Environmental
Update
ROHIT SHARMA
LyondellBasell, Environmental Issues Manager
August 21, 2013
AGENDA
Monitoring Data
 Air Quality
 Regulatory Activity
 Impact to Utilities

2
REAL & MEASURED
IMPROVEMENTS
3
Location of Ozone Monitors in HGB
C78
C555
C26
C557
C561
C560
C553
C610
C8
C551
C15
C408
C554
C617
C405
C559
C607
C604
C1
C562
C411
C410
C611
C603
C81
C403
C53
C552
C1015
C601
C608
C35
C409
C556
C406
C558
C45
C84
C620
C572
C570
C571
C5005
C1022
C619
C1034
C618
TCEQ
HRM
City
C1016
Harris County
C11
Source: Houston Regional Monitoring (HRM)
Independent
4
5
6
7
8
9
10
11
REGULATORY ACTIVITY
12
OZONE

1979 1hr Ozone Standard (120 ppb)



1997 8hr Ozone Standard (85 ppb)



HGB Area must meet the standard by June 15, 2018. Very close to meeting the standard.
Controls: A 25% reduction in the overall HRVOC cap
2008 8hr Ozone Standard (75 ppb)





HGB Area must meet the standard by November 15, 2007. Very close to meeting standard.
Controls: Billions $ spent on overall 80% NOx controls and HRVOC monitoring
Bush administration/EPA lowered standard to 75 ppb
Obama administration/EPA immediately announced lowering of standard to between 60 – 70 ppb
but eventually did not
Texas non-attainment counties
 Dallas/Ft Worth - Collin, Dallas, Denton, Ellis, Johnson, Kaufman, Parker, Rockwall, Tarrant,
Hood, Wise
 Houston – Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, Waller
Controls: TCEQ is conducting modeling; Also looking at “Exceptional Events” and “International
Emissions” contributions
Next Standard




Next 5 year review cycle for the Standard is underway
Current EPA timeline is to publish a draft proposal by year end 2013 and a final rule by Sept. 2014
Compliance deadline will depend on classification of Area: 2017 for Marginal, 2020 for Moderate,
2023 for Serious, and 2029 for Severe
Proposals are for standard to be lowered to between 55 – 70ppb
13
14
BOILER MACT

Final rule issued on March 21, 2011. Applicable to Boilers &
Process Heaters

Reconsidered final published in Federal Register 1-31-2013.
sources – have 3 years from publication to comply. May
request an additional year.
 New sources – comply Jan 31, 2013 or upon startup
 Many more subcategories of Boilers
 Existing

Requirements include CO / O2 CEMS, performance tests, energy
assessments, and controls if not meeting emission limits.
 Strict PM, HCL, Hg, CO and Dioxin limits for existing liquid and some fuel gas
burning boilers
 Very strict limits for coal burning boilers
15
BOILER MACT

Boiler Energy Assessments









A visual inspection of the boiler or process heater system.
An evaluation of operating characteristics of the boiler or process heater systems,
specifications of energy using systems, operating and maintenance procedures, and
unusual operating constraints.
An inventory of major energy use systems consuming energy from affected boilers and
process heaters and which are under the control of the boiler/process heater
owner/operator.
A review of available architectural and engineering plans, facility operation and
maintenance procedures and logs, and fuel usage.
A review of the facility's energy management practices and provide recommendations
for improvements consistent with the definition of energy management practices, if
identified.
A list of cost-effective energy conservation measures that are within the facility’s
control.
A list of the energy savings potential of the energy conservation measures identified.
A comprehensive report detailing the ways to improve efficiency, the cost of specific
improvements, benefits, and the time frame for recouping those investments.
And a lot more requirements…………………..
16
Other Rules

Risk and Technology Review (RTR rules)
 Polymers
& Resin IV, Pesticides, Polyether Polyols (3P) rule
proposed Jan 9, 2012. Final rule by Jan 31, 2014
 Polycarbonate, Acrylic & Modacrylic fibers, Polymers & Resins
III proposal by Dec 11, 2013
 Off-Site Waste & Recovery Operations (OSWRO) proposal by
Dec 11, 2013
 Ethylene MACT Section 114 request likely to be sent out in 4Q
2013
 OLD, MON, HON, NSPS review could be in 2014

Flares
 EPA
pursuing Consent Decrees
 EPA
planning to propose Refinery rule on flares. 1Q 2014.
 Will set precedent for the chemicals sector
17
Greenhouse Gas (GHG)

NSPS for GHGs
NSPS for GHGs for Utilities (new sources) – EPA to repropose by Sept 20, 2013 and finalize by June 1, 2014.
 NSPS for GHGs for Utilities (existing sources) – EPA to
propose by June 1, 2014 and finalize by June 1, 2015.
 NSPS for GHGs for Refineries – after the Utilities


President’s Climate Action Plan (CAP)


17% reduction in carbon emissions from 2005 to 2020
Energy efficiency standards for industry

Mandatory Reporting Rule (MRR) CBI data – possible
proposal 4Q 2013

TCEQ had two outstanding suits against EPA on GHGs
– On July 26, 2013 the Court of Appeals sided with EPA
18
Impact to Utilities

On Aug 21, 2012 the Cross State Air Pollution Rule
(CSAPR) vacated by the courts but CAIR remains in
place.
 Goal
is power sector emissions reductions
 However, was broadened to include chemical/refinery
sector co-generation facilities
 EPA/NGOs successfully petitioned to Supreme Court

Mercury & Air Toxics Standard (MATS)

Cooling Tower Intake Rule
 Effects
Utilities with large intake of cooling water from streams
19
Source: American Coalition For Clean Coal
Electricity (ACCCE)
20
2013 Texas Legislative Session

HB 788 (PASSED) - This bill authorizes the TCEQ to accept delegated authority from EPA for
greenhouse gas permitting and streamlines the permit process.

SB 1300 (PASSED) - amends the Texas Environmental, Health, and Safety Audit Privilege Act to
expand the definition of "environmental or health and safety audit" to include a systematic
voluntary evaluation, review, or assessment of compliance with environmental or health and
safety laws or with any permit issued under an environmental or health and safety law conducted
by a person, including an employee or independent contractor of the person, that is considering
the acquisition of a regulated facility or operation.

SB 1727 (PASSED) - Relating to the use of the Texas Emissions Reduction Plan (TERP) fund.
Several changes to the TERP program were made in this bill along with language negotiated by
industry relating to credit for 185 fees.

SB 1756 (PASSED) - Relating to the expedited processing of certain applications for permits
under the Clean Air Act. Requires TCEQ to adopt a program to expedite the processing of
permits, amendments, registrations, or variances for applicants for projects that will benefit the
local or state economy.
21