UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for EPA ’ s Rulemaking for the Arizona State Implementation Plan

Arizona Department of Environmental Quality

Title 18, Article 3, Section R18

- 2

- 313

Existing Source Emission Monitoring

Prepared by: Stanley Tong

June 12

, 2012 2



RULE IDENTIFICATION

Agency: Arizona Department of Environmental Quality (ADEQ)

SIP Approved Rule: Rule R9

- 3

- 313

– Existing Source Emission Moni toring Submitted

– January 4, 1979, and

April 1, 1980, and July 17, 1980 EPA Approved

– April 23, 1982 ( 47 FR 17483 )

Subject of this TSD: Rule R18

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- 313 Existing Source Emission Monitoring Amended

- Submitted

– Expected August 2012

Purpose of Amend ed Rule

– Section 110(a) of the Clean Air Act (CAA) requires s tates to submit regulations that control volatile organic compounds, oxides of nitrogen, particulate matter, and other air pollutants which harm human health and the environment. Rule R18

- 2

- 313 w as developed as part of the local agency’s program to monitor emissions of certain pollutants. Arizona Department of Environmental Quality (ADEQ) submitted th is r ule to support the infrastructure SIP requirements of section 110(a)(2) of the CAA.

BACKGROU ND

– A DEQ Rule R9

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- 313, Existing Source Emission Monitoring, ( July 17, 1980 )

, was approved into the Arizona State Implementation Plan on April 23, 1982 (47 FR 17483)

. The rule contains minimum requirements for owners and operators to install, calibrate,

o perate and maintain continuous monitoring equipment at certain fossil

- fuel fired steam generators, fluid bed catalytic cracking unit catalyst regenerators, sulfuric acid plants, and nitric acid plants.

Rule R9

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- 313 was subsequently renumbered as R18

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- 31 3 . Rule R18

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- 313 was last amended on March 9, 2001 . Both the 1980 SIP approved version of the rule and the current SIP submittal l argely parallel the requirements found in 40 CFR part 51, Appendix P, Minimum Emission Monitoring Requirements . The rules spe cify the source categories subject to emission s monitoring; contain requirements for recording and reporting data ; re ference 40 CFR part 60

, Appendix B, Performance Specifications for accuracy and reliability of acceptable monitoring systems; and contain e quations to convert monitoring emissions data to units of the emission standards.

RULE SUMMARY

– In order to help determine compliance with applicable emission limits, Rule R18

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- 313 requires fossil

- fuel fired steam generators with an annual capacity fac tor greater than 30% that are subject to an opacity standard

, and are greater than 250 MM Btu/hr to install, calibrate, operate, and maintain a continuous emission monitoring system to measure opacity. Certain exemptions from the requirement to install and maintain continuous emission monitors are allowed by the rule

, such as whe re gaseous fuel is the only fuel burned

, or when oil or a mixture of oil and gas are the only fuels burned and the stationary source is able to comply with the particulate and opaci ty standards without the use of control equipment for particulate matter

. The rule also requires continuous emission monitoring systems to meet 3



the performance specifications in 40 CFR part 60, Appendix B, for sulfur dioxide, nitrogen oxides, and oxygen or carbon dioxide.

In addition to steam generators, Rule R18

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- 313 also specifies the minimum requirements for continuous emission monitoring system s covered by the rule for nitrog en oxides at Nitric Acid plants, sulfur dioxide at Sulfuric Acid plants, and opacity at fluid bed catalytic cracking unit catalysts regenerators at petroleum refineries.

The Rule also contains requirements for calibration gases, measurement cycling times, monitoring locations, and recording zero and drift daily calibration checks.

The following significant amendment s were made from the SIP approved version:

1. Section A.3, Variances

. The amended rule clarifies that extreme economic conditions are those conditions that " would cause the source to be unable to continue in business. "

2. Section E, Minimum data requirement, was amended to update a citation from R18

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- 310 to R18

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- 310.01. R18

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- 310.01, Reporting Requirements , was originally contained in R18

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- 310(C) and (D) . These sections were moved to a new separate section, R18

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- 3 10.01 to remove any ambiguities regarding the need and process for reporting an excess emission event.

EPA EVALUATION

– Generally, prohibitory SIP rules must be enforceable (see section 110(a) of the CAA) and must not relax existing requirements (see sect ions 110(l) and 193). We have evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the Act (CAA 110(l)).

EPA guidance documents that we used to help evaluate enforceability requirements consistently includes the following:

• Requirements for Preparation, Adoption, and Submittal of Implementation Plans, U.S. EPA, 40 CFR part 51.

• Issues Relating to VOC Regulati on Cutpoints, Deficiencies, and Deviations, EPA (May 25, 1988) (The Bluebook).

T he submitted SIP revision is more stringent than the rule previously approved into the SIP and would not interfere with any applicable requirement concerning attainment and r easonable further progress (RFP) or any other applicable requirement of the Act (CAA 110(l)) or modify, in a nonattainment area, any SIP

- approved control requirement in effect before November 15, 1990 (CAA 193).

The submitted rule contains r ecordkeeping a nd reporting requirements and performance specifications that generally ensure that the submitted rule can be enforced.

RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revisions are recommended for the next time the rule is amended but do not interfere with approval of this rule at this time. 4

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1. Section D.1.d

– typographical error This section states continuous emission monitoring systems for measuring sulfur dioxide shall comply with performance specification 3. The term "sulfur dioxide" in this section should be changed to "o xygen" to be consistent with Section F.1.c (see legend for %O(2), %CO(2) cite to subsection (D)(1)(d)) , and consistent with the SIP approved rule R

- 9

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- 313 section D.1.d and 40 CFR part 51 Appendix P section 3.1.4.

2. S ection D.6

– typographical error Please insert the word "and" between "zero" and "span" in the fifth line:

... recommendations shall be followed; shall adjust the zero span whenever the

...

3. Section F 1.a.ii

– typographical error s The second equation unde r ii contains an error. The 29.9 should be changed to 20.9 ; there should be a "minus sign" in front of the %O(2ws) in the first equation; and B(wa) should be B(ws) in both equations under F1.a.ii.

should instead be:

should instead be:

4. ADEQ may want to determine if the re are continuous emissions monitoring systems at stationary sources that should be covered by, but are not currently subject to Rule R18

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- 313 and amend Rule R18

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- 31 3 as appropriate. If R18

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- 313 is amended, ADEQ should also review

, and incorporate as appropriate, the administrative and technical requirements in South Coast AQMD Rule 218

– Continuous Emission Monitoring and Rule 218.1

– Continuous Emission Monitoring Performance Specifications.

EPA RECOMMENDED ACTION

– We recommend full approval of Rule R18

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- 313

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REFERENCES

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1. ADEQ Rule R18

- 2

- 313, Existing Source Emission Monitoring, submittal expected August 2012

. 2. ADEQ Rule R9

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- 313, Existing Source Emissi on Monitoring, as approved into the SIP on April 23, 1982 (47 FR 17483)

. 3

. “ Requirements for Preparation, Adoption, and Submittal of Implementation Plans , U.S. EPA, 40 CFR part 51. 4

. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Devia tions , EPA (May 25, 1988) (The Bluebook). 5

. 40 CFR p art 51, Appendix P. 6. EPA

- 450/2

- 78

- 042a, October 1978, Stack Sampling Technical Information

– A Collection of Monographs and Papers Volume 1 http://www.epa.gov/ttn/emc/informd/tid

020.pdf