Guidance on Establishing Monitoring to Comply with CAM and Other Title V Requirements A Summary of Technical and Policy Materials Barrett Parker, EPA, OAQPS

Presentation Overview Describe EPA technical guidance documents format and content Discuss procedures for designing monitoring and establishing indicator ranges Discuss monitoring design evaluation factors

Guidance Documents - Purpose and Scope Provide general and detailed guidance on the implementation of the Compliance Assurance Monitoring Rule and Other Monitoring Requirements Describe regulatory requirements and implementation procedures For industry users and permit reviewers (applicability, requirements, tools, examples) "Living" documents (will continue to add examples, other information)

General Structure and Format Explanatory chapters – Rule Overview - requirements, procedures – Monitoring elements – Description of monitoring approaches – Technical reference of monitoring tools – Bibliography Appendices – Example monitoring plans (based on actual case studies)

Step-by-step Process Description Selecting a monitoring approach (guidance includes a work sheet) – Review current procedures – Compare with CAM or PM requirements – Identify potential indicators (control device parameters) – Select reasonable approach Develop permit application submittal

Design Evaluation Factors Monitoring frequency (rule may define continuous monitoring)- general monitoring frequency concerns: Sufficient to allow calculation over appropriate averaging periods CAM rule minimum requirements: Data collection at least 4/hour for large units Data collection 1/day for other units

Design Evaluation Factors Averaging periods: Sufficient to detect control device or other potential compliance problems Not so short as to flag minor perturbations as excursions

Design Evaluation Factors Level of confidence issues: Subjective - provides reasonable assurance of proper operation and compliance Examples of confidence levels for different parameters for range of control measures provided in guidance Permit application must include justification for selections

Design Evaluation Factors Equipment needs - factors to consider Location and installation logistics Maintenance and training needs Cost factors – inherent in source owner’s planning and design

Design Evaluation Factors Selecting and justifying indicator ranges - define a basis: Parameter data collected during testing Historical data Design or engineering data From similar operations

Design Evaluation Factors Selecting and justifying indicator ranges: Type of data (e.g., instrumental or manual) Frequency Quantity of data for analysis Data variability

Design Evaluation Factors Selecting and justifying indicator ranges (continued) - performance criteria: Data measured during compliance test must fall within range Range must be indicative of good operations and compliance performance Range must be sensitive to control device changes Range should account for normal operational variability

Design Evaluation Factors Indicator range formats: Mean value + set value (e.g., + 50 F) Mean value + percent of mean Max/min value(s) observed Max/min + set value Max/min values + percent of mean Combination of more than one of above (e.g., if "x" and "y", then excursion)

Estimating pre-control emissions PSEU Control Device Pre-controlled Emissions Annual emissions = restrictions X emissions rate Post-control Emissions

Determining Emissions Rates Emissions testing – EPA test methods – Control device inlet and outlet Mass balance measurements – e.g., VOC from solvents – Chemical reactions Emissions factors X activities data Other?

Mass balance example: coal-fired boilers Coal-fired boiler – 9% ash – 12,000 Btu/lb Calculate precontrol emissions: 0.09 lb ash/lb coal = 7.5 lb/mmBtu 0.012mmBtu/lb coal Pulv. Coal: 90%suspended ash 6.8 lb/mmBtu Stoker: 20% suspended ash 1.5 lb/mmBtu

Mass balance example: wood working facility source dust collector EoEo EiEi E o = 8 T/Y (measured via source test) Control Eff = 90% E i = 8 {1/(1 - 90/100)} = 80 T/Y

Uncertainty Emissions testing data – Accurate but short term – Do not represent process upsets Emissions factors (e.g., AP-42) – Variable from SCC to SCC – Can easily be factor of 2 Emissions control efficiencies – Higher efficiencies (e.g., >90%) can lead to huge errors in calculating precontrol emissions

Part 64 applicability examples

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