What’s in Your Dirty Laundry? Delving into The Importance of Your Facility’s Emissions Data

Adulting. A new, but effective, verb coined by young professionals (YPs) to relay their feelings about having to do grown-up things and hold responsibilities such as: a retirement fund, a mortgage, a car payment, or anything else that makes one think of grown-ups. This may seem silly to some of you, but for the more than 1/3 of ALL4 employees who fit the YP-criteria, this whole adulting thing can prove to be terrible a bit challenging. Remember, ALL4 hires engineers and scientists with impressive GPAs and outstanding work ethics. Not to toot my own horn or anything, but we’re certainly not a bunch of morons. However, most of us weren’t exactly learning a lot of “real life” skills in school like our friends studying accounting or economics (see below)…

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Seriously, though. As a group of science nerds, could anything be more relatable? But before I go any further into this rabbit hole, I feel like I need to make a couple of confessions…

  1. Back in 2013 when my Dad gave me the ol’ “you’re on your own, kid” and I had to file my taxes on my own for the first time, it ended in real, I’m-so-overwhelmed-I’m-just-going-to-cry tears. I was just about to finish college and could have given you gory details about reactor engineering, the refrigeration cycle, heat transfer, and so on, but itemized deductions? Dividends? Exemptions? No. Way. That stuff was gibberish and I was in over my head (and to be perfectly honest, I still pretty much am).
  2. Also, while writing this article, I had to reference Urban Dictionary more than once. Urban Dictionary, for those who aren’t familiar, is a website where old people (aka me, apparently) go to decipher slang like “NSFW.” It turns out NSFW means Not Safe For Work (which, coincidentally, Urban Dictionary probably is). So, clearly I am not as young and hip as I like to think I am.

Stick with me – I swear I have a point.

I’ve been giving this whole thing a lot of thought and I have a theory that some of you might be able to relate to No. 1 above. For me, its taxes, credit scores, interest rates, etc. etc. – I know it’s out there… I know it probably definitely matters and will affect me significantly down the road. But it’s also confusing, overwhelming, and, honestly, more easily ignored. For you, is it Continuous Monitoring Systems (CMS) data? Is it the way your Data Acquisition and Handling System (DAHS) is processing and validating your CMS data? What about U.S. EPA’s new Electronic Reporting Tool (ERT)? Is there something at your facility that you’re treating like a pile of dirty laundry that you can just throw in the closet and slam the door before it all comes tumbling out?

Unfortunately, just like my credit score is and will continue to be important, the data at your facility is, too. We are in the middle of the shift to electronic reporting (or “e-reporting). This means that it is now much easier for U.S. EPA, your state agency, the public, or whoever feels like it to take a gander at your CMS data, performance test results, compliance reports, emissions reports, and anything else submitted on U.S. EPA’s Central Data Exchange (CDX) using the Compliance and Emissions Data Reporting Interface (CEDRI). And, not only will regulators take a look at it, but they will scrutinize it and use it to develop emissions factors, influence future rulemaking, and possibly even issue enforcement actions.

BUT, lucky for you, ALL4 is not-so-afraid of this stuff. You can think of us like the Dad that doesn’t kick you to the curb (love you, Dad). We’re here and ready to help you understand the ins and outs of your data and make sure that it is thorough, accurate, and submitted on-time in the correct format.

So, while the YPs at ALL4 are working on the whole #AdultingAndConsulting thing (shout out to Matt Wolf!), maybe this is a good time for you to brush up on your data (you may discover that it’s time to make a change!). If you’d like to chat about CMS/CEDRI/environmental data, or if you just want me to send you more funny memes like the one above, feel free to give me a call at 678-460-0324 x213!

Telling You Like It Is, Your CEMS are NOT Ready for PA RACT 2 Compliance!

What started as a blog, has turned into an article written like a blog. We call it a “Blogicle.” There is just too much information to share on complying with Pennsylvania Department of Environmental Protection’s (PADEP’s) RACT 2 Rule using Continuous Emissions Monitoring Systems (CEMS). ALL4 has been providing you information on RACT 2 (published final on April 23, 2016) since July 2014 and keeping you up–to-date with dozens of blogs, articles, and training sessions since then (check out our RACT 2 page here for the entire suite of information on RACT 2). Consistent with always thinking one step ahead, ALL4 is already working well past RACT 2 applicability and initial compliance strategies to how ongoing compliance will be demonstrated specifically using Continuous Monitoring Systems (CMS), including CEMS.

Regardless of whatever else you take from this Blogicle, the one thing that you must take away is this:

  • If CEMS are part of your RACT 2 compliance strategy, then you will be required to make changes to your data acquisition and handling system (DAHS) and in Pennsylvania’s Continuous Emissions Monitoring Data Processing System (CEMDPS).

Most of these changes will be substantial, involving calculations and reporting functions. Other changes could require revisions to emissions limits or certification of additional CMS. To set the stage, many facilities will be determining a presumptive or case-by-case emissions standard for nitrogen oxides (NOX) (most likely expressed as lb/MMBtu on a 30-operating day average). “No worries,” you may say, “I already submit quarterly reports via CEMDPS for a certified NOX lb/MMBtu CEMS. Once submitted, PADEP will just average the hourly values for the previous 30-operating day average to assess compliance with my RACT 2 emissions standard. Right?” Not so fast my friend, what you currently measure is an hourly NOX emissions rate (i.e., average mass of NOX emitted per MMBtu) that cannot (on its own) be used for RACT 2 compliance.

Determining Compliance using CEMS the RACT 2 Way

RACT 2 requires compliance with NOX lb/MMBtu emissions standards much like the quantification of NOX emissions for trading programs. You first must quantify the sum of the NOX mass emissions (i.e., lbs) measured over the previous 30-operating days. Then you divide by the total heat input (i.e., MMBtu/hr) measured over the same previous 30-operating days. What does this mean? For the first time ever you will be reporting the mass (i.e., lbs) of NOX emitted in the hour in your quarterly report. Consider this, if you have an emissions rate of 100 lb/hr and you only operate for 30 minutes in that hour, you have only emitted 50 lbs of NOX in that hour. The result is that operating time (fraction of an hour) will have to be included in your calculation when reporting hourly NOX mass emissions. Since we are quantifying mass emissions we also most consider missing data procedures for periods when the CEMS are down and the unit is operating. Where typically missing data are used for compliance with annual ton per year (tpy) limitations (or trading programs), it will now be used to assess compliance with a shorter term 30-operating day average as required by RACT 2.

It may be a good time to review your missing data substitution options and potentially prepare petitions for consideration by PADEP for missing data procedures that better suit your facility’s operations. Poor foresight here could result in future compliance issues. As a quick example, the PADEP’s Continuous Source Monitoring Manual Revision 8 (CSMM 8) approved missing data procedures require the use of the highest value recorded during the reporting period for each minute during which CEMS data are not available and you are subject to monitoring. Hypothetically, what if you combusted oil during a reporting period, measured higher NOX emissions, and are required to substitute for missing CEMS data while combusting natural gas (where you would expect lower NOX emissions)? You may be substituting data that are not representative of the operating conditions. What about data collected during startup/shutdown? Should that data be used to potentially substitute data collected during normal operating scenarios? The point is, there are a lot of things to carefully consider here!

Let’s say we have the NOX mass emissions calculations figured out so we can move on to quantifying heat input (i.e., MMBtu). Many of you may be using a NOX concentration, diluent, and F-factor to determine NOX lb/MMBtu. You cannot quantify mass without either a certified stack flow monitor or a certified heat input CMS. Don’t have either? Or maybe your heat input CMSis certified only under 40 CFR Part 75 and not CSMM 8? ALL4 has been working with PADEP to seek resolution on exactly “What constitutes a CEMS under RACT 2?” Did PADEP intend that RACT 2 would require facilities to install additional CMS to meet RACT 2 or can facilities opt to use stack testing to demonstrate compliance unless all CMS components are currently certified under CSMM 8? Keep checking in with us on this one, there will be more information over the next couple of weeks as we continue to work with PADEP on the use of CMS to demonstrate compliance with RACT 2.

Wait a Minute, CEMDPS Can’t Handle Data the RACT 2 Way?

That is correct. Currently CEMDPS cannot calculate emissions from multiple Emission IDs to determine compliance… but it will. PADEP is moving towards implementing these changes to CEMDPS to allow for facilities to report separate Emission IDs for NOX mass (lbs in the hour) and heat input (MMBtu in the hour). Then CEMDPS will use these Emission IDs to assess compliance on a 30-operating day average. I am trying not to bring up timing, but let’s just say that the updates to CEMDPS are complicated with not a lot of time to complete. Not to mention that every facility using a CEMS to demonstrate compliance with RACT 2 will have to construct a Phase I – Monitoring Plan (MP) (a whole other issue) and complete the required Phase II/III certification activities (including a DAHS Verification). (See below, “Phase I Monitoring Plans – A Whole Other Can of Worms“.)

Do you have a turbine with a concentration based RACT 2 emissions standard (i.e., ppmvd @ 15% O2)? You’re not off the hook either. Where numerically your limits may be lower, it may not include all the data that RACT 2 requires to demonstrate compliance. The RACT 2 emissions standard for combustion turbines includes startup and shutdown, your current limit may have alternative startup and shutdown work practice standards allowing for those operational states not to be included in the current compliance average. It is anticipated that Emission IDs will be created specifically for RACT 2 emissions standards. We do not want to streamline emissions standards here – no sense being out of compliance with a lower, short-term emissions standard without separately determining if you were out of compliance with the higher, longer-term RACT 2 emissions standard. Remember that CEMDPS can only assess compliance with a single emissions limit per Emission ID. You may end up submitting the same data for multiple Emission IDs in order to assess compliance with a RACT 2 and non-RACT 2 emissions standard. Cement kilns, glass manufacturing plants, and any other facilities with a “lb of pollutant per ton of product” (clinker, glass pulled, lime, etc.) that utilizes CEMS are on deck. Production Emission IDs will now be possible. RACT 2 emissions standards for cement kilns (lbs NOX/ton of clinker) will be possible in CEMDPS. Even emissions averaging under RACT 2 can be administrated with the addition of Emission IDs and functional upgrades in CEMDPS. A heat input CMS and emissions factor is all that you need to for CEMDPS to average multiple units across a single facility.

I Picked Myself Off the Floor, What Should I be Doing Now?

Nothing is in the way of you getting started on determining how ongoing compliance will be demonstrated under RACT 2 (especially using CEMS). Decisions need to be made, correspondence with PADEP may be needed, your DAHS will need to be upgraded, Phase I Monitoring Plans need to prepared and submitted, and ducks need to be lined up (in a row).

This is complicated stuff with a lot of moving parts. Want to talk it through? We would love to hear your concerns so that we can continue to shape the use of CMS to demonstrate compliance with RACT 2. ALL4 has been working on it. We’ve been, making you aware; and we will continue to be all over it. Give me a call to discuss your specific example at (610) 933-5246 extension 117 or email Eric Swisher at eswisher@all4inc.com.

Phase I Monitoring Plans – A Whole Other Can of Worms

So now you understand that maybe RACT 2 compliance isn’t going to be as easy as you once thought, but it still sounds like all you need to do is update and re-submit a couple of CEMDPS plans. Have you completed a PADEP Phase I MP recently? If so, you may have realized that a lot of effort goes into compiling the required information and figuring out how to get it entered correctly into CEMDPS with the least amount of rejections. Haven’t done a Phase I MP recently, but plan on using CEMS to demonstrate compliance with RACT 2? You may be in for a surprise when you attempt to obtain Phase I approval through the online system.

If you plan to demonstrate compliance with RACT 2 using CEMS, a Phase I MP will be required to get the RACT 2 specific emissions results into CEMDPS (e.g., NOX lbs, heat input, etc.). Also, any other associated changes, including the addition of analyzers, will need to be addressed too. If you haven’t submitted a Phase I MP through CEMDPS in accordance with CSMM 8 yet, there will likely be a larger effort ahead of you. Hardcopy Phase I MPs that were previously submitted to PADEP have not been fully transferred into the online system. What does that mean for you? You may need to dig up old submittals and information, seek out new information, and update old documents in order to complete all the information as part of this new Phase I MP submittal.

Here at ALL4, we’ve been pulling together Phase I MPs for multiple clients and compiling tips and tricks to complete Phase I MPs with the minimum amount of rejections. Yes, this is the second time I’m mentioning rejection. It’s a scary word, but essentially it is just the method used by PADEP to request changes and/or additional information. It is a part of the process and should be expected (although the rejection emails still don’t feel good). We have been learning through the process what information should be provided and how it should be provided in order to minimize those rejections. Understanding the organization and intricacies of CEMDPS as well as the steps that need to be taken to make different types of changes is critical when submitting an acceptable Phase I MP.

To give you an idea of the things that should be considered, here are a few pieces of information that you will need to obtain, update, and/or develop:

  1. Quality Assurance/Quality Control (QA/QC) Plan
    Your facility will need to make sure the QA/QC plan that is submitted is complete and updated (including CSMM 8 requirements). These plans are now under more scrutiny than in the past and PADEP will be performing a detailed review of the document to ensure it is adequate.
  2. Electronics Checklist
    This is a checklist used by instrument technicians for periodic checking of the measurement device(s). CSMM 8 requires this checklist to be submitted as part of the Phase I MP and it may be hard to find. It may be included with manufacturer’s information, in an Operations & Maintenance (O&M) Plan, or may need to be developed.
  3. Process Flow Diagram
    A process flow diagram is required to be submitted as part of the Phase I MP and needs to include specific process distances required by CSMM 8. Do you know the distances upstream and downstream from the CEMS? How about the distance the probe is in the stack? These distances, as well as several others, are required and will need to be determined or verified.
  4. Lowest Monitored Emission Standard Equivalent (LMESE)
    Do you know how to calculate this and/or where to find guidance on how to calculate it? Do you have documentation showing this calculation? PADEP has been requesting documentation of how the LMESEs are calculated, so you should be prepared to provide it.
  5. New Emission Results
    Do you know how to create a new Emission Result in CEMDPS? How about how to associate the CEMS correctly and also fill in information regarding data availability and penalty information? New emissions results will need to be added for RACT 2, so this process will need to be understood to reduce the likelihood of rejection.
These are just a few of the considerations when beginning to prepare a Phase I MP through CEMDPS. ALL4 has experience with this process and can help your facility navigate the requirements, with the least amount of headaches. Reach out via email Megan Stroup at mstroup@all4inc.com or by phone (610) 933-5246 extension 140 if you have any questions or would like more information.

You Talkin’ about QA/QC Plans? – Are your plans and procedures “Up to Snuff”?

Do you operate a CEMS to comply with a State or Federal emissions limitation? If so, you know the importance of ongoing QA procedures in maintaining the accuracy of the CEMS and representativeness of the data being collected. In most instances, ongoing QA procedures are performed by your plant instrument technicians. In other instances, these procedures are performed by a contracted instrument technician. Either way, it is critical that both the plant and instrument technician (internal or externally contracted) understands the regulatory backbone behind the QA procedures being performed. Why? Depending on the regulatory program or programs which require your plant’s CEMS, the ongoing QA procedures associated with each CEMS vary in often times subtle, but other times not so subtle, ways.

For example:
Your plant utilizes a NOX CEMS to comply with a PADEP emissions limitation, as well as a 40 CFR Part 60 (New Source Performance Standards or “NSPS”) emissions limitation from an applicable subpart. To be in compliance with both regulations (i.e., PADEP and Part 60), you must meet, at a minimum , the QA requirements required by CSMM 8 and 40 CFR Part 60, Appendix F, Procedure 1 (Appendix F). What QA procedures should you utilize on the NOX CEMS to maintain compliance with both CSMM 8 and Appendix F?

The correct answer is both, and although CSMM 8 and Appendix F require similar ongoing QA activities, the intricacies of the references, tolerances, and frequencies required under the two regulations differ and intersect in multiple ways that can often times be overlooked. How so, you may ask? Let’s take a quick look at our quarterly QA activities required under both requirements.

CSMM 8 requires a quarterly 3-point linearity test (LT) that utilizes low (between 0 and 30% of measurement range), mid (between 50 and 60% of measurement range), and high (between 80 and 100% of measurement range) reference gas concentrations. Part 60 requires a quarterly 2-point cylinder gas audit (CGA) that utilizes low (i.e., 20-30% of span) and mid (i.e., 50-60% of span) reference gas concentrations. The principles of both tests are similar, but should you be performing the 3-point LT, the 2-point CGA, or both, on a quarterly basis? If you are subject to both the monitoring requirements of CSMM 8 and Appendix F, you must satisfy both requirements by conducting the 3-point LT required under CSMM 8 and a 2-point CGA. A well-developed QA/QC plan may be able to find a “sweet-spot” where one set of tests should meet both the LT and CGA requirements. The development of the QA procedures may also identify the need to petition U.S. EPA to accept the LT required by CSMM 8 in lieu of the CGA required by Appendix F.

Simple enough? Let’s take this a little further to make sure we’re all on the same page. The Appendix F CGA must be performed three calendar quarters per year, with a relative accuracy test audit (RATA) in the fourth non-CGA calendar quarter. CSMM 8 requires a LT to be performed in each operating quarter that the unit operated for more than 168 hours. If we followed Appendix F guidance, we would have missed a quarterly LT required by CSMM 8, thus causing an entire quarter (or more) of data to be invalidated.

OK, I got it…we have a few discrepancies to keep tabs on, how bad can it really be? Well this example simply highlights some of the key differences in quarterly QA requirements between PADEP and Federal (i.e., Part 60/ Appendix F and even Part 75) QA requirements. We have yet to address (and we won’t in this blog) the discrepancies in the required daily and annual QA activities, nor additional overlapping requirements that could come as a result of being subject to 40 CFR Part 75 NOX monitoring. Furthermore, these conflicting QA requirements also apply to the ancillary monitoring systems that are depended upon by the primary CEMS (e.g., an O2 continuous monitoring system for O2-corrected emissions limitations).

The point is that overlapping regulatory requirements related to CEMS occur more frequently than not, and the presence of these requirements is only increasing as new regulations are promulgated (e.g., PADEP’s recently promulgated RACT 2, which is a whole different headache). Whether these overlaps arise as a result of intersecting State and Federal requirements (as demonstrated in the example above), or multiple Federal requirements, the take-home message is clear: From the plant manager, to the instrument technicians performing QA activities, know what you are monitoring, know why you are monitoring, and know how you are demonstrating compliance with your QA activities!

If you feel your QA procedures may not be “up to snuff,” ALL4 has experience in identifying potential issues, working through any found issues, and communicating with agencies to navigate through the regulations and bring you into compliance. Reach out via email to Matt Carideo at mcarideo@all4inc.com, or by phone (610) 933-5246 extension 139 if you have any questions or would like additional information.

Ethylene MACT ICR Component II: It’s Here! What’s Your Game Plan?

The long awaited Component II of U.S. EPA’s Ethylene Production Section 114 Information Collection Request (ICR) has been issued. Ethylene production facilities were issued Component I in July 2014 with the ‘promise’ of an upcoming Component II to collect test data from certain operations. U.S. EPA has delivered on their promise! (see ALL4’s August 2015 and April 2016 4 The Records: Ethylene Production – A Tale of Explosive Growth and Air Quality Compliance and The Ethylene MACT – An Air Quality Compliance Marathon, respectively). Twenty-one ethylene production facilities are required to perform emissions testing on ethylene cracking furnaces, decoking operations, as well as heat exchange systems. If that weren’t enough, facilities are also required to provide historic test data, continuous emissions monitoring system (CEMS) and continuous monitoring system (CMS) data.

So, you’re an environmental manager at an ethylene manufacturing facility or perhaps your role is corporate support for a number of facilities. If I was a betting person, I’d say your plate is likely already too full and you’re not really looking forward to the next 6 months of “Ethylene ICR To Dos.” Let’s break down the ICR and answer the following questions and in doing so, I’ll throw in a few watchouts to be aware of:

  • What are the testing requirements?
  • What historic test data do I need to submit?
  • What historic CEMS and CMS data do I need to submit?
  • What are the due dates and how do I submit?
  • What’s my game plan?

What are the testing requirements?

Facilities are required to select one furnace and decoking operation to test for a variety of pollutants. U.S. EPA breaks them into two categories (A and B) and they range from aldehydes, organic hazardous air pollutants (HAPs), polycyclic aromatic hydrocarbons (PAHs), and total hydrocarbons (THCs) to ammonia (NH3), nitrogen oxides (NOX), filterable particulate matter (PM), metal HAPs and hydrogen cyanide (HCN). (refer to the ICR for the complete list). As with any test program there are a few watchouts to be aware of:

  • U.S. EPA establishes required methods for each pollutant/pollutant family. However, U.S. EPA provides alternative methods as well. For certain pollutants, CEMS data can be used but only if properly certified per 40 CFR Part 60 Appendices B and F.
  • A minimum of seven valid test runs are required for furnaces and three valid test runs for decoking operations (based on three decoking cycles).
  • Testing of each of the pollutants is to be conducted simultaneously unless it’s not possible due to duct diameter or sampling port constraints. In this case, facilities can test sequentially provided all Category A pollutants are tested for at the same time and all Category B pollutants are tested for at the same time.

Heat exchange systems requirements are two-fold: concurrent water sampling and analysis and air sampling. The procedures to follow in Component II are driven based on a facility’s Component I sampling and analysis reporting (i.e., Modified El Paso Method or an alternative). Facilities are required pick one heat exchange system and test for organic volatile HAP, ethylene/propylene, organic semi-volatile HAPs, chlorine, and total strippable VOC (as methane).

A few additional testing watchouts:

  • Test plans do not need to be submitted to U.S. EPA if using the methods prescribed. However, a test plan is encouraged for onsite coordination and if facilities are proposing an alternative method permission must be sought from U.S. EPA.
  • If you’ve tested recently for the pollutants identified and per the test conditions, you may be able to use this test data in lieu of testing again.
  • With all three unit types, U.S. EPA is asking for considerable process parameter data to be collected during the tests. It’s important to make sure that all the data requested are properly collected during the test programs. Prior to testing, facilities should make sure they are actually monitoring these data and have the means to record this data during testing.
  • Guidance is provided for calculating and reporting values measured below detection limits.

What historic test data do I need to submit?

While the testing requirements gave facilities the choice in furnaces and decoking operations to test, historic data need to be provided for each furnace and decoking operation affected by 40 CFR Part 63 Subpart YY [National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories: Generic Maximum Achievable Control Technology Standards (MACT)]. The most recent stack test for criteria and/or HAP which occurred between January 1, 2010 and December 31, 2015 must be submitted. If any pollutant CEMS data were gathered during the test, it must be submitted with the report.

For heat exchange systems affected by 40 CFR Part 63 Subpart XX (NESHAP For Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations), historical sampling and analysis data used to demonstrate compliance with 40 CFR §63.1086 and any state rules (e.g. 30 TAC Chapter 115) must be submitted for the time period January 1, 2013 through December 31, 2015. U.S. EPA specifies seven items to be included.

What historic CEMS and CMS data do I need to submit?

U.S. EPA is requiring facilities to submit CEMS and/or CMS data for any furnaces and decoking operations as part of the ICR. Specifically, facilities are required to submit hourly averages from January 1, 2015 through December 31, 2015 for ammonia, NOX, oxygen (O2), carbon dioxide (CO2), and carbon monoxide (CO). With these data, operating modes of the units must also be identified (e.g., Normal Cracking, Decoking, Startup and Shutdown, Malfunction, Hot Steam Standby, Feed In/Feed Out).

What are the due dates and how do I submit?

U.S. EPA establishes a sliding scale, albeit a short one, for due dates with the first due date in 2 months for historic data and wrapping up with stack test emissions data for furnaces and decokers 6 months from now. I hear ya, there’s a lot of work to be done and that’s not much time! The table below identifies the specific requirement, due date and submittal format:

A few watchouts regarding due dates and submittal of data:

  • Emissions test results for crackers and decokers are submitted via ERT for applicable pollutants/test methods (currently PAHs, THC, FPM, Metal HAP, O2, CO2, moisture, CO, and flow rate). ERT is part of U.S. EPA’s Central Data Exchange (CDX) and is a Microsoft Access based system (see ALL4 blog: ERT and CEDRI: What the Heck Is It and How Does It Impact You?). ALL4 recommends that you plan accordingly for use of ERT. ERT will require the download of software, use/knowledge of the system and workarounds for ERT nuances, quality assurance (QA) of data that ERT calculates based on your inputs, considerable time and resources (e.g., facility personnel, stack test firm, consultant), etc. Additionally, there are no ‘optional’ test data and as a result all data fields in the ERT are required fields.
  • For data that must be submitted via U.S. EPA Excel Templates, be aware that certain fields have been prepopulated with dropdown choices and shaded where U.S. EPA is requesting data. ALL4 suggests knowing what information they are requesting and evaluating whether you are currently collecting this data and/or if your data fall into their predefined categories.
  • For all files, U.S. EPA has established a naming convention for facilities to follow upon submittal of data. Upon the last submittal, a responsible official will be required to sign off on all data submitted via a certification statement.
  • Data can be submitted via upload to the Ethylene 114 website, email and/or mail. Should you have confidential business information (CBI), there are specific instructions for identifying and submitting this data.

What’s my game plan?

This blog just skims the surface of the requirements of the Ethylene MACT ICR. There are many particulars involved with a proper and timely submittal to U.S. EPA: lots of data to collect, measure, record, analyze, review, quality assure and submit. With due dates every 2 months for the next 6 months, you have your work cut out for you. You need an ICR Game Plan! Here are a few things ALL4 suggests you consider:

  1. What resources do I have internally? What external resources do I need to utilize? Have I allocated budget for the ICR?
  2. What furnace/decoker am I going to test? What heat exchange system am I going to test?
  3. Who’s going to test the units and when? Who’s going to manage the program? Who’s going to collect the process data? Who’s going to compile, QA, and submit the test data (in ERT and U.S. EPA’s spreadsheets)?
  4. What historic data (stack test, CEMS, CMS) do you have for all of your subject furnaces, decokers, heat exchange systems? Who’s going to gather it, review it, compile it, upload it, submit it?

ALL4 has been intimately involved with many ICR responses for a variety of industries from polyvinyl chloride to pulp and paper, to medical waste and power. Our efforts span:

  • Development of testing programs for ICR and regulatory purposes
  • On-site testing program management
  • Compilation of ICR data and submittal data to U.S. EPA
  • ERT and CEDRI reporting

Need help with your ICR Game Plan? Have further questions about the Ethylene ICR? Reach out to Kristin Gordon (kgordon@all4inc.com or 281.937.7553 x301).

U.S. EPA Issues Draft Information Collection Request for Existing Oil & Gas Facilities

On May 12, 2016, the U.S. Environmental Protection Agency (EPA) issued a draft Information Collection Request (ICR) that when final, will require existing oil and natural gas facilities to provide extensive information on facility operations. The U.S. EPA has deemed this information as necessary to develop regulations to reduce methane emissions from the oil and gas industry. The issuance of the draft ICR follows the U.S. EPA’s initial announcement in March 2016 to take steps to regulate existing sources of methane emissions in the oil and natural gas industry. If you are not familiar with the March 2016 announcement, here is ALL4’s takeaway.

U.S. EPA’s goal is to gather a comprehensive range of information to determine the best approach to accurately and cost-effectively locate, measure, and mitigate methane emissions. The ICR will be applicable to onshore production; gathering and boosting; gas processing; transmission; storage; and import/export facilities, and is comprised of two (2) parts:

  1. Operator Survey – The survey is designed to obtain general information from onshore petroleum and natural gas production facilities. Information requested by the Operator Survey will include facility-level information (e.g., facility name, location, and contact information), as well as the quantities and types of equipment present at the facility.
  2. Detailed Facility Survey – A statistical approach will be utilized to select a representative sample of oil and natural gas facilities to participate in Part 2 of the ICR. If selected, the facility will be required to provide detailed information on its emissions sources and emissions control practices within 120 days.

The draft ICR will be available for Public comment shortly. Visit the Federal Register for more information regarding specific review periods. If you have any questions about this blog or other actions surrounding the oil and gas industry, feel free to contact us.

U.S. EPA Issued Final Updates to the Suite of Methane Rules for the Oil & Natural Gas Industry

On May 12, 2016, the U.S. Environmental Protection Agency (EPA) took a huge step forward with their plan to reduce methane emissions from the oil and natural gas industry. This “huge step forward” was the issuance of three final rules.

  1. Updates to 40 CFR Part 60, Subpart OOOO and establishment of 40 CFR Part 60, Subpart OOOOa
  2. Source determination rule (aka the meaning of the term adjacent)
  3. Federal Implementation Plan for U.S. EPA’s Indian Country True Minor Sources

The actions above should not overshadow the fact that U.S. EPA also issued the draft Information Collection Request (ICR) for the oil and natural gas industry on the same day. ALL4 posted a blog in April 2016 that announced the ICR was looming. We also posted a follow-up blog that provides hyperlinks to the draft ICR just issued by U.S. EPA. Go ahead and click the links above to check them out.

If you find yourself forgetting the details of the three rules listed above and need to take a stroll down memory lane, ALL4 can help you with that. We published several blogs on our website about the various draft rules and comment periods. They are conveniently located on our Oil and Gas Sector Initiative page. Go ahead and explore the page while you are thinking about it.

The remainder of this blog touches on Subpart OOOO, OOOOa, and the Source Determination rule. Note that the preamble and final rules for these two actions are a combined 648 pages. This few hundred word blog is only going to be the tip of the iceberg. However, it provides essential links to prepublication versions as well as one click access to a library of related content.

Subpart OOOO & OOOOa News

  • Amended Subpart OOOO applies to facilities constructed, modified, or reconstructed after August 23, 2011 and on or before September 18, 2015.
  • Subpart OOOOa was added and applies to facilities constructed, modified, or reconstructed after September 18, 2015.
  • Final rule is effective 60 days after the date of publication in the Federal Register. (Are you ready for this?)
  • U.S. EPA’s fact sheet quotation “EPA’s final rule will get more methane reductions than estimated at proposal because of changes made in response to the more than 900,000 public comments…” The following changes are cited by U.S. EPA as contributing to the increased methane reductions:
    • The final rule requires low production wells to monitor leaks while the proposed rule exempted them.
    • The final rule requires compressor stations to monitor leaks four times a year while the proposed rule required monitoring twice a year.
  • U.S. EPA’s short list of changes made to the final rule as a result of public comments:
    • Fixed schedule for leak monitoring while the proposed rule established monitoring based on performance (e.g., Well Sites: semiannual leak monitoring and up to one year to complete the initial survey).
    • Final rule allows Method 21 (aka sniffer) as an alternative to optical gas imaging with a repair threshold of 500 ppm.
    • Final rule also allows other technologies to monitor leaks. However, Agency approval is required for other technologies.
  • U.S. EPA clarified that annual reports are due January 13 of each year.
  • Subpart OOOO is one of the rules potentially affected by the proposed “Electronic Reporting and Recordkeeping Requirements for New Source Performance Standards” (80 FR 15099, March 20, 2015). Owner/operators would be required to use Compliance and Emissions Data Reporting Interface (CEDRI) for the subpart or an alternate electronic file format consistent with the form’s extensible markup language (XML) schema.
    • Take note that ALL4 has been busy providing electronic reporting (e.g., CEDRI) consulting assistance to the Cement and Refinery industries. Check out this blog to learn more about CEDRI and electronic reporting.
  • Final rule requires a monitoring plan that covers the collection of fugitive emissions components at well sites or compressor stations within a company-defined area. The proposed rule required “corporate-wide and site-specific monitoring plans.”

Source Determination News

  • Final rule is effective 60 days after the date of publication in the Federal Register.
  • The final definition is based on the proximity of emitting activities and consideration of whether the activities share equipment. Specifically,
    • U.S. EPA selected ¼ mile as a “bright line” distance for clarifying the meaning of “adjacent”.
    • Emitting equipment located on separate surface sites within ¼ mile of each other would only be aggregated as a single stationary source if the emitting equipment also has a relationship that meets the “common sense notion of a plant.”
      • Shared equipment necessary to process or store oil or natural gas will be aggregated within the ¼ mile.
      • Two well sites that feed to a common pipeline are not considered to be part of the same stationary source if they do not share any processing or storage equipment between them.
  • The U.S. EPA is adopting this revised definition in the regulations that apply to permits issued by the U.S. EPA and states to which the U.S. EPA has delegated federal authority to administer these programs.

If the above U.S. EPA actions aren’t enough excitement for you (sarcasm), the U.S. EPA anticipates issuing final Control Techniques Guidelines (CTG) for reducing VOC emissions from existing sources later this spring. ALL4 will remain vigilant and keep you informed when it happens.

As always, ALL4 is rolling up the sleeves and digging into these final rules to continue to stay ahead of this ever changing subject matter. Help is only a phone call or email away. My contact information is (610) 933-5246, extension 120 or jkleinle@all4inc.com.

The Dos and Don’ts of Meteorological Monitoring

One of the service areas ALL4 provides our clients is the setup, maintenance, and breakdown of meteorological monitoring towers.  For some, on-site meteorological data are required for air dispersion modeling demonstrations; for others, meteorological monitoring data are required as part of a regulation (e.g., the Refinery Sector Rule’s benzene fenceline monitoring requirement).  Whatever the reason, ALL4 has helped numerous clients with the task of setting up and maintaining a meteorological tower equipped with the associated instruments.  In a blog I posted in June 2015, I wrote about some of my experiences out in the field, and some of the regulatory background as to why I was out there.  This follow-up blog will dig deeper, and divulge some of ALL4’s secrets to success by exploring the “Dos and Don’ts” of meteorological monitoring.  We had to learn some of these points the hard way, but we are a better team because of those experiences!

DO: TEST EQUIPMENT AT THE OFFICE
DON’T: ASSUME IT WILL ALL WORK ON SITE

When ALL4 orders meteorological equipment, we always have it delivered to our office well before the installation is scheduled.  Prior to bringing it to the project site, we test the datalogger, program, and wiring to ensure that everything was set up correctly.  We make sure that we can connect to the station with our laptops.  Before our audits of existing installations, we test the audit equipment connections and readings to mitigate possible issues we could have out in the field.  Sometimes, even with this preparation, meteorological sensors can break once they are deployed.  For example, about two (2) weeks after we installed a tower, one (1) of the sensors started reading “0”.  ALL4 had to arrange a trip out to the tower, replace the sensor, and send the sensor back to the manufacturer.  We found out later that the circuit board of the brand new sensor needed to be replaced.  What are the odds?

DO: UTILIZE AN EQUIPMENT CHECKLIST
DON’T: ASSUME THAT EVERYTHING IS IN THE BOX

This is a biggie.  Before every trip, whether it is a tower installation or audit, we print out our checklist and go through it – multiple times.  We assemble the equipment the day before the trip, and then go through the checklist again the day of the trip.  Even if you ‘know’ that equipment should be in a box, we always pull out each piece to verify that we are bringing what we need.  Sometimes, during this process, we will identify equipment or tools that are missing, and we will take a trip to the local hardware store to pick it up.  Last year, while at a site for a meteorological tower audit, our ratcheting wrench set was unable to loosen an old (and I mean old), rusty bolt to let down the tower.  We didn’t have a simple, adjustable wrench with us, which would have saved a good bit of time.  We ended up using – and I kid you not – a bottle opener to loosen the bolt!  Now, we have an adjustable wrench in the ALL4 toolbox, and I store an adjustable wrench in my car (a Christmas gift from my dad last year).

DO: BE SAFE
DON’T: TAKE ANY CHANCES

As with any of ALL4’s site visits, we not only comply with the site’s safety rules, but with ALL4’s safety policy as well.  When you see us out in the field, we’ll at least be wearing long pants, steel-toe/composite toe boots, safety glasses, and a sweet ALL4 hard hat.  You never know what hazard you will run into (literally – 2-meter boom arms are just low enough to cause head bumping issues)!  In my blog last year, I told you about being out in the polar vortex; we had to make sure we were prepared for the below 0°F temperatures.  In the summer, our main adversaries are bees and wasps; they really love the aluminum tower and we often find them nesting in and around our enclosures, so we bring wasp spray with us to battle them.  Some other useful weapons to have in your arsenal include bug spray, sun screen, water, and snacks.  Let me remind you that these jobs are outside and usually in remote areas so that there is minimal disturbance of the data.  Due to the remote location, we are usually on the site for extended periods of time without the option of stopping over at a nearby convenience store for a coffee or a protein bar (let alone lunch!).  Snacks need to be pre-planned and packed ahead of time.  There is nothing worse than fighting the battle against your stomach while you are trying to perform intricate tests with delicate equipment.  Not to mention that at some of our more remote sites, we have been in earshot of gunshots and had visits from nosy, rifle-carrying, ATV-driving locals.

DO: BRING SPARE EQUIPMENT
DON’T: ASSUME “WE’LL BE FINE”

When ALL4 is responsible for ordering and installing a meteorological tower, we always order spare sensors to keep on site just in case there is a problem.  During audits, we rely on these onsite spares, or, if it is a remote site, we bring spare sensors with us, just in case nature damaged our sensors (such as a large bird) or a person on the project team gets their steel-toe safety boots too close to the equipment. Of course, the one (1) time we didn’t bring a spare, we ran into a problem with a plastic cupset… but don’t worry – the team member’s toes were properly protected with the steel -toe barrier (we are always on top of our safety policy). One (1) of the cups snapped off, and we were five (5) hours away from the office. An awesome ALL4 employee (shout out to Kayla!) drove out and met us halfway to give us the replacement parts that we needed to finish the job that day – even if it meant putting in a few extra hours. Needless to say, we always carry spares of everything for these trips!

DO: CHECK ON THE DATA DAILY
DON’T: CHECK ON THE DATA AT THE END OF THE QUARTER

As part of ALL4’s maintenance of meteorological towers, we download and review the data daily. We have a dedicated computer that remotely connects and downloads data from each of the sites we maintain. Then, a technical staff member reviews the data to confirm that the sensors appear to be working properly. If the meteorological tower is being used to provide data for air dispersion modeling, U.S. EPA requires at least 90% of each calendar quarter to have complete data.  If you are only checking on your data at the end of the quarter, an extended period of downtime might lead to an issue with meeting that requirement.  This issue can be avoided if someone is routinely checking the data so that valuable time is not lost if a trip needs to be planned to replace a faulty sensor. In the example above, the only way we found out that the sensor wasn’t operating correctly (since the circuit board had broken) as by performing daily reviews of the data.

Working with meteorological towers and the data they collect are one (1) of my responsibilities at ALL4.  I like going out into the field (love the change of scenery) and getting to work with my hands. If I have learned anything from these trips, it is that A LOT of time and planning goes into each of these visits (that includes late nights and long drives).  It is crucial to be prepared and to take all of the precautions that you can to ensure that you will have a safe, efficient, and successful trip in the field.  Main take-away: Always expect the unexpected.

Want to know more?  Shoot me an email at aessner@all4inc.com, or reach out to our Technical Manager, Dan Dix at ddix@all4inc.com!

The Forecast Calls for a Mixed Bag of Options for the SSM SIP Call

Our staff at ALL4 includes meteorologists who still have that weather forecasting bug in them. Our business is air quality consulting, and we are often asked about our short-term and long-term forecasts on air quality regulations and how they may impact a specific facility or an industry sector as a whole. In fact, each January, our “look ahead” 4 The Record article is just that – a forecast of important topics to follow for the upcoming year. Since we did not specifically address the Startup, Shutdown, and Malfunction (SSM) State Implementation Plan (SIP) Call in our January 2016 look ahead article, the timing feels right to do so now since we are approximately six (6) months away from the U.S. Environmental Protection Agency’s (EPA) November 22, 2016 deadline for affected states to submit SIP revisions to address excess emissions during SSM events. With weather forecasting, it is often a good idea to look at what has happened before forecasting what is to come. So let’s start with a brief recap of the SSM SIP Call.

A Little Refresher

On May 22, 2015, the U.S. EPA issued a final action regarding state SIPs that were deemed to not meet the Clean Air Act (CAA) requirements of treatment of excess emissions during periods of SSM. The U.S. EPA found that certain SIP provisions in 36 states were substantially inadequate to meet the CAA requirements and, therefore, issued a “SIP call” for these 361 states. The final action for the SIP Call was published in the Federal Register on June 12, 2015. The affected states have until November 22, 2016 to submit their corrective SIP revisions.

A list of U.S. EPA’s final actions for all affected states can be found here.

In the final action, U.S. EPA made the following key clarifications regarding SIP emissions limitations:

  • The emissions limitations do not need to be numerical in format
  • The emissions limitations do not have to apply the same limitation (e.g., numerical level) at all times, and
  • The emissions limitations may be comprised of a combination of numerical limitations, specific technological control requirements and/or work practice requirements.

U.S. EPA further clarified that emissions limitations in SIPs may contain components applicable to different modes of operation that take different forms. U.S. EPA emphasized that regardless of how a state agency expresses a SIP emissions limitation, the emissions limitation as a whole must be continuous, must meet applicable CAA stringency requirements, and must be legally and practically enforceable. U.S. EPA gave states “approved” options to adequately address SSM provisions within their SIPs. Those options included:

  • Removing SSM exclusions so that emission limits apply at all times,
  • Adding enforcement discretion language,
  • Revising emission standards, or
  • Creating alternative work practice standards (WPS) for periods of startup and shutdown.

States can use any combination of these options to meet the requirements of the CAA.

The Forecast for SSM Compliance Options in Select States

Through our project work and our participation in various air quality technical associations, ALL4 has learned what several states are proposing for their response to the SSM SIP Call. These options are still under review by the states and are subject to change. A sampling of what certain states are proposing is provided below. If your facility is located one (1) of these states, the operational and permitting implications will not affect you in the near term. However, ALL4’s long range forecast for compliance at such facilities calls for a 90% chance for permit modifications, changes in operational procedures, and/or more scrutiny of data. Why not 100%? We are accounting for additional lawsuits and related legal challenges that go hand in hand with sweeping regulatory actions such as this.

Of note: if the U.S. EPA finds that an agency fails to submit a complete SIP revision that responds to the SIP call, or if the U.S. EPA disapproves such SIP revision, then the U.S. EPA has an obligation under CAA section 110(c)(1) to promulgate a Federal Implementation Plan (FIP) no later than two (2) years from the date of the finding or the disapproval, if the deficiency has not been corrected before that time.

Georgia

Even though Georgia is one (1) of a group of states currently associated with a lawsuit to have the SSM SIP Call stricken, Georgia has made significant progress in developing a plan to revise its SIP. Georgia plans to implement WPS for periods of startup and shutdown, but would not include periods of malfunction. Georgia is proposing general standards for air pollution control devices (i.e., operating at all times unless some other situation related to safety or a hazardous operating conditions precludes operation), adhering to work practice standards established in applicable New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations, and implementing case-by-case determinations that would be enforceable through either a Title V permit or Prevention of Significant Deterioration (PSD) permit. Georgia is on-track to meet the November 22, 2016 deadline.

Tennessee, South Carolina, North Dakota, and Louisiana

Tennessee, South Carolina, North Dakota, and Louisiana are proposing to remove the SSM exemptions from their state rules. In other words, numerical limits will apply at all times. At this time, they are not proposing replacement of the SSM exemptions with WPS.

North Carolina

The North Carolina Division of Air Quality (NCDAQ) is proposing a similar approach as Georgia, with a slight twist. NCDAQ proposes to remove the SSM exemptions within their state rules and replace them with WPS. However, NCDAQ is creating a WPS for periods of startup and shutdown, as well as another for periods of malfunction. ALL4 also understands that North Carolina’s legislative process may preclude meeting the statutory deadline.

Alabama

ALL4 understands that Alabama has not fully developed its proposed revisions at this time, and likely will not meet the statutory deadline.

Arkansas

Arkansas Department of Environmental Quality (ADEQ) has initiated revisions to their SSM exemption rules. ADEQ has proposed to remove the language that provides for affirmative defense during periods of SSM and replace it with language that provides factors for the Director’s consideration in determining whether enforcement action is warranted. ADEQ is also proposing to include a rescission clause that would restore affirmative defense in the event the U.S. EPA or Federal court stays, vacates, or withdraws the SSM SIP Call. Arkansas anticipates meeting the November 22, 2016 deadline.

Oklahoma and New Mexico

Oklahoma Department of Environmental Quality has drafted revised rule language to replace affirmative defense with mitigation and alternative emission limits. Oklahoma has proposed mitigating factors for excess emissions during malfunctions. New Mexico Environment Department Air Quality Bureau is proposing revisions to remove the applicable sections of its SSM rules. The Air Quality Bureau recently held public hearings to gather feedback from the public and industry representatives. New Mexico is proposing to adopt affirmative defense as a State-only rule.

Texas

Texas has chosen to wait on the outcome of the SSM SIP Call litigation before proceeding with rule changes.

Other SSM activity

We have noticed other SSM activity in recent months as part of Federal rulemakings. U.S. EPA extended several comment periods for an Information Collection Request (ICR) for multiple NSPS subparts. The ICRs are focused on data already submitted by the affected facilities that includes initial notifications, performance tests and periodic reports and results, and maintaining records of the occurrence and duration of periods of startup, shutdown, and malfunction. U.S. EPA is also interested in reviewing data around any period when monitoring systems were inoperative. The affected NSPS subparts include the following:

  • NSPS for Secondary Lead Smelters (Subpart L)
  • NSPS for Small Municipal Waste Combustors (Subpart AAAA)
  • NSPS for Stationary Combustion Turbines (Subpart KKKK), and
  • NSPS for Grain Elevators (Subpart DD)

Other SSM Implications

How could these changes to your state SIP rules impact your existing permits? As we discussed in an October 2014 4 The Record Article, Title V operating permits must include “emission limitations and standards, including those operational requirements and limitations that assure compliance with all applicable requirements at the time of permit issuance” or “all applicable requirements”. Applicable requirements can include emission limits, WPS and the associated monitoring, testing, recordkeeping, and reporting provisions associated with the limits or work practice standards. Currently effective SSM provisions may exempt the source from compliance with numeric standards during SSM events. Therefore SSM provisions may be included in Title V operating permits as source specific “stand alone” conditions, facility-wide general requirements, or included within specific monitoring, recordkeeping or reporting requirements.

Reconciling the SSM SIP Call, various court decisions, mandates, and U.S. EPA guidance memoranda with a given facility’s operating permit is not exactly a straight forward proposition. For example, if a Title V operating permit includes specific SSM exemption language, an argument could be made that the SSM provisions of the Title V permit for the source would remain in effect for the term of the permit. Of more concern, particularly given the fact that many times the state regulatory authorities do not reopen Title V operating permits just to add in new applicable requirements, is the fact that 40 CFR §70.5(b) obligates owners and operators to supplement or to correct information as necessary to address requirements that become applicable to a source after the date that a complete application was filed, but prior to the issuance of a draft permit. This provision could affect facilities with sources impacted by SSM changes that are operating for extended periods under an application shield due to somewhat common delays in the regulatory agency review/issuance of operating permit renewals. In such instances, the owner/operator may be obligated to supplement or correct their Title V operating permit application to remove the SSM provisions associated with the SSM SIP Call.

Sounds like a good time to have an attorney on speed dial!

Where Do We Go From Here?

We expect to see even more activity from the states involved in the SSM SIP Call. The November 22, 2016 deadline is fast approaching for the affected states to get their SIPs revised to comply with the CAA. The SIP call and the threat of the imposition of a FIP are indications that SSM exemptions are truly endangered. Stay tuned for the outcome of the SSM SIP Call litigation. If you need help navigating your state’s SSM (or removal of) rules, let us know.


1Note that 39 states were identified in the original Petition, but only 36 states were identified in the May 22, 2015 final action.

RACT 2 Rule Published: Clock Starts on RACT 2 Proposals – “The trouble is, you think you have time.” – Gautama Buddha

The internet is confused and gives me contradictory answers as to whether the title of this blogpost is a legitimate quote uttered by the Buddha himself or a paraphrase – authored by some Western scholar and without context I’m sure – of a Buddhist teaching.  If I was a betting man, I’d say it’s probably the latter.  Regardless of its historical authenticity (and original context), the sentiment expressed is perfect for my intended purpose here.  Anyway…

On April 23, 2016, the RACT 2 Rule was published final in the Pennsylvania Bulletin.  That bears repeating – As of April 23, 2016, the RACT 2 Rule was published final in the Pennsylvania Bulletin.  We have arrived.  It has happened.  We’ve been talking about this for months.  Talking and waiting, talking and waiting…a lot of talking and a lot of waiting.  Honestly, it was starting to feel like we were crying wolf a bit, but then the Environmental Quality Board (EQB) published the final RACT 2 Rule on April 23rd.  Finally and not a moment too soon let me tell you.  Personally, I’m relieved.  The suspense is over.  The anticipation has ended.  The rule is here.  Now what?  What does that mean for you?

Well, if you’re a major source of either of the ozone precursor pollutants (i.e., NOX and/or VOC), meaning that you have the potential to emit greater than 100 tons of NOX and/or greater than 50 tons of VOC, and you operate within the Commonwealth of Pennsylvania, you are subject to the RACT 2 Rule and need to evaluate its applicability to your NOX and VOC emitting sources ASAP.  I know that people use the acronym ASAP flippantly…“Can I have that ASAP?” “Call me ASAP!” “I need that report ASAP!”  It’s a term all but devoid of meaning at this point.  That said, when I use the term ASAP in reference to the RACT 2 Rule I do mean as soon as possible; without a moment to spare.  Here’s why…

RACT 2 proposals or alternative RACT 2 petitions need to be submitted to PADEP by October 24, 2016 and facilities must be able to comply with applicable RACT 2 requirements by January 1, 2017.  We are now within six (6) months of the submittal date and well within a year of the compliance date.  So when I say ASAP, I literally mean ASAP.  As the Buddha may or may not have said, “The trouble is, you think you have time.”  In actuality, with regard to RACT 2, you don’t.

First time you’ve heard of this?  Want to know more about what these regulations could mean to major sources of NOX and VOC in the Commonwealth?  Go here and read all about it in ALL4’s previous RACT 2 blogs or reach out to jslade@all4inc.com or (717) 822-0009 or me at Ron Harding at rharding@all4inc.com or (610) 933-5246 extension 119.

Who We Are…

A week or so ago one of our Project Managers asked me to get on a call with our client and a regulator in an Upper Midwestern state where we’ve done a reasonable amount of work over the past few years.  There were some unique aspects to the permitting but nothing too far out of the ordinary.  As we introduced ourselves on the call, the regulator immediately replied that he was familiar with ALL4 as he had visited our website and seen a number of the technical articles and blogs that we put out and that he found them very informative and valuable.  It was pretty cool to hear this, but not completely surprising to me.  ALL4 puts out a lot of technical information as well as other details about our company and our people.  All of our staff are actively engaged in this process that is managed by our RegTech Operations Group. 

This sharing of information is consistent with our vision of shaping environmental responsibility and, as a company, we see great value in sharing what we know and what we are experiencing in the hopes that it will help others, or possibly just provide a little entertainment.  However, we also don’t shy away from the fact that that there are additional reasons for this sharing.  First, it builds credibility for our company and our consultants when we do perform work in new states or locales (as evidenced by my story above).  Second, we know our competition reads our stuff.  Why do we put our intellectual capital out there for our competition to learn from, and sometimes even “borrow” from?  Because we are a growing company and we feel that when consulting professionals see the depth and quality of our technical expertise and when they experience the lighter side of our blogs that provide a window into our culture, that they may think – ALL4 could be a place for me!  (p.s., we are hiring, check out our Careers page.)  Third, we are writing about those areas that we think are important to our clients and prospects so that they can also see the need at their facility, and either they contact us to help them or they welcome the conversation when we contact them about the needs that we see for their facility.

Do we know who is looking at our material?  The answer is a resounding – YES!  

So welcome clients, regulators, future clients, and, yes, even our competition.  In exchange for the great content, you shouldn’t be surprised that if you’ve been reading our stuff, you may well receive a call from someone at ALL4 reaching out to see if there is any place you might be able to use our help – that is us living our vision statement of shaping environmental responsibility AND it is our intentional commitment to growing our business! 

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