NCASI Air Quality Program Lee Carlson NCASI Arkansas Environmental Federation Air Seminar - May 9, 2018
Air Quality Program Targeted Studies to Address Technical and Regulatory Needs Emission Measurement Methods and Emission Factor Development Instrument Evaluations - Fill critical gaps in emissions data - Filterable PM2.5 and Condensable PM (CPM) - Low-level HAPs and VOC speciation - Develop one-of-a-kind emissions database – used for permitting, PSD impact analyses and - Instrumentation methods (FTIR, PM2.5 inventories measurement using ambient monitors) - Next gen portable monitors Air Quality Informing Regulatory Development and Focused Member Technical Support Implementation - Impacts of operating parameters on emissions - Communicate technical studies and analyses to - Emission test planning and data review EPA and States and enable development of achievable regulations - Mill Environmental issues - Regulatory compliance tools and compliance demonstration support Arkansas Environmental Federation Air Seminar – May 2018 2
Emission Measurement Methods – USEPA Method 202 Federal Reference Method for Condensable Particulate Matter (CPM) • Need for reliable PM 2.5 and CPM data for permitting and PSD applicability analyses Why? • Data gaps and bad data frequently derail viable expansion projects • NCASI research indicates USEPA Method 202 yields positively biased measurements How? • Best practices for Method 202 (CPM) to minimize blank (zero) bias • Collaborative research with EPA on artifact bias due to ammonia (NH 3 ) and SO 2 Measurement Method Research and • Alternate methods to minimize artifact bias T echnical Fixes What? • Reliable data for natural gas boilers, paper machines and combustion sources • Data widely used for PSD analyses and permitting Relevant and Timely • NCASI technical credibility and direct interactions with EPA / state agencies Emission Factors critical to achieve favorable permitting outcomes Arkansas Environmental Federation Air Seminar – May 2018 3
EPA Method 202 for Condensable Particulate Matter (CPM) Zero Bias Reagent impurities, sampling environments and work-practices result in measurement bias Gravimetric mass from blank run incorporating all method-related steps, except source sampling Artifact Bias Potential for SO 2 oxidation and capture as sulfate Greatly increased in the presence of ammonia Ammonium and sulfate erroneously quantified as CPM Arkansas Environmental Federation Air Seminar – May 2018 4
Method 202 Zero Bias Data – Summary Reduction in gravimetric mass from 6 ~5 mg to 2 mg 5 Are we splitting hairs? 4 Depends on source being sampled Zero Bias, mg 3 Bias can be a significant fraction of CPM on low emitting sources – paper 2 machines and natural gas boilers 1 0 EPA Field 1 NCASI Lab Field 1 Field 2 FTRB and 2 Pre-Best Practices 5.33 5.02 0 0 0 0 With Best Practices 0 0 1.65 1.85 1.78 1.82 5 Arkansas Environmental Federation Air Seminar – May 2018
Laboratory Studies on Method 202 Artifact Bias ➢ Synthetic gas mixtures with known concentrations of SO 2 and NH 3 ➢ Mixed with moisture, heated, and sampled through Method 202 train ➢ Concentrations confirmed with real-time FTIR measurement ➢ Used for assessment of artifact ammonium sulfate formation 6 Arkansas Environmental Federation Air Seminar – May 2018
Impact of Ammonia on Method Artifact Bias – Method 202 At a given SO 2 concentration (200 ppm) ammonium plus sulfate proportional to ammonia content 55 mg equates to 0.04 Captured Sulfate Normalized to Sample Volume lb/MMBtu for a coal as Function of NH 3 Concentration fired source (based on a (20% Moisture, 200 ppm SO 2 ) Sulfate Concentration one cubic meter sample 150.00 volume) 136 mg Ammonium + Sulfate (mg/dscm) R² = 0.94 PM limit for existing 100.00 coal fired sources under boiler MACT = 0.04 lb/MMBtu 50.00 3.2 mg Sulfate PM limit for new coal 55 mg Ammonium + Sulfate fired sources under 0.00 0 5 10 15 20 25 boiler MACT = 0.0011 Ammonia Concentration (ppm by vol. dry) lb/MMBtu Arkansas Environmental Federation Air Seminar – May 2018 7
Capture of SO 2 and NH 3 as Sulfate and Ammonium (Dilution Tunnel Method Versus Method 202) Dilution tunnel method simulates discharge to atmosphere Most of the ammonium and sulfate captured in Method 202 is method artifact Arkansas Environmental Federation Air Seminar – May 2018 8
Evaluation of OTM-036 to Measure Filterable PM 2.5 Emissions from Sources with Wet Control Devices • Need for reliable filterable PM 2.5 data for permitting and PSD • Current EPA guidance (filterable PM = filterable PM 2.5 ) can lead to Why? gross overestimates • Important given the low 10 tpy PM 2.5 PSD threshold How? • Co-funding development and refinement of particulate pre-cutter used to remove water droplets and larger (>20µm) particles Measurement Method Research and • In-field implementation and evaluations on lime kilns, smelt dissolving tanks T echnical Fixes and thermal oxidizers with wet scrubbers ongoing What? • Data for wet PCD combustion sources and paper machine wet-end sources • Critical for PSD analyses and permitting Relevant and Timely Emission Factors • Call us for more information Arkansas Environmental Federation Air Seminar – May 2018 9
Emission Factor Development PM 2.5 and CPM Emissions from Natural Gas Boilers NCASI stack testing involved 16 to 24-hour Why? sample runs to address Detection Limit issues Many natural gas boiler conversions or installations underway AP-42 factors reflect older test methods and appear to be limited by detection limit issues NCASI identified opportunity to better understand test method performance on low emitting source Goal – fill critical data gaps with scientifically defensible information. 10 Arkansas Environmental Federation Air Seminar – May 2018
Regulatory Development & Implementation PM 2.5 Related Technical Outreach Recent PM 2.5 Related Regulatory Why? Activity Wisconsin PM 2.5 Modeling and Permitting When NCASI findings are used to inform Guidance regulatory and policy decisions, our utility WI DEQ issued guidance that PM2.5 emissions as a reputable source of data and science is from non-combustion sources are to be excluded from most permitting activities. The improved stated assumption is that mechanical sources Goal – assist industry and regulators are not significant NCASI supplied data to support justification in development of reasonable, achievable and scientifically valid EPA Changes to Test Methods emissions standards, practices and EPA has proposed changes to M202 that regulations implement and support NCASI results from the zero bias work. EPA is beginning to work on alternative strategies to address M202 artifact bias 11 Arkansas Environmental Federation Air Seminar – May 2018
Regulatory Support Activities Outreach to State Boiler MACT Subpart MM RTR Regulatory Agencies • Technical justifications for work • Reviews of facility inventories at EPA’s • Communicating key technical studies to practice standards for D/F request to identify data quality issues EPA and State regulatory agencies for use in developing guidance that streamlines permitting • Guidance to set emission standards for • NCASI involvement in emissions Hg based on method detection and inventory corrections critical in quantitation limits lowering risks to acceptable with • Potential for PM 2.5 emissions from wood Ample Margin of Safety in handling sources Subpart S and MM RTRs • PM 2.5 data from paper machines and • Floor analyses during various natural gas boilers reconsiderations • Additional involvement to support • Options to treat PM 2.5 data below potential remand/reconsideration of method detection limits (MDL) • Parallel floor analysis to support EPA final rule expected reanalysis of floor data in response to Dec 2016 remand • NCASI work informed recent PM 2.5 permitting guidance in WI • NCASI summary enabled MI facility to get relief from the PM 2.5 modeling requirement for Title V renewal Arkansas Environmental Federation Air Seminar – May 2018 12
Member Support Development of PM 2.5 Emission Why? Factors for Paper Machines PM 2.5 from Paper Machines can be Handling of detection limit limited data significant driver of modeled plays a key role ambient impacts PM 2.5 Emissions, tons/yr Method Used to Treat Vent-Level PM 2.5 Fenceline Annual PM 2.5 Emissions Data < MDL Concentration Impact @ 8.3% Data <MDL Detected @ MDL = 0 Mass 39.5% 18.5 27.8 1.4 Small Paper Tissue Machine 3.0 3.6 2.4 Linerboard 60.5% 91.4 138 5.9 Tissue Large Paper 91.7% Machine Paper Machine 13.8 17.2 10.8 Linerboard Remaining Mill Key Takeaway: Call Us 13 Arkansas Environmental Federation Air Seminar – May 2018
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