RACT 2 – Source Testing and Monitoring Requirements

1. RACT 2 – Source Testing and Monitoring Requirements Air Quality Technical Advisory Committee August 4, 2016 Harrisburg, PA Tom Wolf, Governor Patrick McDonnell, Acting Secretary

2. Background • On April 23, 2016, the Environmental Quality Board (EQB) promulgated additional reasonably available control technology (RACT 2) requirements for major stationary sources of nitrogen oxides (NOx) and volatile organic compounds (VOCs). • An owner or operator must demonstrate compliance with the RACT 2 regulation by January 1, 2017. • An owner or operator of air contamination sources with continuous emission monitoring systems (CEMS) must use them to demonstrate compliance.

3. Background • Existing emission and data availability standards remain in place. • An owner or operator of an air contamination source without CEMS must conduct source testing to demonstrate compliance.

4. 30 Operating Day Rolling Average Emission Rate • For an air contamination source with CEMS, compliance will be demonstrated with a 30 operating day rolling average emission rate (except municipal waste combustors that will comply using a daily average). • An operating day is defined as a 24-hour period beginning at 12:00 midnight during which the source operates at any time and produces emissions. It includes emissions that were generated during startups, shutdowns, or malfunctions.

5. 30 Operating Day Rolling Average Emission Rate • Hourly data validation will be conducted as per the data reduction criteria contained in Revision No. 8 of the Department’s Continuous Source Monitoring Manual (Manual). • Data substitution is required for invalid hours in which monitoring is required. • Data availability criteria will apply for hours in which monitoring is required.

6. 30 Operating Day Rolling Average Emission Rate • The 30 operating day rolling average emission rate will be calculated as follows: • Sum the total pounds of pollutant emitted from the combustion unit for the current operating day and the previous 29 operating days. • Sum the total heat input to the combustion unit in million Btu (MBtu) for the current operating day and the previous 29 operating days. • Divide A (above) by B (above) to determine the emissions rate (lbs/MBtu).

7. Monitoring Plan • An owner or operator of an air contamination source with CEMS will submit a monitoring plan (MP) in the Department’s CEM Data Processing System (CEMDPS). • Each major source category requires slightly different content to be included in the MP.

8. Monitoring Plan • For a combustion unit or process heater, include the following in the MP: • A new emission result and CEMS for hourly mass emissions (lbs), hourly heat input (MBtu), and hourly (lbs/MBtu). • A new emission result and CEMS for allowable hourly emission rate (lbs/MBtu) for those that have a variable emission standard. • Each CEMS should be associated with the appropriate analyzer(s).

9. Monitoring Plan • For a combustion turbine, include the following in the MP: • A new emission result and CEMS for hourly concentration emissions (PPM @ 15% O2). • A 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. • Each CEMS should be associated with the appropriate analyzer(s).

10. Monitoring Plan • For a Portland cement kiln, include the following in the MP: • A new emission result and CEMS for hourly mass emissions (lbs), hourly clinker production (tons), and hourly (lbs/ton-clinker). • Each CEMS should be associated with the appropriate analyzer(s).

11. Monitoring Plan • For a municipal waste combustor, only submit a monitoring plan if a new daily average NOx emission standard must be added.

12. Performance Testing and Certification • An owner or operator of an air contamination source with CEMS will submit a certification test protocol and certification test report in the CEMDPS once the MP has been approved. • A data acquisition and accuracy check must be successfully completed. • Sample hours of emissions data (under various scenarios) will be required. • An acceptable sample report must be submitted in the CEMDPS for any new emission results.

13. Quarterly Emission Reports • Upon Department certification, the owner or operator of an air contamination source with CEMS will submit hourly emissions data to the Department. Data will be required starting with the first quarter of 2017.

14. Quarterly Emission Reports • For a combustion unit or process heater, submit hourly mass emissions (lbs) and hourly heat input (MBtu). The owner or operator will also submit the allowable hourly emission rate (lbs/MBtu) for sources that have a variable emission standard. • Department software will calculate a 30 operating day rolling average emission rate (lbs/MBtu) for each operating day. The software will also calculate the allowable for sources that have a variable emission standard.

15. Quarterly Emission Reports • For a combustion turbine, submit the hourly concentration (PPM @ 15% O2). The owner or operator will also submit the allowable hourly concentration (PPM @ 15% O2) and hourly heat input (MBtu) for sources that have a variable emission standard. • Department software will calculate a 30 operating day rolling average emission rate (lbs/MBtu) for each operating day. The software will also calculate the allowable for sources that have a variable emission standard.

16. Quarterly Emission Reports • For a Portland cement kiln, submit hourly mass emissions (lbs) and hourly clinker production (tons). • Department software will calculate a 30 operating day rolling average emission rate (lbs/ton-clinker) for each operating day. • For municipal waste combustors, submit average hourly concentration emissions (PPM @ 7% O2).

17. Units Firing Multiple Fuels • The emission limit shall be determined on a total heat input fuel weighted basis using the equation in RACT 2. • A fuel representing < 1% of the unit’s annual fuel consumption on a heat input basis is excluded when determining the emission limit. • The owner or operator of the unit must demonstrate that this exclusion applies over a 12-calendar month period, rolling by 1-month. • For example, the exclusion would exist for the month of July if the fuel met this criteria from August of the preceding year to July of the current year.

18. Units Firing Multiple Fuels • Corroborating information should be included in the cover letter of the quarterly emissions report if the exclusion is utilized. • The owner or operator of a unit 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.

19. Emissions Averaging Plans • You may use the CEMDPS to demonstrate compliance on a facility-wide 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. Additional testing may be required. • Those not meeting the above must submit a quarterly compliance report to the applicable DEP Regional Office to demonstrate compliance.

20. Emissions Averaging Plans • 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.

21. Source Testing Requirements • Monitoring and testing must be conducted in accordance with a Department approved emissions source test that meets the requirements of Chapter 139, Subchapter A (relating to sampling and testing methods and procedures). • Source testing must be conducted one time in each 5-year calendar period.

22. Source Testing Requirements • The owner or operator of a unit may reference a previously approved test protocol (i.e. no new protocol needed) if the following conditions are met: • They agree to meet all conditions of acceptance of the protocol. • Nothing has changed since Department approval was granted (i.e. same relevant testing requirements, same process operating conditions, same testing subcontractor, etc.).

23. Division of Source Testing and Monitoring Program Contact Charles J. Zadakis, Program Manager Department of Environmental Protection Harrisburg, PA 17105-8468 Telephone: (717) 783-9479 czadakis@pa.gov