Important Update Regarding Hurricane Florence

NJ Issues Advisory for Air Permits Issued Prior to 1998

 

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Immediate Action Required for Air Permits Issued Prior to 1998

Who is affected by this advisory?

Air-regulated facilities with equipment or sources permitted under pre-construction permits with activity numbers beginning with PCP96 and/or PCP97 are affected by this advisory; for example, PCP960001 and/or PCP970001. These activity numbers are referred to as pre-NJEMS and are permits that were approved before the existence of the DEP’s New Jersey Environmental Management System client-server application, commonly known as NJEMS.

 

What is the background information regarding this advisory?

Before 1998, facilities used paper forms to complete their air permit applications (pre-NJEMS permits). In 1998, the DEP implemented NJEMS, and the Remote AIMS Data Input User System (RADIUS) was used to allow for electronic submittal of air permit applications into NJEMS. After 1998, the pre-NJEMS permits were created in NJEMS for facilities that listed only one piece of equipment and no compliance plan. An activity number was created for each paper permit (the preconstruction permits beginning with 96 and/or 97). The DEP currently maintains about 5,000 preNJEMS permits, of which about 800 are expired.

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Industry Pushes EPA to Continue Implementing MATS Rule

In a letter to EPA air chief Bill Wehrum released July 10, Edison Electric Institute, along with other industry trade groups, urged the government to keep the air toxics standards largely intact.  The about-face comes after years of legal battles to halt implementation of the Mercury and Air Toxics Standards (MATS) earlier this decade.

“It is important to note that all covered plants have implemented the regulations and that pollution controls—where needed—are installed and operating,” the letter read.

“We believe a complete and robust RTR [Residual Risk and Technology Review] will recognize the capital investments already made for compliance and will allow the industry to continue full implementation of the MATS rule, which was completed in April 2016.”

“Therefore, we urge EPA to move forward with an RTR for power plants under CAA [Clean Air Act] section 112 and to leave the underlying MATS rule in place and effective.”

The letter comes as Wehrum said in April that EPA was still considering how to proceed after the Supreme Court’s ruling generally upholding the standards with concern over the expensive price tag associated with compliance measures.

The power industry appears to be seeking regulatory certainty after the bid to block the rule outright failed.  There is evidently concern that continued legal hesitation on the MATS rule could create additional problems.

See the letter here.

OSHA Enforcing New Silica Dust Standard

OSHA has released a memoradum outlining the provisions of its respirable crystalline silica in general industry and maritime standard.

The standard’s provisions, which will be enforceable beginning June 23, establish a new 8-hour time-weighted average permissible exposure limit, action level and associated ancillary requirements.

The agency will offer compliance assistance during the first 40 days of enforcement and will continue to issue interim enforcement guidance until a compliance directive on the new standards is finalized.

OSHA’s Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime discusses methods of compliance, such as using engineering and work practice controls, assessing exposure levels, respirator use, medical surveillance and written exposure plans.

EPA Amends Two Provisions of 2016 NSPS for Oil and Gas Industry

WASHINGTON — EPA has finalized amendments for certain requirements contained within the 2016 oil and gas New Source Performance Standards (NSPS) and proposed to withdraw the control techniques guidelines (CTG) – an action that EPA estimates would save $14 to $16 million in regulatory compliance costs for the oil and gas industry from 2021-2035.

“The technical amendments to the 2016 oil and gas NSPS are meant to alleviate targeted regulatory compliance issues faced by affected sources,” said EPA Office of Air and Radiation Assistant Administrator Bill Wehrum.  “While this action addresses an immediate need, it does not deter the ongoing work at the Agency to assess the 2016 rule as a whole, including whether it is prudent or necessary to directly regulate methane.”

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Why Are Sampling Ports Required to be 90 Degrees Apart?

Why Are Sampling Ports Required To Be 90 Degrees Apart?

This question often arises regarding the requirement to place sampling ports 90 degrees apart in order to be Method 1 compliant.  This article will explain why this requirement is important to keep in mind during stack construction or alteration.

Quick Overview of EPA Method 1

Diagram 1

  1. The flow through the stack at the port location must be minimally cyclonic.
  2. For Method 1, the stack diameter must be 12 inches or greater or 113 square inches in a cross-sectional area–Method 1A includes ducts that are between 6 and 12 inches.
  3. The sampling plane must be located more than two stack diameters downstream from the nearest upstream disturbance and more than half a stack diameter upstream from the stack exit or next downstream disturbance. (See Diagram 1).
    1. A minimum of two (2) test ports 90° apart must be installed on the sampling plane
    2. Common sense dictates that four (4) ports are preferred to allow for multiple trains and train maneuverability.
    3. Platform width should be greater than 4 feet from the stack to the handrail.

 

(See the original blog post for more details on the above)  (See the full text of EPA Method 1)

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Proposed Changes to EPA Method 202 for Condensable Particulate Matter (CPM)

On August 23, 2017, the U.S. Environmental Protection Agency (EPA) proposed technical revisions and editorial changes to clarify and update the procedures specified in Method 202.

Method 202 describes the procedures that stack testers must follow to measure condensable particulate matter (CPM) emissions from stationary sources. It is known as the “dry impinger” method.  The proposal does not modify the method significantly. It is in line with steps EPA has taken since 2010 to improve the implementation of the method and promote consistency in the measurement of CPM.

EPA is proposing the following revisions to Method 202:

  • Revisions to the procedures for determining the systematic error of the method, which is used to correct the results of the measurements made using this method;
  • Removes some procedural options to the method to standardize the way method is performed while also eliminating the potential for additional blank contamination;
  • Revise overly prescriptive requirements for the method specific reagents and equipment with more flexible performance-based criteria; and
  • Revise the method to correct inconsistent terminology, improve the readability, and to simplify the text to aid in consistent implementation of the method.

BACKGROUND

In 2010, the EPA revised Method 202 for determining condensable particulate matter (PM) from stationary sources to improve the measurement of fine PM emissions. These revisions increased the precision of Method 202 and reduced potential bias. The revisions improved the consistency in the measurements obtained between source tests performed under different regulatory authorities.

In 2014, the EPA issued interim guidance on the treatment of CPM results in the Prevention of Significant Deterioration (PSD) and Nonattainment NSR Permitting Programs. The guidance addressed concerns that the use of source-specific CPM test results obtained with Method 202 could include a positive bias — resulting in the overestimation of emissions due to the potential for blank contamination associated with the implementation of Method 202. As part of this guidance, the EPA announced plans to issue guidance on best practices for Method 202 implementation and to revise Method 202 as necessary.

In 2016, EPA issued the Best Practices Handbook to mitigate the bias concern, which was developed with significant input from stakeholders and trade groups. The proposed technical revisions incorporate the findings from the handbook.

FOR MORE INFORMATON

EPA Issues New Emissions Factors for Enclosed Ground Flares

Background

On February 5, 2018, EPA completed its review of the emissions factor for volatile organic compounds (VOC) for flares at natural gas production sites pursuant to section 130 of the Clean Air Act.

EPA evaluated test data available to the Agency for elevated and enclosed ground flares from natural gas production sites.  The agency’s review of available flare data did not result in a revision to this VOC factor, which remains available for estimating VOC emissions from elevated flares at natural gas production sites.

EPA has developed two new THC emissions factors for enclosed ground flares at natural gas production sites.  The EPA recommends the use of the new THC emissions factors to estimate VOC emissions for enclosed ground flares with the SCCs specified in Table 1, as this new emissions factor is based on field data from similar units.  Additionally, EPA has developed four new THC emissions factor for enclosed ground flares at certain chemical manufacturing processes.

Additional information about the review of the factor is below.

[Read more…]

Fuel Economy Reaches New Record, Manufacturers Meet Greenhouse Gas Standards, EPA Reports Show

EPA issued two annual reports that provide information on fuel economy and greenhouse gas emissions from light duty vehicles in the United States. The reports show auto manufacturers continue to innovate and make progress increasing fuel economy and reducing pollution.

The Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975-2017 report is the authoritative reference for real world fuel economy, technology trends and tailpipe carbon dioxide emissions, for new personal vehicles sold in the U.S. every year since 1975.  The report shows fuel economy for the U.S. fleet continues to improve.  Model year (MY) 2016 vehicle fuel economy was 24.7 mpg, slightly higher than MY 2015, and a record high overall. Since MY 2004, fuel economy and CO2 emissions have improved in ten out of twelve years.

The Manufacturer Performance Report assesses compliance performance for individual automakers and for the U.S. fleet as a whole with the greenhouse gas emissions standards for light duty vehicles.  This year’s report shows all manufacturers are in compliance with the standards.

EPA, the Department of Transportation, and the California Air Resources Board implement coordinated regulations for passenger cars and light trucks on fuel economy and GHG emissions.

The Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975-2017: https://www.epa.gov/fuel-economy-trends/highlights-co2-and-fuel-economy-trends

Manufacturer Performance Report:  https://www.epa.gov/regulations-emissions-vehicles-and-engines/greenhouse-gas-ghg-emission-standards-light-duty-vehicles.


Source:
EPA Press Office ([email protected])


ESS provides emissions testing, air quality analysis, and ambient air testing services for municipal water treatment plants, public utilities, manufacturers, paper mills, and other industrial facilities in the US and overseas.  Since its inception in 1979, ESS has conducted thousands of emissions tests and provided countless hours of environmental consulting services.  ESS specializes in conducting the EPA testing methods for all applicable EPA subparts, such as: NSPS (40 CFR 60), NESHAP (40 CFR 63), RATA (40 CFR 75), and various other federal and state regulations.

Call us at 910.799.1055 to request a quote for your next stack emission test project.

What is the Ozone Transport Region and Why Are States Suing the EPA to Enforce It?

Although the issue of pollution carriage was first addressed by the EPA in 1990, there appears to be a growing concern among state regulatory authorities that the current measures taken by the EPA are not stringent enough.  This article will provide an overview of existing regulations and current complaints against the EPA in an effort to inform readers of this re-emerging air quality regulation issue.

What is the Ozone Transport Region?

In 1990, Congress established the Ozone Transport Region (OTR) in the federal Clean Air Act (Section 184(a)) in order to address air pollution in downwind states that is caused by activities in upwind states.  The OTR is essentially a single, 13-state ozone nonattainment area.  The original member states of the OTR are: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, parts of Virginia and the District of Columbia.

The Clean Air Act contains what is known as a “good neighbor” provision, which requires states to examine whether pollution generated in their state contributes to poor air quality in another. If a significant contribution is found, the state must adopt measures to alleviate this contribution and include these measures in its State Implementation Plan. EPA must approve these plans.

[Read more…]

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