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Emissions Factors and Policy Application Center Highlights for 2008
This is a status report from the Measurement Policy Group of projects and other current activities involving air emissions monitoring and other emissions quantification tools, databases, and protocols. June 2008.
Improving Emissions Monitoring through Rulemaking
- Draft Performance Specifications and QA/QC for Continuous Parameter Monitoring Systems (PS-17) - Our newer emissions standards (e.g., MACT and NSPS) frequently include requirements for monitoring of process or control device operational parameters. There are also requirements for the operator to stay within site-specific or rule-specific operating ranges. We recognized the need for more-detailed performance specifications for installing, operating, and maintaining these parametric monitoring systems (e.g. temperature, pressure, pH, liquid flow, conductivity) and have begun work on drafting performance specifications and quality assurance requirements. We plan to propose these requirements in 2008. Public review and comment will follow the proposal. Contact: Barrett Parker parker.barrett@epa.gov, 919-541-5635.
New and Revised 40 CFR Part 51, Appendix M, Test Methods
- Method 201A Revisions – Method 201A is used to determine in-stack PM10 emissions using a cyclone or cascade impactor. Planned revisions will specify a PM2.5 cyclone from a conventional five-stage cascade cyclone train to allow measurement of PM2.5. The PM2.5 cyclone would be inserted between the PM10 cyclone and the filter of the Method 201A train and stack gas is sampled at a predetermined constant flow rate through the in-stack cyclones and filter. Proposal of the Method 201A revisions (which will ultimately replace CTM-040) is planned for 2008. Contact: Jason DeWees, MTG, dewees.jason@epa.gov, 919-541-9724 and/or Ron Myers, MPG, myers.ron@epa.gov, 919-541-5407.
- Improving Method 202 for Measuring Condensable PM2.5 - This project is designed to develop technical information for future improvement of the method to reduce sulfur dioxide (SO2) artifact formation. We have conducted in-house laboratory evaluations of the effects of a range of SO2 and moisture concentrations on artifact formation. We have also evaluated several potential modifications to the sampling train to reduce artifact formation. Interested stakeholders have been undertaking field studies of various source types using the method with the modifications. The purposes of these studies will be to: 1) verify the characteristics of the improved Method 202 and any modifications and 2) to collect new data more representative of condensable PM emissions than those currently published in emissions factors compilations. Our current focus is to propose and promulgate a revised Method 202. We hope to propose this year and promulgate in early 2009. Contact: Jason DeWees, MTG, dewees.jason@epa.gov, 919-541-9724 and/or Ron Myers, MPG, myers.ron@epa.gov, 919-541-5407.
Improving Emissions Monitoring through Rulemaking
- Inadequate Monitoring (Advanced Notice of Proposed Rulemaking) - On February 16, 2005 (Volume 70, Number 31)], we published an ANPR asking for public comment to help us identify monitoring in applicable requirements under the Clean Air Act (Act) that is potentially inadequate for both statutory monitoring requirements and operating permits issued under title V of the Act. We also requested comment on ways to update and/or improve such monitoring. We have reviewed those comments and prepared responses with a view towards identifying opportunities for and criteria to use in prioritizing potential future regulatory activities to update emissions monitoring and testing provisions in parts 60, 61, and 63.. We expect to target those regulations where monitoring would improve assurance of significant emissions reductions. Currently, we are evaluating the parts 60 and 63 regulations as required by the Clean Air Act to determine whether updates/revisions (including emissions monitoring and performance testing) are needed. Contact: Tom Driscoll, driscoll.tom@epa.gov, 919-541-5135.
- Interpretive Rule for Parts 70/71 Monitoring - On June 2, 2006, we proposed and on December 15, 2006, we finalized an Interpretive Rulemaking to Clarify the Scope of Certain Monitoring Requirements for State and Federal Operating Permits Programs. This action addressed an interpretation of certain existing regulatory language relative to the need to address the sufficiency of existing monitoring requirements included in State and federal operating permits programs developed under title V of the Clean Air Act (Act). Specifically, the final interpretation is that §§ 70.6(c)(1) and 71.6(c)(1) of 40 CFR parts 70 and 71 (previously referred to as the Umbrella Monitoring Rule) do not authorize an independent assessment of the adequacy of or adding monitoring requirements to operating permits. This interpretation has no effect on implementing the other monitoring provisions required under existing federal air pollution control rules and State implementation plan (SIP) rules (i.e., monitoring required under applicable requirements), including monitoring required under part 64 (the compliance assurance monitoring, or CAM, rule) where it applies, and such monitoring as may be required to fill gaps under the separate periodic monitoring requirements of the operating permits rules in §§ 70.6(a)(3) and 71.6(a)(3). The EPA was sued by environmental action groups on this rulemaking. Oral arguments were heard on February 8, 2008 and a written ruling is expected later this year. Contact: Peter Westlin, MPG, westlin.peter@epa.gov, 919-541-1058.
- Revisions to Part 64, Compliance Assurance Monitoring - We have drafted rulemaking entitled “Proposal of Revisions to Part 64 - Compliance Assurance Monitoring Rule,” that would govern how states implement monitoring in the title V operating permit program. The revised rules would expand the applicability of part 64 applying the same monitoring design principles to nearly every type of pollutant-specific emissions unit at title V sources. The rule would define more specifically when monitoring may be needed on a pollutant-specific emissions unit basis and set forth a process by which sources and permitting authorities would assess existing monitoring and create periodic monitoring, as needed, to provide a reasonable assurance of compliance with applicable requirements. This proposal is part of the Agency’s four-step approach to addressing monitoring in title V permits as explained in the January 22, 2004 Federal Register notice (69 FR 3202). Although the rule revisions’ documents are currently undergoing internal review, their proposal does not appear to be happening soon. Public review and comment will follow any rule proposal. Contact: Peter Westlin, MPG, westlin.peter@epa.gov, 919-541-1058.
Emissions Factors Improvement
- Emissions Factors Development Procedures – In June of 2006, we made available for review and comment Detailed Procedures for Preparing Emissions Factors on the CHIEF website. The purpose of this document is to describe the specific tasks involved in the development of air pollution emissions factors and their subsequent incorporation into EPA’s web-based Factor Information and REtrieval (WebFIRE) system (see below). The major changes to the historic emissions factor development process are to
- provide more extensive detail on the emissions factor development procedural and technical steps,
- clarify roles for emissions test data and report review and approval, and
- incorporate data assessment tools particularly the uncertainty assessment available through the electronic reporting tool (ERT, see below).
- Emissions Factors Data Uncertainty - In 2006, we completed a statistical study of the uncertainty associated with published emissions factors that are based on emissions testing data, such as those contained in AP-42. We presented the study’s approach and the results to internal EPA reviewers and a panel of expert peer reviewers and have addressed comments and suggestions received as a result. Last year, we submitted a report describing the technical approach and the results to Congress and the Office of Management and Budget. We also put the report on the MPG website (www.epa.gov/ttn/chief/efpac/uncertainty.html) to seek more public comment. Currently, EPA OAQPS is considering how to implement the uncertainty findings in this report. Contact: Barrett Parker, parker.barrett@epa.gov, 919-541-5635.
- WebFIRE – The Factors Information REtrieval system (WebFIRE) (http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main) is on the CHIEF website. WebFIRE is an automated data base that replaces the existing AP-42 documents (AP-42 sections, supporting background reports and source test reports) with an electronic storage and calculation program. The database provides storage of complete source test reports; extracts associated process, control device, and emissions data from source test reports; and may eventually automatically calculate the arithmetic mean of the data in individual source test reports to provide updated emissions factors. When completed, uncertainty information (when we determine a policy for implementing uncertainty information) based upon emissions test characteristics and applications can be included, enabling users to obtain the information that they need to make informed decisions. We have also provided a list of frequently asked questions that describe in more detail the functions of the WebFIRE program and how the emissions factors are derived. In 2008, we plan to continue our development efforts by making further enhancements and refinements to the system as well as populating the system with data from AP-42. Contact: Michael Ciolek, ciolek.micheal@epa.gov, 919-541-4921.
- WebFIRE Emissions Factors Updates –We updated and added several sections to AP-42 in 2006. The new and updated materials are largely a result of collaborative efforts between MPG and industry and agency stakeholders. New materials published this past year and/or planned for 2008 include:
- Iron and steel minimills – anticipate finalizing this section by September 2008 with a description of the industry and revised EFs for PM (filterable and condensable), NOx, CO, SO2, lead, fluoride, and VOC,
- Ordnance detonation – continue to develop final and new draft sections describing the weapons and the emissions produced by detonation including criteria pollutants, CO2, and hazardous and toxic pollutants,
- Fugitive Dust Emissions from Paved and Unpaved Roads – corn refiners are developing emissions factors for paved roads at low speeds,
- Municipal Waste Combustors,
- Refineries – development of formaldehyde emissions factors for petroleum refineries,
- Rubber Manufacturing – data have been collected to develop new emissions factors but are awaiting decision on EPA data uncertainty status,
- Landfills – data have been collected and compiled and is currently going through peer review for new and revised emissions factors,
- Taconite Ore industry – developing emissions information for larger weight vehicles for unpaved roads, and
- Coke Ovens – anticipate finalizing emissions factors for all emissions points by June 2008, but are specifically responding on the HCl emissions factors and entered into WebFIRE.
Contacts: Michael Ciolek, ciolek.micheal@epa.gov, 919-541-4921, John Schaefer, schaefer.john@epa.gov, (919) 541-0296, and John Bosch, bosch.john@epa.gov, 919-541-5583
Tools for Improved Monitoring and Testing
- Electronic Reporting Tool (ERT) - In early 2006, we made available a Microsoft Access desktop application, called the ERT that is an electronic alternative for paper reports documenting EPA's emissions measurement Methods 1 through 5 and Method 202 for stationary sources. The ERT replaces the time-intensive manual preparation and transcription of stationary source emissions test plans and reports currently performed by contractors for emissions sources and the time-intensive manual quality assurance evaluations and documentation performed by State and Local Air Pollution Control Agencies. This tool provides a format that: 1) highlights the need to document the key information and procedures required by the existing EPA Federal Test Methods; 2) facilitates coordination among the source, the test contractor, and the regulatory agency in planning and preparing for the emissions test; 3) provides for consistent criteria to characterize quantitatively the quality of the data collected during the emissions test; 4) standardizes the form and content of test reports; and 5) provides for future capabilities to exchange information in the reports electronically with facility, State, or Federal data systems. In addition to improving the content and quality of source emissions test reports, the ERT should reduce the workload associated with manual transcription of information and data contained in the report, the resources required to store and access the reports, and redundant efforts in using the data for multiple purposes. The current version of the ERT is available for review and comment at http://www.epa.gov/ttn/chief/ert/ert_tool.html. In 2008, we plan to expand the capabilities of the tool to address EPA emissions testing methods for SO2, NOx, THC (Method 25A), metals, and halides. Contact: Ron Myers, myers.ron@epa.gov, 919-541-5407.
- RACT/BACT/LAER Clearinghouse (RBLC) – The RBLC (http://cfpub.epa.gov/rblc/htm/bl02.cfm) contains case-specific information on the "Best Available" air pollution technologies that have been required to reduce the emissions of air pollutants from stationary sources (e.g., power plants, steel mills, chemical plants, etc.). EPA has provided this vehicle for State and local permitting agencies to use to distribute this information. The Clearinghouse also contains a data base of State and local regulations and summarizes EPA emission limits required in New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) standards. The RBLC also includes links to software tools (e.g., emissions modeling tools, databases) that can be used to estimate emissions, evaluate alternative control and prevention technologies, or identify less polluting materials. In 2006, we launched a Spanish language version of the RBLC providing Mexico and other Central and South American agencies, and many European agencies direct access to the databases including the ability to input data. In 2008, we plan to extend access to the data sources to Canadian national and provincial agencies. Contact: Iliam Rosario, rosario.iliam@epa.gov, 919-541-5308.
- Fugitive VOC and Dust Emissions Measurement – We continue to focus on more complete and accurate characterizations of fugitive VOC and fugitive dust emissions. We also continue to examine policy implications of using such technology. We are holding numerous stakeholder workshops on the availability and capabilities of various testing and monitoring technologies using open path optical remote sensing tools. Contact: John Bosch, bosch.john@epa.gov, 919-541-5583.
- Greenhouse Gas (GHG) Emissions Reporting - The FY2008 Consolidated Appropriations Amendment, signed by the President on December 26, 2007, “… authorizes EPA to develop and publish a draft rule (no later than 9 months after the date of enactment of the amendment, September 2008) and a final rule (no later than 18 months after the date of enactment of the amendment, September 2009) to require mandatory reporting of GHG emissions above appropriate thresholds in all sectors of the economy. EPA was further directed to include in the rule reporting of emissions resulting from upstream production and downstream sources, to the extent that the Administrator deems it appropriate. The Administrator shall determine appropriate thresholds of emissions above which reporting is required, and how frequently reports shall be submitted to EPA.” MPG’s role in this project will be to evaluate and work with stakeholders to develop better emissions factors and to review data submissions as needed. Contact: Tom Driscoll, driscoll.tom@epa.gov, 919-541-5135.