Workshop O Clean Air … Lessons Learned, Best Practices & Avoiding Pitfalls in Managing a Stack Test Program Tuesday, March 27, 2018 2 p.m. to 3:15 p.m.
Biographical Information Margot Fosnaugh - Senior Consultant, Trinity Consultants 1717 Dixie Hwy, Suite 900, Covington, Kentucky 41011 859-341-8100 x107 mfosnaugh@trinityconsultants.com Margot Fosnaugh is a Senior Consultant in Trinity Consultants’ Covington, Kentucky office, specializing in air permitting and environmental compliance strategies. After earning her B.S. in Chemical Engineering from the University of Cincinnati, Margot began her career as a consultant in Trinity’s Columbus, Ohio office in 2006, followed by 6 years in Trinity’s Chicago office. Margot has over 11 years of experience developing customized and automated compliance tracking tools, in state construction and Title V operating permitting, NSPS and MACT compliance assistance, air emissions reporting, and toxic release inventory (TRI) reporting. Margot manages projects across multiple industry sectors, with a special emphasis in petroleum refining and chemical manufacturing. Jason Mennino, CHMM, Dow Corning Corporation A wholly owned subsidiary of The Dow Chemical Company 4770 US Highway 42 East, Mail# CAR 029, Carrollton, KY 41008 502.732.2051 jason.mennino@dow.com Jason Mennino is an Environmental Specialist at Dow Performance Silicones (formerly Dow Corning) in Carrollton, KY. He oversees the Title V program for the Dow site of 400 employees and 1500 acres. After earning his B.S. in Environmental Engineering from the University of Dayton, he worked in an environmental lab then moved on to an R&D project management role for an environmental products company in Yellow Springs, OH. Jason cut his teeth in all environmental regulatory media as an environmental engineer at a shipyard in Pascagoula, MS. Once he earned an MBA, Jason moved on to an air specialist consulting role in Nashville, TN. From there, he went back into industry as an environmental manager for an adhesives and coating manufacturer in Franklin, KY. But that wasn’t enough. He wanted to take a walk on the wild side and try his hand at health and safety so he took an HSE Management position for a nonwoven manufacturer in Old Hickory, TN. He did well but was made an offer he couldn’t refuse to go to Hemlock Semiconductor as an Environmental Specialist. This was by far the most interesting position because it was a green field site which ended up closing without making a single kilogram of polysilicon metal. Fortunately, Hemlock was a JV and Dow Corning was one of the owners. He took an environmental team Leader position at the Carrollton site and has been there ever since.
consumer.dow.com Workshop O: Lessons Learned, Best Practices & Avoiding Pitfalls in Managing a Stack Test Program March 27, 2018 Margot Fosnaugh –Trinity Consultants Jason Mennino – Dow Corning
Agenda ˃ Reasons to conduct a stack test ˃ Contracting with a stack test firm ˃ Reviewing test protocols ˃ Preparing for the test ˃ Managing operational parameters (e.g., combustion temperature, pressure drop, flow rate) ˃ What to do on test day ˃ Reviewing test reports and submitting test results ˃ What could go wrong – a case study
Reasons for Stack Testing 3/ 15/ 2018
Purpose of Test ˃ Initial Performance Tests: New S ource or Modifications to an Existing S ource ♦ Baseline tests of current operations ♦ Test during trial of post modification operations New Rule ♦ New S ource Performance S tandards (NS PS ) ♦ National Emissions S tandards for Hazardous Air Pollutants (NES HAP) ♦ S tate Reasonably Available Control Technology (RACT)
Purpose of Test ˃ Routine Tests: Retest based on calendar time/ permit term or on hours of operation Retest when operating conditions change or change to control device Relative Accuracy Test Audits (RATA) for CEMS ˃ Informal Tests: Engineering diagnostic testing Choosing size/ design features of a control device to be added Demonstrate conformance with a manufacturer’s guarantee
Purpose of Test ˃ Emission factor development ˃ Compliance with an underlying rule ˃ Response to an Agency request ˃ Compliance with permit condition Concentration – flow not considered in calculation Mass – flow is critical to results % reduction - test inlet / outlet simultaneously
Purpose of Test
Stack Emission Testing Key Emission Information Objectives ˃ Mass-emissions (pounds/ hour) are calculated from emission concentrations and volumetric flow-rate. ˃ Emission Concentrations corrected for air dilution (ppmv @ X% O2) calculated from emission concentration and diluent concentration
Contracting with a Test Firm 3/ 15/ 2018
Prepare an RFP ˃ S pecify the purpose of the test – regulatory as well as internal obj ectives Compliance – Identify applicable regulations and emissions limits Engineering – Identify terms of the results and expected emissions (lb/ hr, lb/ ton, etc.) ˃ S pecify if initial test or if routine test conducted in the past Provide prior test protocol
Prepare an RFP ˃ Provide preferred or required test methods, by pollutant Leave this up to tester? ˃ Process information Continuous/ Batch/ Other Pollution Control Equipment S tack parameters Test port locations
Prepare an RFP - Timing Plan ahead 3 months Engineering Test Compliance Test New Regulation Compliance Test 12 months
Considerations When Choosing a Test Firm ˃ Prior experience at your facility ˃ Cost Check all proposals are apples to apples ♦ Test Methods ♦ Days onsite and preparation ˃ Expertise in your test methods and industry ˃ Availability
Reviewing Test Protocols 3/ 15/ 2018
Planning Considerations ˃ Do not leave testing firm to draft protocol alone Team approach required for success Testers need plant or consultant input on plant specifics, concerns, coordination Testers cannot be the experts on nuances of your specific regulation If tester does not welcome your involvement in these aspects, find another 3/ 15/ 2018
Planning Considerations Testing Firm • Test Methods SUCCESS Plant Consultant Personnel • Regulations • Facility / • Agency Operations Expectations • Permit 3/ 15/ 2018
Test Protocol Elements ˃ Protocol is high level outline of test ˃ Make internal protocol for informal tests ˃ Critical: Process description Operation – Normal/ Worst Case Test location information Test methods to be used S chedule Method exceptions/ changes (if any)
Test Protocol Elements ˃ Desirable/ Internal: Key test personal CVs Photographs/ diagrams of test location(s) and emissions unit(s) Example field data sheets Example calculations
Test Protocol Review ˃ Agency review practices vary widely Written approval of test protocol PRIOR to test Protocol review AFTER receipt of test report ˃ Review focuses on compliance with methods and regulations – NOT accuracy of results ˃ Actively seek approval in advance Deviations from regulatory or permit requirements Deviations from test methods
Selecting Test Methodology > Check permit for regulated pollutant(s) and applicable regulation(s) > Review Ohio EP A Administrative Code > Check U.S . EP A Regulation – eCFR Online http:/ / www.ecfr.gov/ cgi-bin/ text- idx? S ID=ac0a7c178d1c53dec8a6abe091a2f120&tpl=/ ecfrbrowse/ Title 40/ 40tab_02.tpl
Sampling/Analytical Method Sources > 40 CFR Part 60, Appendix A; Part 63 –Applicable subpart > EP A Emission Measurement Center. Includes promulgated, alternate, conditional and preliminary test methods. http:/ / www.epa.gov/ ttn/ emc > EP A Office of S olid Waste, S W-846 Methods http:/ / www.epa.gov/ epaoswer/ hazwaste/ test/ under.htm > California Air Resources Bureau http:/ / www.arb.ca.gov/ testmeth/ testmeth.htm > National Council for Air and S tream Improvement (NCAS I) Methods. http:/ / www.ncasi.org/ Publications/ Detail.aspx? id=172400
Preparing for the Test 3/ 15/ 2018
Select Test Date(s) ˃ S chedule the test date with Tester Plan for intent to test notification (30-60 days prior to test) Provide buffer before regulatory deadline in case something goes wrong Be aware of process shutdowns, turnarounds, or other situations ˃ S chedule the necessary production. The maj ority of compliance tests in Ohio and Kentucky must be performed at a “ Maximum Achievable Rate” or a Worst Case scenario Plan for two hours of production for every 1 hr of scheduled sampling.
Planning Considerations ˃ Test Ports Accessibility/ Clearance Has source been tested before? Are ports adequate/ correct/ usable? Any obstructions ? ˃ S afety Plant S afety Training Required? Contractor S afety Plan 3/ 15/ 2018
Good Test Platform Test Ports Heat Shield Hand, Knee and Toe Rails
Clearance Problem
Safety/Environmental Problem
Ladder Types Always Tie Off! Safety Cage Tracked, with Free Climb Temporary Safety Harness
Other Access Stack Elevators Articulated Lifts ASK ABOUT WEIGHT LIMITS
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