STACK TESTING 101: EMISSIONS TESTING FOR REPORTING AND ... · Dust collector guarantee 0.002...

5/20/2019

1

STACK TESTING 101: EMISSIONS TESTING FOR REPORTING AND PERMIT

COMPLIANCE

Kathy MooreVice President Air Services

[email protected]

Indiana Chamber of CommerceEnvironmental Permitting and Reporting Conference

May 22, 2019

Discussion Items

Permit Requirements – Performance Testing Understanding operating permit requirements

Compliance with different permit conditions

Predicting result

Retaining a stack testing supplier and/or consultant

Stack Testing Recommendations

2

1

2

5/20/2019

2

Permit Requirements

Performance testing is used to demonstrate compliance with permit conditions Opacity Requirements is performance testing and covered in

IDEM regulations as well as in certain federal rules (NSPS and NESHAPs).

PM/PM10/PM2.5, VOC, NOx, CO, HAPs

For PSD Minor Limits, FESOP, Process Weight Rate, NESHAPs, NSPS – can have multiple limits on a single operation

IDEM permits spell out these requirements specifically or with references to federal requirements.

3

Emission Factor Development

Performance testing is also used to verify or set site specific emission factors. To verify emission factors not listed in accepted

databases

To set site specific emission factors lower than accepted factors EPA factors frequently 30 years old

Modern processes are more environmentally friendly

4

3

4

5/20/2019

3

Yes – Your have to read your permit!

Review your current air permit to determine stack test requirements. Timing?

Determine why the stack testing is being performed? Demonstrate compliance with a permit limit or in-house test (pretest)? OR to set a site-specific emission factor.

Determine the limits for the process in question.

5

What operations require stack testing?Are they isolated units or combined with other

sources?

If combined, how are you proposing to test the regulated units?

Are there multiple stacks on the process?

Does the process stack have test ports and straight runs allowing a stack test to be performed? (1/2 dia. up – 2 dia. down stream) Make sure port caps can be removed.

6

Permit Review

5

6

5/20/2019

4

Your Operating Permit

Limits might be stated in several parts of your permit and they all apply to your processes: Process Weight Rate

PSD Limits or Avoidance

Title V Avoidance

NESHAP

NSPS

7

What permit conditions?

What limits?

Process Weight Rule = Lbs/hr limit

PSD Avoidance = Lb/hr or Lbs/ton of process

NSPS Grain loading (gr/dscf)

Opacity

NESHAP

Grain loading (gr/dscf)

Lb/ton

Lb/hr

All of the above need to be included in stack test report.

8

7

8

5/20/2019

5

When is stack testing required?

Within 180 days after issuance of this Permit XXXX, in order to demonstrate compliance with Condition D.1.1(a), the Permittee shall perform PM and PM10 testing on baghouse controlling the…..

Within 90 days of startup……

Five years from last stack test…..

From NESHAP compliance date….

9

Example – Particulate Limits10

Shotblast Machine – multiple limits

Limits to make PSD not applicable: The particulate matter (PM) emissions after control (DC-1) from the

shot blast machine, Shot #1, shall not exceed 5.68 pounds per hour. The PM10 emissions after control (DC-1) from the shot blast machine,

Shot #1, shall not exceed 3.40 pounds per hour. The PM2.5 emissions after control (DC-1) from the shot blast

machine, Shot #1, shall not exceed 2.24 pounds per hour.

Process Weight Rate Limit The allowable particulate matter (PM) emission from Shot #1 shall not

exceed 10.72 lbs/hr when operating at 4.2 tons/hr, calculated as described below.

E = 4.10 P0.67 where E = rate of emission in pounds per hour; andP = process weight rate in tons per hour

9

10

5/20/2019

6

NESHAP Requirements11

E.2.2 National Emissions Standard for Hazardous Air Pollutants for Iron and Steel Foundries Area Sources [40 CFR Part 63, Subpart ZZZZZ] Pursuant to CFR Part 63, Subpart ZZZZZ, the Permittee shall comply with the provisions of 40 CFR Part 63.10880, for the affected source, as specified as follows:

(1) 40 CFR 63.10880(2) 40 CFR 63.10881(3) 40 CFR 63.10885(4) 40 CFR 63.10886(5) 40 CFR 63.10890(6) 40 CFR 63.10895(7) 40 CFR 63.10897(8) 40 CFR 63.10898(9) 40 CFR 63.10899(10) 40 CFR 63.10900(11) 40 CFR 63.10905(12) 40 CFR 63.10906(13) Table 1 to subpart ZZZZZ of Part 63(14) Table 2 to subpart ZZZZZ of Part 63(16) Table 3 to subpart ZZZZZ of Part 63(18) Table 4 to subpart ZZZZZ of Part 63

Initial testing and again every 5 years.

NESHAP Requirements12

E.1.2 National Emissions Standard for Hazardous Air Pollutants for Miscellaneous Coating Manufacturing [40 CFR Part 63, Subpart HHHHH] Pursuant to CFR Part 63, Subpart HHHHH, the Permittee shall comply with the provisions of 40 CFR Part 63., for the affected source, as specified as follows:

(1) 40 CFR 63.7980(2) 40 CFR 7985(a),(b)(1)(3) 40 CFR 63.7990(a),(b),(c)(4) 40 CFR 63.7995(b),(d)(5) 40 CFR 63.8000(a),(b)(2),(c)(1),(c)(3)(6) 40 CFR 8005(a)-(d),(e),(f),(g)(7) 40 CFR 63.8070(a),(b)(2),(c)(8) 40 CFR 63.8075(a),(b)(2),(c),(d),(e)(9) 40 CFR 63.8080(a),(b),(c),(d),(g)(10) 40 CFR 63.8095(11) 40 CFR 63.8100(a),(b)(12) 40 CFR 63.8105(13) Tables 1, 7, 8, 9, 10

Initial testing only –but, IDEM has general authority to require testing every 5 years –326 IAC 2-1.1-11

11

12

5/20/2019

7

What operations require stack testing?Are they isolated units or combined with other

sources?

If combined, how are you proposing to test the regulated units?

Does the process stack have test ports and straight runs allowing a stack test to be performed? (1/2 dia. up – 2 dia. down stream) Make sure port caps can be removed.

13

Prior to Stack Test

Operations requiring stack testing (continued)

Are there multiple stacks from a single process, requiring simultaneous stack tests or special approvals?

Is the process equipment exhaust captured? Limit might be imposed on fugitive sources. (GET HELP) Alternate methods of compliance

Temporary enclosures

14

Prior to Stack Test

13

14

5/20/2019

8

One More Suggestion

Determine likely stack test results.

WHAT????

Perform a calculation to determine your chances of passing the stack test.

Review design capabilities of dust collectors, scrubber, or RTOs before performing stack testing.

It is easier to adjust permit limits before failing a stack test than afterwards.

15

Likely Stack Test Results - PM

Dust collector guarantee 0.002 gr/dscf

Dust collector fan rating 25,000 cfm

So… 0.002 x 25,000 x 60 ÷ 7,000 = 0.43 pounds/hrDry collectors are somewhat related to both an efficiency rating and bag material design. Do not use efficiency and EF only.

16

15

16

5/20/2019

9

Stack Test Report

Always require a draft report to be submitted to you prior to final submission. It is not unusual to require changes to the draft report. Ensure that the source is described in the same

manner as the permit. Include the permit condition and specific references to the stack test requirement.

17

Stack Test Report

Describe the limits or rules being verified.

Make sure that process rates are included. (Test may be used as EF)

Check to make sure the units specified in the permit are listed on the stack test results. (lbs/ton, lbs/hr. gr/dscf, etc.)

Make it easy for regulators to see that you passed the test.

18

17

18

5/20/2019

10

Stack Test Report

Review the final report but remember there is a requirement to turn it in to regulators within a specified time frame (IDEM 45 days).

Submit the final stack test to regulatory agency on time or request an extension to correct irregularities.

Submit the stack test with a cover letter stating the purpose of the stack testing.

19

How do you get help?

IDEM Web-site has a list of consultants that perform environmental consulting services as well as stack testing.

Stack Testing Typically clients require two or three prices

unless they have history with certain stack test suppliers.

20

19

20

5/20/2019

11

Summary

Do your homework and don’t assume the stack testing supplier knows your processes or permit requirements.

Communicate with the Agency, Stack Test Team, and Plant Management.

Make sure Permit limits are achievable.

Review the stack test report to make sure it meets the requirements of your operating permit and your future needs.

21

Questions?

Kathy MooreKERAMIDA Inc.Tel: (317) [email protected]

22

21

22

5/20/2019

12

Avoiding Stack Testing Problems

Dave Cline, Chief

Compliance Data Section

IDEM – Office of Air Quality

[email protected]

(317) 232‐8443

Review your Draft Permit …Please

• Detailed review by qualified staff essential

• Check descriptions, capacities, air pollution control device parameters, etc.

• Consultants may be useful in some situations

• Correct problems while the permit is in draft form!

23

24

5/20/2019

13

Draft Permit ReviewAreas of Concern

• Facility description/maximum capacity of each unit not accurate or cannot be achieved

• Multiple units tied to common control or controls venting to common stack

• Control device permitted ranges

• Applicable timeframes/deadlines

Draft Permit Review (cont.)

• Thoroughly review modifications – permit conditions may change

• NSPS/NESHAP applicability (The “E” Section)

• Limitations and requirements will not be spelled out in the “E” section

25

26

5/20/2019

14

Test Protocol Submittal Requirements

• For state sources, 35 days in advance of the test date per 326 IAC 3‐6‐2 (if actual date has not been set or if test must be rescheduled, 14 day notice is required per 326 IAC 3‐6‐2(h)

• For 40 CFR Part 63 (NESHAP), 60 days unless a different timeline is contained in an individual rule.

Protocol Review

• Two important reviews of the test protocol

• Internal review by the source

– If a consultant is used the company must stay involved with the protocol

• Compliance Data Section Review

– Does the protocol contain all required elements and address all units to be tested?

27

28

5/20/2019

15

Common Protocol Problems

• Late submittal

• Proposed operating speed concerns

– Flag raisers! ‐ max, 95%, as hard as possible, unknown, blank

• Visible emissions?

• No stack information (to be determined?)

• No rule applicability information

What to Expect During Stack Testing

• An agency representative may be on site to verify/assist with the following:– Production rates at agreed upon levels and are being recorded

– Control device parametric monitoring being recorded

– Contractor conducting the test acceptably– Provide assistance and technical interpretations of:

• State or federal regulations• Method changes or modification requests

• Other testing questions as applicable

29

30

5/20/2019

16

• Delays – Plan for delays during the test

– Make arrangements to operate at maximum capacity for as long as possible on test day• If timing is critical discuss this with your test consultant

– Identify personnel or staffing issues and make arrangements prior to testing• Union breaks

• Shift changes

• Normal plant hours of work

What to Expect During Stack Testing(cont.)

• Perform testing within applicable timeframes

• Designate a company contact familiar with the unit and its operations

• Inform agency personal of safety concerns and provide escort if necessary

• Perform testing according to the approved test plan

• Record production information and control device parameters as necessary

• Ensure test reports submitted to IDEM within 45 days of testing

What are Your Responsibilities During Stack Testing?

31

32

5/20/2019

17

• Testing cannot be completed within permitted timeframes

– Extensions cannot be granted; enforcement discretion may be extended

– Requests must be received prior to the testing deadline

– A VL is not an NOV

Common Stack Testing Problems


• Rescheduling test dates (what is your deadline for testing?)

– If possible give yourself some room between the deadline and the scheduled test date

– Don’t call to reschedule tests on short notice

33

34

5/20/2019

18


• 14 day notice clarification 326 IAC 3‐6‐2(h)

– The stack test protocol, if it contains a test date which has not changed, satisfies this rule

– Any test rescheduled inside of 14 days needs approval by rule

• Source finds on test day they cannot achieve 95% of maximum capacity

– May test at lower rates with certain limitations

– In some cases test results may be acceptable

– Source may be asked to de‐rate the unit

– Source may be asked to retest if certain production levels are achieved in the future


35

36

5/20/2019

19

• Source wishes to halt a compliance test

– Depending on when the test is halted you must still submit any results obtained

• Test halted prior to its commencement

• Test halted during the testing

– Any data obtained may be used as credible evidence of a violation



• Malfunctions during testing

– Discuss immediately with on‐site observer if present

– Call CDS to discuss if no observer on‐site

– Much harder to claim malfunction after the testing has been completed and results indicate non‐compliance

37

38

5/20/2019

20


• How many test runs do you need?

– Generally 3 with some exceptions in NSPS or SIP tests

• May be able to accept two runs in some circumstances

– Both runs below the compliance limit

– Both runs show good precision

– Some risk involved with < 3 runs

– Always 3 with NESHAP testing


• The goal is to complete at least 3 good test runs

– If a test is lost and you have the ability while on‐site, then complete another run

39

40

5/20/2019

21

Parametric Monitoring Concerns

• Parametric monitoring (ranges and implications)

– Testing when out of range/range establishment during testing

• Testing of thermal oxidizers and temperature parametric monitoring

Submittal of In‐House Tests

• In‐house testing – is it acceptable?

– What is in‐house testing?

• Testing done without protocol submittal

• Generally in‐house testing is not accepted for compliance purposes

• IDEM often allows it for emission factor (EF) development but you will probably be asked to verify the EF in the permit

41

42

5/20/2019

22

Representative Testing

• Representative testing done according to the nonrule policy document (Air‐034) and meeting the requirements of the policy may be accepted

– Done at an identical at another facility

– Potential to emit of unit less than 250 TPY

– Emissions less than 50% of applicable limit

– Approved by a different state agency

Submitting Test Reports

• Reports should be submitted for each test where a protocol was submitted

• Reports for partial tests or tests that were stopped should be submitted

• Reports where the company is claiming malfunction should be submitted

43

44

5/20/2019

23

Examples of Testing Problems

• Permit requires testing for nonexistent limits

• No power – at a power plant

• Port caps stuck/ports clogged/ports filthy

• Source used wrong fuel on day of test

• Source/tester changes protocol on the fly

• Stack testers do poor quality work

– Not punctual

– Fail to submit protocols/test reports within timeframes

– Constantly correcting submittals

– Making assumptions with their client’s testing

– Smaller problems are often an indicator of bigger ones


45

46

5/20/2019

24

• Stack testers should be actively involved with you in learning your facility

– Questions regarding such items as:

• Stack dimensions

• Stack temp, moisture, airflow

• Process conditions

• Special considerations?


• Poor communication within company, and between testers

– Get everyone involved and on the same page

• Operators

• Technical staff

• Testers


47

48

5/20/2019

25

• Environmental extremes

– Avoid testing at certain times of the year if possible

– Heat exposure and access/escape concerns

– Cold exposure and the realities of how people and equipment function in cold weather


Compliance and Technical Assistance Program (CTAP)

49

50

5/20/2019

26

CTAP provides free and confidential compliance and technical assistance, training on environmental requirements and regulations, and online resources to regulated entities to support environmental compliance.

CTAP assistance is:

• Nonregulatory – CTAP staff members are not regulators and do not have regulatory authority. Businesses will not be penalized for reporting relevant environmental information to CTAP when requesting assistance.

About CTAP

• Free and Confidential – While CTAP staff members serve as liaisons between IDEM’s regulatory programs and businesses, they do not provide any details about the company to regulators, as the information is protected under Indiana Code 13‐28‐3‐4.

• Flexible – CTAP’s staff provides assistance through on‐site visits or by phone or email, and will provide a full compliance review or just target a single issue.

• Multimedia – CTAP staff members are knowledgeable in air, water, land, and Community Right‐to‐Know regulations and are happy to answer questions in these areas.

About CTAP (cont.)

51

52

5/20/2019

27

Hotline: (800) 988‐7901

Email: [email protected]

Website: www.idem.IN.gov/ctap

For CTAP Assistance

CTAP staff members assist businesses that:• Contact them directly• Are referred by regulatory inspectors or permit writers• Are impacted by a new U.S. Environmental Protection

Agency or state regulation.

About CTAP (cont.)

Questions?

Dave Cline, Chief Compliance Data Section

IDEM – Office of Air Quality

[email protected]

(317) 232‐8443

53

54

STACK TESTING 101: EMISSIONS TESTING FOR REPORTING AND ... · Dust collector guarantee 0.002...

Documents

Transcript of STACK TESTING 101: EMISSIONS TESTING FOR REPORTING AND ... · Dust collector guarantee 0.002...