PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated!
Did you know that the Pennsylvania Department of Environmental Protection (PADEP or Department) Continuous Emissions Monitoring (CEM) Section within the Division of Air Quality released an updated Frequently Asked Questions (FAQs) document to support Continuous Source Monitoring Manual Revision No. 8 (CSMM Rev. 8) on October 8, 2019? Well if not, don’t worry, because now you do! The updated document provides a reference point for certain gray areas within CSMM Rev. 8 and continuous monitoring in the Commonwealth of Pennsylvania. This article will be the first of several that detail PADEP’s most recent responses to questions related to CSMM Rev. 8.
The first question and answer (Q&A) we’ll discuss is related to the use of a diluent cap for diluent carbon dioxide (CO2) and oxygen (O2) monitors. What is a diluent cap? A diluent cap is utilized for instances in which the heat input of a boiler or stationary gas turbine approaches zero (i.e., whenever the CO2 or O2 concentration is at or near ambient air levels, such as during unit startup and shutdown). During these operating scenarios, calculated pollutant emission results often spike to non-representative levels that result in violations of an existing emission standard. The non-representative pollutant emission results are typically caused by extremely high or low diluent CO2 or O2 concentrations measured by the CO2 or O2 analyzer and subsequently used to calculate pollutant emissions rate (lb/MMBtu). When diluent CO2 or O2 concentrations reach such levels, the calculated pollutant emissions that utilize these values become unrealistic and not representative of operations. So how do we handle these scenarios? Well, prior to this updated FAQ document being published by PADEP, 40 CFR Part 75, Appendix F was often referred to for guidance addressing these scenarios because 40 CFR Part 75 provides an option for the calculation of nitrogen oxide (NOX) emissions (lb/MMBtu) with the use of a “diluent cap”. The diluent cap provision allows for the substitution of more reasonable CO2 (minimum 5.0% CO2) or O2 (maximum 14.0% O2) concentrations during instances in which the hourly average CO2 concentration is <5.0% CO2 or the hourly average O2 concentration is >14.0% O2. Thus, the diluent cap functions to correct these unrealistic emissions that are calculated during shutdown/startup scenarios.
We know what a diluent cap is, what the purpose is, and where it comes from. However, if you aren’t a source continuously monitoring for NOX subject to the requirements of 40 CFR Part 75 this is only guidance that can be referenced as supporting evidence in your petition to PADEP to utilize a diluent cap. And prior to this updated FAQ document, the mention of a diluent cap in CSMM Rev. 8 (in the “Quality Assurance” section), states that if sources are subject to Federal requirements for diluent caps, they must petition the Department for use of such substituted data for PADEP purposes. With this recently released FAQ document from the Department, we now have specific guidance from PADEP applicable to boilers or stationary gas turbines required to monitor emissions on a lb/MMbtu basis. So, what does PADEP say about diluent caps?
- For boilers, the diluent cap requirements are identical to what 40 CFR Part 75 details for NOX emissions rate (lb/MMBtu) – a minimum concentration of 5.0% CO2, or a maximum concentration of 14.0% O2 can be substituted for the measured diluent gas concentration value for any operating hour in which the hourly average CO2 concentration is <5.0% CO2 or the hourly average O2 concentration is >14.0% O2.
- For stationary gas turbines, the requirements change – a minimum concentration of 1.0% CO2 or a maximum concentration of 19.0% O2 may be substituted for measured diluent gas concentration values for any operating hours in which the hourly average CO2 concentration is less than 1.0% CO2 or the hourly average O2 concentration is greater than 19.0% O2.
PADEP also notes that substitution of the diluent concentration must occur at the hourly level – you should not substitute data at the minute level and include any “normal” diluent concentrations in the hourly average. Additionally, for quarterly reporting purposes, for hours in which the substituted diluent data is utilized, a Monitoring Code (MC) 99 and Method of Determination Code (MODC) 14 should be utilized, unless otherwise stated by the Department in the petition approval letter. We can’t forget about that last part – if you want to utilize either of the previously described diluent cap provisions mentioned in the FAQ document, you still must petition the Department for use of a diluent cap. And in addition to petitioning the Department on the use of a diluent cap, you will also have to work with your data acquisition and handling system (DAHS) vendor to ensure the MC and MODC stipulated by PADEP for these scenarios are successfully incorporated into your quarterly electronic data reports (EDR).
If you have any questions about diluent caps, or any other general continuous monitoring system (CMS) questions, please reach out to me at (610) 933-5246 extension 139, or at mcarideo@all4inc.com. Lastly, don’t forget to keep an eye out for our next article that goes over PADEP’s response to the question “How is a 3-hour average, rolling by one hour calculated?” That’s right, there is more than one way to calculate a 3-hour rolling average – let’s get clear on how it is done in Pennsylvania.
Did you know there are 5 emissions trading programs in Texas?!
This blog is the first in a series where I will discuss Texas Emissions Banking and Trading (EBT) programs specifically in the Houston-Galveston-Brazoria (HGB) region. In this edition, I will explain what EBT programs are, the purpose they serve, the different types of programs, and the requirements for following their regulations.
At the publish date of this article, the HGB region has ozone levels above the National Ambient Air Quality Standards (NAAQS), making it a non-attainment area for ozone. Because of this, a State Implementation Plan (SIP) is required. The purpose of a SIP is for states to reduce emissions with the goal of reducing pollutant levels back below the NAAQS. One of the most popular ways for states to reduce emissions is by implementing EBT programs. EBT programs provide facilities flexibility in their methods to reduce emissions and in permitting matters.
There are two main categories of EBT programs; voluntary and mandatory. The voluntary EBT programs are the Discrete Emission Credit (DERC) program (30 Texas Administrative Code [TAC] Chapter 101, Subchapter H, Division 4) and the Emission Reduction Credit (ERC) program (30 TAC Chapter 101, Subchapter H, Division 1). Mandatory EBT programs are the Emissions Banking and Trading of Allowances (EBTA) program (30 TAC Chapter 101, Subchapter H, Division 2), the Highly Reactive Volatile Organic Compound Emissions Cap and Trade (HECT) program (30 TAC Chapter 101, Subchapter H, Division 6), and the Mass Emissions Cap and Trade (MECT) program (30 TAC Chapter 101, Subchapter H, Division 3).
The voluntary EBT programs give facilities the opportunity to generate emission reduction credits by making permanent emissions reductions (e.g., permanent shutdown of an emissions unit, installation of an air pollution control device) at their facilities. These credits can be used in many ways. One popular way to use emission reduction credits is for offsets for a new source or major modification to an existing source.
Facilities that are required to participate in mandatory EBT programs (e.g., emissions cap and trade programs) must cover their emissions that exceed their allocations by purchasing additional allowances. These programs give the Texas Commission on Environmental Quality (TCEQ) an avenue to control emissions in nonattainment areas, for example in the HGB region to bring ozone levels back down below the NAAQS.
Stay tuned for an upcoming edition of 4 The Record where I will discuss more in depth about the MECT program which affects major sources in the HGB region. If you have any questions regarding this blog, please do not hesitate to reach out to me at thenson@all4inc.com or 281-937-7553 x308.
ALL4 at the Environmental Federation of Oklahoma Conference
With conference season in full “swing”, just as the baseball season is coming to a close, ALL4 has been hitting the road and attending conferences. On October 8-9, 2019 ALL4 attended the Environmental Federation of Oklahoma (EFO) Conference held in Oklahoma City, OK. In Oklahoma, there has been legislative activity impacting various media, including air, waste, and water. This year’s EFO Conference underscored regulatory updates. Through this blog, my intent is to share a summary of some important topics discussed and the key takeaways from each of those topics.
Specifically, as it relates to air quality the following four topics were highlighted:
- Oklahoma’s Environmental, Health, And Safety Audit Privilege Act
- Per- and polyfluoroalkyl substances (PFAS)
- Continuous Emissions Monitoring Systems (CEMS) Regulatory Interpretation
Oklahoma’s Environmental, Health, And Safety Audit Privilege Act
Hot off the press! Oklahoma’s Environmental, Health, And Safety Audit Privilege Act (abbreviated hereafter as the Act) became effective on November 1, 2019. See the complete Bill information on the Oklahoma State Legislature’s website: here. The Act, which was heavily inspired by a similar program implemented by the Texas Commission of Environmental Quality (TCEQ), creates a level of immunity for companies from administrative and civil penalties by conducting a voluntary audit. In order for a successful audit, a four-step process must be followed, including: [1] the submission of a Notice of Audit (NOA), [2] the submission of Disclosure of Violations (DOV) [3] the submission of an extension request (if needed) and [4] the submission of the Conclusion of Audit. A good resource for you to evaluate your facility’s environmental compliance to uncover potential unknown environmental liabilities without the concern for actions is by conducting an audit in accordance with the Act. If you need help conducting an audit or have questions about Oklahoma Department of Environmental Quality’s (ODEQ’s) procedure reach out to us. ALL4 has assisted our clients in TX commence, execute and complete audits under TCEQ’s Environmental, Health, And Safety Audit Privilege Act, on which ODEQ has based their Act. We can leverage our experience with TCEQ’s Environmental, Health, And Safety Audit Privilege Act to support audits within Oklahoma.
PFAS
As our very own Kristen Aune eloquently explained in her blog, Sticky Situation: What You Should Know About PFAS, PFAS is center stage on both a Federal and State level. To cater to the rising need for PFAS education, an entire two-and-a-half-hour session was dedicated to discussing potential regulatory nuances and testing requirements associated with PFAS. Topics ranging from a general overview of the risks, uses, sources and exposures of PFAS to a summary of ODEQ’s evolving approach towards addressing PFAS and their acknowledgment of how difficult it can be to sample and create field and laboratory testing programs. While there was a lot of buzz around PFAS at the EFO Conference, there still remains a significant amount of uncertainty associated with these compounds. Stay tuned for updates from our team. If you have additional questions, reach out to our team at info@all4inc.com.
CEMS Regulatory Interpretation
Our very own Eric Swisher has been instrumental in working alongside Oklahoma industry, the U.S. Environmental Protection Agency (U.S. EPA) and ODEQ on a very interesting issue regarding the interpretation of CEMS monitor downtime. While I won’t delve into fine details, this topic illustrates an example of how ALL4 is continuing to shape environmental responsibility throughout the U.S., I will share the conclusion. Essentially where things landed is following approximately a two-year process, on June 13, 2019 U.S. EPA withdrew a Regulatory Interpretation that would have changed the way hourly averages were evaluated as it relates to CEMS data. If you’d like to understand more background details of the interpretation and its potential implication’s check our one of Eric’s original presentations located here.
Be sure to stop by our booth next year at the 29th annual EFO Conference to be held in Tulsa, OK. In the meantime be sure to reach out to me if you have any additional questions or comments about the conference or our work within Oklahoma at fdougherty@all4inc.com or 281-933-5246 x302.
