UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Antelope Valley Air Qualit y Management

Rule 218 Continuous Emissio n Mo nitoring

Prepared by: Stanley Tong

May 1

, 2013 2



RULE IDENTIFICATION

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

SIP Approved Rule: Rule 218

– Stack Monitoring

A mended

– May 17. 2005

Submitt ed

– March 10, 2006 EPA Approved

– September 2, 2008 ( 73 FR 51226 )

Subject of this TSD: Rule 218

– Continuous Emission Monitoring

Amended

– July 17, 2012

Submitted

– February 6, 2013

BACKGROUND

– EPA requested AVAQMD consider updating Rule 218 since the technical requirements in the rule ha d not been updated in several years and Rule 218 was being referenced in R ule 431.1

– Sulfur Content of Fuels , which was being

amended

.

EP A suggested the District may want to follow South Coast Rule 218 May 14, 1999

amendments and EPA’s comments on the South Coast rule as a guide to updating
AVAQMD Rule 218 . This would separat e the existing AVAQMD Rule 218 into two separate rules, one contai ning administrative requirements and the other containing technical requirements

.

RULE SUMMARY

- Rule 218 as amended on May 17, 2005 was titled “Stack Monitoring”. The rule specified requirements for continuous emission monitoring systems to measure emiss ions of oxides of nitrogen (NOx), carbon dioxide (CO 2 ), oxygen (O 2 ), and sulfur dioxide (SO 2 ) for certain types of operations such as those involving steam generators with a heat input of at least 250 MMBTU/hr and with a use

factor of at least 30%.

At EPA ’s request , AVAQMD updated the technical requirements of Rule 218 and separated it into two rules. Rule 218

– Continuous Emission Monitoring contains administrative requirements and Rule 218.1

– Continuous Emission Monitoring Performance Specifications con tains technical requirements for continuous emissions monitoring systems.

Changes from the SIP approved rule include:

1. Revised the applicability section of the rule to cover all sources that require continuous emissions monitoring systems ( CEMS ) as requi red by a n AV AQMD regulation or permit condition except CEMS which are subject to: AVAQMD Regulation IX

– Standards of Performance for New Stationary sources ; Regulation X

– National Emissions Standards for Hazardous Air Pollutants ; or Rule 3010

– Acid Rain Provisions of Federal Operating Permits. 3

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a. AVAQMD’s staff report 1 states that previously there were no sources subject to the applicability limits of Rule 218. The staff report further states that while

several facilities will become subject to the ame nded rule , the District anticipates

that the facilities will not have any additional requirements since their CEMS are already subject to the CEMS requirements in 40 CFR 60 Appendices B and F.

2. Rule 218 does not apply to CEMS subject to permit conditions whose purpose is to monitor the performance of basic control equi pment rather than to meet an applicable limit or standard

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3. Rule 218 does not apply to CEMS where alternative performance specifications are required by another District rule.

4. Adds approval requirements for new and modifi ed CEMS and semi

- continuous emission monitoring systems ( SCEMS )

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5. Provide s an option that CEMS may be certified and operated according to Rules 218 and 218.1 or certified according to 40 CFR 60 Appendi x B and operated and

mai ntained in accordance with Rule 218 and 40 CFR 60 Appendix F.

6. Allowes the use of SCEMS in lieu of CEMS.

7. Require s existing CEMS and SCEMS be subject to standards for a new or modified CEMS when a modification is made that requires recertification.

8. Requir es existing time

- shared SCEMS be subject to standards for a new or modified CEMS when a modification is made that requires their recertification.

9. Adds recordkeeping provision for calculations

, raw parameter data used for

calculations

, and emissions rates.

10. Changes the submission of CEMS data from once a month to once every six

months.

11. Requires reporting exceedances and failure or shutdown within 24 hours, or by the next business day.

12. Update s several definitions.

EVALUATION CRITERIA

- The following crit eria were used to evaluate the submitted

rule s

1. 40 CFR 60 Appendix B

– Performance Specifications

1 See AVAQM D Rule 218 and 218.1 Continuous Emission Monitoring Final Staff Report: 08/24/12, page 11. 4



2. 40 CFR 60 Appendix F

– Quality Assurance Procedures

3. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints,
Deficiencies, and Deviat ions , 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

. S IP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

EPA EVALUATION

- A summary of our evaluation follows.

1. Changes to Rule 218 include defining "continuous monitoring" as a mi nimum of

one measurement taken and recorded each minute. Semi

- continuous emission monitoring systems (SCEMS) are allowed a minimum of one measurement taken and recorded every 15 minutes. Measurements may be concentration, mass emission rate, stack gas fl ow rate and/or fuel flow rate . The requirements for the application submittal and approval of CEMS in Rule 218, Section (D)(1) also appl ies to SCEMS.

2. CEMS owners or operators are required to submit a CEMS report once every six

months within 30 days fo llowing the end of the six month period . This reporting requirement relaxes the original monthly reporting requirement to be consistent

with reduc ing the burden of recordkeeping and reporting as discussed in 64 FR

7458 , February 12, 1999

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3. EPA reviewed draft amendments to Rule 218 and asked AVAQMD whether

facilities with existing CEMS already comply with the proposed standards, and if they do , the District should consider removin g the grace period existing CEMS are given to comply with the new standards. The grace period provision was subsequently removed from the final version of Rule 218.

4. The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and determine compliance with Rule 218 consistently.

5. W e propose to determine that our approval of the submittal would comply with

CAA §§ 110(l) and 193 because (1) the proposed SIP revision would not interfere

with the on

- going process for ensuring that requirements for reasonable further

progress and attainment of the National Ambient Air Quality Standards are met, 5



and (2) the administrative require ments for continuous monitoring systems in the submitted rule are more stringent than the existing SIP

- approved control requirements that they would replace.

EPA ACTION

- The submitted Rule 218 strengthens the SIP. There are no expected

emission reductio ns 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 staff recommends approval of Rule 218 pursuant to CAA §110(k)(3 ) and §301(a).

REFERENCES

- 1

. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” (a.k.a., Bluebook) 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, Augu st 21, 2001 ( htt p://www.epa.gov/region09/air/sips/littlebluebook2001.pdf )

.

3

. AV AQMD Rule 218, Continuous Emission Monitoring, amended July 17, 2012,

submitted on February 6, 2013

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4. AV AQMD Rule 218, Continuous Emission Monitoring, amended May 17, 2005

.