Workshop K Air Quality Best Practices Successful Compliance - - PDF document

Workshop K

Air Quality Best Practices … Successful Compliance Emission Measurement Program

Tuesday, March 27, 2018 11:15 a.m. to 12:30 p.m.

Biographical Information

Katie Kistler, Environmental Manager of Air Programs AK Steel Corporation, 9227 Centre Pointe Dr., West Chester, OH 45069 513-425-2972 katie.kistler@aksteel.com

Katie Kistler works in AK Steel corporate offices and has more than 12 years experiences in the air quality field; she worked 5 years as a consultant and 7.5 years with AK Steel. With AK Steel Ms. Kistler worked at the Middletown Works facility for 3 years and in the corporate offices for 4.5 years. AK Steel

• perates 8 iron and steel facilities, one coke making facility, 3 tube mills and 8 automotive tooling and

stamping operations for which Ms Kistler provides environmental support to onsite environmental

• personnel. Ms. Kistler earned her B.S. degree in Chemical Engineering and Masters of Business

Administration from the University of Dayton.

Tom Gerstle, Vice President Engineering and Consulting Programs and Emission Measurement Environmental Quality Management, Inc. 1800 Carillon Blvd, Cincinnati, OH 45240-2788 513.742.7251 tgerstle@eqm.com

Tom Gerstle is the Vice President of Engineering and Consulting Programs and Emission Measurement at Environmental Quality Management, Inc. (EQM). Mr. Gerstle has more than 30 years

• f experience in air compliance, emission measurement and evaluation, emission factor development,

source apportionment, and regulatory compliance. He has worked in a variety of industries including, but not limited to, steel and coke manufacturing, energy production, chemical manufacturing, petroleum refining, pharmaceutical manufacturing, and food processing. He has been responsible for the development of multiple unique emission sampling protocols including the quantification of jet engine emissions using tracer gas and slipstream sampling technology. Mr. Gerstle graduated from the University of Cincinnati with a B.S. in Civil and Environmental Engineering and a M.S. in Environmental

• Engineering. He is a Professional Engineer in the State of Ohio and a Qualified Source Test Individual

(QSTI Sections 1-5).

Dawn Mays, Permits & Enforcement Area Supervisor Southwest Ohio Air Quality Agency 250 William Howard Taft Rd. 1st Flr., Cincinnati, OH 45219-2660 dawn.mays@hamilton-co.org

• Ms. Dawn Mays is the Permits & Enforcement Area Supervisor with Southwest Ohio Air Quality

Agency, a division of the Hamilton County Department of Environmental Services where she has over 20 years’ experience. During her time there she has conducted observations and validations of stack tests as well as had oversight of the testing program. She has also had oversight of asbestos and anti- tampering programs. Ms. Mays has presented the following presentations on this topic in the past: January 27, 2015 – Measurement Technology Workshop (Research Triangle Park, NC): “The Alpha and Omega of Stack Test Validation”; April 11, 2011 – Overview of Stack Testing and Stack Test Report Review (Reynoldsburg, OH): “Review of Stack Test Reports”; Numerous presentations on stack testing and the role of the regulatory agency at Cincinnati State and Technical College for its EVET program (ongoing since 1995).

Biographical Information

Hope Manning, Project Manager Environmental Quality Management, Inc. 1800 Carillon Blvd, Cincinnati, OH 45240-2788 800-229-7495 hmanning@eqm.com

Hope joined EQM in August 2015 with over 13 years of technical and compliance management experience in the environmental field. She has been involved in a broad range of programs including air compliance and permitting, NESHAP Boiler GACT compliance, NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting. Prior to EQM, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for over 50 locations in over 15 states. These activities included assisting in minor and major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole

• program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University of

Cincinnati.

How to manage a successful compliance emission measurement program How to manage a successful compliance emission measurement program

• Ms. Hope Manning, EQM
• Ms. Hope Manning, EQM
• Ms. Dawn Mays, SWOA
• Ms. Dawn Mays, SWOAQA

QA

• Ms. K
• Ms. Katie Kistler

tie Kistler, AK Steel AK Steel Mr

• Mr. T

. Tom Gerstle, EQM m Gerstle, EQM

Overview

• Forecast
• Planning
• Test protocol
• Pre-test mtg/Site visit/Test plan

review

• Site preparations
• Production planning
• Process equipment PM
• Testing set-up
• Test completion
• Data review/reporting

Forecast

• What will trigger a compliance test?

– Permit requirements (1/term, annual, etc.) – Federal MACT/NESHAP requirements – Process or equipment modifications – New construction – Industry Information Collection Request (ICR) – Elective/engineering testing/agency request/response to complaints – New rule changes that pull in existing sources (RICE generators)

Planning

• PLAN AHEAD!
• Long term planning

– Incorporate anticipated testing into annual budgets – Global schedule with testing frequency and timing

Title V Stack Testing Schedule

EU ID Stack of Emissions Source 1st Test Required 2nd Test Required Test Method

B918 Combustion Stack Within 12 Months None Method 5 B918 PEC Baghouse 24-36 Months Within 6 Months of Permit Expiration Method 5 P047 HMT/Desulf 12-24 Months None Method 5 P062 EGL Scrubbers Within 12 Months None Method 5 P902 Caster Within 12 Months None Method 5 P925 Casthouse Baghouse 12-24 Months None Method 9 P925 Bischoff Scrubber 24-36 Months None Method 5 P934 CAS/OB Baghouse Within 6 months of startup None Method 5 P956 Outside Desulf Baghouse Within 6 Months of Startup None Method 5 P926/P927 BOF Scrubbers 24-36 Months Within 6 Months of permit expiration Method 5 B007:B010 #2Boilerhouse Within 18 Months None Method 6 P023/P024 Pickler Fume Scrubbers Annually §63.1162(A)(1)

Planning Cont.

• 6+ months

– Contact regulatory agency for confirmation

• f scope

– Define scope

• Review permit and regulatory specific

requirements

• Contact regulatory agency for confirmation of

scope

– Draft request for proposal – What is the compliance deadline?

• Test by or report date?

– Production planning – Identify and complete special safety needs – Roof/platform inspections – Sample ports/electrical needs

Proposal Solicitation

• In house staff, unlikely
• Research experienced firms

– Corporate requirements (ISNETWorld, Ariba, Avetta, etc.) – Are they “in our system” (may take more time) – Trade organization – Google – LinkedIn – QSTI – Years in business – AETB – Experienced in region – Contact regulatory agency – ERT experience

• Request proposals

– Review and evaluate them

• Select a team

Test Protocol Preparation

• It is not “Just a Form”
• Who prepares this?

– Was it in the scope of work and proposal

• Prepare Intent to test (ITT)

notification

– Review permit and regulatory specific requirements – Verify scope, source info, proposed production information, test dates, test methods, method modifications – Audit samples. Additional lead time and costs.

• Submit Protocol

– > 30 days – >60 days some federal requirements – Why wait, Send it in.

Indiana ITT Ohio ITT

State Protocols

Kentucky ITT

State Protocols Cont.

Pre-Test Meeting

• Optional but recommended (at least

2 weeks away from test date)

• Test Team, EHS, Production,

Operations, Maintenance, Regulatory Personnel

• Review test dates and expected

production operating scenarios

– Who is working on test day?

• Site specific safety training

– PPE – Drug screening – Schedule for training – Items in original budget?

Pre-Test Meeting cont.

• Process data collection

– Critical for ongoing parametric monitoring (as important as emission data)

– Production rate – RTO Temperature – Scrubber water flow and pH – Fan amps, damper positions – Who collects this data? On what media? (pencil and paper, data

logger) – Communication on test day

• Radio, phone, text, who is in the loop?

Sampling Site Review

• Completed during pre-

test meeting

• Test ports (EPA Method 1

Criteria)

• Test platform and work

area

• Site access needs

– Schedule modifications, Scaffolding, man lifts, access, lighting, power

• Parking
• Action items

General Sample Port Requirements

Sample ports must be 90° from each other and in the same horizontal plane A flow disturbance is an

• bject that changes the flow

direction The eyebolt needs to be approximately 40 inches above the tab and needs to be inserted securely. It will be the bearing point for most the weight. “Eye”

• f the bolt inside diameter

should be at least ¾ of an inch. The material thickness for the tab should be 0.25 inches to 0.35 inches.

Test Setup

• Everything in place

ready to go

• Plant personnel follow

up

• Test team should be

ready to start

• Brief test team

meeting

• Expected start time for

first run on next day

Test Completion - Be w ith the Team

• Regulatory interaction
• Field questions
• Review data
• Everything on schedule
• Don’t assume everything

is OK!

• Typical excuses

– I have an audit – Corporate is in town – You got this! – That’s what we pay you for – It’s too dirty/hot/cold/high

Test Completion Cont.

• Production steady well before start
• f first test run
• Regulatory personnel arrival

– Tour of production – Wait to start testing until arrival?

• Start sampling at designated time
• Review field and production data

– Air flows – Stack temperatures – CEM concentrations – Preliminary lbs/hr – Test run consistency – Similar to historic data? – Production data within limits, meet ITT projections, parametric data

• Keep a log of events/data

Test Completion Cont.

• Potential problems

during testing

– Sample equipment leak check failure

• Mathematical

Correction

• Repeat Run

– Calibration failure – Production upset

• Repeat test
• Extend run time

Test Completion cont.

• Maintain Communication

Between Test Team, Operators, and Regulatory Personnel

• Complete sampling (wait for

final leak check/calibration)

• Regulatory review comment,

agreement, acknowledgement

• Clean up
• Data and report delivery

expectation

– Analytical result timing – Expedited Sample Turnaround

Report Preparation

• Draft report

– Read the report! – Check process description and process data summaries – Closely review report and lab data – Check emission calculations

• Included in EPA reference methods

– Audit sample results

• Review and comment
• Final report

– Submit by deadline (30 or 60 days from test date) – Report certification – Where do I send it

• Ebiz
• Email
• Mail
• Electronic reporting tool
• If new operating limits established, update relevant

procedures

What if I Didn’t Pass?

• Investigate immediately

– Review stack test data

• Analyze samples again
• Check results versus permit limit (correct interpretation)
• Alternative lab for sample analysis

– Split sample analysis

• Outside review

– Control equipment inspection – Process condition review

• Determine course of action

– Provide timeline and findings to regulatory agency

• Re-Test

Questions? Questions?

• Ms. Hope Manning, EQM
• Ms. Hope Manning, EQM
• Ms. Dawn Mays, SWOA
• Ms. Dawn Mays, SWOAQA

QA

• Ms. K
• Ms. Katie Kistler

tie Kistler, AK Steel AK Steel Mr

• Mr. T

. Tom Gerstle, EQM m Gerstle, EQM