NEW RISK SCREENING TOOLS Joel Leon September 16, 2011

1. NEW RISK SCREENING TOOLS Joel Leon September 16, 2011

2. 2 NEW RISK SCREENING TOOLS • Developed for non-road diesel engines and drycleaners using perchloroethylene • Goals of both screening tools • Provide better upfront data that could be used by a permittee • Make risk screening process streamlined and predictable • Results more reflective of unique aspects of the source operation • Should be available for use by October

3. Nonroad Diesel Engine Risk Assessment • Developed for several reasons • Determine whether engine’s risk is insignificant • Adjust parameters to minimize risk

4. Nonroad Diesel Engine Risk Assessment • Inputs to the Risk Assessment: • Engine’s horsepower (hp) • Annual Operating Hours • Distance to Property Line in Feet • Engine’s Tier or year of Manufacture • Worksheet picks emission factor (of diesel particulate matter-DPM) in grams /horsepower-hour • Higher tier, lower emissions, lower risk • Higher tier, more likely to able to have its DPM minimized

5. Nonroad Diesel Engine Risk Assessment • Outputs • DPM emissions in tons per year • Incremental cancer risk • Underlying assumptions • PM-10 emissions are equivalent to DPM emissions • Stack height and plume rise based on horsepower • Hp <= 600: stack height 15 ft, plume rise 25 ft • Hp > 600: stack height 25 ft, plume rise 50 ft

6. Nonroad Diesel Engine Risk Assessment • If a significant risk is determined, several options • Forward plot plan so a second level risk screening assessment can be conducted • Evaluate ways to minimize DPM emissions • Ultralow sulfur diesel or biodiesel blends • Retrofit DPM Control Device • Lower annual operating hours • Annual fuel usage cap

7. Nonroad Diesel Engine Risk Assessment • For use by Facility with an unpermitted, older engine already in use • Can determine quickly whether the engine can be permitted • Save time and expense of having to submit permit application • Can enter into an agreement with NJDEP enforcement on a replacement schedule or schedule for electrification

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9. Dry Cleaner Risk Assessment • Based upon assumptions made for GP-12A, “General Permit For Perchloroethylene (PERC) Drycleaning Equipment” • Half the PERC emissions emitted from the vent stack • Half the PERC emissions emitted from the volume source • 58’ by 58’ building • Two Options Available • Option A –Based on General Assumptions • Third or fourth Generation Machine, which will determine what recovery rate will be used • Volume of PERC Purchased • Distance from edge of building to the nearest sensitive receptor

10. Dry Cleaner Risk Assessment • Option B –Based on Actual Recovery Data • Weight of the waste in drum including PERC and water (in pounds) • Volume of waste container (gallons) • Volume of PERC purchase annually (gallons per year) • Number of liquid waste containers per year • Hours of operation per year • Distance from edge of building to the nearest sensitive receptor • Output • Incremental risk (for carcinogens) • Hazard Quotient (for non-carcinogens) • Applicant can choose Option A or B, giving greater flexibility

11. Dry Cleaner Risk Assessment • Use output to • Confirm that there will be an insignificant risk • Vary parameters to lower risk to insignificant level • If confirmed that a second level risk assessment will be necessary • Submit plot plan to Department • Adjust project schedule to account for a second level risk assessment to be done