August 2017

Will the Changes to the PM CEMS QA/QC Requirements Impact my PM CPMS?

The answer is probably not. U.S. EPA has recently revised certain quality assurance requirements for sources using particulate matter (PM) continuous emission monitoring systems (CEMS) under 40 CFR Part 60 Appendix F, Procedure 2 (P2). P2 includes quality assurance/quality control (QA/QC) procedures for PM CEMS used for compliance determinations at stationary sources. The revisions may be welcomed for those with certified PM CEMS, however, many facilities use PM CEMS as a continuous parametric monitoring system (CPMS) because the applicable rule allows it. Therefore, the changes will not likely entice sources that currently use PM CPMS to rush out and certify their CPMS under P2. The cost and effort associated with the certification still outweighs the benefit of having a PM CEMS.

The revisions to P2 were proposed in the Federal Register on November 21, 2016 and specifically address the procedure for conducting the annual Relative Correlation Audit (RCA) or Relative Response Audit (RRA) QA/QC test. The annual RCA or RRA requires that a minimum amount PM CEMS response values be measured with the PM CEMS response range used to develop the PM CEMS correlation curve. U.S. EPA noted that PM emissions from some sources that accepted tighter PM emissions limitations and/or installed better PM control devices now fall below the levels used to establish the initial correlation curve causing facilities to not be able to meet the RCA or RRA requirements. The revisions to P2 remove the requirement that the PM CEMS response values must not be higher or lower than the values used to develop the correlation curve for that PM CEMS. The final rule becomes effective on September 13, 2017. More information can be found here.

Any other ideas of how this could work for you? We are always open to unique, creative ideas and approaches to monitoring. Give me a call at (610) 933-5246 extension 117 or email at eswisher@all4inc.com.

When You are No Longer the New Guy in Town: Eight Months After the Relocation

In December 2016, I decided to take a risk that I had never taken before…I was going to move out of Pennsylvania. Pennsylvania is the state I grew up in, and I had lived in various parts of it throughout my first 22.5 years of life. However, I was attracted to the opportunity to go somewhere new and explore what other areas of the world (or at least a Commonwealth slightly south of Pennsylvania) had to offer. In discussions with Kevin Hickey, our Chief Operating Officer, we decided I would be a good fit for the technical staff position in the All4 Inc. (ALL4) Washington, D.C. office, and I was going to relocate to Northern Virginia in January. The decision to leave home and my family behind was not an easy one to make, but I was swayed by my desire to further accelerate my career development, live somewhere new, and meet new people. So now that it has been eight months since the big move, how have things gone?

By moving to the WDC office, I was hoping to expand my expertise in various new areas. As I had hoped, with the new office also came many new opportunities. I could begin working with various clients and industries that I had not interacted with before. I was also able to strengthen my relationships with the Project Managers in the office, as well as grow a trust between us. I set out to challenge myself to take on new roles and responsibilities within the office, and have been able to do more than I ever expected. The Project Managers in the office enrolled me into proposal writing, reviewing proposals, fact-finding calls, and much more. I had never been involved with the ALL4 sales process, and this was a great entry into how it works. My client interaction has also increased exponentially since moving to the WDC office. I am regularly involved with client communication, including emails and phone calls, as well as visiting clients on-site. This has allowed me to better understand our client’s needs, as well as develop a solid working relationship with them.

Although the move has been overwhelmingly positive professionally, there were also many challenges including understanding air quality regulations and the air quality permit application process for several “new” states, more “overhead” assignments and responsibilities, and adapting to a new office environment. While in our Philadelphia office, my work was predominantly with Pennsylvania clients and I became familiar with the Pennsylvania-specific air quality regulations. In D.C. I am working with a more dispersed group of clients located in several states that I had not previously worked in. In terms of office setting, I knew it would be an adjustment going from a 40 plus person office to an office of five including me, but I was not entirely sure what that adjustment would feel like. My biggest concern was no longer having someone next to me to bounce questions off, but this was quickly resolved. Through electronic communications, I could efficiently discuss these questions with colleagues, and so I have the same level of support as I did in the Philadelphia office.

On top of the professional challenges and opportunities for development that were presented, the move also brought me personal success in my ability to thrive in a new community and meet new people. Relocating to Northern Virginia was the first time in my life I didn’t live in Pennsylvania, and the first time I didn’t have a family member living under 20 minutes away. Growing up in a very large family, this was an adjustment for me. I was also presented with the challenge of making new friends. Relocating also forced me out of my comfort zone as my life-long friends were now more than four hours away and I had to make new “local” friends. At times, I felt like I was back in high school or a freshman in college trying to sell someone on being my friend. However, despite the challenges, living in the D.C. area has provided me an opportunity to explore new places, expand my career, meet new people, and continue to enjoy the adventure of “adulting” and consulting.

If you have any questions about ALL4’s new Flex program, please contact us.

RACT 2

With a compliance date of January 1, 2017, affected facilities operating within the Commonwealth of Pennsylvania will need to evaluate the applicability and impact of RACT 2 on their operations, assess the need to develop a RACT 2 proposal, and submit said proposal to the Pennsylvania Department of Environmental Protection (PADEP) within six (6) months from issuance of the final rule in the PA Bulletin (projected January 2016/February 2016 timeframe).

To assist those facilities affected, ALL4 and PADEP presented a training and Q&A session on the revised Final-Form RACT 2 Rule, RACT 2 Review on March 1, 2016. The panel also included a representative from Clean Air Engineering, a company that provides a wide range of testing services.

For more information, you can find all of the articles we have written about the RACT 2 Rule and additional resources in our RACT 2 Toolbox.

ALL4’s Pennsylvania RACT 2 Toolbox

The Pennsylvania Department of Environmental Protection (PADEP) has new Additional Reasonably Available Control Technology (RACT 2) regulations that were proposed in mid April 2014.

So, who’s affected? The RACT 2 regulations, when promulgated, will likely impact every major source of ozone precursor pollutants (i.e., nitrogen oxides (NOx) and volatile organic compounds (VOC)) in Pennsylvania.

What are the implications to my facility? The impacts of the final RACT 2 regulation on major sources of NOx and VOC, if promulgated in its current form, could range from merely responding to the administrative requirements of the rule all the way up to the design, specification, purchase, installation, and permitting of new or additional air pollution control systems.

Have additional questions? Want to talk through your RACT 2 strategy? Call Ron Harding at 610.933.5246 x119 or email him at rharding@all4inc.com.

RACT 2 Tools:

Download RACT 2 FAQs
Review the Revised Final Form RACT 2 Rule
RACT 2 Review – ALL4’s RACT 2 training featuring Q&A with PADEP

Read up on relevant ALL4 Articles:

ERT/CEDRI

U.S. EPA has started to promulgate regulations under
40 CFR Part 60 (NSPS) and Part 63 (NESHAPs) that are transitioning certain forms of reporting to an electronic platform, also known as “E-Reporting.” E-Reporting is completed using U.S. EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) and/or Electronic Reporting Tool (ERT). There is little guidance or support around this software which can lead to a steep learning curve associated with E-Reporting. ALL4’s ERT/CEDRI Focus Area provides a variety of services and expertise to assist our clients in complying with Federal and state E-Reporting requirements. The main services of the ERT/CEDRI Focus Area are as follows:

Performance test reports and performance evaluation reports for programs such as emissions testing or continuous emissions monitoring systems (CEMS) relative accuracy test audits (RATAs), including report preparation and submittal using ERT and CEDRI, respectively
Air emissions compliance reports including, but not limited to, ongoing compliance reports, monitoring data reports, and emissions reports using CEDRI
Notification reports for notifying compliance status or other required notification submittals using CEDRI
Training programs to support ALL4 services or to aid clients with developing in-house electronic reporting capabilities

ALL4 understands that E-Reporting can often be complex, time-consuming, and an additional compliance burden. Please contact Kayla Turney at kturney@all4inc.com to find out how ALL4 can help you and your facility.

Articles

Electronic Reporting for Stack Testing and the Dangerous Assumption “It Won’t Take THAT Long”
PC MACT and Electronic Reporting: What You Need to Know
Lessons Learned from E-Reporting
Wait…We Have to Report our Generator Use to U.S. EPA?
ERT and CEDRI: What the Heck Is It and How Does It Impact You?
Electronic Reporting: Great in Theory
Compliance and Emissions Data Reporting Interface (CEDRI) Review

Presentations

Compliance and Emissions Data Reporting Interface (CEDRI) – What can you expect from Next Gen Compliance?
U.S. EPA’s Electronic Reporting Tool and Compliance and Emissions Data Reporting Interface: What Do the Requirements REALLY Mean for Petroleum Refineries?

Regulatory Resources

Promulgated regulations with electronic data reporting requirements
EPA test methods and pollutants currently supported by ERT

Extension of a Wool Fiberglass Manufacturing Compliance Deadline

The National Emissions Standards for Hazardous Air Pollutants (NESHAP) located at 40 CFR Part 63 Subpart NNN regulates hazardous air pollutants (HAPs) emitted from wool fiberglass manufacturing facilities. The rule was first proposed in 1997 and finalized in its original form in 1999. In 2011, amendments to Subpart NNN were proposed, and, after four years of public comment and hearings, the 2011 amendments were finalized in 2015. The 2015 amendments included the following:

The establishment of emissions limits for chromium compounds.
The establishment of pollutant-specific emissions limits for certain HAPs (i.e., phenol and methanol) that were previously regulated under a surrogate emissions limit (i.e., formaldehyde) for flame attenuation (FA) lines.
The finalization of Generally Available Control Technologies (GACT) standards for gas-fired glass-melting furnaces
The removal of the startup, shutdown, and malfunction (SSM) provision. (Editorial Note: This provision previously exempted emissions during SSM periods from the emissions limits of the rule.)
The addition of the requirement that the submittal of performance testing reports shall be made through the Electronic Reporting Tool (ERT).

The general takeaway is that the 2015 amendments increased the level of emissions control and environmental protection provided by Subpart NNN.

In July 2017, U.S. EPA took direct final action to amend a portion of Subpart NNN that affects flame attenuation (FA) lines at regulated facilities. Under this action, sources subject to Subpart NNN are provided an additional year to comply with the emissions limits for FA lines. The Clean Air Act (CAA) stipulates that U.S. EPA can provide sources up to three additional years to comply with applicable emissions limits. The July 2017 direct final rule extends the compliance date to the maximum of three years, as affected FA lines were initially provided only two years to comply with the emissions limits of Subpart NNN. Unless U.S. EPA receives “significant adverse comment” by August 28, 2017, this amendment will become effective October 25, 2017.

Additionally, ALL4 has learned that Subpart NNN is currently being amended again to add methanol and phenol emission limits to the currently existing formaldehyde emission limits on Rotary Spin (RS) lines. This change is required under consent agreement, and is slated to be finalized by December 2017.

As with hundreds of other state and federal regulations, ALL4 will continue to track additional changes to Subpart NNN. Please bookmark all4inc.com and subscribe to ALL4’s Air Quality Insider podcast for future updates. If you have questions about this action or you’d like assistance complying with Subpart NNN, please reach out to ALL4 at 610-933-5246.

How My Next Chapter Helps Write ALL4’s Book

I’m sitting in the Charlotte airport. My flight from Philly was delayed and I missed my connection to Columbus, OH. Now I have more than three hours to spare before the last scheduled flight out of here. I’m still panting from my sprint across the B and C Terminals as I sit down at the first airport bar I see. The work I could accomplish while I’m waiting crosses my mind…. but I think I’ll order a beer. As a baby screams behind me, I watch the lightning storm outside (which will almost definitely result in me being stranded in Charlotte tonight) and I recall how I used to think traveling for work sounded so exciting! So adventurous! So glamorous! News flash – it’s not. It usually means less sleep, more stress, less exercise, more eating out, less routine… you get the picture.

Before you start thinking I’m a pessimistic complainer (I swear I’m not), let me finish.

All of these thoughts about my current (less than ideal) situation make me take a step back and start to wonder: “Why am I here? Why am I doing this? What is the point?” And I’m not talking about the profound, existential sense of those questions; I mean literally, why am I doing this?

The answer is simple. Growth.

For most of you reading this, it won’t come as a surprise when I say that ALL4 is growing. We are a 60-person company that has doubled in both number of employees and revenue over the past 6 years. John Egan’s blog about “Who We Are” reminded our readers of our “intentional commitment to growing our business”. We are actively recruiting and hiring in each of our four offices. Recently, Tina Mathis joined ALL4 as a full-time business development professional. [Side note – that’s new for us! ALL4, being a small company where everyone “wears multiple hats”, has never had a dedicated sales team before. This doesn’t mean we are changing our consulting philosophy or our process for enrolling new clients. However, it does mean that ALL4 is dedicating significant resources for our growth intention. To me, this change is evidence that the ALL4 Principals are seriously invested in creating opportunity for our clients, employees, and partners.]

You might already know where I am going with this, but…

I am growing, too. Within the past few months, I relocated from our Atlanta office (back) to the Philadelphia office. Almost in tandem, I decided to transition from a technical role into – you guessed it – business development. This might not sound like growth (in fact, it sounds a lot more like transition), but for me, periods of change – while tough, uncomfortable, and occasionally terrifying – tend to coincide with the greatest periods of personal growth. This notion makes me think of a quote by football coach Lou Holtz, which ALL4 Principal Bill Straub sometimes likes to borrow:

“In this world, you’re either growing or you’re dying so get in motion and grow.”

So that’s great and all, but I still haven’t really answered the question of WHY?

I believe in ALL4. I believe in our clients. I believe that together we can make an impact. I believe that industrial facilities can grow, prosper, and create opportunity in their communities all while reducing their environmental impact. I believe that, in my new role, I can combine my air quality consulting experience and engineering background with my ability to grow meaningful relationships to enroll ALL4’s next client. I am energized by this opportunity and by the possibilities of the future.

Don’t get me wrong – I know this path I’ve chosen won’t always be unicorns and rainbows! I can pretty much guarantee that in the coming months years, I will hit roadblocks, get frustrated, or feel rejected (but don’t we all have those days?). However, here is my promise to my ALL4 colleagues, our clients, and our future clients. In my new role alongside Tina, I will:

Be intentional,
Embrace uncomfortable,
Stay fearless, and
Live our CORE4 (ownership, accountability, authenticity, and culture).

So, please don’t be surprised if you hear from me! I will be actively seeking input from our current and prospective clients on what we do well, what we could do better, and who may benefit from our service areas. And if you’re considering hiring a consultant, changing consultants, or have any curiosity about ALL4, give me a call (610-422-1154). Even if you just want to chat (I’m good at that), I’d love to hear from you.

And on that note, I think I’ll finish this beer…☺

Ohio EPA Requests Feedback Before Amending RACT Regulations

The Ohio Environmental Protection Agency (Ohio EPA) is planning to amend its nitrogen oxides (NO_X) reasonably available control technology (RACT) regulations, which are found at Ohio Administrative Code (OAC) 3745-110. In what is known as the Early Stakeholder Outreach step of the rule development, Ohio EPA has invited interested parties to provide input on the RACT regulations before they begin drafting the amended rule language.

The Ohio RACT regulations apply to the following source groups for facilities located in Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, or Summit Counties:

Very large, large, mid-size, and small boilers,
Stationary combustion turbines,
Stationary internal combustion engines or reheat furnaces, or
Other sources of NO_X emissions located at a facility that emits or has the potential to emit a total of more than 100 tons per year (100) of NOx emissions from all sources at that facility.

Potential amendments to the rule include: administrative corrections, revisions to site-specific requirements for three facilities in northeast Ohio, new exemptions for lime kilns and stationary internal combustion engines, and other changes based on comments received during the Early Stakeholder Outreach.

If you are interested in providing comments on the rule, Ohio EPA has proposed the following questions that may help you to develop your comments.

Is the general regulatory framework proposed the most appropriate? Should the Agency consider any alternative framework?
What options are available for improving an identified concept? What options are available for improving the existing rules?
Are there considerations the Agency should take into account when updating the existing rules? Are there considerations the Agency should take into account when developing a specific concept?
Is there any information or data the Agency should be aware of when developing program concepts or rule language?

The deadline for submitting comments is fast approaching; Ohio EPA is accepting Early Stakeholder Outreach comments through close of business Friday, August 18, 2017. Comments should be submitted to:

Mr. Paul Braun
Ohio EPA Division of Air Pollution Control
P.O. Box 1049
Columbus, Ohio 43216-1049
(614) 644-3734
Paul.braun@epa.ohio.gov

There will be additional opportunities for stakeholders and interested parties to comment on the proposed rule language once it has been drafted by Ohio EPA. We will be watching the development of the amended RACT regulations closely. In the meantime, if you have questions about applicability or how these amendments may potentially affect you, please contact me at (610) 933-5246, extension 155, or at cchinofsky@all4inc.com.

Is Your Cleanup Site “Stuck”?

Guest article by Ross Tabachow, P.E./Excalibur Group, LLC

“Going nowhere, fast.” An odd expression, but a circumstance to which we can all relate to from time to time. But it’s a particularly unproductive circumstance when corporate resources are expended at remediation sites and there is no apparent prospect for a timely and cost-effective site closure. In fact, status quo conditions are often simply accepted or not questioned, and the result is a “stuck” site cleanup with corporate resources remaining unavailable to meet more productive business needs.

For example, you have a leaking petroleum UST site that has undergone 9 years of in-situ remediation already, and projections suggest it will likely take another 10 years to meet onsite groundwater cleanup goals and 50 years to meet off-property wells cleanup criteria. Moreover, the added cost for sticking with the status quo was estimated to be $2.5M. Instead, by taking a fresh look at the site data, a new action plan was developed that saved an estimated $2.3M and cut the cleanup timeframe down to 2 years. The substituted plan involved terminating the ineffective remediation system, excavating key secondary source soils onsite, and implementing an innovative carbon-based injection (CBI) technology. The end result? On-property groundwater achieved the cleanup goals within three months, and key off-property wells achieved and remained below the cleanup goals after a year and a half.

What if you’re a potentially responsible party of an inactive abandoned industrial facility and have already endured 15 years of site remediation that is no closer to achieving site closure? You substitute limited Polychlorinated Biphenyls (PCB) source removal (with regulatory pre-approval of the excavation limits), apply in-situ chemical oxidation to address localized groundwater contamination, and negotiate focused environmental covenant restrictions that achieve a “No Further Action” determination in less than 5 years. Again, a concerted effort motivated to realize certainty for the client’s budgeting, business planning, and future resource allocations transformed the status quo.

In these and other instances, the impetus for seeking a change often does not come from the regulatory oversight agency or, sadly, the existing site consultant. Certainly, the clients were not content with the “going nowhere fast” outcome but were at a loss as to how the status quo could be changed cost effectively. What it required was combining remedial strategy diagnostic expertise, knowledgeable design improvements, and a genuine desire to realize benefits for the client’s business. Clients do not have to accept an apparently “stuck” cleanup site. With fresh thinking and a little effort, it is possible to net site closure momentum, successful regulatory outcomes, and substantive cost savings.

EXCALIBUR GROUP, LLC manages and mitigates environmental risks and liabilities with our clients’ business objectives in mind. In our experience, the best ideas lead to client advocacy wins. See what EXCALIBUR’S customers say at:

http://www.excaliburgrpllc.com/customers-commendations/commendations/. For more information on EXCALIBUR, visit www.excaliburgrpllc.com.

Proposed Industrial Cleaning Solvents RACT Rule is Out

Does your facility use industrial cleaning solvents? If so, you should be aware that the Pennsylvania Department of Environmental Protection (PADEP) has proposed a new rule, 25 Pa. Code 129.63a – Control of Volatile Organic Compound (VOC) Emissions from Industrial Cleaning Solvents, to adopt reasonably available control technology (RACT) requirements and RACT emissions limitations for sources of VOC from industrial cleaning solvents which are not regulated elsewhere is 25 Pa. Code 129 or 130. An industrial cleaning solvent is any solvent used or applied in a cleaning activity that is formulated with one or more regulated VOCs. Per 25 Pa. Code §129.63a, a cleaning activity is defined as the use or application of an industrial cleaning solvent to remove a contaminant, such as an adhesive, ink, paint, dirt, soil, oil or grease, by wiping, flushing, brushing, soaking, spraying or a similar effort. PADEP has proposed the rule in response to the 2006 Control Technique Guideline (CTG) document for industrial cleaning solvents. States are required to implement RACT requirements for affected sources located in nonattainment areas within two years of publication of a final CTG.

Specifically, the proposed 25 Pa. Code §129.63a would implement control measures to reduce VOC emissions from industrial cleaning solvents used or applied during a cleaning activity at a cleaning unit operation, a work production-related work area or a part, product, tool, machinery, equipment, vessel, floor, or wall. Per proposed 25 Pa. Code §129.63a(e), facilities with total combined actual VOC emissions from applicable cleaning unit operations equal to or greater than 2.7 tons per 12-month rolling period, before consideration of controls, shall either (1) utilize compliant solvents (i.e., a VOC content less than or equal to 0.42 lb VOC/gal or a VOC composite vapor pressure less than or equal to 8 mm mercury at 68°F) or (2) install a VOC emissions capture system and add-on air pollution control device. Facilities with actual VOC emissions greater than 2.7 tons per 12-month rolling period will also be subject to additional work practice standards per 25 Pa. Code §129.63a(f).

Facilities that are subject to one or more of the current Pennsylvania RACT rules affecting surface coating operations should review the language of such rules to determine if the use of clean up solvents is specifically addressed by the rule. If not, then the proposed rule could impact your operations. Also, as the rule is currently written, facilities that recently completed a RACT proposal for industrial cleaning solvent operations may need to comply with the emissions limitations of 25 Pa. Code §129.63a(e), regardless of the alternative RACT proposal that was submitted to PADEP. The proposed rule, published in the Pennsylvania Bulletin (Volume 47 Number 24, 47 Pa.B. 3356) on Saturday, June 17, 2017, can be reviewed here. Comments on the proposed rule are due to PADEP by August 21, 2017. If you would like assistance in developing comments in response to the proposed rule, please contact me at 610.933.5246 ext. 135 or cgiannascoli@all4inc.com.