Survey: Implementation Step 1 of 21 - SLIDE 1 4% Introduction This presentation covers two issues: applicability (meaning which sources should be subject to the new risk-based air toxics permitting program) and implementation (how those sources should be brought into the program). 'Sources' is the terminology DEQ uses for facilities that emit air pollutants. The presentation will ask for your input on six questions. New, Modified, Existing The first question you will be asked to give your response to in this presentation is about which sources DEQ should regulate to adequately protect public health: New sources (ones that haven't been constructed yet), modified sources (existing sources that made some type of change, like adding a piece of equipment) or existing sources (sources that haven't made any changes.) The following slides will provide information about these types of sources in Oregon, to help you answer the question. New/Modified Sources in Oregon This slide shows how many new source and modification applications DEQ receives each year for more complex sources on Simple, Standard and Title V permits. (The next slide will explain the different permit types.) The blue line shows new permit applications, meaning permit applications for brand new facilities. This type of application ranged from 8 in 2015 up to 27 in 2013. The red line shows the modification applications received; these application types are more complex than new permit types. If a source wants to make a physical change or wants an increase in emissions, they must submit a modification application. The number of modification applications received ranged from 4 in 2013 to 28 in 2007. The green line shows the total number of new and modified applications added together, a total number ranging from 16 to 48 over the past 8 years (or about 4% to 12% of the total of this type of permit application, with the total average for the time period shown being 28 permits.) These figures represent an approximate number of permits DEQ would work on each year, if regulating permits for new and modified sources only. For context, DEQ receives an average total of 700 permit applications each year. This slide shows some examples of existing source air permit categories in Oregon. Summary of Considerations for Regulating New/Modified/Existing Sources The following three slides will outline some considerations to think about, to give you the information you will need to respond the upcoming questions, firstly health protection considerations. Summary of Considerations for Regulating New/Modified/Existing Sources - Continued There are some cost considerations relevant to implementation. Regulation of existing sources in addition to new/modified sources will extend permitting timelines and increase costs. Retrofitting pollution control equipment to some existing facilities might be technically difficult. Summary of Considerations for Regulating New/Modified/Existing Sources - Continued New facilities might not build in Oregon and existing facilities might relocate due to the cost of compliance. New/modified sources could have a business disadvantage compared to existing sources. Select One OptionWhat types of facilities should DEQ regulate for air toxics?*A. New or modified sources onlyB. New, modified and existing sourcesC. Don’t know/not sure Risk Levels for New/Modified vs. Existing Sources If existing sources are subject to the health-based air toxics permitting program, should OHA and DEQ allow different risk levels for new facilities that are seeking approval to build versus existing facilities that are already in operation? Some state regulatory programs require a more protective or stringent risk level for new facilities than existing facilities. This is because most of the time, it is easier and cheaper to design and build a piece of equipment from scratch with a target emission rate in mind than it is to retrofit an existing piece of equipment with emission control equipment to meet the same target emission rate. Agree or Disagree? Agencies in some other states allow for a flexible range of risk from air toxics, generally in the range of 1 in 1 million to 100 in 1 million, shown in the brackets on the risk continuum graphic. This is what is meant by the term 'higher range of risk'. Existing facilities may be allowed to emit air toxics at levels that pose a higher risk to health than new facilities. Do you agree or disagree?Existing facilities may be allowed to emit air toxics at levels that pose a higher risk to health than new facilities.*A. Strongly AgreeB. Somewhat AgreeC. Neither agree nor disagreeD. Somewhat disagreeE. Strongly disagreeF. Don’t know/not sure Risk Levels and Use of TBACT Another consideration is whether industrial facilities that are already using the best available control technology for air toxics should be allowed a higher risk level (as defined per the risk continuum graphic) than facilities that are not. Best Available Control Technology for air toxics - or TBACT - is a case-by-case emission limit, based on the maximum degree of reduction for an air toxic that is technologically achievable, taking into account energy, environmental, and economic impacts. Examples of emissions control devices that may qualify as TBACT include baghouses, wet scrubbers, and thermal oxidizers. The types of emission controls that qualify as TBACT depend on the type of facility or piece of equipment that is to be controlled. In Washington, TBACT is required before permits will be approved. In the Los Angeles area, if a facility installs TBACT, then they are allowed to meet a less-stringent allowable risk level of 10 in a million rather than 1 in 1 million. In Louisville Kentucky, a facility using TBACT is allowed a risk level as high as 25 in 1 million. Agree or Disagree? Again defining the 'higher range of risk' as shown on the risk continuum graphic, please indicate whether you agree or disagree with the following statement. Industrial facilities may be allowed to emit air toxics at levels that pose a higher risk to health if they have installed and are using pollution controls properly. Industrial facilities may be allowed to emit air toxics at levels that pose a higher risk to health if they have installed and are using pollution controls properly.*A. Strongly AgreeB. Somewhat AgreeC. Neither agree nor disagreeD. Somewhat disagreeE. Strongly disagreeF. Don’t know/not sure Implementation The following slides will look at implementation considerations for the Cleaner Air Oregon program. Prioritizing by Renewal/Industry/Risk/Emissions? If existing sources are included in Cleaner Air Oregon, how should they be phased in? This slide outlines the different approaches for prioritizing sources taken by the six programs reviewed by DEQ and the Cleaner Air Oregon technical workgroup. Most of the six programs reviewed used an automatic prioritization approach. They permitted new and modified sources as applications were submitted, and handled existing sources at the time of permit renewal. Currently all DEQ permits are issued for five years except Basic and General permits, which are issued for ten years. At the end of the respective permit period, the permits need to be renewed. Rhode Island targeted industry sectors, but not in a clear or consistent way. The South Coast program in Southern California focused on the most complex emitters first, which was both an advantage and a disadvantage: this approach addressed the highest risk but it also created the greatest workload. None of the six programs prioritized by areas of the state, but that is another option to consider. New/Modified/Existing Sources This graph shows the combination of new and modification applications received by DEQ from 2011 – 2015, and also shows DEQ's permit renewal schedule. The red line shows new and more complex modifications. The blue line shows the permit renewal schedule (permit renewal being every 5 or 10 years, depending on the type of permit.) The graph shows that in 2017, DEQ will be working on over 60 permit renewals. The total number of new and modifications applications along with renewals is shown by the green line. It is not possible to predict how many new and modification applications DEQ will receive in the future, and therefore the green line ends in 2015. Based on DEQ's historic data for new and modified applications and their renewal schedule going back to 2011, they would be working on an approximate average of 48 permits each year to incorporate risk-based air toxics requirements if they regulated existing sources and waited until permit renewal to do so. Summary of Considerations for Implementation This slide summarizes some factors to consider when thinking about implementation, in preparation for the question to follow on the next slide. Please select your top 3 options with the most important being your first choice: How should DEQ prioritize which facilities to permit using new air toxics requirements?*Click and drag the statements into the order of importance from top (most important) to bottom (least important). A. By permit renewal and as requests for new and modified permits come inB. By industry typeC. By facilities posing the highest riskD. By areas of highest risk to the most peopleE. By highest concern to most vulnerable populations Summary of Policy Forum A summary of this Applicability and Implementation presentation. Two final overarching questions will follow. Please select your top three priorities with the most important being first. tionsWhat are the most important overall considerations for developing a health/risk-based air toxics permitting program?*Click and drag the statements into the order of importance from top (most important) to bottom (least important). A. Preventing risks to healthB. Protecting vulnerable populationsC. Protecting populations most exposed to air toxicsD. Compliance cost for businessesE. Ensuring business can continue to operateF. Fairness: all businesses that emit air toxics included in programG. Effective public notification/updates Please select your top three priorities with the most important being first. If limited resources were available to implement a new air toxics permitting program for industrial facilities, how would you prioritize the program's work?*Click and drag the statements into the order of importance from top (most important) to bottom (least important). A. Quantity of air toxics reducedB. Number of industrial facilities regulatedC. Number of people potentially exposedD. Areas with the highest potential risk A summary of the results taken from this online survey and the results from the four regional forums will be presented to the Cleaner Air Oregon advisory committee. 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