Guidance on Establishing Monitoring to Comply with CAM and Other Title V Requirements

A Summary of Technical and Policy MaterialsBarrett 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

ControlDevice

Pre-controlledEmissions

Annual emissions = restrictions X emissions rate

Post-controlEmissions

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

source dust collector

Eo

Ei

Eo = 8 T/Y (measured via source test)Control Eff = 90%Ei = 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

precontrol (tpy)

postcontrol (tpy)

part 64 applicable?

large? other?

600 20 yes other (1/ day)

200 105 yes large (4/ hr)

90 25 no

110 110 no

Questions? Lunch?