.3 (97.3)* * In Study 1, the reported HQ was 13.9, but the HEAST 7 ug/m3 RfC was used although the California 1 ug/m3 REL was higher in the stated hierarchy for references • Cancer Risk Exceeded 10,000 in one million all four years (cancer risk not calculated in Study 1)

  21. ATSDR ... 8 Years Later • Based on WLATS 2000-2001 and ATSDR’s methodology: • “Low increased risk of developing cancer” from individual chemicals • Cumulative risk exceeded 100 in one million ... ATSDR’s “level of concern” ... “a low increased risk of developing cancer” • “Prudent public health measure to reduce or eliminate releases of chemical carcinogens ... wherever possible” • ATSDR supports EPA’s goals of looking at stationary, mobile, and indoor source emissions ... The STAR Program follows the EPA’s overall goals

  22. ATSDR’s Cancer Risk Yardstick • < 10 in one million No increased risk • 10 to 100 in one million No apparent increased risk • 100 to 1,000 in one million Low increased risk • 1,000 to 10,000 in one million Moderate increased risk

  23. For more information: Jon Trout Louisville Metro Air Pollution Control District (502) 574-7251 Jonathan.Trout@louisvilleky.gov http://www.louisvilleky.gov/APCD/

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