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New Source Review:Monitoring Recordkeeping and

Reporting

Donald LawEPA Region 8

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OutlineMonitoring

Types of Monitoring methodsTypes of Monitoring limitsShort Term and Long Term Limits

RecordkeepingReportingPermit Conditions Review

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MonitoringFor each emissions unitFor each regulated pollutant emittedBased on an applicable requirement

derived from Prohibitory Rules Applicable BACT LimitsEngineering EvaluationNESHAP, MACT, NSPS RequirementsPotential To Emit Calculations

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Monitoring (cont.)Lists specific monitoring methodSource Test

Direct measurement of stack gas pollutant emissionsMeasured at the stack for a set period of time Source test methods describe apparatus

usedConducted at maximum operating capacityPerformed at start-up and usually annually

thereafter Witnessed by Permitting Authority

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Source Test MonitoringTitle 40 Code of Federal Regulations Part 60

Appendix AMethods 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

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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

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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 recordedSome CEM data linked directly to permitting

authority

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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.

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CEM ApplicationsPollutants that CEMs are good for

NOxSOxCOCO2Particulates

Stack emission monitoringUncontrolledPost controls

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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

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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 CO2 concentrations) and

Record average operational parameter value(s) on a continuous basis

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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 MonitoringContinuous Opacity Monitor (COMs) Dependant on stack moisture conditions

Visible Emissions Evaluation (VEE)** Must be certified to read smoke

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Where do limits come from?

Limits can come from almost any documentNSPS (40 CFR Part 60)MACT (40 CFR Part 63)NESHAP (40 CFR Part 61)PSD permit (BACT)Non-NSR (LAER)State/Tribal Pre-construction permitState/Tribal Implementation Plan

Do NOT come from Title V permit

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Examples of Emission Limitations

Pounds per hour/Tons per yearGrains per dry standard footUsage rates (gallons per hour, gallons per square foot of surface areaNOx lbs/dscf; dscf/hr, hours per yearNOx PPMVD corrected to 15 % O2VOC Lbs/gallon, gallons per yearGrams per horsepower hourPounds/MMBtu20% Opacity

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Short-Term LimitsShort-term emissions usually

represent the worst case allowable emissions for equipment operating at maximum capacity.

These limits provide a way to verifyemission estimates are accurate control devices are operating as

designed air quality standards are being met

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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

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Long-Term limitsLong-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

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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” averages30-day roll: Day 31 is added and Day 1 drops off24 hour roll: Hour 25 is added and Hour 1 drops

off

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ExampleThe 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.

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Example SolutionYearly limit of 1/3 capacity = 48,000/3 = 16,000 scf per

year28 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

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RecordkeepingCompliance with emission

limits, throughput limits, or other limits established in permit conditions needs to be verifiable through adequate record-keeping requirements

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Recordkeeping (cont.)Examples of specific records that

must be keptFuel useVOC contentThroughput/salesHours of operationMonitoring dataForms that must be used or approved

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Recordkeeping (cont.)Describes length of time records

must be maintainedTypically 2 yearsTitle V is minimum of 5 years

Describes where records may be keptOnsite, Offsite, available to inspection

personnel at all times, next to equipment being monitored

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ReportingTells the source what reports are

required to be generatedAnnual fuel useAnnual Source test report

When the reports are to be submittedAnnual fuel use to the district prior to

June 1Annual Source test report within 30

days after the source test was completed

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Reporting (cont.)Upset/Breakdown reporting

Reported within 4 hoursDescription of equipment, reason for

breakdown, how and when repaired, excess emissions estimate

Compliance Certification Signed by responsible official

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Reporting (cont.)Examples of reports that must be

filedStart date of constructionStart-up/First Fire dateStart date of productionStart and Finish dates for source testing Annual compliance certificationAnnual throughput reporting

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Permit ConditionsReviewing Permits

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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

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Permit Conditions (cont.)Each decision or conclusion made

on the engineering evaluation should show up as a permit condition on the permitIt should be as near to 1:1 as possible!

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Permit Conditions (cont.)Clear idea of the proposal

Permit should clearly indicate the equipment installation/changes authorized

Ask: Is permit a stand-alone document?

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Permit Conditions (cont.)Example

Installation of a boilerWhat questions come to mind?

Equipment descriptionEmission limitsMonitoringRecordkeepingReporting

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Permit Unit DescriptionDetailed 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

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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

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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

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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

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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.

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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.

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Reviewing PermitsAmbiguous ConditionsRun-On ConditionsConfusing ConditionsEnforceabilityAveraging TimesMonitoring of ComplianceOff Permit ComplianceDepartment or Permittee Discretion

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Permit conditions should…Use simple declarative sentencesAvoid compound sentence structureAvoid complex sentence structureBe short, simple and to the point

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Ambiguous Conditions Material usage shall not exceed

32.2 gallons per day or 7,467 gallons in any

12-month period32.2 gallons/day x 365 days/year = 11,753

gallons11,753 gallons > 7,467 gallon annual limitCan both limits apply? Which one applies?

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

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Run-On ConditionsThe 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.

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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.

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Reducing Confusion

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Confusing Conditions 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

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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…”

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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.

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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.

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Ambiguous ≠ Enforceable• “In accordance with the

manufacturer’s specifications…”• “Take reasonable precautions…”• “Use best engineering

practices…”How can these conditions be improved?

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Averaging TimesBoiler 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.

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Monitoring of ComplianceBoiler shall not emit more than 10

pounds/Hour.Lacks a compliance demonstration method

Boiler shall not emit more than 10 pounds/Hour. Compliance shall be determined by the use of a NOx continuous emissions monitor. Monitor shall be properly installed, certified and operated in accordance with U.S. EPA.

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Off PermitOpacity shall be met by following a

fugitive dust plan.If a plan is used to demonstrate compliance, it

should be in the permit.Compliance with the co emissions

limitation shall be demonstrated by following manufacturers recommendation.What are recommendations? How is

compliance demonstrated?

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Department or Permittee Discretion

The permittee shall measure opacity using method 9 for 15 minutes.Does not define when opacity test shall be run;

permittee can test during non operation or when unit is in compliance only.

The APCO shall determine the emission rate after one year of testing and maintenance.No actual emission rate until a year has passed.

No way for general public to know exact emission level.

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A Few RecommendationsPay particular attention to new or

modified equipment descriptions, conditions and requirements

Review BACT levels and ensure limits are reflected in permit conditions

Review daily, quarterly and annual emission limits and ensure conditions adequately limit emissions

Review MRR requirements