WASHINGTON—Federal environmental regulators are keeping existing hazardous air pollution standards in place for rubber tire manufacturing operations after a review of those rules.
The U.S. Environmental Protection Agency has determined "the risks from the source category following implementation of MACT (maximum achievable control technology) standards are acceptable, considering all the health information and factors evaluated."
Existing National Emission Standards for Hazardous Air Pollutants provide "an ample margin of safety to protect public health and to prevent an adverse environmental effect," the agency said. "The EPA received no new data or other information during the public comment period that affected our determination."
EPA, last October, issued a proposed determination, and then opened the matter up for public comment before offering a final determination.
The U.S. Tire Manufacturers Association came out in support of the EPA's "data-driven final rule."
"USTMA has supported EPA's review of hazardous air pollutants emissions and technologies to control HAP emissions at USTMA member major source facilities," the trade group said in a statement.
"In the final rule, EPA found that emissions of hazardous air pollutants from rubber tire manufacturing facilities are within an ample margin of safety. Additionally, EPA found that there have been no new, cost-effective air emission control developments since the issuance of the original MACT standards in 2002. As a result, EPA did not make any changes to the existing MACT standards," USTMA said.
EPA, in making its determinations, indicated "there are no developments in practices, processes, and control technologies" that would require a change to the MACT standards.
EPA, however, has finalized changes "to remove and revise provisions related to" startup, shutdown and malfunction, or SSM, at facilities.
It was in 2008 that a court case by the Sierra Club versus the EPA vacated two Clean Air Act exemptions regarding SSM. The court ruled emissions standards or limitations must be continuous in nature and the SSM exemptions violates a Clean Air Act requirement that some standards apply continuously.
"We proposed to remove the SSM exemptions for the Rubber Tire Manufacturing source category and require that the standards apply at all times … consistent with the court decision," the agency said.
EPA also did not establish emissions standards for malfunctions, as the agency interprets the Clean Air Act does not require emissions occurring during a malfunction to be factored into those standards.
The agency, however, said it does have the discretion to set standards when feasible. "For the action, it is unlikely that a malfunction would result in a violation of the standards, and no comments were submitted that would suggest otherwise."
EPA will start requiring owners and operators in the rubber tire manufacturing source category to submit electronic copies of test reports, compliance reports and notification of compliance status reports through the EPA's Central Data Exchange website. Operators also will be allowed to seek extensions for submitting electronic reports "for circumstances beyond the control of the facility."
It was nearly 20 years ago that the EPA created national HAP standards for the rubber tire manufacturing sector. Companies covered by these rules include those producing components of tires, including rubber compounds, sidewalls, tread, tire beads, tire cord and liners. There currently are 21 such facilities, the EPA said.
The rubber tire manufacturing source category also is broken down into four subcategories that include rubber processing, tire production, tire cord production and puncture sealant application, the EPA said.
Emissions limits established in 2002 in the rubber tire manufacturing source category were set for each subcategory. Rubber processing has no emission limits. Tire production has two options to comply with allowable HAP based on the total amount of cement and solvents used or the amount of rubber used.
For tire cord production, there are three options. The first two are based on whether the production is new or from reconstructed tire cord. The third is available to both new or reconstructed.
For puncture sealant application, there are three options based on the material coming from a new or existing source.
EPA determined, through a risk analysis, that "the cancer risk to the individual most exposed is 4-in-1 million from both actual and allowable emissions.
"The risk analysis also estimates a cancer incidence of 0.002 excess cancer cases per year, or 1 case every 500 years," EPA said.
"Based on the results of the environmental risk screening analysis, we do not expect an adverse environmental effect as a result of HAP emissions from this source category and, therefore, we are finalizing our determination that it is not necessary to set more stringent standards to prevent an adverse environmental effect," the EPA said.
USTMA indicated the group worked with EPA in the review by "sharing comprehensive and accurate data and information regarding emissions."