AWMA Meeting October 15, 2013 Stack testing issues and questions Dennis Thielen

Compliance with Permit Limits If testing fails to show compliance with permit limits –Why were limits set? Synthetic Minor, NAAQS, NESHAP, NSPS, SIP, BACT Most failures result in Notice of Violation with request for compliance plan –Failure to demonstrate initial compliance with a BACT Limit Review testing with facility –Control Equipment –Production Review test results with permit engineer –Can permit limit be increased? Options – make adjustments and retest and/or modify permit Compliance response after resolution

Testing and Flow Rate/Temp Flow Rate/Temp is +/- 25% of the permitted flow rate/Temp. –Not a violation. –Facility will need to submit construction permit modification request in accordance with Permit Condition 11.

Testing below maximum capacity. Section 12 of Permit –The unit(s) being sampled should be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.

Testing below maximum capacity. If unit fails to test at maximum capacity Evaluation of the capacity and test result Linear extrapolation –If extrapolation predicts emissions greater than permit limit then the test is not acceptable for demonstrating compliance Notice of Violation (NOV) –Retest, or –Modify the permit and take operating limits –Current proposal made to ABI for a different approach

DNR/ABI Stack Testing Workgroup ABI requested workgroup to discuss stack testing issues such as: –Clarification on amended Methods 201A & 202 –Minimum particulate matter catches –Operating at maximum capacity during test

DNR/ABI Stack Testing Workgroup –Clarification on amended Methods 201A & 202 Joint letter sent to EPA to confirm understanding of the methods and the 85°F threshold for including condensable PM in results (>85°F must include condensable) Asked EPA if variability in ambient temperature could be used to exclude source categories from Method 202 testing (ie. testing an ambient temperature source on a hot summer day) EPA response - The 85°F threshold must be followed with no exceptions for source categories, however, a moderate level of cooling of the sampled gas to achieve a filtration temperature below 85°F is acceptable. Modest cooling provides option for facilities that want to avoid Method 202 and simplify and reduce the cost of testing

DNR/ABI Stack Testing Workgroup Minimum particulate matter catches were changed to align with amended Method 201A detection limits Design test to capture a minimum of 3 times the detection limits New minimum catches DesignLDL PM7.62 mg2.54 mg PM mg1.44 mg PM mg1.35 mg –These changes resulted in much shorter run times, previous minimum catch was 10mg

DNR/ABI Stack Testing Workgroup DNR proposed alternative for facilities that are not able to operate at maximum capacity during compliance testing Modeled proposal from Minnesota stack testing rules Tested rate would become new operating limit by rule Defines when retest is required Would develop rulemaking for this change If implemented there would be no NOV for failing to test at capacity and no permit modification needed –ABI is reviewing and considering the proposal –Others can provide comments

Contact Info Dennis Thielen Iowa DNR Air Quality Bureau Lead Worker Compliance and Stack Testing