New Source Review : Monitoring Recordkeeping and Reporting

1. New Source Review:Monitoring Recordkeeping and Reporting • Donald Law • EPA Region 8

2. Outline • Monitoring • Types of Monitoring methods • Types of Monitoring limits • Short Term and Long Term Limits • Recordkeeping • Reporting • Permit Conditions Review

3. Monitoring • For each emissions unit • For each regulated pollutant emitted • Based on an applicable requirement derived from • Prohibitory Rules • Applicable BACT Limits • Engineering Evaluation • NESHAP, MACT, NSPS Requirements • Potential To Emit Calculations

4. Monitoring (cont.) • Lists specific monitoring method • Source Test • Direct measurement of stack gas pollutant emissions • Measured at the stack for a set period of time • Source test methods describe apparatus used • Conducted at maximum operating capacity • Performed at start-up and usually annually thereafter • Witnessed by Permitting Authority

5. Source Test Monitoring • Title 40 Code of Federal Regulations Part 60 Appendix A Methods prescribe how testing is to be done: • Method 1--Sample and velocity traverses for stationary sources • Method 1A--Sample and velocity traverses for stationary sources with small stacks or ducts • Method 3A--Determination of Oxygen and Carbon Dioxide Concentrations in Emissions From Stationary Sources (Instrumental Analyzer Procedure) • Method 4--Determination of moisture content in stack gases • Method 5--Determination of particulate emissions from stationary sources

6. Source Test Monitoring (cont.) • Method 7--Determination of nitrogen oxide emissions from stationary sources • Method 7A--Determination of nitrogen oxide emissions from stationary sources--Ion chromatographic method • Method 7B--Determination of nitrogen oxide emissions from stationary sources (Ultraviolet spectrophotometry) • Method 7C--Determination of nitrogen oxide emissions from stationary sources--Alkaline-permanganate /colorimetric method • Method 7D--Determination of nitrogen oxide emissions from stationary sources- • -Alkaline-permanganate/ion chromatographic method • Method 7E--Determination of Nitrogen Oxides Emissions From Stationary Sources (Instrumental Analyzer Procedure) • Method 9--Visual determination of opacity of emissions from stationary sources remotely by lidar

7. Monitoring (cont.) • Continuous Emission Monitoring (CEM) All of the equipment that may be required to meet the data acquisition and availability requirements to sample, condition (if applicable), analyze, and provide a record of emissions on a continuous basis. • Reference test methods provide detailed instruction for source sampling • Data immediately available and recorded • Some CEM data linked directly to permitting authority

8. CEM Requirements Title 40 Code of Federal Regulations, Part 60, Appendix B : Performance Specification 1 -- Specifications and test procedures for opacity continuous emission monitoring systems in stationary sources. Performance Specification 2 -- Specifications and test procedures for SO[2] and NO[x] continuous emission monitoring systems in stationary sources. Performance Specification 3 -- Specifications and test procedures for O[2] and CO[2] continuous emission monitoring systems in stationary sources. Performance Specification 6 -- Specifications and test procedures for continuous emission rate monitoring systems in stationary sources.

9. CEM Applications • Pollutants that CEMs are good for • NOx • SOx • CO • CO2 • Particulates • Stack emission monitoring • Uncontrolled • Post controls

10. Monitoring (cont.) • Predictive Emission Monitoring (PEM) All the equipment necessary to monitor process and control device operational parameters (E.g. control device secondary voltages and electric currents) and other information (E.g. gas flow rate, O2 or CO2 concentrations), and calculate and record the mass emissions rate (E.g. lb/hr) on a continuous basis

11. Monitoring (cont.) • Continuous Parameter Monitoring System (CPMS) • All equipment necessary to meet data acquisition and availability to monitor • Process and control device operational parameters (e.g. control device secondary voltages and electric currents) • Other information (e.g. gas flow rate, O2 or CO2concentrations) and • Record average operational parameter value(s) on a continuous basis

12. Monitoring (cont.) • Continuous emissions rate monitoring system (CERMS) The total equipment required for the determination and recording of the pollutant mass emissions rate (in terms of mass per unit of time). • Opacity and Visible Emissions Monitoring • Continuous Opacity Monitor (COMs) • Dependant on stack moisture conditions • Visible Emissions Evaluation (VEE)* * Must be certified to read smoke

13. Where do limits come from? • Limits can come from almost any document • NSPS (40 CFR Part 60) • MACT (40 CFR Part 63) • NESHAP (40 CFR Part 61) • PSD permit (BACT) • Non-NSR (LAER) • State/Tribal Pre-construction permit • State/Tribal Implementation Plan • Do NOT come from Title V permit

14. Examples of Emission Limitations Pounds per hour/Tons per year Grains per dry standard foot Usage rates (gallons per hour, gallons per square foot of surface area NOx lbs/dscf; dscf/hr, hours per year NOx PPMVD corrected to 15 % O2 VOC Lbs/gallon, gallons per year Grams per horsepower hour Pounds/MMBtu 20% Opacity

15. Short-Term Limits • Short-term emissions usually represent the worst case allowable emissions for equipment operating at maximum capacity. • These limits provide a way to verify • emission estimates are accurate • control devices are operating as designed • air quality standards are being met

16. Short-term Limits (cont.) Averaging periods (1-hour, 3-hour, 8-hour, or 24-hour for pound-per-hour limits; usage rate limits such as gallons per hour or gallons per day) should be specified in setting short-term emission limits Short-term limit should not exceed a 30-day averaging period, in keeping with EPA guidance on practical enforceability

17. Long-Term limits Long-term (usually annual) emission limits take into account any restrictions on operating hours, throughput, or other parameters that reduce overall emissions May be used to legally avoid applicability of a program (such as Major NSR or PSD) In calculating annual emissions, important to include only those restrictions made enforceable through legally and practically enforceable permit conditions

18. Considerations about Limits • Limits need some form of monitoring to be effective • If you have a limit, you need to have recordkeeping and reporting • Limits are seldom “instantaneous” and should be “rolling” averages • 30-day roll: Day 31 is added and Day 1 drops off • 24 hour roll: Hour 25 is added and Hour 1 drops off

19. Example The Rutherford Rubber Baby Buggy Bumper Company is seeking to place an operational limit on their rubber baby buggy bumber production line. At full 24hr per day operations, the rbb line uses 48,000 scf per day. They want to limit their yearly operations to 1/3 of that, but retain some operational flexibility to increase production during the 4 week time period when the new year’s model of rubber baby buggy bumpers are produced. During this time, they operate 12 hours a day. What kind of operational limit could they receive. What kind of monitoring would be appropriate.

20. Example Solution • Yearly limit of 1/3 capacity = 48,000/3 = 16,000 scf per year • 28 days of the year they need 12 hours of production per day. • 48,000 / 8760 = 5.5 scf/hr • 5.5 * 12 = 66 scf/day • 30 days * 66 = 1980 scf / 30 days • Limits = 16,000 scf per 365 day roll, 1980 scf per 30 day roll • A fuel flow monitor to the rbbb production line would monitor for both limits

21. Recordkeeping Compliance with emission limits, throughput limits, or other limits established in permit conditions needs to be verifiable through adequate record-keeping requirements

22. Recordkeeping (cont.) • Examples of specific records that must be kept • Fuel use • VOC content • Throughput/sales • Hours of operation • Monitoring data • Forms that must be used or approved

23. Recordkeeping (cont.) • Describes length of time records must be maintained • Typically 2 years • Title V is minimum of 5 years • Describes where records may be kept • Onsite, Offsite, available to inspection personnel at all times, next to equipment being monitored

24. Reporting • Tells the source what reports are required to be generated • Annual fuel use • Annual Source test report • When the reports are to be submitted • Annual fuel use to the district prior to June 1 • Annual Source test report within 30 days after the source test was completed

25. Reporting (cont.) • Upset/Breakdown reporting • Reported within 4 hours • Description of equipment, reason for breakdown, how and when repaired, excess emissions estimate • Compliance Certification  • Signed by responsible official

26. Reporting (cont.) • Examples of reports that must be filed • Start date of construction • Start-up/First Fire date • Start date of production • Start and Finish dates for source testing • Annual compliance certification • Annual throughput reporting

27. Permit Conditions Reviewing Permits

28. Permit Conditions (cont.) • A permit condition must be easily understood by operator of facility, inspectors and general public • May not have clear idea of proposal • Did not write Engineering Evaluation • Did not determine BACT • Did not determine offsets • Did not determine method of compliance with prohibitory rules

29. Permit Conditions (cont.) • Each decision or conclusion made on the engineering evaluation should show up as a permit condition on the permit • It should be as near to 1:1 as possible!

30. Permit Conditions (cont.) • Clear idea of the proposal • Permit should clearly indicate the equipment installation/changes authorized • Ask: Is permit a stand-alone document?

31. Permit Conditions (cont.) • Example Installation of a boiler What questions come to mind? • Equipment description • Emission limits • Monitoring • Recordkeeping • Reporting

32. Permit Unit Description Detailed permit unit descriptions are essential to matching equipment with appropriate regulations and permit conditions. Example: 75 MMBtu/Hr Boiler with SCR OR… 75.0 MMBTU/HR BIGELOW NATURAL GAS-FIRED BOILER, S/N 576, WITH A TODD MODEL V.485.FGX LOW NOX BURNER, FLUE GAS RECIRCULATION SYSTEM, 02 TRIM CONTROLLER, AND CO TRIM CONTROLLER SERVED BY A CRI COMPANY MODEL SHELL DNOX LFR SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM

33. Emission limits Requirements Boiler shall not exceed 7 ppmvd NOx at 3% O2 or more than 0.008 lb/MMBtu Boiler shall not exceed 200 ppmvd CO@ 3% 02 or more than 0.148 lb/MMBtu NOx emissions shall not exceed 15.9 lbs/day and 5,804 lbs per year CO emissions shall not exceed 349.3 Lbs/Day and 127,484 lbs per year

34. Monitoring (cont.) • Source testing to measure NOx, CO. NH3 emissions from this unit shall be conducted at least once every twelve months. After demonstrating compliance on two consecutive annual source tests, unit shall be tested not less than once every 36 months. If result of 36-month source test demonstrates that unit does not meet applicable emission limits, source testing frequency shall revert to at least once every 12 months

35. Monitoring (cont.) • Permittee shall monitor and record stack concentration of NOx, CO, NH3, and 02 at least once every month (in which a source test is not performed) using a portable emission monitor that meets District specifications

36. Monitoring (cont.) • All NOx, CO, 02 and NH3 emission readings shall be taken with the unit operating either at conditions representative of normal operations or conditions specified in the permit-to-operate. The NOx, CO and 02 analyzer as well as the NH3 emission monitoring equipment shall be calibrated, maintained, and operated in accordance with the manufacturer's specifications and recommendations or a protocol approved by the APCO. Emission readings taken shall be averaged over a 15 consecutive-minute period by either taking a cumulative 15 consecutive-minute sample reading or by taking at least five readings, evenly spaced out over the 15 consecutive-minute period.

37. Recordkeeping (cont.) The permittee shall record the daily startup and shutdown duration times of the boiler. The permittee shall maintain records of: (1) the date and time of NOx, CO, NH3 and 02 measurements, (2) the 02 concentration in percent by volume and the measured NOx, CO and NH3 concentrations corrected to 3% 02, (3) make and model of exhaust gas analyzer, (4) exhaust gas analyzer calibration records, (5) the method of determining the NH3 emission concentration, and (6) a description of any corrective action taken to maintain the emissions at or below the acceptable levels. All records shall be maintained and retained on-site for a minimum of five years, and shall be made available for District inspection upon request.

38. Reviewing Permits Ambiguous Conditions Run-On Conditions Confusing Conditions Enforceability Averaging Times Monitoring of Compliance Off Permit Compliance Department or Permittee Discretion

39. Permitconditions should… Use simple declarative sentences Avoid compound sentence structure Avoid complex sentence structure Be short, simple and to the point

40. Ambiguous Conditions Material usage shall not exceed 32.2 gallons per day or 7,467 gallons in any 12-month period 32.2 gallons/day x 365 days/year = 11,753 gallons 11,753 gallons > 7,467 gallon annual limit Can both limits apply? Which one applies?

41. Reduce Ambiguity Daily material usage shall not exceed 32.2 gallons. Usage during any consecutive 12-month period shall not exceed 7,467 gallons. No ambiguity here!

42. Run-On Conditions The permittee shall ensure that the Phase I tank truck and trailer vapor recovery systems are utilized during each transfer of gasoline and that product and vapor (poppet) caps are securely replaced and remain in place following each transfer. The Phase I and Phase II vapor control systems shall be operated in accordance with District Rules 61.3, 61.4, and 61.7 and the ARB Executive Orders specified above.

43. Run-On Conditions (cont.) Condition No. 1: The Phase I and Phase II vapor control systems shall be operated in accordance with District Rules 61.3, 61.4 and 61.7 and the ARB Executive Orders specified above. Condition No. 2: The permittee shall ensure that the Phase I tank truck and trailer vapor recovery systems are utilized during each transfer of gasoline and that product and vapor (poppet) caps are securely replaced and remain in place following each transfer.

44. Reducing Confusion

45. ConfusingConditions • Undefined abbreviations and acronyms • The gasoline AST shall be PE&O’d with an OPD (The gasoline aboveground storage tank shall be properly equipped and operated with an overfill protection device.) • Two different terms used for same thing • Condition 1: No more than 4 cars shall be painted per day • Condition 2: No more than 12 vehicles shall be painted per week

46. Confusing Conditions (cont.) • Pronouns that don't clearly refer to specific nouns • “Permittee shall keep it at a minimum of 3% moisture at all times.” • Wordy, hard to read language • “Let us pontificate upon the ramifications of their non-compliance…”

47. Enforceability “The overall VOC destruction efficiency of the control device shall be at least 95% by weight.” With no other conditions for monitoring, this is unenforceable.

48. Enforceability • The overall VOC destruction efficiency of the control device shall be at least 95% by weight. • The control device shall be source tested annually using CARB Method 100. Or…… • Permittee shall monitor the flame temperature of the control device daily.

49. Ambiguous ≠ Enforceable • “In accordance with the manufacturer’s specifications…” • “Take reasonable precautions…” • “Use best engineering practices…” How can these conditions be improved?

50. Averaging Times • Boiler may not emit more than 10 Lbs of NOx. • Lacks averaging period • Boiler shall not exceed 7 PPMVD at 3% O2. • Lacks averaging period • Boiler NOx emission rate shall not exceed 7 ppmvd at 3% O2 and not more than 10 lbs/hour in any 24-hour rolling average.