Overview
Title
Notice of Request for Approval of Alternative Means of Emission Limitation
Agencies
ELI5 AI
The EPA is asking for people's thoughts on a new way to stop pollution from a big tank at a factory in Illinois. This new method uses special tricks to keep the air clean, and they'd like to know if it works as well as the old methods.
Summary AI
The Environmental Protection Agency (EPA) is seeking public comments on a request made by Rohm and Haas Chemicals LLC, a subsidiary of The Dow Chemical Company, for an alternative method of controlling emissions for a new vinyl acetate storage tank at their plant in Kankakee, Illinois. This proposed method differs from standard emission control systems stipulated by existing regulations, relying instead on a vapor balancing system and pressure containment to reduce emissions. The EPA invites feedback on whether the alternative approach can effectively minimize emissions to a comparable level as current standards. Comments are due by March 25, 2021.
Abstract
This action provides public notice and solicits comment on a request by Rohm and Haas Chemicals LLC, a subsidiary of The Dow Chemical Company (Dow), under the Clean Air Act (CAA), for an alternative means of emission limitation (AMEL) for the Standards of Performance for Volatile Organic Liquid Storage Vessels, that would apply to a proposed new vinyl acetate bulk storage tank to be used at its chemical plant in Kankakee, Illinois.
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Sources
AnalysisAI
The Environmental Protection Agency (EPA) is inviting public comments on a proposal by Rohm and Haas Chemicals LLC, a subsidiary of The Dow Chemical Company. The request involves an alternative method for controlling emissions from a new vinyl acetate storage tank at its facility in Kankakee, Illinois. The proposed method aims to reduce emissions through a combination of a vapor balancing system and pressure containment, diverging from the standard systems mandated by existing regulations.
General Summary
This document primarily serves to inform the public about Rohm and Haas's request for an alternative emission limitation method and to invite comments. The company seeks to implement a system that does not include conventional floating roofs or vent systems, which are typically required. Instead, they propose a high-pressure tank design meant to prevent emissions by containing vapors and balancing them effectively. The EPA is assessing whether this new approach can achieve similar or better emission reductions compared to current standards.
Significant Issues and Concerns
One significant concern is the document’s complexity, marked by technical jargon and numerous references to regulatory codes without adequate explanation. This may hinder understanding among everyday citizens who might wish to participate in the commentary process. Additionally, the lack of cost analysis or financial implications associated with this new method leaves the public without a clear picture of the economic impact.
Moreover, there is insufficient clarity on why this alternative method is deemed equivalent to the existing standards in effectiveness. How the vapor balancing and pressure containment specifically match or exceed current emission reduction standards remains vague.
The process for public engagement, notably the details on how to participate in the virtual public hearing, is densely packed, potentially creating confusion. The statement that the EPA may not respond to public hearing presentations could discourage people from engaging, fearing their input may not influence the decision-making.
Impact on the Public
Broadly, this document represents an opportunity for public involvement in environmental regulation, emphasizing the importance of community voices in shaping policies that affect air quality. However, the technical nature of the document and procedural complexity might limit effective participation.
Impact on Stakeholders
For stakeholders like Rohm and Haas and others in the chemical industry, the proposal could set a precedent for alternative emission control methods, potentially leading to more flexible regulatory approaches. Conversely, environmental advocacy groups and community members near the Kankakee plant might worry about the environmental impact of such changes, demanding reassurance that the alternative method will not diminish air quality standards.
In summary, while the EPA's invitation for public comment represents a democratic process in regulatory decisions, the document's complexity and procedural nature could impact effective public participation. Ensuring accessible information and clarifying the potential technological efficiency and financial implications will be key to gaining comprehensive feedback and trust from all stakeholders.
Issues
• The document does not mention the estimated cost or any financial implications related to the AMEL request or the implementation of the new storage tank, making it difficult to assess potential wasteful spending.
• There is a lack of clarity regarding the justification for the AMEL, specifically on how exactly the proposed system will achieve emission reductions equivalent to the existing standards.
• The document contains technical jargon and references to specific regulations (e.g., 40 CFR 60.112b and NESHAP subpart G) without sufficient explanation, which might be difficult for a general audience to understand.
• The process for public comment and participation, including details about the virtual public hearing and how to pre-register, is densely packed and may be confusing.
• The document contains statements indicating that the EPA may not respond to presentations at the public hearing, potentially discouraging public engagement.
• The document refers to COVID-19 adjustments for public participation but lacks a clear explanation of how these adjustments might impact the overall decision-making process.
• There is no mention of whether alternative technologies were considered besides the proposed vapor balancing and pressure containment system, which could be important for transparency and understanding potential biases towards certain technologies.