New Source Performance Standards Research Articles

Development of an integrated duty cycle test method to assess cordwood stove performance

ABSTRACT The US Environmental Protection Agency’s (EPA’s) New Source Performance Standards (NSPS) for Residential Wood Heaters (RWH) require certification emission testing of prototype appliances. In 2015, EPA revised those standards to further reduce particulate matter emissions from this critical source. However, to achieve that goal, lower emissions measured in certification tests must reflect lower emissions when the appliance is operated in homes. Woodstove certification tests have used either the Federal Reference Method (FRM), a crib wood method, or a cordwood testing method developed by ASTM International that was designated as a broadly applicable Alternative Test Method (ATM) by the EPA until December 2021, when that status was revoked. There is broad agreement that the FRM and ASTM procedures do not simulate typical fueling and operating of wood stoves in the field, raising questions about the efficacy of the current program. Effective emission reduction efforts require robust, accurate, and reproducible test methods. With input from a range of stakeholders, the Northeast States for Coordinated Air Use Management (NESCAUM) developed the Integrated Duty Cycle Test Method for Certification of Wood-Fired Stoves Using Cordwood (IDC), a cordwood testing protocol designed to improve the efficacy of residential wood heater certification testing. That method was approved by EPA as a broadly applicable ATM in 2021. IDC test runs assess appliance performance under a range of operating and fueling conditions representative of typical consumer use patterns. Unlike previous test methods, the IDC protocol requires three replicate runs to assess appliance performance variability. Including variable fueling and operating conditions, along with the requirement for replicates runs, will increase the effectiveness of certification testing and promote the development of improved wood stove technology. This paper reports on experiments conducted to develop and test the IDC method. Implications: Residential wood heating is one of the largest sources of primary particulate matter pollution nationwide. EPA’s New Source Performance Standards (NSPS) establish emission limits for this source category and require certification testing of prototype wood appliances to demonstrate compliance with those limits. However, the operating and fueling requirements in NSPS compliance testing protocols do not represent typical conditions in the field. We developed a new testing approach, the Integrated-Duty Cycle (IDC) Test Method, to address the shortcomings of current certification test approaches. The IDC procedure for cordwood stoves, which was approved by EPA as a broadly applicable alternative test method in 2021, assesses appliance operations over various operating and fueling conditions representing typical consumer use patterns in an integrated run and requires three replicate runs to enable the assessment of variability in stove performance. Stoves certified with this method will be equipped to meet the NSPS limits consistently in field operation.

Residential wood heating: An overview of U.S. impacts and regulations

ABSTRACT Air pollution from residential wood heating poses a significant public health risk and is a primary cause of PM nonattainment in some areas of the United States. Those emissions also play a role in regional haze and climate change. While regulatory programs have focused on emissions reductions from large facilities, the residential heating sector has received limited attention. The failure to develop effective programs to address this emission source hampers the ability of state and local air quality programs to meet clean air goals. An updated New Source Performance Standard (NSPS) for Residential Wood Heaters was promulgated in 2015, which includes more stringent emissions standards for wood stoves and broadens its scope to regulate additional types of wood heating appliances. However, weaknesses in the test methods and programs used to certify compliance with the NSPS limits hamper the efficacy of those requirements. Current emissions certification tests measure stove performance under defined laboratory conditions that (1) do not adequately reflect operation and performance of appliances in homes, (2) are not sufficiently repeatable to allow for comparison of emissions of different appliances, and (3) allow manufacturers leeway to modify critical test fueling and operating parameters which can significantly impact performance outcomes. These foundational regulatory issues present substantial challenges to promoting the cleanest and most efficient wood heating systems. This paper provides an overview of the air quality and public health impacts of residential wood heating and discusses the weaknesses in the current emission certification approaches and work by the Northeast States for Coordinated Air Use Management (NESCAUM) and the New York State Energy Research and Development Authority to develop improved testing methods. Other articles in this issue discuss the development and testing of those methods in detail. Implications: Air pollution from residential wood heating poses a significant public health risk and is a primary cause of PM nonattainment in some areas of the United States. Those emissions also play a role in regional haze and climate change. While regulatory programs have focused on emissions reductions from large facilities, the residential heating sector has received limited attention. The failure to develop effective programs to address this emission source hampers the ability of state and local air quality programs to meet clean air goals. This paper provides an overview of the issue.

State of the Art in Separation Processes for Alternative Working Fluids in Clean and Efficient Power Generation

Gas turbines must now comply with much stricter emission control regulations. In fact, to combat the greenhouse effect, regulatory authorities have drastically reduced allowable emission levels. For example, in less than 12 years, the United States’ Clean Air Act issued the New Source Performance Standards (NSPS), which tightened the NOx emission margin of natural gas combustion (from 75 ppm to 10 ppm). On the other hand, despite those efforts, the high demand for energy produced by fossil-fueled gas turbines in power plants has resulted in dramatic increases in anthropogenic CO2 and NOx emitted by gas combustors. Most systems responsible for these undesirable emissions are directly linked to power generation, with gas turbines playing a pivotal role. Yet, gas turbines are still widely used in power plants and will continue to meet the growing demand. Therefore, sequestration and separation techniques such as Carbon Capture and Storage (CCS) and Air Separation Units (ASU) are essential to reduce CO2 and NOx emissions while allowing large amounts of power to be generated from these systems. This paper provides an in-depth examination of the current state of the art in alternative working fluids utilized in the power generation industry (i.e., gas turbines, combustion). In addition, this paper highlights the recent contribution of integrating separation techniques, such as air separation, steam methane reforming, and water-gas shifting, to the power generation industry to facilitate a continuous and adequate supply of alternative working fluids.

Methane Emission Controls: Toward More Effective Regulation

In the United States, emissions to the air from the oil and natural gas sector are regulated by the Environmental Protection Agency New Source Performance Standards (NSPS). Unfortunately, the pace of emission reductions has been slow. In 2016, the Obama administration pledged to reduce methane emissions from the oil and gas sector by 40-45% by 2025, representing a compound annual decline rate of roughly 6%. However, the rate of methane emissions has changed slowly since the promulgation of natural gas emission control rules in 2012 and 2016, resulting in a compound annual decline rate of about 0.3%. This disappointing outcome is mainly the result of a narrow scope of regulation that has not confronted the realities of oilfield operations. Devised at a time when the technology for the measurement of natural gas emissions was relatively immature, performance-based regulations could not be implemented effectively. Therefore, NSPS regulations are either prescriptive or, if performance-based, lack means of verifying performance. Amendments promulgated in 2020 did little to change this situation. Thus merely reverting to the status quo ante, either by use of the Congressional Review Act or by conventional regulatory processes, will do little to improve the industry's environmental performance. Instead of proposing patchwork amendments to the current rules, which are outdated and ineffective, EPA should entirely rethink natural gas emission control. This paper analyzes why the rules were constructed as they were, examines the data that highlights the inadequacies of present regulations, explores the new technologies that have improved the prospects for effective regulation, and proposes a new, more efficient and effective regulatory regime.

EPA Methane Emission Controls, Obama vs Trump vs Biden: What Needs to Be Fixed and What Should be Left Alone

On 13 August 2020, the U.S. Environmental Protection Agency promulgated its final rule amending the New Source Performance Standards (NSPS) for the Oil and Natural Gas Sector. Both adherents and detractors of President Donald J. Trump saw the new rule as contributing to the President’s deregulatory agenda, taking an important step toward American dominance in fossil fuels (desirable or not), and winning yet another battle in the war on the environmental protection legacy of President Barack Obama. This simple story line is compelling, but when the details are examined, it is found that the changes were in some ways more important, and in other ways less important than advertised by supporters and opponents. Moreover, some of the changes have damaged positions Trump championed, while others have the potential to substantially improve the environmental performance of the oil and gas industry. Most importantly, some major sources of methane emissions have been inadequately dealt with across both administrations. Therefore the Biden administration EPA, in re-examining NSPS, should take care to discard the mistakes made by the Trump administration, retain the improvements, and move forward on a number of new fronts. Topics explored include redundancy of methane and volatile organic compound leak detection, regulation of older and low production facilities, abandoned wells, pneumatic controllers, oil storage tanks, routine flaring, malfunctioning and unlit flares, gathering pipelines, and EPA certification of new methane emission detection technology.

EPA's Rollercoaster of Repealing Methane Rule for Oil and Gas

Over the past two months, a daily battle has been raging between oil and gas interests, states, and environmentalists in the DC Circuit over the methane new source performance standards (NSPS) for oil and gas operations.

Oxy-combustion Carbon Capture for Pulverized Coal in the Integrated Environmental Control Model

This paper describes the newly-developed techno-economic models of oxy-combustion carbon capture systems for pulverized coal-fired power plants now available in the Integrated Environmental Control Model (IECM) developed and maintained by Carnegie Mellon University. The new model is used in case studies that compare the overall performance and cost of electricity generation for power plants employing either oxy-combustion (oxyfuel) or an amine-based post-combustion process to capture and sequester 90% of the flue gas CO2 emission using a variety of U.S. coals. The probabilistic results for 500 MW plants using three coal types (bituminous, sub-bituminous and lignite) show that the oxyfuel option is cost-competitive or less costly than the post-combustion option, especially for the lower-rank low-sulfur coals. However, oxy-combustion would not be cost-competitive as a compliance option for the recently promulgated New Source Performance Standard (NSPS) for CO2 in the United States, which requires CO2 capture levels well below the capability of current technology. Other case studies show that alternative policy options, such as a tax on CO2 emissions, could incentivize oxy-combustion capture.

Cement Plant Environmental Technology for Achieving High <inline-formula> <tex-math notation="TeX">$\hbox{SO}_{2}$</tex-math></inline-formula> Removal

The U.S. Environmental Protection Agency has adopted revised emission limits to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland cement manufacturing industry and revised emission limits to the New Source Performance Standards (NSPS) for Portland cement plants. These changes revise the emission limits for specified air pollutants for new and existing cement plants. The NESHAP regulations address the emission limits for materials such as mercury, total hydrocarbons (THCs), hydrochloric acid (HCl), and particulate matter. The NSPS address particulate matter, opacity, nitrogen oxides (NO <sub xmlns:mml="http://www.w3.org/1998/Math/MathML" xmlns:xlink="http://www.w3.org/1999/xlink">x</sub> ), and sulfur dioxide (SO <sub xmlns:mml="http://www.w3.org/1998/Math/MathML" xmlns:xlink="http://www.w3.org/1999/xlink">2</sub> ). Herein, a case study is presented in which a novel environmental technology was utilized to help achieve SO <sub xmlns:mml="http://www.w3.org/1998/Math/MathML" xmlns:xlink="http://www.w3.org/1999/xlink">2</sub> removal efficiencies in excess of 97% for a cement plant located in the United States. A slurry scrubber was specified for this application due to its unique ability to achieve high removal efficiencies for SO <sub xmlns:mml="http://www.w3.org/1998/Math/MathML" xmlns:xlink="http://www.w3.org/1999/xlink">2</sub> -rich waste gases, using a low-cost reagent. Additional capabilities of this system specific to the cement industry are also discussed, such as hot gas quenching, particulate removal, and resistance to the corrosive, abrasive, and thermally intense environments often found in cement plants.

Direct Federal Controls: New Source Performance Standards and Hazardous Emissions

Direct Federal Controls: New Source Performance Standards and Hazardous Emissions

Key Aspects of Transitions Occurring in Electric Power Systems and Baseload Generation

Coal-fired generation has historically provided 70 percent or more of the baseload generation capacity in the eastern U.S. [Ventyx, 2012] and due to new environmental regulations combined with stable low cost natural gas, this percentage will likely decrease. New source performance standards (NSPS) proposed by the EPA [EPA, 2011] for greenhouse gas (GHG) mitigation put the electric power industry on a course that gradually eliminates coal generation from being a major source of electric power. With electricity being a fundamental service to all economic sectors, such a transition could potentially increase the cost of electricity to levels detrimental to U.S. economic growth. Transitioning away from coal to other fuels for electric power involves additional costs and key capabilities historically provided by coal generation. Three characteristics of coal-fired electric power are its baseload operating characteristics, the ability of it to provide system stability through generator response and turbine inertia, and the additional reliability assurance provided by on-site fuel supply. This paper provides an overview of these characteristics to heighten the awareness of the strengths provided by coal generation that have contributed to highly reliable and low cost electric power systems in the U.S.

Reduced-Emission Completions Improve Safety, Decrease Footprint

Green completions In its proposed New Source Performance Standards (NSPS) established in August 2011, the EPA estimated that, of the 25,000 new and modified fractured gas wells completed each year, approximately 3,000 to 4,000 currently employ reduced-emission completion (REC). Once finalized, the new rule will increase this number to more than 21,000 RECs annually as operators comply with the proposed NSPS. By 2015, every hydraulically fractured well will be required to use a green completion to capture and measure all oil and gas released during the flowback and drillout phases. Typically, the gas/liquid separator installed for normal well flow is not designed for the high-rate, four-phase (gas, hydrocarbon liquid, water, and sand) flow of a typical shale well. A common practice for the initial well completion has been to produce the well to a pit or tanks where water, hydrocarbon liquids, and sand are captured and slugs of gas vented to the atmosphere or flared. Completions can take anywhere from one day to several weeks, during which time a substantial amount of gas may be released to the atmosphere or flared. Green completion equipment is only necessary for the time it takes to complete the well. Operators typically transport this system from site to site to be used in a number of well completions, often on a truck-mounted skid. Don Atencio, manager at Fracmaster, said, “The setup for a green completion depends on the area and the type of well you are completing.” There is no set amount of equipment that is required. An REC can be performed with one self-contained unit, or it can be set up using individual components. Each job is based on need, the volume of gas and fluids being produced, and the size of the pad. For a multiwell pad, the equipment set up can be extensive. “Some of the work we are doing in New Mexico involves three major pieces of equipment that are too big to load onto one skid,” Atencio said.

Using Section 111 of the Clean Air Act for Cap-and-Trade of Greenhouse Gas Emissions: Obstacles and Solutions

ABSTRACT The Environmental Protection Agency (EPA) is moving forward with regulation of greenhouse gases under section 111 of the Clean Air Act. The next step could be creating a cap and trade system for the electrical utility industry using of as the statutory foundation. Past litigation on EPA's proposed mercury cap-and-trade program provides insights about potential challenges to a carbon-trading program. This article describes those insights and discusses how EPA could set a national cap by defining a standard of performance for greenhouse gas emissions and then allow regulated facilities to use allowances to cover their greenhouse gas emissions. This article also looks to the specifics of the proposed California cap-and-trade program in order to demonstrate how EPA could allow states to use their participation in regional cap-and-trade programs to comply with section 111(d) requirements for existing sources. I. INTRODUCTION II. BENEFITS OF USING SECTION 111 A. Regulating GHGs under Section 111 Has a Strong Legal Foundation in Comparison to Other Sections of the Clean Air Act B. EPA Has a Robust Regulatory in Place under Section 111 C. Standard of Performance Does Not Depend on a Technological System D. No Significant Difference Exists Between New and Existing Sources for the Issue of Trading E. EPA Could Later Transition NSPS to a Section 110 Program III. NEW JERSEY V. EPA: ARGUMENTS OVER TRADING AS A STANDARD OF PERFORMANCE A. What is a Standard? B. Must Each Source Decrease Its Emissions to Meet the Standard, Thereby Precluding the Use of Allowances? 1. Must Every Source Achieve Actual Emissions Reductions? 2. What is Continuous Emissions Reduction? 3. Does Cap-and-Trade Violate ASARCO by Implementing a Bubble Concept? C. Does Cap-and-Trade the Degree of Emission Limitation Achievable? D. Does Cap-and-Trade Reflect the Best system of Emission ? IV. TRADING UNDER SECTION 111 A. Outline of a Trading Program 1. Defining the Cap 2. Allocating Allowances 3. Use of a Minimum Emission Baseline B. Trading as a Standard of Performance 1. Standard of Performance as a Cap 2. Standard of Performance as a Minimum Emissions Baseline 3. Measuring Achievable Emission Limitation by Considering Cap-and-Trade the Best of Emission Reduction V. HARMONIZING STATE CAP-AND-TRADE PROGRAMS WITH SECTION 111(D) OBLIGATIONS A. Standards of Performance B. Scope of Coverage C. Banking D. Borrowing and Multi-year Compliance E. Offsets and Out-of-State Trading F. Initial Allowance Distribution: Allowance Reserve and Auction Price Floor VI. CONCLUSION D. Borrowing and Multi-year Compliance E. Offsets and Out-of-State Trading F. Initial Allowance Distribution: Allowance Reserve and Auction Price Floor VI. CONCLUSION I. INTRODUCTION Starting in January 2011, Environmental Protection Agency (EPA) began regulating large stationary source emissions of greenhouse gases (GHGs). First, EPA is implementing regulations for power plants and industrial facilities under the Prevention of Significant Deterioration (PSD) and Title V permitting programs. (1) Second, EPA will regulate power plant and refinery emissions using new source performance standards (NSPS) set forth under section 111 of the Clean Air Act (CAA). (2) All of these regulations face numerous challenges in the courts. (3) On December 23, 2010, EPA announced a schedule to develop rules regulating GHG emissions from refineries and power plants under NSPS. (4) Electricity generation represents thirty-four percent of overall U. …

Potential emissions reductions from grandfathered coal power plants in the United States

A two-tiered approach to environmental regulation in the United States has long allowed existing coal-fired power plants to emit air pollutants at far higher rates than new facilities. The potential for reducing the emissions of existing coal-fired facilities is quantified via two hypothetical scenarios: the installation of available retrofit control technologies, or the imposition of New Source Performance Standards (NSPS). Available control technologies could have reduced year 2005 emissions by 56% for NOx and 72% for SO2 for a cost of $11.3 billion/year (2004$), likely yielding far larger benefits to human health. Slightly more emission reductions would be achieved by upgrading or replacing existing facilities to achieve the NSPS emissions limits required of all new facilities. Potential CO2 reductions are more speculative due to the emerging nature of carbon capture and efficiency retrofit technologies. Recent policies such as the Cross-State Air Pollution Rule would likely achieve most of the NOx and SO2 reduction potential identified by the scenario analyses for grandfathered facilities. However, escalating obstacles to new generation capacity may perpetuate the reliance on an aging fleet of power plants, resulting in higher rates of coal consumption and CO2 emissions than could be achieved by new or retrofit units.

Greenhouse Gas Regulation Under the Clean Air Act: Structure, Effects, and Implications of a Knowable Pathway

It appears inevitable, absent legislative intervention, that regulation under the Clean Air Act (CAA) will move beyond mobile sources to the industrial and power facilities that emit most U.S. greenhouse gas (GHG) emissions. We analyze the mechanisms available to the EPA for regulating such sources, and identify one, New Source Performance Standards (NSPS) as the most predictable, likely, and practical, i.e. knowable, pathway. Based on the legal structure of the NSPS and the EPA’s traditional approach, we analyze a hypothetical GHG NSPS for one sector, coal electricity generation. This analysis indicates that efficiency improvements and perhaps biomass cofiring could be implemented through the NSPS, yielding modest but meaningful emissions reductions. Trading could also rein in costs. Though analysis is limited to one sector and does not include modeling of costs, it suggests that CAA regulation, though inferior to comprehensive climate legislation, could be a useful tool for regulating stationary-source GHGs.

Unified process assessment for resources use and waste emissions by coal-fired power generation

A unified process assessment is carried out to integrate various resources and emissions associated with the life cycle of typical coal-fired power generation systems, based on the thermodynamic concept of exergy as a common objective measure. For a comprehensive assessment of industrial production systems, three indicators termed as ecological efficiency, resources use efficiency and environmental emission intensity are devised to evaluate the overall efficacy. Concretely assessed in the present work are three typical modes of coal-fired power generation systems, i.e., the Average mode that represents the average emissions and efficiency of coal-fired power plants operating in the US in 1999, the New Source Performance Standards (NSPS) mode that meets the New Source Performance Standards, and the low emission boiler system (LEBS) mode as a kind of highly advanced coal-fired power plant utilizing a low emission boiler, as benchmark cases in related NREL (National Renewable Energy Laboratory) report.

Reply to comment by Ted Michaels on “Recent trends in anthropogenic mercury emission in the northeast United States”: Waste‐to‐energy's low mercury emissions

[1] Sigler and Lee [2006] (hereinafter referred to as SL06) combined measurements of mercury (Hg) and a combustion tracer at a background site to estimate regional Hg emission rates in the northeast United States from 1999/2000 to 2003/2004. Significant interannual variation in regional Hg emission was observed. Inventory calculations of Hg flux from the regional electric power sector suggested that the power sector strongly influences annual variation in Hg emission in the northeast but may not account for as large of a percentage of the total atmospheric Hg flux as expected given previous inventory estimates. [2] We thank Michaels [2007] (hereinafter referred to as M07) for comments on SL06. M07 cited substantial reductions in Hg emissions from municipal waste combustors (MWC) nationwide since 1990 and a clear ability of MWC to achieve federal emissions standards and suggested improper speculation by SL06 as to the role of MWC in Hg emissions in the northeast. Here we briefly address several of the important issues raised by M07. [3] We stress that SL06 did not claim that MWC cannot or do not test significantly lower than U.S. emission standards as defined by the Clean Air Act. More importantly, SL06 did not speculate that ‘‘high mercury emission levels in the northeast might be attributable’’ to MWC and failure to achieve standards, as suggested by M07, or to the performance of any other source category. SL06 cited multiple sources which indicate significant reductions in Hg emissions from MWC in several northeastern states since the late 1990s and were led to specifically investigate inventory Hg flux from the electric power sector because the substantial decline in MWC emissions due to legislative impact would leave power plants as by far the most important Hg emission category in the northeast [U.S. Environmental Protection Agency (EPA), 1997]. Rather than qualifying or searching for reasons behind high emission rates, SL06 sought to understand the observed interannual variation in Hg emissions determined from atmospheric measurements and gain insight into the relative contributions of different sources to total emissions in the northeast. [4] SL06 posited several potential contributing factors for the observation that power sector emissions were unable to account for as high a percentage of total Hg emissions in the northeast as expected. Among them (SL06, paragraph 38) was the possibility that ‘‘emissions from municipal and medical waste combustion emissions have not been reduced to the level targeted by EPA in 1997 and still contribute significantly to the regional Hg emission rate.’’ While not intended to suggest that MWC are responsible for ‘‘high mercury emission levels’’ in the northeast or are unable to test below federal standards, this contention could be misleading and deserves clarification. [5] As M07 noted, U.S. Hg emissions from large MWC declined significantly (95%) between 1990 and 2000 because of Maximum Achievable Control Technologies (MACT) compliance [EPA, 2002]. According to EPA [1997], New Source Performance Standards (NSPS) adopted in 1995 sought to reduce U.S. Hg emissions from municipal and medical waste combustion by at least an additional 90% over 1995 levels by 2000. Using inventory estimates presented by EPA [1997] as a baseline, we therefore expected MWC emissions to have declined from roughly one third of total Hg emission (1995 inventory) in the source region considered by SL06 (New England, MidAtlantic, Maryland, and Delaware) to on the order of 5% during the observation period (1999/2000–2003/2004), assuming no changes in emission among other major sources. This is clearly not the case, despite the dramatic reductions in bulk Hg emissions from MWC that have been achieved during the past decade. For example, recent inventory data suggest that MWC may have contributed approximately 21% of total Hg emissions in the northeast (not including Pennsylvania, Maryland, and Delaware) as recently as 2002, roughly the midpoint of the observation period of SL06, despite an 86% reduction in total MWC emissions in the same region since 1998 [Northeast States for Coordinated Air Use Management (NESCAUM), 2005]. We also note that total Hg emissions from MWC in New England, New York, and New Jersey were approximately 8.5 Mg in 1995 [EPA, 1997]. If a 90% reduction were JOURNAL OF GEOPHYSICAL RESEARCH, VOL. 112, D13314, doi:10.1029/2006JD008069, 2007 Click Here for Full Article

Pelarangan Submarine Tailing Disposal di Berbagai Negara Serta Aksi Hukum yang Dapat Dilakukan

Submarine Tailing Disposal (STD) is waste disposal activity to the sea through pipelines. Recently, the documentation system becomes the main problem of STD implementation. It is very weak so it can not cover the unpredicted effect to marine environment and the possibility of STD implementation’s failure. In United States, prohibition of STD is regulated in Clean Water Act. It requires 2 (two) important matters that are implementation of the Best Available Technology (BAT) and New Source Performance Standard (NSPS). While Canada regulate it i Canadaian Federal Metal Mining Liquid Effluent Regulation (MMLER) and Canada’s Fisheries Act. Indonesia itself doesn’t have special regulation to prohibit STD. That is why Indonesia need to have a clear and strict regulation about STD. This article tries to describe the importance pf the regulation that prohibit STD.

The MACT for petroleum refinery FCCs is a fraud!

This paper is a continuation of the author's research on the MACT regulation for abating pollution from Petroleum Refinery FCCs in the US. This paper highlights the flaws in the recently promulgated MACT for NSPS and non-NSPS FCC units. It details the inadequacies and the potential for perversity in the New Source Performance Standards (NSPS) that are an integral part of the FCC MACT. It elaborates upon the potential for multi-media risk-exacerbations under the NSPS resulting from changes in feedstock quality, "unit conversion", advances in cracking technology (that favour inferior crudes and feedstock), lack of NSPS standards for NOx emissions, inter-unit transfer of contaminants/pollutants within a refinery, and the blind eye turned by RCRA to the disposal of spent FCC catalyst waste to landfills. The paper also questions EPA's motives as regards sub-categorisation of FCCs and SBREFA concessions. This paper proposes four standards that remedy these deficiencies. The first standard controls heavy metals, PM, and SOx (along with SO2), while the second proposes an integrated percentile control standard for CO (VOC) and NOx emissions. The paper also proposes a percentile standard for opacity and a spent catalyst tax to control environmental risk posed by disposal of spent FCC catalyst waste to landfills. It explains the calibration of the proposed standards using a novel strategy to bridge the regulatory gap between NSPS, MACT and Residual Risk standards and demonstrates how the calibrated standards apply to FCCs processing feedstock of different qualities. The paper concludes by urging the US EPA to rescind the NSPS and the MACT for FCCs and re-promulgate an integrated set of standards for criteria and toxic pollutants along the lines proposed in this paper.

Pelarangan Submarine Tailing Disposal di Berbagai Negara Serta Aksi Hukum yang Dapat Dilakukan

Submarine Tailing Disposal (STD) is waste disposal activity to the sea through pipelines. Recently, the documentation system becomes the main problem of STD implementation. It is very weak so it can not cover the unpredicted effect to marine environment and the possibility of STD implementation’s failure. In United States, prohibition of STD is regulated in Clean Water Act. It requires 2 (two) important matters that are implementation of the Best Available Technology (BAT) and New Source Performance Standard (NSPS). While Canada regulate it i Canadaian Federal Metal Mining Liquid Effluent Regulation (MMLER) and Canada’s Fisheries Act. Indonesia itself doesn’t have special regulation to prohibit STD. That is why Indonesia need to have a clear and strict regulation about STD. This article tries to describe the importance pf the regulation that prohibit STD.

Air regulatory impacts of the use of tire‐derived fuel

AbstractAs a fuel, scrap tires are an economically viable choice to supplement existing sources. In addition, policies promoting the use of scrap tires as a fuel can reduce their potential for creating environmental hazards. For example, when in stockpiles, scrap tires cause emissions of toxic compounds from arson‐caused fires, and can be a breeding ground for disease‐carrying insects. The growing number of industrial applications where scrap tires can serve as a supplemental fuel includes cement kilns, the pulp and paper industry, and utility boilers.Over the past decade, there have been a number of emissions studies on scrap tire and tire‐derived fuel (TDF) supplemented combustion. In many cases, co‐combustion with TDF has been shown to decrease emissions. This paper summarizes how supplementing combustion with TDF affects emissions of different pollutants.Scrap tire and TDF combustion are not currently regulated by a specific New Source Performance Standards (NSPS) or Most Achievable Control Technology (MACT) standard because they typically regulate an emission unit, not a fuel type. The United States Environmental Protection Agency (EPA) is currently debating how to regulate facilities that supplement their combustion with scrap tires. This paper discusses some of those options.