1 Title V Permitting and CAM Planning Title V Permitting and CAM Planning APPA E&O Technical...

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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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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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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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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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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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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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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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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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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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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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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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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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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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Estimating pre-control emissionsEstimating pre-control emissions

PSEU

ControlDevice

Pre-controlledEmissions

Annual emissions = restrictions X emissions rate

Post-controlEmissions

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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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Applicability Logic DiagramApplicability Logic Diagram

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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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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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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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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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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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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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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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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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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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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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Establishing Indicator RangesEstablishing Indicator Ranges

Parameter data collected during testing

Historical data

Design or engineering data

From similar operations

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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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Establishing Indicator RangeEstablishing Indicator Range

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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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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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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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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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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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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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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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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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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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