Air/Compliance Consultants, Inc.

1050 William Pitt Way

Pittsburgh, PA 15238
Phone: 412-826-3636

Fax: 412-826-3640

Home

Employment Opportunities

Staff Experience

Services

News Letters

Articles

Contact Us

Links

EPA Updates Coke Production Emission Factors

On May 21, 2008, EPA posted an update to Section 12.2, Coke Production, in AP-42, Compilation of Air Pollutant Emission Factors.  In this update, all emission factors were revised and new factors were added, and the industry and process descriptions were updated, primarily to provide more details on the newer non-recovery coke plants. The draft revisions went through the public review and comment process, and all comments, responses, and subsequent revisions are discussed in the background report.

The new section and the updated background documentation are available from the CHIEF web site at: http://www.epa.gov/ttn/chief/ap42/ch12/index.html

Notice of Broadly Applicable

Alternative Test Method Approval

This notice announces broadly applicable alternative test method approval decisions that the Environmental Protection Agency  has made under and in support of the New Source Performance Standards and the National Emission Standards for Hazardous Air Pollutants.  Although we have made both site-specific and . . . continued

EPA proposes residual risk reviews for eight new source categories

On Dec. 12, 2007, the EPA announced a proposed rule and requested comment on the residual risk and technology reviews for eight industrial source categories regulated by four national emission standards for hazardous air pollutants (NESHAP). [72 FR 70543]

The eight industrial source categories and the four national emission standards are:

1. Polysulfide rubber production
2. Ethylene propylene rubber production
3. Butyl rubber production
4. Neoprene production
5. Epoxy resins production
6. Nonnylon polyamides production
7. Acetal resins production, and
8. Hydrogen fluoride production.

The EPA proposed that no revisions to the national emission standards regulating the eight source categories listed above are required at this time under Clean Air Act Sections 112(f)(2) or 112(d)(6). Comments must be received on or before Feb. 11, 2008.

Big Changes in Mercury Control

When the Clean Air Mercury Rule (CAMR) was vacated by a Federal Court on February 8, 2008, it set in motion a number of activities which will significantly impact the power plants and the suppliers.  Decisions already made must be reviewed and flexibility initiated to cope with the uncertainties.  Since many expensive projects are underway, and since it may be months or years before a clear federal program is instituted, it will be necessary to continually monitor developments.

The McIlvaine Company is advising power plants on this subject in a service entitled Power Plant Air Quality Decisions.  It is advising suppliers in the Utility Environmental Upgrade Tracking System and in Mercury Air Reduction Markets. The consequences and problems which are created are substantial.

1. The ruling by the Court was broad and reinstates coal-fired power plants as toxic emitters.  Since virtually every plant exceeds the toxic threshold with HCl, it will result in Best Available Control Technology (BACT) at every plant.
2. The present burden is on the states and many are proceeding with mercury control programs which will be relatively unaffected by the court decision.
3. New coal-fired plants under construction or planning will have to revise permits as the mercury New Source Performance Standard (NSPS) is also vacated.  However, most of the permits reflect stringency far beyond the NSPS.  However, the challenge may only be procedural.
4. The CAMR monitoring program is well underway with most utilities already purchasing mercury monitoring systems in anticipation of reporting requirements starting next year.  The monitoring rules were also vacated.  Hence, a week by week scrutiny of developments in this area will be needed.
5. Particulate air toxics will now have to be monitored in one form or another.  CAMR disregarded particulate mercury as inconsequential.  This dismissal may no longer be possible and, at the very least, could result in frequent stack testing.
6. Multi-pollutant control coordination will likely become more important.  In addition to mercury, selenium, cadmium, lead, chromium and other metals will need to be considered.
7. Senator Carper with bipartisan support is initiating a bill which would require mercury control of at least 90 percent at each plant with a proposal date of October 2008.  Thus there is at least the possibility of fast track regulation in 2009 and possible impact on small boilers in the 2010 timeframe.

For more information on McIlvaine services on these subjects, click on:

Power Plant Air Quality Decisions: http://www.mcilvainecompany.com/brochures/energy.html#44i ,

Utility Environmental Upgrade Tracking System: http://www.mcilvainecompany.com/brochures/energy.html#42ei ,

Mercury Air Reduction Markets: http://www.mcilvainecompany.com/brochures/air.html#n056 .

. . . QSTI Exams!. . . .

As of March 18, 2008, several ACCI personnel have taken the Source Evaluation Society (SES) Qualified Source Testing Individual (QSTI) - Congratulations to Bill Cowell, Mike Matvey, Bill Ondriezek, Josh Varner, Jaimes Contreras, Eric White,

Todd Haas, and Rich Williams.

PSD Reconsiders Inclusion of  Fugitive Emissions

"On December 31, 2002, we (the EPA) issued our final New Source Review (NSR) Improvement Rule which, among other things, requires all sources to include ‘‘fugitive emissions’’ in assessing whether a proposed physical or operational change qualifies as a ‘‘major modification’’ that is subject to review under major NSR. On July 11, 2003, we received a petition for reconsideration on behalf of Newmont .  .  .  . continued

Technical Support for Clean Air Interstate Rule (CAIR)

Are you ready for the monitoring requirements in the Clean Air Interstate Rule (CAIR)?  The deadlines are coming fast – January 1, 2008 for year-round reporters and May 1, 2008 for ozone-season reporters.  Most are required to begin reporting on January 1, 2008.

ACCI can assist you in preparing or updating Monitoring Plans, certification testing and preparing the appropriate test notices to meet Part 75 requirements.   Monitoring Plans are required at least 45 days before certification testing begins – which could mean as early as September 2007. . . . continued

  Revision to Definition of Volatile Organic Compounds— Exclusion of HFE–7300

"This action revises EPA’s definition of volatile organic compounds (VOC) for purposes of preparing State implementation plans (SIPs) to attain the national ambient air quality standards (NAAQS) for ozone under Title I of the Clean Air Act (CAA)". . . . . . . continued

EPA Accepts Alternate Test Methods

"This notice announces broadly applicable alternative test method approval decisions that the Environmental Protection Agency has made under and in support of the New Source Performance Standards and the National Emission Standards for Hazardous Air Pollutants". . . . . .continued

 Update on PADEP CSMM Revision 8

The latest news is that PADEP hopes to post Revision 8 to the Continuous Source Monitoring Manual (CSMM) in the next month or so.  They plan to host workshops in early 2007 in each region.  Sources will most likely be required to utilize the new requirements and software changes by the 4th quarter of 2007 or 1st quarter of 2008.  We’ll keep you posted!

 Methods for Measurement of Visible Emissions

SUMMARY: This action finalizes Methods 203A, 203B, and 203C for determining visible emissions using data reduction procedures that are more appropriate for State Implementation Plan (SIP) rules than Method 9, the method currently used. This action was requested by the States and is needed for the special data reduction requirements in their rules.  The intended effect is to provide States with an expanded array of data reduction procedures for determining compliance with their SIP opacity regulations.  In addition, this action amends various testing provisions in the New Source Performance Standards (NSPS) to correct inadvertent errors and amend a testing provision.  This final rule is effective on September 21, 2006.

 Compliance News

EPA and U.S. Customs and Border Protection have seized and prevented the import of over 11,000 pieces of illegal gasoline and diesel-powered vehicles and equipment in the past nine months.  EPA has assessed over $798,000 in civil penalties against the importers, in addition to U.S. Customs penalties and storage fees. The substandard equipment, which includes tractors, lawn and garden equipment, off-road motorcycles, all-terrain vehicles and electric generators, poses a significant risk to the U.S. public health and the environment. The federal Clean Air Act (CAA) requires new gasoline and diesel engines sold or distributed in the United States to meet EPA emissions requirements to protect public health and the environment from air pollution. There has been a recent and dramatic increase in imports of gasoline and diesel equipment, chiefly from China, which do not meet these standards. For more information:  http://cfpub.epa.gov/compliance/cases/

 Clean Air Clarity May Come

Clarity to the Clean Air Act may soon come. In November, the U.S. Supreme Court will hear a case involving older coal-fired power plants and whether they have intentionally upgraded their plants under the ruse of doing routine maintenance.  The law requires utilities that modernize or upgrade their facilities to get permits and to implement modern pollution control equipment.  Utilities with a total of 51 facilities in question are now being sued by the Environmental Protection Agency.  The power companies say that they are exempt because they are just fixing their plants. http://www.energycentral.com/site/newsletters/ebi.cfm?id=200

FYI, on August 4, 2006, EPA published its Notice of Data Availability (NODA) in the Federal Register (see link) for the allocations of NOx allowances for the CAIR rule.   EPA is receiving comments/objections on or before September 5, 2006. http://www.epa.gov/airmarkets/cair/noda/index.html

EPA is Proposing to Allow Optical Methods for LDAR

For more information click on the link below.

 http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/E6-5005.pdf

Federal Register concerning reporting requirements for producers  and importers of High Production Volume (HPV) chemicals  http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/E6-13479.pdf

BACK Half Condensable PM Method Under Study 

EPA is undergoing review of EPA Reference Method 202 - the test method used for condensable particulate matter. The Method is reported to have a bias of 0.005 gr/dscf - 0.015 gr/dscf. The Proposed modification to Method 202 is supposed to reduce bias by 85% - 90%. EPA is running tests on Modified Method 202 and proposed (conditional) Method 39 to come up with an improved method.  Method 202 Improvement Project

Changes to AP 42, Fifth Edition, Volume I, Chapter 13:

Miscellaneous Sources

EPA is now accepting comments until June 16, 2006 for recent changes to Chapter 13 of AP-42.  The sections that have changed are Paved Roadways 13.2.1, Unpaved Roadways 13.2.2, Aggregate Handling and Storage Piles 13.2.4, and Wind Erosion 13.2.5.  Each section has a change in the PM_2.5 emission factor or multiplier.  These changes are a result of a wind tunnel study performed and published Feb 1, 2006.  For more information click on the link below.

 http://www.epa.gov/ttn/chief/ap42/ch13/index.html

Sharon S. Diday, Project Engineer, ACCI, 3/29/2006

Understanding Operational Flexibility Provisions in Pennsylvania

PADEP has found that the permitting operational flexibility provisions in their regulations are being underutilized, and are trying to change that.  In general, these provisions can provide the means for facilities to make certain process changes without having to go through a permit modification.  To start to educate the regulated community, PADEP has posted an explanatory summary of the operational flexibility provisions on their website, at the following address: http://www.depweb.state.pa.us/news/cwp/view.asp?a=3&q=490059.

Mark C. Schooley, Senior Environmental Project Manager, ACCI, 3/10/2006

HAP Delisting

EPA is amending the list of hazardous air pollutants (HAP) contained in Section 112 of the Clean Air Act (CAA) by removing the compound methyl ethyl ketone (aka MEK or 2-Butanone) (CAS No. 78-93-3).  This delisting is effective on 12/19/2005.

Mark C. Schooley, Senior Environmental Project Manager, ACCI, 12/19/2005

EAC Designations Deferred

EPA has extended the deferred effective date of the 8-hour ozone nonattainment designation for all 14 Early Action Compact areas until December 31, 2006.  Prior effective date was September 30, 2005.  See 68 FR 70108 or this link for more information regarding Early Action Compact areas.  http://www.epa.gov/ttn/naaqs/ozone/eac

2004 Naphthalene Classification Change

The International Agency for Research on Cancer (IARC) has evaluated naphthalene and classified it as “possibly carcinogenic to humans (Group 2B)”  Based on these classifications the de minimis level for naphthalene is lowered from 1.0% to 0.1% starting with the 2004 reporting year.

CSMM Revision 8 Coming!!

Sources in Pennsylvania should look for Revision 8 of the “Continuous Source Monitoring Manual.”  PADEP plans to release the draft “soon.”  Keep checking their web site at http://www.dep.state.pa.us/dep/deputate/airwaste/aq/cemspage/cems.htm .  Rev. 8 of the CSMM will apply to all CEMS, COMS, flow, etc. - current and future.  PADEP plans to phase in compliance with the new requirements.

 Upcoming Part 75 Audits

EPA’s Clean Air Markets Division (CAMD) has announced that they will be conducting in-depth electronic audits of 40 CFR Part 75 Appendix D (fuel flow) and Appendix E (low mass emitters) monitoring systems in the first quarter of 2006.  They will focus on the QA/QC status of the systems, including accuracy tests, transmitter calibrations, and visual inspections of Appendix D fuel flowmeters and the Appendix E emission tests.  EPA urges sources to be up-to-date in preparation for the audit.

 What constitutes a valid hour for Part 75 data?

Question 15.30 of the Part 75 Policy Manual responds that “§75.10(d)(1) states that in order to validate data for an hour, you must obtain at least one valid data point in each quadrant of the hour in which fuel is combusted.”

For hours in which quality assurance testing and preventive maintenance activities are performed, “a minimum of two data points, separated by at least 15 minutes, are required to validate the hour.”

 EPA Changing Part 75 Quarterly Reporting Architecture

EPA is currently working on a project to re-engineer the processes and data systems associated with emissions, monitoring plans, and certification data for Part 75 sources.  EPA desires to create a single application for users and eliminate the current system of ETS-FTP, ETS Mainframe, and MDC to check and submit data.  Multiple feedback reports will be eliminated.  The new application will be of XML file format.  Beta testing of the new system is scheduled for mid-2006 through 2007.  After a transition year in 2008, sources will be required to report data exclusively with the new system beginning in the 1st Quarter of 2009.  Additional information can be obtained at http://www.epa.gov/airmarkets/business/ecmps/index.html

Contact Nancy Hirko, ACCI Senior Engineer, for more information on any of the above topics.nhirko@air-comp.com or 412-826-3636