Temporary and Permanent Rulemaking concept for control of

Temporary and Permanent Rulemaking concept for control of Hazardous Air Pollutants from Log Fumigation Operations Mike Abraczinskas, Director, Division of Air Quality August 15, 2018 Department of Environmental Quality

Methyl Bromide Log Fumigation Operations Department of Environmental Quality 2

Methyl Bromide Log Fumigation Operations • NC experiencing an uptick in permit applications and inquires from entities interested in using methyl bromide for fumigation of whole logs. • Log export market requires: 1) fumigation with methyl bromide - or 2) debarking Department of Environmental Quality 3

Methyl Bromide Log Fumigation Operations • The process: • • Logs placed in a shipping container. Close doors. Fumigation of logs inside container. Residence time ~60 -72 hours. Aeration process = Open the doors and vent to atmosphere. Label instructions that workers must follow. • Buffer zones, buffer zone entry restrictions, respirator requirements, work time restrictions. Department of Environmental Quality 4

Methyl Bromide Log Fumigation Operations The Montreal Protocol banned most uses of methyl bromide due to its ozone depleting properties. However, import/export quarantine treatments currently have a critical use exemption. NC has 5 permitted synthetic minor log fumigation facilities: • Report 100% usage as emissions • Reporting conditions & 9. 9 tpy limit Department of Environmental Quality 5

Methyl Bromide Log Fumigation Operations DAQ’s concerns: 1. Methyl Bromide is a Hazardous Air Pollutant (HAP). 2. The potential for acute (short-term) exposures. . . methyl bromide is highly toxic and studies in humans indicate that the lung may be severely injured by the acute inhalation exposures. Acute and chronic inhalation of methyl bromide can lead to neurological effects in humans. 3. There are no federal or state air quality regulations to protect the public from these emissions. 4. Unlike many agricultural uses, log fumigation facilities are more of an industrial point source where much greater quantities of methyl bromide are used in one spot. Department of Environmental Quality 6

Methyl Bromide Log Fumigation Operations New interest: • Tima Capital applied for a 60 ton/year Title V permit at an existing log fumigation facility (thus avoiding a Case-By. Case Maximum Achievable Control Technology evaluation. ) • Due to public interest (2000+ comments), DAQ scheduled a public hearing on the draft permit. • Tima withdrew their permit application Department of Environmental Quality 7

Methyl Bromide Log Fumigation Operations New interest: • Malec Brothers applied for a 100+ ton/year Title V permit. • New facility. • 2 public hearings on draft permit. Each had >300 attendees. • >1000 comments received • New information received during that public comment period on demonstrated controls… resulted in a reevaluation by DAQ. Department of Environmental Quality 8

Methyl Bromide Log Fumigation Operations Multi-faceted strategy: 1. Temporary and Permanent rule – Control technology based standard. – Draft to Environmental Management Commission in September 2. Science Advisory Board (SAB) to evaluate inhalation risks of Me. Br. -Recommend an Acceptable Ambient Level (AAL) 3. Existing facilities – 5 in NC. 60 -day notice of intent to modify their air permit. -Put them on a path to comply with the temporary rule. 4. New major source – Malec Brothers Transport: DAQ requested additional info. -Capture/control technology plan; Detailed monitoring plan; Operational limitations 5. Other new permit applicants: DAQ requested additional info. -Capture/control technology plan; Detailed monitoring plan; Operational limitations 6. Letter to USEPA requesting log fumigation be a listed category under Section 112(c) of the Clean Air Act. -MACT/GACT Department of Environmental Quality 9

Control of Log Fumigation Operations Outline for rule Title: Control Of Log Fumigation Operations 15 A NCAC 02 D. 0546 • Purpose: • The purpose of this Rule is to establish control requirements for hazardous air pollutant and toxic air pollutant emissions from log fumigation operations. • Definitions: • Aeration, bulk log fumigation, charge rate, container log fumigation, fumigant, fumigation process • Applicability: This rule applies to all new, existing, and modified log fumigation operations that use a hazardous air pollutant or toxic air pollutant as a fumigant. • Emission Control Requirements. • Operation and Maintenance. • Monitoring. • Recordkeeping. • Reporting. • Compliance Schedule. Department of Environmental Quality 10

Methyl Bromide Log Fumigation Operations Temporary Rule Schedule: 9/12/18 9/13/18 9/20/18 9/25/18 10/11/18 11/8/18 12/14/18 Draft (temp) rule to AQC Draft (temp) rule to EMC Comment period begins Earliest date for a public hearing Comment period ends EMC considers adoption of temp rule Temp rule published in Register (Potential effective date) Department of Environmental Quality 11

Methyl Bromide Log Fumigation Operations Permanent Rule Schedule: 9/12/18 11/8/18 12/17/18 1/17/19 2/15/19 5/9/19 7/1/19 Draft rule to AQC Request to proceed to public hearing at EMC Comment period begins Earliest date for a public hearing Comment period ends EMC considers adoption of rule Potential effective date Department of Environmental Quality 12

Methyl Bromide Log Fumigation Operations Images showing examples of control systems. Department of Environmental Quality 13

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Thank you! Mike Abraczinskas, EIT, CPM Director NC Division of Air Quality 919 -707 -8447 Michael. Abraczinskas@ncdenr. gov Twitter: @airmikeab http: //deq. nc. gov/about/divisions/air-quality Department of Environmental Quality 19