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 operates 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 of 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 How to manage a successful compliance successful compliance emission measurement emission measurement program 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 Stack of 1 st Test Required 2 nd Test Required EU ID Test Method Emissions Source B918 Combustion Stack Within 12 Months None Method 5 Within 6 Months of B918 PEC Baghouse 24-36 Months Method 5 Permit Expiration 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 Within 6 months of P934 CAS/OB Baghouse None Method 5 startup Outside Desulf Within 6 Months of P956 None Method 5 Baghouse Startup Within 6 Months of P926/P927 BOF Scrubbers 24-36 Months Method 5 permit expiration B007:B010 #2Boilerhouse Within 18 Months None Method 6 Pickler Fume P023/P024 Annually §63.1162(A)(1) Scrubbers
Planning Cont. • 6+ months – Contact regulatory agency for confirmation of 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.
Ohio ITT State Protocols Indiana ITT
State Protocols Cont. Kentucky ITT
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
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