Results you can rely on
TRC Companies, Inc.
November, 2012
TRC Companies, Inc.
July 2009

Jeff Thomason, QSTI
Project Director, TRC Air Measurements
9225 U.S. Highway 183 South
Austin, Texas 78747 jthomason@trcsolutions.com
512/243-0202
Results you can rely on
2

Safety Moment
• Most of the time, the most dangerous thing we do is drive to work. Try not to let it become routine. Take a different route occasionally. Stop at a different place for your morning coffee.
• Even if it’s your personal vehicle, do your walk around just to make certain. Your kids can pick up your good habits, too.
• If there’s a vehicle in your mirror and you don’t know where it came from, check your mirror more often.
• Always wear your seatbelt, and put your phone up.
• Remember, all those people who claim you owe them money will still want it if you die.
Results you can rely on
3

Resources
• Electronic Code of Federal Regulations:
– ecfr.gpoaccess.gov
– Enter “40” at Title
– Enter “Subpart JJJJ” or “Subpart ZZZZ” at Retrieve
• EPA - TTN EMC - Emissions Measurement Center
– epa.gov/ttn/emc/
– All promulgated EPA test methods
• State and Territorial Environment Agencies | US EPA
– epa.gov/epahome/state.htm#CA
– Links to all state/regional regulatory agencies
• jthomason@trcsolutions.com
– I’ll talk to you if I can, and won’t charge you for phone time
Results you can rely on
4

Air Quality Regulation Drivers
• Clean Air Act (CAA)
• Past Actions, Current Status, and Projected Path
Forward
– NSPS – New Source Performance Standards
– NESHAP – National Emission Standards for
Hazardous Air Pollutants (HAPS)
– Ozone NAAQS – National Ambient Air Quality
Standards
– NO
2
NAAQS
– Fine Particulate
– Greenhouse Gas Emissions
Results you can rely on
5

The Way it Works
Results you can rely on
6

Terms and Acronyms
• NSPS – New Source Performance Standards
• SIP – State Implementation Plan
• VOC – Volatile Organic Compounds: non-methane, non-ethane hydrocarbons
• NESHAP – National Emission Standards for
Hazardous Air Pollutants (HAP)
• NSR – New Source Review
• SI – Spark Ignition
• CI – Compression Ignition
• ICE – Internal Combustion Engine
• RICE – Reciprocating Internal Combustion Engine
Results you can rely on
7

Terms and Acronyms
• CFR – Code of Federal Regulations
• PSD – Potential for Significant Deterioration
– A new major source with the potential to emit >100 tons/year of 28 specific pollutants OR >250 tons/year of a single pollutant
• BACT – “Best Available Control Technology”
– Case-by-case analysis under PSD for NEW units
– No less stringent than NSPS; must be an emission limitation
– “Top-down” five step process for BACT analysis
Results you can rely on
8

Terms and Acronyms
• BACT (continued)
– Identify ALL potential controls
– Eliminate infeasible options
– Rank controls by their effectiveness
– Evaluate economic ($/ton), energy and environmental impacts
– Select BACT and create permit limits
Results you can rely on
9

Terms and Acronyms
• RACT – “Reasonably Available Control Technology”
• Is broadly applicable (State Rule) for EXISTING units
– “The lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.”
• MACT – “Maximum Achievable Control Technology”
• Designed to reduce the effect of industry HAPS
– Based on emissions achieved by best performing sources
– Control technology can include process as well as equipment
Results you can rely on
10

Key Emissions
• Combustion by-products
– NOx, CO, VOC
 NOx reacts in the atmosphere to form ozone and fine particulateNOx is a “precursor” to ozone and PM
2.5
– NOx = NO + NO
2
– VOC is also an ozone precursor
– Hazardous Air Pollutants – HAPS
 Formaldehyde-combustion by product; aldehydes are HAPS
 EPA Required to develop NESHAP standards – CO used as a surrogate for lean burn engines
11
Results you can rely on

Key Emissions
• Greenhouse Gases
– CO
2
from combustion
 Methane and N
2
O from combustion also reported
– Methane from fugitives (leaks) and venting
Results you can rely on
12

Schedule Overview for EPA Rules
• CAA requires EPA to develop regulations and complete timely review of existing rules
– Review NAAQS every 5 years
– Review NSPS/NESHAPS every 8 years
• Historically, EPA did not fulfill obligation
– In recent years, lawsuits have forced EPA to abide by CAA schedule
– EPA loses the lawsuits
• EPA and litigants typically agree to Consent Decree
Schedule
– EPA typically meets court ordered deadlines: firm dates
– Most recent EPA rules driven by Consent Degree Schedules
Results you can rely on
13

Primary CAA Rules that Trigger Emission Control
Regulations
• National Ambient Air Quality Standard – NAAQS
• Standards for six “criteria pollutants”
– Ozone , particulate, NO
2
, CO, SO
2
and lead
 Ozone drives NOx regulations for natural gas industry
 NOx and VOC regulated as a precursor to ozone
 New 1-hour NO
2
NAAQS has large potential impact for recips
– “Nonattainment Areas” are defined by EPA
Results you can rely on
14

Results you can rely on
15

Results you can rely on
16

Results you can rely on
17

Primary CAA Rules that Trigger Emission Control
Regulations
• EPA requires states to develop a State Implementation
Plan (SIP). The state identifies regulations that it will adopt to improve air quality and “attain” the NAAQS
• NAAQS RACT – for ozone and PM
2.5
nonattainment,
EPA requires states to consider NOx RACT for existing equipment in the SIP.
Results you can rely on
18

Primary CAA Rules that Trigger Emission Control
Regulations
• NSPS – EPA adopts standards for “new” sources of criteria pollutants (ozone, NOx, SOx, CO, PM, Pb) and associated precursors for source categories that contribute to pollution
– National based on “best demonstrated technology”no geographical difference
 Affects new, modified and reconstructed equipment
– RICE NSPS adopted in January, 2008
 Limits for NOx, CO and VOC
Results you can rely on
19

Primary CAA Rules that Trigger Emission
Control Regulations
• NESHAP – EPA adopts standards for HAPS
– Formaldehyde is the HAP of concern for IC engines
– NATIONAL rule
– EPA adopts major source standards (RICE MACT) and may adopt area source rules
 Major Source – facility with HAP emissions of 10
TPY of a single HAP or 25 TPY aggregation of all
HAPS
 For existing major sources, based on “average emission limitation achieved by the best performing
12%” (MACT floor)
20
Results you can rely on

Primary CAA Rules that Trigger Emission
Control Regulations
• NESHAP (continued)
– For new and reconstructed major sources, based on best controlled similar source
– If EPA adopts area source rule, it can be based on a lesser degree of control
 GACT – Generally Achievable Control Technology
 Management Practices
Results you can rely on
21

Primary CAA Rules that Trigger Emission
Control Regulations
• NSR and PSD - requires Lowest Achievable Emission
Rate (LAER) technology in nonattainment areas and
BACT in attainment areas for “new” facility emissions or emission changes at an existing facility above a defined threshold
– Threshold depends on pollutant and air quality severity at location
– No cost consideration for LAER
– BACT requires “top down” analysis that considers cost and feasibility
• States implement through permitting process-variability state-to-state; BACT may trigger SCR
Results you can rely on
22

Modification and Reconstruction
• Both are relatively complex topics that are subject to interpretation
• NSPS: modified or reconstructed engines are affected
– NESHAP includes reconstruction, not modification
• Reconstruction: the replacement of components such that the capital cost of the new components exceeds
50% of a comparable new facility (includes peripheral costs)
– Must be feasible for source to meet the standard
– EPA proposed rule-specific definition for recip
NSPS
Results you can rely on
23

Modification and Reconstruction
• Modification
– Change which results in an increase in the emission rate to the atmosphere of any pollutant for which a standard applies
– Upon modification, an existing facility is affected for each pollutant with a standard and an emission rate increase
– Exemptions include installation of pollution controls
• In and of itself, engine relocation does NOT trigger modification/reconstruction
24
Results you can rely on

Summary
• NSPS and NESHAP apply everywhere in the U.S.
– New, reconstructed and modified units
– NESHAP may apply only at “major sources”
– There are rare examples of location-based exemptions due to technology limitations (Artic Circle turbines)
• NOx RACT for existing IC developed through SIP process where
NAAQS nonattainment requires emissions decrease
– EPA adopts standard and implementation rules
– States required to devise a strategy & implement controls through SIP process, including RACT
 It’s a state decision, RACT varies across U.S
• NSR/PSD implemented by states through permitting
– In nonattainment areas, lower thresholds trigger review
Results you can rely on
25

Summary, Part Deux
• The Past: rules began to affect compressor drivers
– Legacy units “grandfathered”
– Select application of NOx RACT to existing units near ozone nonattainment areas and first regional rule
 NOx SIP call affects large, high use recips in Eastern US
(<200 total)
• Current Path: next round of rules being developed
– NO
2
and ozone NAAQS bring continued pressure for NOx control and significant risk to grandfathered status for existing units
– NESHAPS revisions: turbines stay at risk, existing recips at risk
 Formaldehyde risk review will impact NESHAP decision
Results you can rely on
26

Meanwhile, back at the ranch…
• BREAK TIME!!!
Results you can rely on
27

Reciprocating IC Engine NSPS
• 40 CFR 60, Subpart JJJJ
• An IC engine NSPS was proposed in July ‘79 but never finalized
• In response to litigation, Consent Decree Schedules
– CI proposal by 6/29/05, Final rule by 6/28/06
– SI proposal by 5/23/06, Final rule by 12/20/07
– EPA met these deadlines
• EPA tried to model rules after mobile source diesel rules for non-road and marine engines
– Certification & adherence to MFG O&M specs
– Not feasible for gas-fired engines
28
Results you can rely on

Spark Ignition IC Engine NSPS
• Subpart JJJJ published in Federal Register 1/18/08
– NOx, CO, VOC limits for ALL new ICE’s (no size limit)
– Also applies to modified or reconstructed engines
– Two phases of limits based on mfg. date
• NOx, CO, VOC limits in either g/bhp-hr or ppmv
– Rich burn engines require NSCR
– Lean burn engines require Low Emission Combustion (LEC)
– Allowance for retrofit ( 3.0 g/bhp-hr NOx vs. 2.0)
• Compliance: Periodic Emissions test & maintenance plan (or purchase/operate a certified engine)
– Compliance test at high load
Results you can rely on
29

• Natural gas and LPG engines ≥ 100 hp & Emergency ICE’s
Engine Type
Maximum
Engine Power
MFG Date
NOx g/bhp-hr
CO
Emission Standards a
VOC NOx ppmv @ 15% O2
CO VOC
Non-
Emergency
Engines
100 ≤ hp < 500
7/1/2008 2.0
4.0
1.0
1/1/2011 1.0
2.0
0.7
Non-
Emergency,
Lean Burn
Non-
Emergency
Engines c
500 ≤ hp < 1350 hp ≥ 500
1/1/2008
7/1/2010
7/1/2007
2.0
1.0
2.0
4.0
2.0
4.0
1.0
0.7
1.0
7/1/2010 1.0
2.0
0.7
Emergency
25 < hp <130
1/1/2009
10 b
387.0
N/A
Engines hp ≥ 130
2.0
4.0
1 a Operators of non-certified engines may chose to comply with either limit b Emergency engine standards (25 < hp <130) are in terms of NOx + HC c Except lean burn engines 500 ≤ hp < 1350
160
82
160
82
160
82
N/A
160
540
270
540
270
540
270
N/A
540
86
60
86
60
86
60
N/A
86
Results you can rely on
30

SI ICE NSPS
• June 28, 2011 Revision
• “Date of Manufacture” definition includes:
– Reconstructed engines are assigned a new date of manufacture if the fixed capital cost of the new and refurbished components exceeds 75% of the fixed capital cost of a comparable entirely new facility.
An engine that is produced from a used engine block does not retain the date of manufacture of the engine in which the engine block was previously produced using all new components except for the engine block. In these cases, the date of manufacture is date of reconstruction.
31
Results you can rely on

RICE NESHAP
• 40 CFR 63, Subpart ZZZZ aka “RICE MACT”
6/15/2004
– Affects IC engines > 500 hp at major sources
– New or reconstructed units >500 hp and existing rich burns
>500 hp at HAPS major source
 10 tons/25 tons rule
• Amended in January, 2008 to include small major source engines and area sources
– Affects NEW or reconstructed units: Major source engines and all area source engines
• 8/20/2010 Amendments address recent court cases
– Affects existing ICE: all area source & major source ≤500 hp
Results you can rely on
32

RICE NESHAP 2010 Revisions
• Revision per Consent Decree schedule and related court decisions
– Final CI rule published 3/3/2010
– Final SI rule published 8/20/2010
• Now includes all engines except existing major source
LB >500 hp
– These will be addressed in 2012 (8 year) review
• Effective date of final rule was 10/20/2010
– Three years for newly effected engines to comply – compliance date is October 19, 2013
Results you can rely on
33

RICE NESHAP 2010 Revisions
• When emission standards apply
– CO limit or catalyst % reduction for LB
– HCHO or catalyst % reduction for RB
• If emissions standards apply
– CO: EPA or ASTM portable methods
– HCHO: FTIR or Method 323
 Initial test required for major source engines from 100-500 hp and area source engines >500 hp
• For area source 4SLB and 4SRB engines > 500 hp, continuous catalyst inlet temperature monitoring and monthly catalyst ΔP measurements
– Work practice for other area source engines
Results you can rely on
34

Source Standards
• Emission limitations for all source types
MAJOR SOURCE
Engine
100 - 500 hp
Type
2SLB 225 ppmv CO
AREA SOURCE
≤500 HP > 500 hp
MP MP
4SLB 47 ppmv CO MP
47 ppmv
CO/93% RE
4SRB 10.3 ppmv HCHO MP
2.7 ppmv
HCHO/ 76%
RE
Small RICE <100 hp - Mangement Practices
All concentrations are dry at 15% O
2
Limits apply at all times other than startup
Results you can rely on
35

RICE NESHAP 2010 Revisions
• Work/Management Practice Requirements
• Apply more broadly than in proposed rule
• Requires scheduled maintenance/inspection
– Change oil/oil analysis (compare vs. condemning limits)
 Parameters: viscosity, total acid number, water content
– Inspect plugs, belts and hoses; replace as needed
– Intervals as follows:
 4SLB/4SRB: every 1,440 operating hours
 2SLB: every 4,230 operating hours
 Emergency engines: every 500 operating hours
 At least once annually in all cases
• Maintenance Plan and records are required
Results you can rely on
36

Performance Tests – Subpart JJJJ
• Pollutants and Emission Limits
– Technology Basis
 Rich Burn: NSCR
 Lean Burn: combustion based controls
• Emission limits for NOx, CO, VOC
– VOC as defined includes HCHO, but NOT included in Subpart JJJJ
– NOx + HC included for some smaller engines
Results you can rely on
37

Performance Tests – Subpart JJJJ
• Pollutants and Emission Limits
– Non-Emergency Engines
 100 ≤ hp < 500
– Non-Emergency LB Engines
 500 ≤ hp < 1350
– Non-Emergency Engines
 hp ≥ 500
Results you can rely on
38

Performance Tests – Subpart JJJJ
– Non-Emergency Engines
 100 ≤hp<500
MFG g/bhp-hr ppmv @ 15% O
2
DATE NOx CO VOC NOx CO VOC
7/1/2008 2.0 4.0 1.0 160 540 86
1/1/2011 1.0 2.0 0.7 82 270 60
Results you can rely on
39

Performance Tests – Subpart JJJJ
– Non-Emergency Lean Burn Engines
 500 ≤ hp<1,350
MFG g/bhp-hr ppmv @ 15% O
2
DATE NOx CO VOC NOx CO VOC
1/1/2008 2.0
4.0
1.0
160 540 86
1/1/2011 1.0
2.0
0.7
82 270 60
Results you can rely on
40

Performance Tests – Subpart JJJJ
– Non-Emergency Engines (except LB)
 ≥500 hp
MFG g/bhp-hr ppmv @ 15% O
2
DATE NOx CO VOC NOx CO VOC
7/1/2007 2.0 4.0 1.0 160 540 86
7/1/2010 1.0 2.0 0.7
82 270 60
Results you can rely on
41

Performance Tests – Subpart JJJJ
– Non-Emergency Lean Burn Engines
 500 ≤hp<1,350
MFG g/bhp-hr ppmv @ 15% O
2
DATE NOx CO VOC NOx CO VOC
1/1/2008 2.0
4.0
1.0
160 540 86
1/1/2011 1.0
2.0
0.7
82 270 60
Results you can rely on
42

Performance Tests – Subpart JJJJ
– Natural Gas Fired Lawn Mower Engines
 25≤hp≥100
MFG
DATE
7/1/2008 g/bhp-hr
HC + NOx
3.8
CO
6.5
Results you can rely on
43

Performance Tests – Subpart JJJJ
– Date the engine was ordered is the day construction starts
• If ordered on or before 6/12/06, engine is EXISTING and Quad J doesn’t apply
• If ordered after 6/12/06 but MANUFACTURED before, Quad J doesn’t apply
• If ordered after and manufactured after 6/12/06,
Quad J DOES apply
• Both Quad J and Quad Z can apply to the same engine, depending on date and type
Results you can rely on
44

Performance Tests – Subpart JJJJ
What about Relocation?
• In and of itself, relocation does NOT trigger
“modification” or “reconstruction” and are not subject to
NSPS
(unless manufactured after the earlier dates)
• Evaluate whether reconstruction or modification occurs
• EPA says changes in control equipment or method of operation can trigger applicability
Results you can rely on
45

Performance Tests – Subpart JJJJ
• Operators must understand changes, if any, to relocated engines
– Has engine been modified, i.e. rich to lean?
– Was engine rebuilt or was “major maintenance or repair” completed?
• Ownership changes
make an engine new
• Operators ARE responsible for ensuring compliance of relocated engines
Results you can rely on
46

Performance Tests – Subpart JJJJ
“An engine configuration’s maximum engine power is the maximum brake power point on the nominal power curve for engine configuration” o It’s manufacturer nameplate rating without consideration of elevation, etc. o RICE MACT is “site rated.”
Results you can rely on
47

Performance Tests – Subpart JJJJ o Subpart REQUIRES compliance demonstration for
NOx, CO, VOC o Applies to modified/reconstructed o Applies to Non-Certified Engines o Applies to Certified operating as NonCertified ≥100 hp
Results you can rely on
48

Performance Tests – Subpart JJJJ
• Test trigger for rebuild/major repair not currently well defined
– Operator’s burden to determine if tests are required
 DOCUMENT THE DECISION
Results you can rely on
49

Performance Tests – Subpart JJJJ
• Three test runs of at least one hour
• Operate at 100 ± 10%
– Maximum available load on the date of the test; if you go above in the future, re-test
• Measure/collect at the outlet of any control devices
• Don’t test during start up, shut down, or malfunction
Results you can rely on
50

Performance Tests – Subpart JJJJ
• Measure NOx, CO, VOC, O
2
and moisture
– Why moisture?
 VOC’s measured “hot & wet” but concentrations and mass emission are reported dry
 Use moisture to correct to a dry basis
 Example: measured VOC = 20 ppm, H
2
O = 10.00%
 VOC * ((100 + H2O)/100)
– 20 * ((100 + 10.00)/100)
–
VOC dry = 22 ppmvD
• If complying with g/bhp-hr
– Exhaust Gas flow rate
– hp
Results you can rely on
51

Performance Tests – Subpart JJJJ
• EPA Reference Methods
– NOx: 7E
– CO: 10
– O
2
: 3A
– H
2
O: 4 or 19
– VOC methods to follow
• Portable Analyzer Methods
– ASTM D6522
– ASTM D6420-99 (GC/MS
– “Administrator approved alternative portable analyzer method”
Results you can rely on
52

Performance Tests – Subpart JJJJ
• EPA Reference Method 19 for flow
– EPA - TTN EMC Method 19 - SO2 Removal & PM,
SO2, NOx Rates from Electric Utility Steam
Generators
– Requires a fuel compositional analysis from the date of the test event
– If a temporary fuel meter is used, must have post test calibration
– If a permanent meter is used, pre test calibration is acceptable
– Readings must correspond with beginning and end of test run
Results you can rely on
53

Performance Tests – Subpart JJJJ
• VOC Test Issues
– Does not include methane (CH
4
) or ethane (C
2
H
6
)
– Does not include HCHO
– Reported as ppmv (measurement basis)
 Typically propane, can be methane
– Two approaches
 Additive
–
Quantify and sum applicable HC species
– Can be beneficial for NG fired sources due to high CH
4
/C
2
H
6
 Subtractive
– Difference between THC and Non-C1, Non-C2
– Subtracting two very similar numbers can cause error
Results you can rely on
54

Performance Tests – Subpart JJJJ
• Additive Methods
– Gas Chromatography
– FTIR
– “Pre-survey” required
– Option to adjust aldehydes and other oxygenated
HC for THC response factors
Results you can rely on
55

Performance Tests – Subpart JJJJ
• Subtractive Methods
– EPA 25A + Gas Chromatography
 VOC = THC – (CH
4
+ C
2
H
6
)
 Details, Details, Details
– EPA 25A with a “methane cutter”
 Dual channel FID
 Possible high bias if lots of C
2
H
6
Results you can rely on
56

Performance Tests – Subpart JJJJ
• VOC sampling
– Key difference is “hot & wet” vs. “cool & dry”
– By definition, VOC = non-C1, non-C2 HC; some states do include C2
– Total Hydrocarbons (“THC or UHC”)
 EPA Method 25A
– VOC
 EPA Method 18 (GC/FID)
– FTIR
Results you can rely on
57

Performance Tests – Subpart JJJJ
• EPA Method 25A
– Detection by flame ionization: counts the carbonhydrogen bonds by breaking them
– THC is measured then reported based on the calibration basis of the instrument
 Methane vs. Propane
– Methane cutter for VOC contribution
– Insensitive to HCHO
Results you can rely on
58

Performance Tests – Subpart JJJJ
• EPA Method 18
– Detection by FID
– Calibrated on a compound (e.g. C
3
H
8
)
– Challenged with CH
4
and/or C
2
H
6
– All hydrocarbons speciated, VOC determined from area counts
– Can be time intensive
– QA/QC documentation vital for regulatory acceptance
– On site vs. Off site analyses
Results you can rely on
59

Performance Tests – Subpart JJJJ
• Exhaust Flow
– EPA Methods 1, 2, 3A, 4
 Uses a Pitot tube and manometer + moisture
– EPA Method 19
 Preferred due to pulsating flow
 MUST HAVE:
– Fuel flow rate (have the orifice calibration)
– Fuel composition (not last years-current)
– Other criteria as above
– Questions on this method? Bivins.dan@epa.gov
Results you can rely on
60

Flow Measurement – Methods 1 & 1A
• Determine if stack meets criteria
– Upstream: 2 stack diameters, 0.5 minimum
– Downstream: 8 stack diameters, 2 minimum
A
B
Results you can rely on
61

Flow Measurement – EPA Methods 1 & 1A
• Number of traverse points is based upon upstream and downstream distance
(in stack diameters) from the flow disturbance
40
Duct diameters upstream from flow disturbance (Distance
50
0.5
1.0
1.5
Particulate Traverses
A
2.0
A)
Disturbance
2.5
Measurement
Site
B
Disturbance
30
24 or 25*
20
10
*Larger number f or rectangular stacks
20
16 stack diameter > 24 in
12
8 or 9* stack diameter 12-24 in
0
2 3 4 5 6 7 8 9 10
Duct diameters downstream from flow disturbance (Distance B)
Duct diameters upstream from flow disturbance (Distance
50
0.5
40
1.0
1.5
Non-Particulate Traverses
A
2.0
A)
2.5
Disturbance
Measurement
Site
B
30 Disturbance
20
10
0
2
*Larger number f or rectangular stacks
3
16
4 5 6 stack diameter > 24 in
12
8 or 9* stack diameter 12-24 in
7 8 9
Duct diameters downstream from flow disturbance (Distance B)
10
Results you can rely on
62

Flow Measurement – EPA Methods 1 & 1A
24 Point Layout
• Number of traverse points is based upon upstream and downstream distance
(in stack diameters) from the flow disturbance
12 Point Layout
63
Results you can rely on

Emission Limits – Subpart ZZZZ
SOURCE TYPE
4SRB >500 hp @
Major Source
EFFICIENCY
Reduce HCHO by 76%
2SLB >500 hp @
Major Source
Reduce CO by 58%
4SLB ≥ 250 hp @
Major Source
2SLB 100 ≤ hp ≤ 500
4SLB 100 ≤ hp ≤ 500
4SRB 100 ≤ hp ≤ 500
Reduce CO by 93%
CONCENTRATION
350 ppbvd @ 15% O2
ΔP TEMP
<2" H2O drop across catalyst
Catalyst ° F
750 - 1250
12 ppmv HCHO @ 15% O2
<2" H2O drop across catalyst
Catalyst ° F
450 - 1350
14 ppmv HCHO @ 15% O2
<2" H2O drop across catalyst
Catalyst ° F
450 - 1350
CO 225 ppmvd @ 15% O2
CO 47 ppmvd @ 15% O2
HCHO 10.3 ppmvd @ 15% O2
Results you can rely on
64

Performance Tests – Subpart ZZZZ
• Test Frequency
– SI RICE < 100 hp
 No performance test required
 Must develop a maintenance plan that specifies how the management practice will be met and provides for maintenance and operation to minimize emissions
– 2 SLB 100 ≤ hp ≤ 500
 Must conduct an initial performance test to demonstrate compliance
 If oxidation catalyst is changed, conduct new test
Results you can rely on
65

Performance Tests – Subpart ZZZZ
• Major Source
– 2SLB ≥ 500 hp
 Initial performance test required
 Semi-annual tests until compliance demonstrated for two consecutive tests, then annually
 If any annual test shows non-compliance or deviation from operating limitations, resume semi-annual tests
 If oxidation catalyst is changed, conduct new test
66
Results you can rely on

Performance Tests – Subpart ZZZZ
• Test at 100% ± 10%
• DOCUMENT THE LOAD
– How you define it
– How it was measured
• Process data to support results
• Measure catalyst inlet temperature
• Measure catalyst pressure drop
• Use approved test methods
Results you can rely on
67

Performance Tests – Subpart ZZZZ
• Formaldehyde Measurement
– HCHO or H
2
CO or CH
2
O
– FTIR
 EPA Method 320
 ASTM Method D6348 – 03
– EPA Method 323
 Liquid collection method
 Results depend on precision/execution
 Lower detection limits with longer run times
– WATER INTERFERES WITH HCHO
MEASUREMENT!!!
Results you can rely on
68

Performance Tests – Subpart ZZZZ
• Where does HCHO come from?
– All carbon (except CO
2
) is the by product of incomplete combustion
– If there is O
2
in the exhaust, HCHO can form
– Very little formation in RB
– LB with relatively high O
2
can lead to more HCHO
– CO is a trend indicator…or surrogate...for HCHO
Results you can rely on
69

Performance Tests – EPA Guidelines
• EPA’s National Stack Testing Guidelines
– Goals
 Improve uniformity on how tests are conducted
 Improve coordination between EPA and state/local agencies
 Enhance EPA oversight of state/local programs
– Link: epa.gov/ttn/emc/guidlnd/gd-050.pdf
Results you can rely on
70

Performance Tests – EPA Guidelines
• Highpoints:
– Section VI – Conduct of Stack Tests
 Time frame: if you’ve not completed your test in the
“requisite time frame” you are in violation
 Test Waivers: None. Even on identical units unless:
– In service at the same facility and operated/maintained in the same way with emissions less than the applicable standard
 Notification: typically 60 days for EPA and contain the right information
– Must provide notification of delays “as soon as possible”
Results you can rely on
71

Performance Tests – EPA Guidelines
• Test Protocol should be submitted
– Epa.gov/compliance/assistance/air/index.html
– Tell the agency which unit, where, why, when and who
– Explain the test matrix
– Describe process data to be included and how load will be determined
– Identify the test methods and explain any request for deviations
Results you can rely on
72

Performance Tests – EPA Guidelines
• Observation of Stack Tests
– Will they come? It really shouldn’t matter
– If notification wasn’t “timely” then the “resulting test data may be rejected and a new stack test required.”
Results you can rely on
73

Performance Tests – EPA Guidelines
• Representative Testing Conditions
– Test at the maximum load condition the source is designed for
– If you do not test at design maximum, test at where you operate but you must document historical trends
– Different state/local agencies have their own criteria: know what they want
Results you can rely on
74

Performance Tests – EPA Guidelines
• Stoppages
– If you stop because you might fail, you would be considered in violation of both the requirement to test and the permit condition
– If you have to stop because of equipment failure, severe weather and/or safety, complete the run that’s in progress if possible and fully document the reasons for stoppage
Results you can rely on
75

Performance Tests – EPA Guidelines
• Postponements
– Considered the same way as stoppages
– “…the delegated agency should carefully scrutinize the circumstances surrounding the postponement to determine whether the facility was in violation of the underlying emission limitations”...and
“postponed to avoid a documented violation.”
Results you can rely on
76

Performance Tests – EPA Guidelines
• Reports
– Should be detailed enough to assess compliance with the regulatory requirements
– Submit as soon as possible-most states have specific timelines: 30, 45, or 60 days. EPA reports have 60 days
– epa.gov/ttnemc01/guidlnd/gd-043.wpd
– Report in the same number of figures that are in your permit.
Results you can rely on
77

Make it Easy on Yourself
• Too much communication is almost enough
• Cleary define your test objectives
• Make certain that you, operations, environmental, and gas control are on the same page
• Prepare a reasonable schedule with time for things to not go as planned
• Keep the paperwork on the front burner
Results you can rely on
78

Results you can rely on
TRC
Corporate Overview
Innovate. Solve. Transform.

Results you can rely on
TRC
Corporate Overview
Innovate. Solve. Transform.

Corporate Overview
• Leading Engineering and Environmental Services
Company
• Well-established - Founded in 1970; listed on NYSE
(symbol TRR)
• Over 2,700 Professionals
• Operating from over 100 offices
• www.TRCsolutions.com
81
Results you can rely on

Core Services
Results you can rely on
Infrastructure
Environmental
Real Estate
Energy
82

Market Segments & Practice
Groups





Results you can rely on
83

Market Segments & Practice
Groups




Results you can rely on
84