PA RACT 2. Reasonably Available Control Technology. Presented by Suzanne Dibert

Transcription

1 PA RACT 2 Reasonably Available Control Technology Presented by Suzanne Dibert

2 Affected Facilities Facilities with potential emissions that exceed 100 tons per year (tpy) for NOx (nitrogen oxide) and 50 tpy for VOC (volatile organic compound) In existence before July 20, 2012, and for which a NOx and/or VOC requirement has not already been established in certain sections of 25 Pa. Code Chapter 129

3 Timeline April 23, 2016 October 24, 2016 Mid to Late November January 1, 2017 EQB Promulgated RACT 2 Requirements RACT 2 Proposal due to PA DEP Make MP Changes in CEMDPS Demonstrate Compliance with RACT 2 3

4 Any Extensions? Only possible for facilities that submit a Plan Approval Application (PAA) to install a control device, make a physical change, or change the method of operation to comply with applicable RACT 2 requirements Compliance date is extended to 3 years from date of issuance of a resulting Plan Approval Maximum extension is 4.5 years (18 month maximum for PADEP to review a PAA plus the 3 year extension from the date of final Plan Approval issuance)

5 Demonstrating Compliance Facility with continuous emission monitoring system (CEMS) must use CEMS to demonstrate compliance Existing emission and data availability standards continues Facilities without CEMS must conduct source testing

6 30 Operating Day Rolling Average Emission Rate Sources with CEMS compliance will be demonstrated with a 30 operating day rolling average emission rate. Operating day is defined as 24-hour period beginning at 12:00 midnight during which the source operates at any time and produces emissions. Includes startups, shutdowns, or malfunctions. Data substitution is required for invalid hours in which monitoring is required. 6

7 30 Day Averaging for Combustion Units A. The total pounds of pollutant emitted from the combustion unit for each operating hour for the current operating day and the previous 29 operating days will be summed B. The total heat input to the combustion unit in million Btu (Mbtu) for each operating hour for the current operating day and the previous 29 operating days will be summed C. Divide A (above) by B (above) to determine the emissions rate (lbs/mbtu)

8 30-day averages for Combustion Turbines A. Sum the valid operating hours NOX 15% O 2 emitted from the combustion unit for the current operating day and the previous 29 operating days B. Sum the number of operating hours for the combustion turbine for the current operating day and the previous 29 operating days (Do not include hours where the NOX corrected was invalid) C. Divide A (above) by B (above) to determine the emissions rate

9 Units Firing Multiple Fuels Emission limit shall be determined on a total heat input fuel weighted basis A fuel representing < 1% of the unit s annual fuel consumption on a heat input basis is excluded when determining the emission limit The unit must demonstrate this exclusion over a 12-calendar month period, rolling by 1-month Information should be included in the cover letter if the exclusion is utilized The owner may petition the Department to include a fuel representing <1% of the unit s annual fuel consumption on a heat input basis in the emission limit. 9

10 Emissions Averaging Plans Sites may use CEMDPS to demonstrate compliance on a facilitywide basis if the following criteria are met: All underlying emission results, CEMS, and analyzers conform to the requirements of the Manual. The Department may approve the use of analyzers that have been certified under an applicable Federal program. Those not meeting the above must submit a quarterly compliance report to the applicable DEP Regional Office to demonstrate compliance.

11 Emission Averaging Plans PA DEP is not sure how reporting in CEMDPS will be handled for facility-wide averaging. May or may not need to have a new facility-wide ID. Chuck Zadakis said to check back in a few weeks. All demonstrations of compliance on a system-wide basis should be submitted as a quarterly compliance report to the applicable DEP Regional Office. If more than one DEP Region is involved, a copy of the report must be submitted to each. 11

12 PA CEMDPS

13 DEPGreenport CEMDPS (CEM Data Processing System) 13

14 MP CEMDPS (CEM Data Processing System) Combustion Unit or process Heater Include new emission result and CEMS for hourly NOx mass emissions (lbs), hourly heat input (MBtu), and hourly NOx (lbs/mbtu) Include new emission result and CEMS for allowable hourly emission rate (lbs/mbtu) for those that have a variable emission standard

15 MP CEMDPS Combustion Turbine Include new emission result and CEMS for hourly concentration emissions 15% O2) Include new emission result and CEMS for allowable hourly emission rate (PPM@ 15% O2) and hourly heat input (MBtu) for those that have a variable emission standard

16 MP CEMDPS Portland Cement Kiln or Municipal Waste Combustor Include new emission result and CEMS for hourly mass emissions (lbs), hourly clinker production (tons), and hourly (lbs/tonclinker). Each CEMS should be associated with the appropriate analyzer(s) Municipal Waste Combustor submit a MP only if a new daily average NOx emission standard must be added

17 Performance Testing and Certification - CEMS After MP has been approved by PADEP Data acquisition and accuracy check (CEMDPS) Sample hours of emissions data (under various scenarios) Sample quarterly report for new emission results (submit in CEMDPS) Quarterly Emission Reports Submit hourly emissions data in CEMDPS starting with first quarter 2017 As always, submit once PA DEP has approved for submittal

18 STACKVISION

19 Configuration in SV Add new reportable parameters Configure 30 operating day rolling average Possibly add new parameters to Pennsylvania Settings list in StackStudio 19

20 Import CEMDPS Monitoring Plan to SV

21 SV PADEP Parameter Mapping

22 SV PADEP EDR Generation

23 RACT PADEP EDR Example 1646 NOXLBS 1647 HEATN 3033 Allowable NOX Rate 23

24 Sneak Peak SV PADEP Changes 24

25 DAS VALIDATION IN CEMDPS

26 PADEP DAS Validation 26

27 PADEP DAS Validation 27

28 PADEP DAS Validation 28

29 PADEP DAS Validation 29

30 SAMPLE DATA SPREADSHEET

31 Sample Data This spreadsheet includes Different operating scenarios: Normal hours, invalid hours, calibration, maintenance, partial hours, substituted hours The spreadsheet compares the calculated hourly values (from minute data) to the DAS calculated hourly values for your reported parameters 31

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35 References Revised Final Form RACT 2 Rule DEP>Business>Air>Bureau of Air Quality>Permits DEP Greenport 35

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