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

Posted: May 23rd, 2016

Authors: Kristin G.

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 (NO_X), 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, NO_X, 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:

What resources do I have internally? What external resources do I need to utilize? Have I allocated budget for the ICR?
What furnace/decoker am I going to test? What heat exchange system am I going to test?
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)?
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).