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EPA’s Year Ahead 2016

airtox — Wed, 20 Apr 2016 18:42:11 +0000

Clean Power Plan
• The supreme court stayed the implementation of this rule until the D.C. court rules on the pending litigation
• This means states are not obligated to take action to meet the deadlines in the plan
• States can voluntarily work towards these deadlines and goals
• If the D.C. court rules in the EPA’s favor, only the Supreme Court can lift the stay on the rule, so it can be expected this will not happen until 2017 at the earliest.

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

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NSPS for Residential Wood Heaters

airtox — Tue, 24 Nov 2015 16:57:48 +0000

The New Source Performance Standards for hydronic heaters, wood-burning forced-air furnaces, pellet stoves, and other wood heaters was published on March 16, 2015. This rule sets standards for previously unregulated heaters, and updates standards for new, adjustable-rate woodstoves. However, the ruling gives manufacturers until the end of 2015 to sell any inventory that does not meet these standards. With 2015 quickly coming to a close, it will not be long before all new wood heaters sold in the above categories will have to pass an EPA-approved compliance test.

The ruling focuses on PM emission limits that are phased in two steps. The first is a less stringent 2015 limit (2016/17 for forced air furnaces) and a secondary, more strict limit by 2020. The EPA estimates that the rule will yield $74 to $165 in benefits for every dollar spent on compliance. The EPA also encourages owners with older, less clean wood burning heaters to replace them with newer, cleaner options. For more details about the rule and compliance criteria, go to the EPA’s fact page here.

As always, please contact us with any questions you may have.

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Handy Checklist for you Annual QAQC Plan Review

airtox — Tue, 12 May 2015 15:16:48 +0000

As required by both 40 CFR 60 and 75, each facility must perform an annual review of their Quality Assurance Quality Control document. With the halfway point of the year quickly approaching, it is imperative that this process is not overlooked. There are a variety of things that need to be taken into consideration when performing this yearly review. Outlined below are items that should be investigated and confirmed in order for the QAQC plan to reflect the most accurate and up to date facility information.

CHECKLIST:

Monitor Information
- Were any monitors replaced in the past year?
- Were there any certification events in the past year?
- Did the range change on any monitor?
Limits
- Were there any changes to the permit operating limits?
- Were there any changes to the procedure in documenting and reporting excess emissions or downtime? (report format, etc)
Data Channels/DAHS
- Were there any data channels added to the DAHS?
- Were there any calculation changes to a channel? (especially one used for compliance)
- Did the data acquisition system itself change? (i.e. provider)
QA procedures
- Any changes to audit procedures and schedule?
- Any changes in staff duties and responsibilities?
Maintenance/QC procedures
- Were there any changes to calibration procedures? (how they are performed both manually and automatically)
- Changes in preventative maintenance procedure? (daily, weekly, quarterly?)
- Changes in corrective action procedure?
- Changes in spare parts list/inventory?

Other things to consider:

Regulations
- Any new regulations that affect how your facility operates?
Basic facility info
- Were there any changes in address, contact info, owner info?
Forms
- Any new forms/documentation that the facility uses for QAQC purposes?

If this checklist is followed and appropriate updates are incorporated into the QAQC plan, your yearly review will be a success. If you would like assistance of any kind in the review process, Air Tox has considerable experience in performing these for a wide range of facilities. Contact us here.

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