EPA’s proposed Federal Plan under the Clean Power Plan
• For any state that does not submit an approvable state plan
• Contains three main parts:
o Rate-based model trading rule
o Mass-based model trading rule
o Rate-based OR mass-based federal plan (TBD)
• Has not yet been finalized

2008 Ozone NAAQS
• On April 11th 2016, EPA determined which marginal areas reached attainment by the July 2015 deadline, and which did not.
• For the list of those areas, follow this link: https://www.epa.gov/sites/production/files/2016-04/documents/20160411factsheet.pdf
• States that have been re-classified as “moderate” will need to resubmit a SIP for compliance by 2018.

2015 Ozone NAAQS
• Standard is now 70ppb
• Air Quality Index has also been updated-may look like air quality is getting worse but that is not the case.
• States will have to submit their recommendations for designations by October 2016
• EPA will issue final designations by October 2017

CSAPR Update
• EPA issued an update to CSAPR in fall 2015 order to help moderate areas achieve compliance with the 2008 ozone NAAQS
• This identified short term measures the power sector could make that would result in meaningful NOX reductions
o Optimizing operation of existing control technology
o Turning on controls that were idled
o Upgrading to state-of-the-art low NOX combustion controls
o Shifting generation to lower-emitting plants

The post EPA’s Year Ahead 2016 appeared first on Air Tox.

The EPA seeks comment on some specific parts of the rule:

• The EPA would like input on whether short-term NOx concentrations from EGU’s disproportionally affect downwind ozone concentrations. If so, what type of short-term emission limits (daily, monthly, etc.) would be appropriate to limit this impact?

• The EPA would like comments on what types of mitigation strategies for reducing EGU NOx by the 2017 ozone season are reasonable. Options may include:
  • Turning on idling SCR and SCNR’s
  • Upgrade, replace or install state-of-the-art combustion controls such as low-NOx burners or over-fire air
  • Shifting generation towards lower NOx-emitting EGU’s

• Whether or not non-EGU controls are feasible by the 2017 ozone season (this rule does not propose any, at this point)

Comments must be received by January 19, 2016.

For questions, feel free to contact Air Tox.

The post EPA Seeks Comment on CSAPR Update for 2008 Ozone NAAQS appeared first on Air Tox.

Emission Limits

Source: U.S. Environmental Protection Agency

 Testing

• Initial Compliance Test (by March 21 2016)
• Annual Compliance Tests, and/or use of CEMS

Continuous Compliance

• Annual pollution control device inspections (based on control device)
• Monitoring of operating parameters and limits
  • including minimum operating or afterburner temp, feed rate of sludge, moisture content of sludge, and site specific operating requirements for fugitive ash
  • other specific requirements based on control device

Record keeping and Reporting

• Increments of Progress – 1st and 2nd increment
• Initial Compliance Report
• Annual report
• Deviation report
• Qualified operators status report (if a qualified operator is not available for 2 weeks or more)

Other

• All operators must be fully trained and qualified- “An SSI unit cannot be operated unless a fully trained and qualified SSI unit operator is accessible, either at the facility or can be at the facility within 1 hour”. An annual review/refresher course is also required. This documentation must be updated annually on site.
• A site-specific monitoring plan must be submitted before March 21 for each continuous monitoring system, bag leak detection system (if applicable), and for ash-handling.

The post What you need to know about the EPA’s new Sewage Sludge Incinerator Rule appeared first on Air Tox.

1. 17 of these areas will receive attainment status based on 2012-2014 certified data.

2. 8 areas will receive 1-year attainment date extensions based on their 4^th highest daily maximum 8-hour value in 2014.

3. 11 areas will be bumped to “moderate” status, as they did not meet attainment based on 2012-2014 certified data. This implies that a revised SIP must be submitted for affected states. The Moderate attainment deadline is July 20^th, 2018.

In Connecticut, the Greater Hartford area along with the New York, New Jersey, Long Island area (which includes part of CT) were not attaining and not eligible for a 1-year extension. Connecticut will have to revise their SIP accordingly.

For a complete list of EPA attainment/nonattainment area designations, see link below:

http://www.epa.gov/ozonepollution/pdfs/20150819fr.pdf

If you have any questions on how this may affect your facility, please contact AIRTOX.

The post 2008 OZONE NAAQS: Regulatory Update appeared first on Air Tox.

The EPA issued a final action on May 22, 2015 to ensure states have implementation plans in place for emissions to be fully compliant with the Clean Air Act (CAA) during periods of Startup, Shutdown and Malfunction (SSM). In the rule, there are 36 states that are required to correct specific SSM provisions and submit a State Implementation Plan (SIP) revision that addresses this action by November 22, 2016.

In the past, there have been some exemptions from emission limits during periods of SSM that have been approved by the EPA and adopted into SIPs. This final action by the EPA was issued, in part, as recent court decisions have challenged these SSM exemptions to the CAA (which have been allowed as affirmative defense provisions in the past), stating they cannot be allowed in SIPs.

If you are not sure how this rule is going to affect you, or if you need help ensuring that you will maintain compliance, contact Air Tox to see how our staff of experts can help you: info@airtoxenviro.com.

The post Startup, Shutdown and Malfunction Emissions – EPA Final Action appeared first on Air Tox.

The following are steps that states will take to comply with the plan:

1. Under the plan, states are given a unique target rate of CO2 emissions per unit of electricity generated to be achieved by 2030.
2. States will develop and submit action plans by 2016 of how they will achieve their assigned rate.
3. States must show meaningful progress towards their goal by 2020.

According to the EPA, under this plan, carbon dioxide pollution from the power sector will be reduced by 30% by 2030.

The Climate Action Plan allows states a large range of flexibility in developing their action plans, thereby letting states make the decision of when and where to make cuts in emissions. For instance, states can choose from a number of reduction strategies, including

• Co-firing or switching to natural gas only
• Retirements
• Efficiency improvements at plants
• Construction of natural gas combined-cycle plants
• Expanding renewable energy
• Multi-state cooperation programs
• Market-based trading incentives
• Energy conservation programs

It is the EPA’s intention that under this Climate Action Plan, states will be able to reduce harmful CO2 emissions all the while providing an incentive for innovation and guaranteeing a reliable and affordable energy system.

For more information, click on the link below:

http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule

Slider reference: Rahm Emanuael/ CC-BY-SA-3.0

The post EPA’s Clean Power Plan: a Brief Overview appeared first on Air Tox.

Carbon Pollution Standards for New/Modified/Existing Power Plants

• Comment period for these proposed regulations has closed.
• Regulation sets a lbs/MWhr rate limit for each state.
• States have to meet an interim rate goal by 2020-2029, and a final goal by 2030.
• New England states have already expressed interest in using RGGI as a compliance mechanism. In this case, a multi-state rate goal would then take place of an individual state goal.
• States have until summer 2016 to submit compliance plans, with an optional 2 year extension for multi-state plans.
• More info: http://www2.epa.gov/carbon-pollution-standards

http://cliparts.co/power-plant-clip-art

Implementation of 2008 Ozone NAAQS

• Effective date of rule was July 20^th 2012
• 1997 Ozone NAAQS revoked (effective April 6^th 2015)
• D.C. Circuit court decision (December 2014) shortened all attainment dates by 1 year. The revised attainment dates based on classification are as follows:
  • Marginal: July 20^th 2015
  • Moderate: July 20^th 2018
  • Serious: July 20^th 2021
  • Severe: July 20^th 2027
  • Extreme: July 20^th 2023
• This means that only data from 2012 to 2014 ozone seasons can be used for showing attainment for marginal areas.
• There is a 1-year extension available for attainment if, during the attainment year, the area’s 4^th highest daily 8-hr maximum was below 0.075 ppm.
• EPA will make final ruling on marginal attainment areas by January 20^th If states do not meet attainment, they will have 1 year to submit a new SIP.
• More info: http://www.epa.gov/airtransport/ozonetransportNAAQS.html

http://www.epa.gov/groundlevelozone/designations/2008standards/final/finalmap.htm

Cross State Air Pollution Rule (CSAPR)

• No more Acid Rain Program, NOx Budget Trading Program, or CAIR allowances
• 1/1/15-Phase 1 of rule begins
• 1/1/17-Phase 2 of rule begins
• Rule includes separate requirements for annual NOx & SO2 reductions and ozone-season NOx reductions.
• States covered under rule: IL, IN, MD, MI, NJ, NY, OH, PA, VA, WV, WI, TX, KY, MO, OK, LA, FL, GA, SC, NC, AL, NE, MN, TN, AR, MS, IA
• Good Neighbor SIP’s- States under rule could either “demonstrate that its contribution is below screening threshold, or it could evaluate the scope of its transport obligation and indentify measures to achieve any needed emissions reductions.” (http://www.epa.gov/airtransport/)
• More Info: http://www.epa.gov/airtransport/CSAPR/index.html

http://www.epa.gov/airtransport/CSAPR/statesmap.html

2012 PM_2.5 NAAQS

• Primary standard revised to 12 μg/m³ on 12/14/14 (was 15 μg/m³)
• 12/18/14-Final designations issued by EPA
• 3/31/15-Additional designations issued
• Attainment plans of affected areas due within 18 months of designation
• More info: http://www.epa.gov/airquality/particlepollution/implement.html

2015 Ozone NAAQS

• EPA proposing new ozone standards of 65-70ppmb
• Final rule to be issued 10/1/15
• Following that schedule, EPA designations would be complete by October 2017

Standards of Performance for New Residential Wood Heaters, New Hydronic heaters and New Forced Air Furnaces

• Rule published 3/16/15
• Regulates
  • Adjustable stoves
  • Single burn-rate stoves
  • Pellet stoves
  • Fireplace inserts
  • Hydronic heaters
  • Forced air furnaces
• Strengthens emissions standards for new wood stoves
• Establishes standards for previously unregulated heaters (indoor/outdoor wood-fired boilers, indoor wood-burning forced-air furnaces)
• Manufacturing sell-through until 12/31/15
• More info:

https://www.federalregister.gov/articles/2015/03/16/2015-03733/standards-of-performance-for-new-residential-wood-heaters-new-residential-hydronic-heaters-and

The post The EPA’s Year Ahead in Air Regulations appeared first on Air Tox.

Emissions Testing

Facilities can show compliance with emissions limitations in three ways:

1. Periodic emissions testing according to this subsection
2. Periodic emissions testing under New Source Performance Standards in 40 CFR 60
3. Installation/operation of a CEMS monitor for NOx

If the facility is subject to this subsection (option 1 of above), an initial emissions test must be conducted within five calendar years of the effective date of this subsection.

The emissions test will consist of one of the following:

1. Three one-hour tests, each performed over consecutive 60-minute periods
2. Four 15-minute tests, each performed over consecutive 15-minute periods (This is only if the commissioner approves that three one-hour tests are not reasonable.)

Sampling for the emissions test will be conducted when the unit is operating at 90% capacity, except as follows:

1. The unit is subject to testing at a load other than 90% by permit or order.
2. The commissioner approves testing at an alternative maximum capacity because
   1. Operating at 90% is not technically feasible or
   2. Alternative maximum capacity is more representative of operations encountered by the unit.
3. A unit that has operated above 100% of its maximum capacity at any time since December 31, 2016, will be tested at 90% of that new capacity.

Emissions data used to determine compliance will not contain the following:

1. Startup/shutdown data
2. Data during monitoring system malfunctions
3. Out-of-control data
4. Data during required quality assurance or quality control activities
5. Data when the system is in maintenance
6. Data when the unit is not operating

 Compliance and Emissions Limitations

The emissions limitations are as follows:

Boiler serving EGU's Phase I

ICI Boilers Phase I

Simple-cycle Turbines Phase I

Combined-cycle Turbines Phase I

Reciprocating Engines Phase I

Boilers serving EGU's Phase II

ICI Boilers Phase II

Simple-cycle Turbines Phase II

Combined-cycle Turbines Phase II

Reciprocating Engines Phase II

Phase I: 6/1/2018–5/31/2022

Phase II: 6/1/2022Phase I: 6/1/2018–5/31/2022

The owner/operator of the emission unit shall comply with the above emissions limitations or shall take one of the following actions:

1. Implement an alternative compliance mechanism as provided below.
   1. Reduce emission rate by at least 40% from a 2010 baseline rate (or other representative baseline year).
   2. To comply with Phase 1, use banked DERCs.
   3. For EGUs and simple-cycle turbines to comply with Phase 1 non-ozone limits, install/operate a control device.
   4. As an alternative to Phase 1/2 24-hour limit and seasonal limit, accept an enforceable cap on mass emissions or hours of operation.
   5. Commit to combust only natural gas if unit can combust either natural gas or fuel oil. (A suggestion was also made during the meeting to include the option for the unit to comply with the Federal boiler MACT.)
   6. Average emissions with emissions from over-complying units at the same facility or under the same ownership in the same non-attainment area.
   7. Commit to modifying or replacing unit on a schedule so that Phase I limits will be met by June 1, 2019, or Phase 2 limits will be met by June 1, 2023.
   8. Commit to retire another unit at the facility that will result in a reduction of mass emissions equal to or greater than the emission reduction that would be achieved by the unit complying with the applicable emissions limitation.
   9. Limit operations to only OP4, Action 6 events.
   10. Implement any combination of the above options that would result in the reduction in the rate of emissions of the participating units equal to or greater than the emission rate that would be achieved by compliance with a single option.
2. Operate under a case-by-case RACT determination.
   1. This will be determined based on the economic and technical feasibility of achieving the emission limitations of this section. Any case-by-case RACT will establish the lowest emission limit reasonable for the unit.
   2. The emission limitation established under this subsection would expire May 31, 2030.
3. Cease operations. Any owner/operator who is unable to comply with the applicable emissions limitations at the beginning of Phase 1 or 2 shall cease operations on the first day of Phase 1 or 2; OR at the commissioner’s discretion, enter into an agreement to cease operations no later than June 1, 2019, (Phase 1) or June 1, 2023, (Phase 2).

Requests for any of these other compliance options (#1–3 subsections above) must be submitted to the commissioner no later than September 1, 2017, for Phase I and September 1, 2021, for Phase 2.

The post CT Section 22 Updates appeared first on Air Tox.

Drift Specifications

 

	Part 60	Part 75
NOx	2.5% span	5% span OR 5ppm (if range <50ppm) OR 10ppm (if range >50<200ppm)
SO2	2.5% span	5% span OR 5ppm (if range <50ppm) OR 10ppm (if range >50<200ppm)
CO	5% span	None
NH3	2.5% span	None
O2	0.5% span	1%
CO2	0.5% span	1%
Velocity	3% span	6%
Opacity	2% span	None

*References: 40CFR60 App_B Spec 1-4; 40CFR75 App_B § 2.1.4

Out of Control Criteria

 

	Part 60	Part 75
Single Failed Cal	4x drift spec. in a single calibration	1x drift spec. in a single calibration
5 Day Drift Limit	5th consecutive cal at 2x drift spec. is OOC	None

*References: 40CFR60 App_F § 4.3.1; 40CFR75 App_B § 2.1.4

Data Invalidation

 

	Part 60	Part 75
Failed Calibration	OOC back to last passing cal until next passing cal	OOC from failed cal until next passing cal
Missed Calibration	After approximately 24 hours, data is OOC until next passing cal	After 26 hours, data is OOC until next passing cal

*References: 40CFR60 app. F § 4.3.1; 40CFR75 app. B § 2.1.5

Daily Calibration Hourly Requirements

*References: 40CFR60 App_F § 4.1; 40CFR 75 App_B § 2.1.5

**several requirements apply for this exception

Range Requirements

 

	Part 60	Part 75
Zero	0-20% span	0-20% span
Mid	None	50-60% span
High	50-100% span	80-100% span (can use mid in lieu of high if more representative)

*References: 40CFR60.13.d; 40CFR75 App_A § 5.2

As always, if you have questions on which requirements apply to your facility and what that means for you, feel free to contact us.

The post Calibrations–Part 60 vs 75 appeared first on Air Tox.

• Keep copies of all calibration gas cylinder certifications in a central location. Note the date and time of the cal gas bottle change-out on the cert sheet. An excel table organized by quarter detailing the information on the cert sheet and date of change out is also helpful.

• Make sure records are kept of oil and gas GCV’s, sampling procedure and vendor information, as required by your specific permit.

• A log book or excel sheet detailing each daily run is helpful for comparing run times as registered in the DAS. It is also beneficial to note which fuel type was used, especially when using an alternative fuel source.

• Make note of major downtime or excess emission causes and corrective actions when they occur.

• If you have a procedure of “answering” downtime and excess emission events in your DAS, try to do this soon after the event has occurred.

• Keep detailed record of fuel meter certifications and change outs.

• In general, be familiar with your facility permit and what type of documentation is required. Also be familiar with how long that documentation needs to be stored on site.

For any and all reporting questions, contact Air Tox .

The post Tips for Easing the Reporting Process in the Off-Season appeared first on Air Tox.