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

Antelope Valley Air Quality Management District,

Rule 218 .1 Continuo us Emission Monitoring Performance Specifications

Prepared by: Stanley Tong

May 1, 20 13− 2

− RULE IDENTIFICATIO N

Agency: Antelope Valley Air Quality Management District ( AV AQMD)

SIP Approved Rule: There is no prior v ersion of this rule in the SIP

Subject of this TSD: Rule 218 .1

- Continuous Emission Monitoring Performance Specifications

A dopted July 17

, 2012 ; Submitted February 6

, 2013

RULE SUMMARY

- R equirements from the 2005 SIP approved version of Rule 218 were updated and divided into an administrative portion (Rule 218) and a technical portion (Rule 218.1). Rule 218.1 is a new rule and contains requirements for the

certification of continuous emission monitoring systems (CEMS)

, the performance specificat ions of CEMS , and the operation and maintenance of CEMS

.

The rule applies to all sources that require a certified CEMS pursuant to AVAQMD Rule 218, Continuous Emission Monitoring.

Rule 218.1 contains :

1. Technical s tandards for new or modified CEMS

This section includes pre

- certification requirements such as : the location of the

CEMS ; location s for the sampling probe and reference method sampling port ; full

span range of the CEMS; strip chart recorder requirements; and requirements for

the data acquisitio n system.

To demonstrate the acceptability of a new or modified CEMS, Rule 218 requires a series of certification tests be performed using the technical criteria in Rule

218.1. These criteria include: testing to determine calibration error ; testing for

r elative accuracy; and verifying analyzer enclosure environmental control and

alarm requirements are met.

Rule 218.1 also requires CEMS to be properly operated and maintained which

includ es conducting calibration error tests each operating day

, quarterly cylinder gas audits

, and annual system bias and relative accuracy tests

. Rule 218.1 allows the District to require recertification of the CEMS if its annual availability falls below 95 percent.

2. Standards for existing CEMS Existing gaseous air contaminant CEMS must meet certain performance specifications such as: the minimum time a CEMS must operate continuously according to the manufacturer’s specifications without unscheduled maintenance, repair, or adjustment; and requirements for the allowable− 3

− ca librati on error

, response time, zero drift, calibration drift

, and relative accuracy.

Rule 218.1 contains s imilar performance specification s for diluent gas CEMS.

3. Standards, specifications and requirements for new, modified and existing CEMS

This section contai ns specifications for the manufacture, analysis and

certification of calibration and zero gas es , requirements to record the magnitude of automatic calibration adjustments, and a requirement to perform NO 2 to NO

conve rsion efficiency test ing using SCAQMD Me thod 100.1.

4. Time

- shar ed CEMS

Time

- shared CEMS are monitoring systems where the analyzer and possibly the sample conditioning systems are used on more than one source. Rule 218.1 requires t ime

- shared CEMS to meet all performance specifications in the rule

, data

- reading periods at least three times the longest response time of the system, and capable of performing zero and span calibrations at each source.

5. Minor changes were also made to update Rule 218.1’s list of reference test

methods

.

6. Rule 218.1 also i ncludes alternative requirements for CEMS operators who elect or may be required to measure concentrations that fall below 10 percent of the lowest vendor guaranteed full scale span range.

EPA EVALUATION

- The following documents were used to evaluate th e 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 Rule 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 previou s versions of rules have been SIP approved, new submittals must comply with CAA §110(l) and §193 regarding SIP relaxations.

The submitted rule provides performance specifications standards for new or modified CEMS, and standards for existing CEMS. Techn ical s tandards that originally appeared in Rule 218 for existing CEMS were moved to Rule 218.1 and were generally unchanged except for minor technical clarification s

.

The s tandards for new or modified CEMS include specifications and requirements for

ins tallation and sample location, certification tests, relative accuracy tests, and− 4

− performance specifications for the operation and maintenance of the CEMS after they

have been certifi ed by the District

.

Daily calibration error tests, quarterly cylinder gas audits, and annual system bias and relative accuracy test audits are also required for quality assurance/quality control under

Rule 218.1.

AVAQMD incorporated EPA’s r ecommendation on a similar South Coast rule to remov e the relative accuracy de minimus c riteria for NOx and CO.

EPA ACTION

– The submitted Rule 218.1 strengthens the SIP

. There are no expected emission reductions from this rule as it primarily updates technical performance specifications for continuous emission monitoring systems . The ru le largely fulfills the relevant CAA § 110 and part D requirements

. EPA staff recommends approval of Rule 218.1 pursuant to

CAA § 110(k)(3) and § 301(a)

.

REFERENCES

- 1. "Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," (a.k.a., Blu ebook) EPA OAQPS, May 25, 1988. ( http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf ).

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. AVAQMD Rule 218.1, Continuous Emission Monitoring Performance Spec ifications, amended July 17, 2012, submitted on February 6, 2013

.

4. AVAQMD Rule 218, Continuous Emission Monitoring, a dopted July 17, 2012, submitted on February 6, 2013.

5. SCAQMD Rule 218.1, Continuous Emission Monitorin g Performance Specifications, a dopte d May 1 4, 1999

.

6. SCAQMD Rule 218, Stack Monitoring, a mended May 14, 1999.

7. 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 Steck el) to SCAQMD (Elaine Chang).