UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

F or

EPA ' s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District,

Rule 218, Continuo us Emission Monitoring

Prepared by: Stanley Tong

March 18, 20102

RULE IDENTIFICATIO N

Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Rule: Rule 218

– Stack Monitoring

A mended

– August 7 , 198 1 ;

Submitted

– October 23, 1981

EPA Approved

– July 6 , 198 2 ( 47 FR 29231 )

Subject of this TSD: Rule 218

– Continuous Emission Monitoring

Amended

- May 1 4 , 19 99 ;

Submitted Ju ly 23 , 199 9

RULE SUMMARY

- Rule 218 establishes requirements for continuous stack emission

monitor s of oxides of nitrogen (NOx), sulf u r dioxide (SO 2 ), gaseous sulfur

compounds, and carbon monoxide (CO). The South Coast Air Quality Management

District (SCAQMD) staff report for this rule summarizes that many of the provisions

of th e 1981 version of Rule 218 ha ve become out

- of

- date since the adoption of the

Regional Clean Air Initiative Market ( RECLAIM ) program and the advancement in

continuous emission monitoring technology. SCAQMD staff recognized the

deficiency of several provisi ons in Rule 218 and took steps to am end the rule to

better define specifications and guidelines for continuous emission monitoring

systems (CEMS) to eliminate ambiguity in both the administrative and technical

provisions of the rule

. SCAQMD also took the r equirements from the original SIP

approved ru le and separated them i nto an administrative portion and a technical

portion. Rule 218 now covers administrative requirements for CEMS and include s

applicability

, application and approva l process

, and recordke eping and reporting

requirements for CEMS . The technical requirements for CEMS in the 1981 version

of Rue 218 were updated moved to Rule 218.1.

Changes from the approved SIP rule include:

1. Chang ed the title of Rule 218 from " Stack Monitoring " to "Continu ous Emission

Monitoring".

2. Revised the applicability of the rule to cover all sources that require CEMS as

required by a SCAQMD regulation or permit condition except CEMS under

RECLAIM , New Source Performance Standards (NSPS), and Acid Rain. Rule

218 al so does not apply to CEMS subject to permit conditions whose purpose is

to monitor the performance of basic control equipment rather than to meet limits

or standards.

3. Added CEMS application, modification, and certification procedures.

4. Provided an option between 40 CFR 60 Appendices B and F and Rule 218.1 for

CEMS certification and quality assurance.3

5. Allow ed the use of semi

- continuous emission monitoring systems (SCEMS) in

lieu of CEMS.

6. Require d owners or operators of existing CEMS to submit either

a) a certification that existing CEMS meets the requirements for a new or

modified CEMS, or

b) an application for new or modified CEMS, or

c) an application for waiver

7. Required e xisting CEMS to meet the standards for new or modified CEMS by

May 14, 2006

.

8. Required existing CEMS and SCEMS be subject to standards for a new or

modified CEMS when a modification is made that requires recertification.

9. Required existing time

- shared SCEMS be subject to standards for a new or

modified CEMS when a modification is made that requires their recertification.

10. Added recordkeeping provision for calculations and raw parameter data used for

calculations and emissions rates.

11. Revised submission of CEMS data from once a month to once every three

months.

12. Require d reporting exceeda nces and failure or shutdown within 24 hours, or by

the next business day.

13. Updated several definitions.

EPA EVALUATION

- The following documents were used to evaluate the submitted

rule.

1. 40 CFR 60 Appendix B

– Performance Specifications

2. 40 CFR 60 Appendix F

– Quality Assurance Procedures

3. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints,

Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook

( Guidance Document for Correcting Common VOC & Other Ru le Deficiencies,

EPA Region 9, August 21, 2001) were used to help evaluate compliance with the

CAA § 110(a)(2)(A) requirement for enforceability.

4. SIP Relaxation

- Where previous versions of rules have been SIP approved, new

submittals must comply with CAA § 110(l) and § 193 regarding SIP relaxations.4

Changes to Rule 218 include defini ng "continuous monitoring" as a minimum of one

measurement taken and recorded each minute and averaged over 15 minutes or 60

minutes. Semi

- continuous emission monitoring s ystems (SCEMS) are allowed a

minimum of one measurement taken and recorded every 15 minutes. Measurements

may be concentration, mass emission rate, stack gas flow rate and/or fuel flow rate. The

standards for CEMS also apply to SCEMS.

The rule also requ ires certification that existing CEMS meet the new standard and for

facilities to develop and implement a quality assurance/quality control plan. If the owner

or operator of the CEMS elects the performance specifications of Rule 218.1, then they

will be r equired to submit a QA/QC plan within 90 days after CEMS installation or

modification.

CEMS owners or operators are required to submit a CEMS quarterly report within 30

days of the end of each three month period.

EPA reviewed the draft amendments and pr ovided a recommendation that facilities

choosing to continue to operate under the existing CEMS option should be required to

develop a QA/QC plan and that the QA/QC plan should be implemented within a year of

adopting amendments to Rule 218 and that record s be maintained for five years instead

of the minimum two years. Rule 218 was am ended to require the QA/QC plan but did

not extend the recordkeeping requirement to five years.

ADDITIONAL RECOMMENDATION FOR THE NEXT RULE REVISION

- The following

is recomm ended for the next time the rule is amended.

1. Consistent with CAA Title V and the federal statute of limitations, we recommend

that Section e(1) require that records be maintained for five instead of two years.

EPA ACTION

–

The submitted Rule 218 st rengthens the SIP. There are no expected emission

reductions from this rule as it primarily updates administrative requirements for

continuous emission monitoring systems. The rule largely fulfills the relevant CAA § 110

and part D requirements. EPA staf f recommends approval of Rule 218 pursuant to

CAA § 110(k)(3) and § 301(a).

ATTACHMENT S

–

1. SCAQMD Rule 218

, Continuous Emission Monitoring, as submitted on July 23

, 199 9

.

2. SCAQMD Rule 218

, Stack Monitoring , as approved into the SIP on July 6, 1982

.5

3. Comment letter dated March 31, 1999, Review of Proposed Amended Rule 218

and Proposed Rule 218.1, from EPA Region IX (Andrew Steckel) to SCAQMD

(Elaine Chang).

REFERENCES

-

1. "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,"

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2. "Guidance Document for Correcting Common VOC & Other Rule Deficiencies,"

(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001

( http ://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).

3. Comment letter dated March 31, 1999, Review of Proposed Amended Rule 218

(PAR 218

– December 11, 1998) and proposed Rule 218.1 (PR 218.1

– no date)

from EPA Region IX (Andrew Steckel) to SCAQMD ( E laine Chang ).