May 2017 - ALL4

Poking Holes In Your Electronic Compliance Report

So maybe you’re one of the many facilities who are now subject to electronic reporting requirements under a 40 CFR Part 60 (NSPS) or Part 63 (NESHAP) rule. Perhaps even this past year was your first time having to submit your semi-annual or annual compliance report via the U.S. EPA Compliance and Emissions Data Reporting Interface (CEDRI). If either of these sounds like you, you may have also had your fair share of questions or issues while reporting, especially if your compliance report involved reporting continuous monitoring system (CMS) data.

While assisting my clients, I’ve learned that some of these questions don’t have a straightforward answer or even published guidance, so they can be left to individual interpretation. That means that your approach for completing some of the ambiguous CEDRI forms may not be interpreted by others the way you intended them to be. Keep in mind that submitted reports are as easy to access on U.S. EPA’s WebFIRE database as a simple point and click, so it’s easy for an inexperienced viewer to download your data in an attempt to poke holes in what you reported. So how confident are you with the way your data is represented online?

ALL4 has completed and reviewed many compliance reports across different industries, and I’ve summarized some common “holes” and potential solutions or strategies below:

Reporting “0” for CMS averaging data during process down

Although the CEDRI form to submit monitoring data may seem like a numerical value needs to be input for each averaging period (e.g., each day), if the process was down, entering a “0” can lead to misinterpretation of your data by regulators and non-governmental organizations. Instead, you can leave the data fields blank and add a comment explaining why the field is blank.

Change of an operating limit in the middle of a reporting period without differentiating that in your CMS averaging data

This one can be a little tricky since the CEDRI form for CMS only allows you to enter in one operating limit. However, if your operating limit was re-established in the midst of the reporting period (especially if your limit was lowered), then your data could be misinterpreted and improperly compared against the wrong limit. One way to minimize this confusion is to visually break up your data by leaving a blank line between the dates where the limit switched. This should also be accompanied by a comment to the reviewer noting the change in operating limit. Furthermore, be sure that you define the end date for the previous limit, the begin date, including the date of the first valid compliance average for the re-established limit, and any gaps in data that may occur as the compliance average was being “built”.

Reporting CMS data for monitors not required

This is very rule dependent. However, it is important to read the applicable regulation as well as supporting guidance for your industry thoroughly before submitting your report. In some cases, the CEDRI form may prompt you to submit CMS averaging data but under the rule, a particular CMS may be exempt from this requirement (e.g., PC NESHAP dioxin/furan temperature averages). If you are prompted with a form to report CMS averaging data for a CMS in which it is not required, you can leave the form blank and add a comment to the reviewer justifying the blank form.

These are just a few of the common “holes” we’ve seen in electronically submitted reports. My advice is to always review your reports asking the question “How would someone with no understanding of my facility interpret this report?” Maybe even have an experienced third party review your report. The U.S. EPA “NextGen” strategic plan includes expanded transparency. Expanded transparency leads to increased scrutiny. It’s your data, be accountable for it.

If you have any questions about specific rule requirements or how to complete CEDRI reports, please contact me at kturney@all4inc.com or (610) 933-5246 x143.

Re-Entrainment. What is it and should you be evaluating it for your site or next project?

Have you ever seen a plume from a stack swirl around when it gets caught in the wake of a building? Have you seen buildings with air intakes downwind of short stubby stacks or tucked next to back-up diesel generators? These conditions are prime examples of situations where plume entrainment, or re-entrainment, can give rise to elevated contaminant concentration levels that can unnecessarily expose the general public or workers to elevated levels of air contaminants. Assessing the potential for re-entrainment should be of special concern to all project designers or facility managers for existing sites.

So what is re-entrainment? As Amanda Essner discussed in her recent blog post, Re-entrainment is an atmospheric event that occurs when contaminants that are exhausted in a plume from a stack are mixed back into the original volume of air. A scenario of particular concern is where fresh air intakes are located nears areas of plume re-entrainment. The re-entrainment is typically caused by a combination of short stacks, the presence of nearby buildings and structures, and meteorological conditions associated with poor atmospheric dispersion.

ALL4 has been evaluating how pollutants from emissions sources can be re-entrained because of plume interaction with structures and impact nearby locations where the general public or employees have regular access. By using air dispersion modeling to predict concentrations at locations susceptible to re-entrainment, ALL4 can assess if the designed configuration of a site or equipment could result in dispersion scenarios where re-entrainment has the potential to cause concentration levels that exceed published health guidelines or air quality standards. Furthermore, ALL4 can propose stack configurations changes to alleviate the issue for existing sites or suggest stack and building configuration changes to proposed sites in development. ALL4 has evaluated re-entrainment scenarios from many different types of emissions sources including hospitals, pulp and paper mills and even seafaring ships on the Great Lakes. In this article we’ll discuss who should consider a re-entrainment evaluation, the information necessary to conduct a re-entrainment evaluation, the models available for conducting re-entrainment evaluations, and provide some real-world re-entrainment evaluation examples.

Who should consider a re-entrainment evaluation?

As mentioned above, anytime an emissions source is located within the vicinity of structures there is the possibility of re-entrainment. Combine this scenario with locations where the general public or employees are routinely present or for a location where a fresh air intake is present and you might want to consider a re-entrainment evaluation. This evaluation is especially true for emissions sources that have low release heights and are located by nearby structures such as buildings, tanks, earthen berms etc. A common scenario that requires a re-entrainment evaluation is an emergency generator located adjacent to a building and near a building air intake. Other scenarios include facilities where low elevation stacks are located near tall buildings and where employees are routinely working near the stacks and buildings. This stack and building configuration is common at many industrial facilities. Lastly, even large mobile sources such as seafaring ships can be subject to re-entrainment scenarios where plumes from short stacks, which are required to pass under bridges, are influenced by the large structures on deck and can present re-entrainment concerns for the ship’s crew. I’ve just provided a couple of examples but I think you get the idea.

Information necessary to conduct a re-entrainment evaluation

The information necessary to conduct a re-entrainment evaluation is easy to assemble and should be readily available whether you are in the development stages of a project or already have the project built. Information on your emissions sources including stack height, stack diameter, stack temperature, stack flowrate, and stack location is necessary. In addition, detailed dimensional information on all nearby structures is required. Emissions rates can be calculated for pollutants of concern utilizing published emissions factors or based on vendor guarantees. Unprocessed meteorological data can be obtained for free from nearby weather stations from the National Climatic Data Center (NCDC) or a worst case matrix of artificial screening meteorological data can be developed for your site. Once the data is collected the next consideration is what type of approach should be used to assess for re-entrainment. Here are two primary approaches ALL4 recommends for conducting re-entrainment evaluations depending on the type of source(s) and surrounding structures. Each of these primary approaches is discussed below. A secondary approach involves conducting a wind tunnel study. However, the cost and time associated with a wind tunnel study is far greater than the two primary methods discussed in the following paragraphs.

AERMOD

U.S. EPA’s AERMOD air dispersion model is the recommended model in the U.S. to use for near-range (within 50 kilometers), air dispersion modeling for compliance with the National Ambient Air Quality Standards (NAAQS). Although the NAAQS evaluations apply to “ambient air” (i.e., the portion of the atmosphere, external to buildings, to which the general public has access), AERMOD has been used in on-site evaluations, for example, of air toxics. AERMOD can be used for re-entrainment evaluations since it is readily available and widely accepted as a preferred air dispersion model.

AERMOD is appropriate for this application for a number of reasons. First, AERMOD allows the user to input building dimensions and tiers to account for building downwash. This is critical because the re-entrainment evaluation looks at onsite impacts where exhaust air can be pulled back into a building (e.g., at fresh air intake units), typically located on the sides or roofs of buildings. Receptors can be set at flagpole heights; that is, they can be raised up (as opposed to always being at ground level) to be located at the height of the fresh air intakes. AERMOD also allows the user to predict concentrations for both single sources and the combination of multiple sources. In addition, meteorological data is readily available through the NCDC online and can be used in AERMOD after being processed.

ASHRAE Minimum Dilution Models

The American Society of Heating, Refrigeration, and Air Condition Engineers (ASHRAE) provides a geometric stack design method for estimating the minimum stack height required to avoid plume entrainment in the flow recirculation zones of structures. The ASHRAE method was designed to avoid plume entrainment into building air intake vents. The method modifies the Gaussian equation utilized by AERMOD, however; still utilizes many AERMOD equations such as plume spread (i.e., sigma-y and sigma-z) and plume rise. There are two ASHRAE minimum dilutions methods, one for vertical stacks (Dr) and one for wall vents and capped stacks (Ds). For both methods the same general information necessary to use the AERMOD air dispersion model would also be needed for the ASHRAE minimum dilution methods. The ASHRAE minimum dilution methods are recommend for one source located near or on an isolated building. If there is more than one source or multiple and complex nearby structures AERMOD may be a better option because it can handle the complexity of multiple sources and structures in a single analysis whereas the ASHRAE methods could require multiple analyses.

Hospital Example Re-Entrainment Evaluation

An engineering company designing a new hospital building requested a re-entrainment evaluation of the design. The project included a main hospital building and a separate central utility plan (CUP). The proposed main hospital building included two domestic hot water heaters and one steam boiler, all firing natural gas. The proposed CUP included two ultra-low sulfur diesel (ULSD)-fired emergency generators and three hot water boilers running on natural gas with propane back-up. Seven fresh air intakes were to be located on the main hospital building. The pollutants of concern were carbon monoxide (CO) and nitrogen oxides (NOX). The complexity associated with multiple buildings, multiple sources and several fresh air intakes dictated the decision to use AERMOD for this evaluation.

Equipment was modeled at full capacity operating simultaneously at worst-case conditions. Modeling concentrations of CO at the fresh air intakes and air handling units did not exceed health guidelines or the NAAQS. However, issues arose when evaluating NOX emissions from the emergency generators. Since the building and equipment were still in the design phase, the emergency generators were modeled in two different configurations: (1) with the stacks closest to the building and (2) with the stacks farther from the building (i.e., turning the equipment to face away from the building).

Various design iterations were evaluated in which the emergency generators operated alone or as a pair at full load, and then when the emergency generators operated at lower loads. The results of the evaluation showed NOX concentrations at the various air intakes were below the NAAQS and published health guidelines when modeling the emergency generators facing away from the building; therefore, a recommendation was made to the engineering company to turn the emergency generators around so that the stacks were farther away from the buildings. Since this layout of the emergency generators resulted in a favorable re-entrainment evaluation for NOX, the engineering company was able to use the recommendation to consider necessary changes to the design plan.

Ship Example Re-Entrainment Evaluation

An iron-ore ship that operates in the Great Lakes had recently installed a scrubber on the main engine exhaust which resulted in a moist and cool plume. The wet and cool plume buoyancy was lower than prior to the installation of the scrubber and as a result the ship company increased the stack heights on the main engine exhaust by 10 feet (ft). The ship company then conducted CO monitoring, which did not indicate elevated levels of CO onboard. To confirm further that the crew’s health was not being affected by the new stack configuration, a re-entrainment evaluation was conducted using U.S. EPA’s AERMOD air dispersion model. The intent was to evaluate ambient air concentration levels from the main engine exhaust under a full range of meteorological conditions that the ship could experience while traveling the Great Lakes. Additionally, the re-entrainment evaluation also included an evaluation of emissions from four ship service generators and two boilers.

Stack parameters and the ship structures were obtain from engineering drawings of the ship and stack testing was conducted on the main engine and boiler exhaust stacks to obtain site-specific temperature and flowrate information since no data was available after the installation of the scrubber. Ship pollutant emissions were calculated utilizing U.S. EPA emissions factors for input into the AERMOD dispersion model. Lastly, a “site-specific” matrix of worst case meteorological conditions was developed utilizing U.S. EPA’s MAKEMET processor. Using MAKEMET enabled the development of a worst case matrix of meteorological conditions that the ship could experience while traveling on all of the Great Lakes. AERMOD was utilized to calculate pollutant concentration levels at locations on the ship deck where crew had access to and at the ship’s heating, ventilation, and air conditions (HVAC) system intakes. The modeled concentration levels at these locations were compared to NAAQS and published worker health guidelines.

The conclusions of the re-entrainment evaluation determined that the potential for a small amount of main engine exhaust re-entrainment could occur during extreme meteorological conditions. However, during all meteorological conditions it was determined that pollutant concentration levels on-board the ship were well below the NAAQS and published work health guidelines. Therefore, additional stack configuration changes were not necessary.

Re-Entrainment Recommendations

If you’re responsible for the development of a new site that includes emissions sources and structures, the possibility of re-entrainment leading to elevated concentration levels of pollutants exists. Therefore, an important part of the design process should include a re-entrainment evaluation. Additionally, if you’re responsible for the health and safety at an existing site where the potential for re-entrainment exists, there could be stack configuration changes made that could be identified by a re-entrainment evaluation to mitigate any existing or potential issues. If you have any questions about how re-entrainment may be affecting your development site or existing site please contact me (610.422.1118, ddix@all4inc.com) or Amanda Essner (610.422.1129, aessner@all4inc.com), and we can provide some guidance on the best approach for avoiding and remediating potential issues.
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Proposed Amendments to the Massachusetts RACT Regulations

In August 2016, the Massachusetts Department of Environmental Protection (MassDEP) proposed amendments to 310 CMR §7.00 – Air Pollution Control, including amendments to the Massachusetts Reasonably Available Control Technology (RACT) regulations for sources of nitrogen oxides (NO_X) and sources of volatile organic compounds (VOC). The proposed amendments can be viewed here. The Massachusetts NO_X RACT regulations are codified at 310 CMR §7.19 and the RACT requirements for specific sources of VOC are codified at 310 CMR §7.18.

310 CMR §7.19 –RACT for Sources of NO_X

The regulations codified at 310 CMR §7.19 apply to major facilities, meaning facility-wide potential NO_X emissions are 50 tons per year (tpy) or more. In order to comply with obligations to meet the U.S Environmental Protection Agency’s (U.S. EPA’s) 2008 and 2015 National Ambient Air Quality Standards (NAAQS) for ozone, MassDEP has proposed amendments to the NO_X RACT emissions limits for large boilers, stationary combustion turbines (CTs), and stationary reciprocating internal combustion engines (RICE) that meet the following criteria:

Large boilers [i.e., greater than or equal to 100 million British thermal units per hour (MMBtu/hr)] that operate with a capacity factor greater than or equal to 10%, averaged over the most recent three years of operation.
Stationary CTs that operate with a capacity factor greater than or equal to 10%, averaged over the most recent three years of operation.
Stationary RICE that operate greater than or equal to 1,000 hours per year.

If NO_X emissions control needs to be installed to meet the applicable NO_X RACT emissions limit, an Emissions Control Plan must be submitted to MassDEP within 180 days of the promulgation date of the amended NO_X RACT regulations. The proposed rule includes an option to apply for an alternative source-specific NO_X RACT emissions limit if a facility cannot meet the emissions limit specified in 310 CMR §7.19. Sixteen NO_X control technologies or techniques are identified at 310 CMR §7.19(2)(b) that must be evaluated on a case-by-case basis for both technical and economic feasibility if a source-specific RACT evaluation is conducted. The source-specific RACT evaluation must be included in the facility’s Emissions Control Plan.

Affected facilities must be in compliance with the amended NO_X RACT requirements two years after the date of promulgation. If a previously exempted large boiler or stationary CT exceeds the 10% annual capacity factor or if a previously exempted stationary RICE exceeds 1,000 hours per year of operation, an Emissions Control Plan is due to MassDEP within 180 days of promulgation and the source must comply with the applicable RACT regulations by the date two years after such an occurrence.

310 CMR §7.18 – Volatile and Halogenated Organic Compounds

MassDEP has proposed amendments to the Massachusetts VOC RACT regulations consistent with the more stringent emissions limits and work practice requirements identified in several U.S. EPA Control Technique Guidelines (CTGs) published in 2006, 2007, and 2008. Applicability to the amended VOC RACT regulations is triggered when the source emits the greater of 15 pounds of VOC per day or 3 tons of VOC per rolling 12-month period.

Consistent with the revised U.S. EPA CTGs, MassDEP is proposing revisions to the existing RACT regulations for the following source categories,

Metal Furniture Surface Coating – 310 CMR §7.18(3)
Large Appliance Surface Coating – 310 CMR §7.18(5)
Surface Coating of Miscellaneous Metal Parts and Products – 310 CMR §7.18(11)
Packaging Rotogravure and Packaging Flexographic Printing – 310 CMR §7.18(12)
Paper, Film, and Foil Surface Coating – 310 CMR §7.18(14)
Surface Coating of Plastic Parts – 310 CMR §7.18(21)
Flat Wood Paneling Surface Coating – 310 CMR §7.18(24)
Offset Lithographic Printing and Letterpress Printing – 310 CMR §7.18(25)

In addition, MassDEP has developed new regulations for two VOC source categories that will become subject to VOC RACT:

Industrial Cleaning Solvents – 310 CMR §7.18(31)
Fiberglass Boat Manufacturing – 310 CMR §7.18(32)

Finally, MassDEP is proposing to delete the following regulations because there are no longer any facilities in Massachusetts that are affected facilities under the regulation. For any new facilities that would potentially fall under the following source categories, Best Available Control Technology (BACT) would be required and therefore, the RACT regulations will not be applicable.

Automobile Surface Coating – 310 CMR §7.18(7)
Portions of 310 CMR §7.18(21) that are applicable to plastic parts coating operations with the potential to emit (PTE) 50 tpy or more of VOC

Rather than meeting the applicable VOC emissions limit, owners and operators may choose to install a VOC control device that achieves a VOC control efficiency of 90% by weight as an alternate pathway for compliance. If choosing this option, an Emissions Control Plan is required to be submitted within 180 days of the promulgation date of the amended VOC RACT regulations. Affected facilities must be in compliance with the amended VOC RACT emissions limits two years after the date of promulgation (with the option to request an extension of up to one year). Compliance with the VOC RACT work practice standards is required immediately upon the date of promulgation of the amended VOC RACT regulations.

The proposed revisions to the Massachusetts NO_X and VOC RACT regulations are anticipated to be finalized in the near future and will affect a broad range of existing facilities. Affected facilities should immediately begin to develop an understanding regarding how the amended RACT regulations will impact their operations and begin planning to meet the aggressive compliance schedule. ALL4 can help you evaluate rule applicability, develop Emissions Control Plans, and evaluate alternative RACT approaches on a case-by-case basis. If you have questions about how these amendments will affect you and what the next steps towards compliance will be for your facility, please contact me at (610) 933-5246, extension 155, or at cchinofsky@all4inc.com.

CISWI or PC NESHAP Compliance Demonstration Timelines and Milestones Considerations

If you’re like me, it’s hard to believe that it is May already. Time seems to move faster every time I stop and think about it. Why is this relevant? The compliance date for 40 CFR Part 60, Subpart DDDD [Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration (CISWI) Units] affected units is only a few short months away.

Are you, or could you possibly be, operating a CISWI kiln?

A cement kiln is regulated as an incinerator and is subject to the CISWI regulations when a Non-Hazardous Secondary Material (NHSM) is burned without a NHSM non-waste determination. If you are not a CISWI kiln, here are two questions I urge you to consider today:

Does your operating permit include fuel descriptions with the word “waste” (e.g., waste wood, waste derived solid fuel)?
Do you burn any nontraditional fuels in your cement kiln?

If you answered yes to either of the questions above, have you developed a self-implementing non-waste determination, pursuant to the requirements of 40 CFR §241.3(d)(1), for each of the nontraditional fuels burned in the kiln?

ALL4 has been busy helping both corporations and individual facilities develop self-implementing non-waste determinations to ensure the associated kilns do not become subject to the CISWI rules. Please contact me (see below) if you have questions concerning these regulations and the self-implementing non-waste determination process.

CISWI and PC NESHAP Compliance Demonstration Timelines and Milestones Considerations

The CISWI compliance date is “no later than” February 7, 2018, assuming that your state agency has not obtained U.S. EPA approval of their state implementation plan (SIP) for 40 CFR Part 60 Subpart DDDD. Deciding whether you want to remain a CISWI kiln or become a PC NESHAP regulated kiln is the first step in the process. Regardless of the decision you make, you will be required to demonstrate compliance with a variety of CISWI or PC NEHSAP requirements. A short list is provided below of some of these items to get you started.

Compliance considerations when staying a CISWI kiln:
- Submittal of final control plan and waste management plan
- Testing plan, notification, and approval
- Completion of performance test
- Update site specific monitoring plans
- Submit performance test results
- Submit performance evaluation and test results and notification of compliance status

Compliance considerations when becoming a PC NESHAP kiln:
- Determine the date to cease combustion of solid waste
- Determine the effective date of the waste-to-fuel switch and provide the required 30-days prior notice
- Determine the compliance date for PC NESHAP
- Submittal of notification of applicability
- Air pollution control equipment and all monitoring systems necessary for compliance must be installed, operational, and certified, as applicable
- Testing plan, notification, and approval
- Completion of performance test
- Update site specific monitoring plans
- Submit performance evaluation and test results and notification of compliance status

I opened this blog by stating the compliance date for CISWI affected units is only a few short months away. As you can see from lists above, there are many complex issues and requirements that necessitate planning, coordination, communication, documentation, and BUDGET. Point being, time is running out. Feel free to contact me if you would like to discuss anything related to NHSM non-waste determinations, CISWI, or PC NESHAP. My contact information is (610) 933-5246, extension 120 or jkleinle@all4inc.com.

This article is available as a podcast episode on ALL4’s Air Quality Insider

Getting Your CMS House in Order

This article is available as a podcast episode on ALL4’s Air Quality Insider

We are all wondering how the proposed cutbacks at U.S. EPA could influence the day-to-day compliance obligations at facilities using continuous monitoring systems (CMS). The organizations that may be affected the most by the anticipated U.S. EPA cutbacks are the state environmental agencies. Not only will state environmental agencies continue to be challenged with processing new permit applications and renewing existing permits, they will also continue to carry the burden of enforcing the day-to-day compliance obligations at facilities. In most cases, the state environmental agencies were already delegated authority by U.S. EPA to implement and enforce Federal regulations. The biggest change could be, not in this obligation, but the increased scrutiny that state regulators are likely to receive from non-governmental organizations (NGOs). We anticipate this increased scrutiny from NGOs to occur as a result of a perceived regulatory vacuum because of possible cutbacks at U.S. EPA. With the change in administration, NGOs are empowered and have been more successful than ever in raising money. NGOs will most likely have their plates full with challenging the proposed rollback of regulations, while allocating their remaining time to keep an eye on day-to-day facility compliance obligations.

Why could NGOs focus on CMS data used for compliance purposes?

CMS data developed and reported by facilities typically represent “low hanging fruit” with regard to compliance and “deviations”.

CMS data (including excess emissions and CMS downtime) are routinely reported to state environmental agencies.
CMS data is available electronically on U.S. EPA’s Webfire report search retrieval website.
The process for challenging CMS data is reproducible from facility-to-facility and state-to-state making it easy for NGOs to efficiently target and challenge CMS data.

The state environmental agencies will most likely feel the initial pain, being challenged on areas of enforcement (or lack thereof) for excess emissions or excessive CMS downtime. This scrutiny on compliance demonstrations using CMS data will be passed from the state environmental agencies to facilities in an attempt to avoid involvement from NGOs. State environmental agencies may also look to become more proficient in evaluating CMS data, possibly embracing U.S. EPA’s “NextGen” compliance initiative to allow for the electronic submittal of data and the ability to make that data directly reviewable by the public.

ALL4 is has observed that most facilities are choosing to “wait and see” what happens next with the proposed cutbacks at U.S. EPA. Why wait? Your best action now is to “get your CMS house in order.” Multiple regulations came into play over the last several years that required new monitoring systems. Are you subject to these regulations? If so, how are the new monitoring systems performing? Has anyone ever independently reviewed the operation and quality assurance of the new monitoring systems? What about your existing CMS? Now is a great opportunity to “get your CMS house in order” and formulate an action plan to assess and understand how you are using CMS data for compliance purposes. For more information on formulating your CMS action plan including evaluating your existing equipment, data management systems, and even identifying areas for CMS training, please visit our CMS webpage. Also, please feel free to contact me at 610-422-1117 or eswisher@all4inc.com for assistance in formulating your plan to “get your CMS house in order”.