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.

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.

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EPA Adds Additional Public Sessions to Address Repeal of the Clean Power Plan

WASHINGTON — The U.S. Environmental Protection Agency (EPA) will hold three additional public listening sessions on the proposed repeal of the Clean Power Plan in San Francisco, Calif., Gillette, Wyo. and Kansas City, Mo.

“Due to the overwhelming response to our West Virginia hearing, we are announcing additional opportunities for the public to voice their views to the Agency,” said EPA Administrator Scott Pruitt.

Public listening sessions will be on EPA’s proposed repeal of the Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (commonly known as the Clean Power Plan). Dates and specific locations will be released in coming weeks; please see the website for details. All persons wanting to speak are encouraged to register in advance.

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EPA Advances Cooperative Federalism Through Designation Process for Sulfur Dioxide and Ozone Standards

WASHINGTON (December 22, 2017) – The U.S. Environmental Protection Agency (EPA) is taking the next steps in the Clean Air Act process to determine which areas of the country meet national air quality standards for ground-level ozone and sulfur dioxide. In November 2017, the Agency designated the vast majority of U.S. counties as meeting the air quality standards set by EPA’s 2015 National Ambient Air Quality Standards (NAAQS) for ozone. EPA is responding to state and tribal recommendations for ozone designations for the remaining areas and providing additional opportunities for state, tribal, and public input on those areas’ designations. The Agency is also finalizing designations for certain areas for the 2010 sulfur dioxide NAAQS.

“Cooperative federalism is key to maintaining clean air,” said EPA Administrator Scott Pruitt. “Largely due to work by the states and new technological advances by the private sector, monitored levels of SO2 have dropped 85 percent and levels of ozone have decreased 22 percent nationwide since 1990. I am encouraged by the progress we’ve made and will continue working alongside states, tribes, and localities to determine the best methods to meet air quality standards.”

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NESHAP for Area Source Boilers (40 CFR 63, Subpart JJJJJJ)

2017-04-20 NESHAP for Area Source Boilers (40 CFR, Subpart JJJJJJ)

The national emission standards for hazardous air pollutants (NESHAP) for area source boilers (40 CFR part 63, Subpart JJJJJJ) was published in the Federal Register on March 21, 2011 and EPA finalized changes to the rule in the Federal Register on February 1, 2013 and on September 14, 2016. The September 14, 2016, action announced EPA’s final decisions on five issues regarding the February 1, 2013, amendments for which reconsideration was granted.

ESS provides comprehensive emissions testing services to meet the federal and state requirements for industrial boilers, including Subpart JJJJJJ, Subpart DDDDD, Title V, and more.  See our list of capabilities for more information or call 910.799.1055 for more information.

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EPA Answers 63 Questions About the Boiler MACT (40 CFR 63 Subpart DDDDD)

2017-04-04 EPA Q&A DDDDD

GENERAL

Q1. Can a boiler that combusts both gas and oil average its emissions when firing gas with those when firing oil?

A: As stated in 63.7522, emission averaging is only allowed between units in the same subcategory. Averaging emissions of a dual fuel unit burning oil with the emissions of the same unit when burning gas is not permitted. Under 63.7520(c), the unit’s compliance would be based on the emissions when firing oil.

 

Q2. Can a facility that is currently a major source of HAP become an area source before the first substantive date of the Major Source Boiler MACT (i.e., 2016), and comply with the Area Source Boiler MACT/GACT (NESHAP JJJJJJ) provisions? The EPA’s memorandum that was published in 1995 specifically noted the first substantive compliance date of a MACT rule as the last day to switch to an area source, before Once In, Always In takes effect.  Does this memorandum still represents EPA’s policy?

A: The “Once In Always In” Policy does represent the Agency’s policy. You are correct that a source must reduce their emissions below major source thresholds prior to the compliance date of the rule.

 

Q3. Can a facility that is a major source boiler become an area source boiler? If so, what is the latest date by which it may do so, and what has to happen by then?

A: A facility would need to become an area source before the first applicable compliance date, which would be January 31, 2016 for existing sources. The facility would need to show that their potential to emit HAP is less than 10/25 TPY, and a federally enforceable permit restriction would be one way to show emissions are below major source levels.

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Three Decades of Condensable Particulate Matter (CPM) Regulation

2017-03-17 Three Decades of CPM Regulation

WHAT IS CONDENSABLE PARTICULATE MATTER?

Condensable Particulate Matter (CPM) is material that is in a vapor state at stack conditions, but condenses and/or reacts upon cooling and dilution in the ambient air to become solid or liquid Particulate Matter (PM) immediately after discharging from the stack.  All CPM is assumed to be in the PM2.5 size fraction.

HOW DID EPA CPM REGULATIONS DEVELOP?

1987  After promulgating the PM10 National Ambient Air Quality Standards (NAAQS) the EPA began recommending that, in certain circumstances, states consider including the condensable portion of PM10 emissions in the determination of total and fine PM emissions from major stationary sources.

1991  EPA Promulgated Method 202.  The original Method used wet impingers – in which sulfur dioxide was captured and formed sulfur trioxide and sulfuric acid artifacts. This caused captures to be biased high by improperly quantifying the sulfuric artifacts as condensable PM.

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