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

2. 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. 3 Nonroad Diesel Engine Risk Assessment Developed for several reasons –Determine whether engine’s risk is insignificant –Adjust parameters to minimize risk

4. 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. 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. 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. 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

8. 8 *

9. 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. 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. 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

12. 12