title v permitting and cam planning appa e&o technical conference april 19, 2005
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Title V Permitting and CAM Planning APPA E&O Technical Conference April 19, 2005. Robert M. Iwanchuk, C.C.M . ENSR International Westford, MA 978-589-3265/[email protected]. Overview of Topics. Title V Monitoring Principles Part 64/CAM rule summary CAM applicability - PowerPoint PPT PresentationTRANSCRIPT
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Title V Permitting and CAM Planning
Title V Permitting and CAM PlanningTitle V Permitting and CAM Planning
APPA E&O Technical ConferenceAPPA E&O Technical ConferenceApril 19, 2005April 19, 2005
Robert M. Iwanchuk, C.C.M.
ENSR International
Westford, MA
978-589-3265/[email protected]
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Title V Permitting and CAM Planning
Overview of TopicsOverview of Topics
Title V Monitoring Principles
Part 64/CAM rule summary
CAM applicability
Guidance on Establishing CAM Monitoring
CAM Plan example
Technical resources
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Title V Permitting and CAM Planning
Enhanced Monitoring Rule HistoryEnhanced Monitoring Rule History
1990 - CAAA requires EPA to publish monitoring rules for major sources
1992 - EPA proposes Enhanced Monitoring rules CEMS based
All major sources subject
1995 - EPA changes direction Reasonable Assurance of Compliance
Focus on add-on control devices
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Title V Permitting and CAM Planning
CAM Goals / PrinciplesCAM Goals / Principles
Monitoring to provide a reasonable assurance of compliance Ensure control device is properly operated and
maintained Define operational criteria (indicator ranges) for good
O&M of control equipment Take corrective action before it becomes a pollution
problem Compliance can be assumed if indicators within
acceptable range or value
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Title V Permitting and CAM Planning
Compliance Assurance MonitoringCompliance Assurance Monitoring
Impact on Industry Risk of enforcement action will increase
Compliance costs will increase
Increased scrutiny of existing control devices
Marginal control devices will present higher risk
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Title V Permitting and CAM Planning
What is required in Title V for What is required in Title V for Monitoring?Monitoring? Monitoring requirements from applicable rules
Includes CAM rule requirements
CAM only applies to certain units with control devices
Periodic monitoring Gap filling if applicable rule 1) has no monitoring, 2) no
frequency, or 3) initial testing only
If CAM not applicable, PM can still be required
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Title V Permitting and CAM Planning
What is CAM Rule?What is CAM Rule?
40 CFR Part 64 Federal register citation
Regulation implementing the Title V monitoring principle
Targets facilities with add-on pollution control devices
Requires monitoring plan for affected units Monitoring elements reflected in Title V permit
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Title V Permitting and CAM Planning
Who is Affected by CAM?Who is Affected by CAM?
Facility is a major source subject to Title V Emission unit subject to an emissions
limitation or standard Pollutant-specific emission unit (PSEU)
PSEU uses “active” control device to achieve compliance
Pre-control PTE > major source size threshold
Not otherwise exempt
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Title V Permitting and CAM Planning
Major Pollutant and CAM Major Pollutant and CAM Applicability ThresholdsApplicability Thresholds
Nonattainment Major Source CAM PSEU
Pollutant Status Threshold (TPY) Applicability Level (TPY)1
Criteria/NSPS Attainment Attainment 100/250 100
VOC/NOx Marginal 100 100
Serious 50 50
Severe 25 25
Extreme 10 10
All Other Areas in OTR 50 (VOC only) 50
CO Serious 50 50
PM Serious 70 70
1Potential Pre-Control Device Emissions
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Title V Permitting and CAM Planning
Who is exempt from CAM?Who is exempt from CAM?
Rule-based exemptions: Acid rain rules
Post-1990 EPA rules (e.g. MACT standards)
Rules with continuous compliance determinations methods (e.g., Subpart Da facilities for SO2)
One non-rule based exemption Municipally-owned peaking units
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Title V Permitting and CAM Planning
What is an “active” control device?What is an “active” control device?
Equipment used to destroy or remove air pollutants Inherent process equipment not included
Active controls - e.g., fabric filters, scrubbers, incinerators, catalytic oxidizer Includes any capture system
Passive controls exempt
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Title V Permitting and CAM Planning
Examples of control techniques NOT Examples of control techniques NOT coveredcovered
Combustion design features (e.g., lean-burn IC engine)
Low solvent coatings and sprays
Low pollution fuel
Low pollution materials
Low NOx burners
Roofs / covers / lids / storage tank seals
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Title V Permitting and CAM Planning
How are pre-control device emissions How are pre-control device emissions calculated?calculated?
Similar to PTE calculations for Title V except: Capture and control efficiency not counted
May account for enforceable operational restrictions: Hours of operation, throughput restrictions
Testing for applicability unnecessary
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Title V Permitting and CAM Planning
Estimating pre-control emissionsEstimating pre-control emissions
PSEU
ControlDevice
Pre-controlledEmissions
Annual emissions = restrictions X emissions rate
Post-controlEmissions
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Title V Permitting and CAM Planning
When does CAM apply?When does CAM apply?
For large PSEUs (post control > major source threshold): With initial Title V application, if submitted after April 20,
1998
Significant Title V permit revision (only with respect to the PSEUs for which the revision is applicable)
Title V permit renewal
For non-large PSEUs Title V permit renewal
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Title V Permitting and CAM Planning
Applicability Logic DiagramApplicability Logic Diagram
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Title V Permitting and CAM Planning
CAM Plan ImplementationCAM Plan Implementation CAM approved via Title V permit
CAM monitoring upon issuance of Title V permit May be delayed if test program is necessary
Monitoring during all periods when unit is operating Repair, maintenance, QA/QC excluded
Part 70 Periodic Monitoring remains in effect prior to CAM
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Title V Permitting and CAM Planning
What Must Be In The Permit?What Must Be In The Permit?
Description of the monitoring approach What is measured, how, frequency, averaging time
Definitions of exceedances or excursions (e.g., excursion triggers corrective action/reporting)
QA/QC schedule and procedures
CAM Plan is a separate document
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Title V Permitting and CAM Planning
CAM ApproachCAM Approach
Demonstrate controls’ ability to achieve compliance
Indicators define “envelope” of good O&M for control device
Monitor indicators
Compliance can be assumed if indicators within acceptable range or value Basis for Title V compliance certification
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Title V Permitting and CAM Planning
CAM Approach, Cont.CAM Approach, Cont.
Indicators outside of accepted range triggers: investigation, corrective action, QIP (if necessary)
Response depends on whether an excursion or an exceedance
Report exceedances/excursions in Title V Compliance Certification
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Title V Permitting and CAM Planning
CAM PlanCAM Plan
Excursion: Departure from “indicator” range established in accordance with part 64
Exceedance: Condition detected by monitoring (in units of pollutant emissions) that emissions are beyond limit
Note: Excursions lead to corrective actions and may or may not be exceedances
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Title V Permitting and CAM Planning
CAM Plan ContentsCAM Plan Contents Background information
Unit ID, applicable requirement, control device
Monitoring approach General criteria
Performance criteria
Justification Selection of monitoring approach
Indicator range(s)
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Title V Permitting and CAM Planning
Selection of Monitoring ApproachSelection of Monitoring Approach
Identify Potential Performance Indicators (or Combination of Indicators) and Choose Most Reasonable Approach Emphasis on current procedures
Consider Level of Confidence and Costs
Establish Indicator Ranges
Establish Monitoring Frequency
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Title V Permitting and CAM Planning
Selection of Monitoring ApproachSelection of Monitoring Approach
Site-Specific Factors to Consider: Existing monitoring equipment
Data representation of emissions or parameter being monitored
Adequate QA/QC practices
Frequency, collection procedures, and averaging period
Monitor’s ability to account for operational variability
Reliability of control technology
Actual emissions vs. limit
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Title V Permitting and CAM Planning
Performance Indicators Performance Indicators Selection Considerations
Direct or predicted emissions
Process and control device parameter
Recorded findings of inspection and maintenance activities
Performance Criteria Representative data
Verification procedures
QA/QC practices
Monitoring frequency
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Title V Permitting and CAM Planning
Frequency of CAM MonitoringFrequency of CAM Monitoring
Large PSEUs 4 or more data values equally spaced over each hour and
average the values Other PSEUs
At least one data value per 24-hour period Be practical
Frequency should be consistent with averaging times in the permit limits
Short enough to identify problems and do corrective action Long enough so that minor perturbations resulting from
normal variations are not flagged as excursions/exceedances
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Title V Permitting and CAM Planning
Establishing Indicator RangesEstablishing Indicator Ranges
Parameter data collected during testing
Historical data
Design or engineering data
From similar operations
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Title V Permitting and CAM Planning
Indicator RangesIndicator Ranges
Establish range(s) or condition(s) such that operation within the ranges provides a reasonable assurance of ongoing compliance with the emissions limitations or standards within the anticipated range of operating conditions
If detailed data or test information are not readily available, a source must:
Submit an implementation plan and schedule with detailed activities
Perform activities as expeditiously as possible, but not later than 180 days after approval of the permit
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Title V Permitting and CAM Planning
Establishing Indicator RangeEstablishing Indicator Range
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Title V Permitting and CAM Planning
Part 64 applicability examplesPart 64 applicability examples
precontrol (tpy)
postcontrol (tpy)
part 64 applicable?
large? other?
600 20 yes other (1/ day)
200 105 yes large (4/ hr)
90 25 no
110 110 no
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Title V Permitting and CAM Planning
Quality Improvement PlanQuality Improvement Plan Agency discretion to require based on:
Failure to take proper corrective action or Threshold of accumulated excursions/exceedances as
specified in Title V permit
QIP elements - procedures to evaluate control problem and implementation schedule Improved PM, process changes, improved control
method More frequent or improved monitoring
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Title V Permitting and CAM Planning
CAM Reporting and RecordkeepingCAM Reporting and Recordkeeping Semi annual monitoring reports
Number, duration and cause of exceedances/excursions; corrective actions
Monitoring equipment downtime (other than QA) QIP actions
Annual compliance certifications Records of monitoring data, monitor
performance, corrective actions, QIP actions Alternative media (computer files, microfiche, magnetic
tape)
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Title V Permitting and CAM Planning
CAM Plan ExamplesCAM Plan ExamplesEmission Unit Coal-Fired Boiler
Equip ID PB01
Lime Silo
Equip ID SSIL
Control Device Scrubber for SO2
Stack ID: PB1EP
Baghouse for PM
Stack ID: SSILEP
Applicable Requirement
Reg. 61-62.1, Sec II, H (PSD avoidance)
Reg. 61-62.5, Std 4, Sec VIII
PM emission limit based on hourly raw material rate
Emission Limit 1132 tpy SO2 35.43 lbs/hr PM
Is the unit a major source post-control?
Yes No
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Title V Permitting and CAM Planning
CAM Plan Examples (continued)CAM Plan Examples (continued)Emission Unit Coal-fired Boiler Lime Silo
I. CAM Indicator Scrubber pressure drop and liquid flow rate
Pressure Drop
Measurement Approach
Differential pressure gauge and liquid flow meter
Differential pressure gauge
Monitoring Frequency Continuous (once every 15-minute period
Daily
Justification Adequate pressure drop and liquid flow indicate proper gas to liquid contact in scrubber
An increase in pressure drop could indicate that the cleaning cycle is not frequent enough or that the bags need to be replaced
II. Indicator Range The operational ranges developed during performance testing will be used for SO2 CAM indicator ranges.
Maximum pressure drop of 10 psi.
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Title V Permitting and CAM Planning
CAM Plan Examples (continued)CAM Plan Examples (continued)Emission Unit Coal-fired Boiler Lime Silo
III. Performance Criteria
Data Representativeness
Pressure drop measured across scrubber, scrubbing liquid flow meter installed in scrubbing liquid supply line.
Pressure drop across the baghouse is measured at the baghouse inlet and exhaust.
QA/QC Practices and Criteria
Semi-annual calibration of gauges.
Accuracy of pressure gauge must be within +2 in. H2O.
Accuracy of flow meter must be within +5% of design flow rate.
Annual calibration of pressure gauge.
Data Collection Procedures
Once every 15-minute period and each 3-hour average.
Differential pressure is recorded once per day in the plant’s data system.
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Title V Permitting and CAM Planning
Examples of Presumptively Acceptable Examples of Presumptively Acceptable MonitoringMonitoring
Table 3-3 of CAM Guidance www.epa.gov/ttn/emc/cam.html
CEMS, COMS, PEMS satisfying Part 64
Part 75 monitoring
Monitoring required by NSPS or NESHAP proposed after 11/15/90 (must satisfy Part 64)
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Title V Permitting and CAM Planning
SummarySummary
Start planning now TV renewals are upcoming
Modify test programs to accommodate CAM data needs
Initiate dialogue with state agency
Ongoing issues Corrective action for excursions/exceedances
Planning for QIP, if necessary
Consider impact of actions on compliance certifications
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Title V Permitting and CAM Planning
CAM Guidance DocumentsCAM Guidance Documents
Working draft October 1997 Rule Overview
Description of monitoring approaches
Monitoring equipment technical reference
Appendices: Example CAM plans & Illustrations
EPA Website www.epa.gov/ttn/emc/cam.html
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Title V Permitting and CAM Planning
QuestionsQuestions