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New CSAPR NOx Regulations

Environmental Source Samplers, Inc.

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New CSAPR NOx Regulations

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The EPA is proposing a federal plan that would cut pollution from power plants and industrial sources that significantly contribute to unhealthy levels of ground-level ozone, or smog, for millions of Americans who live downwind. 

Beginning in 2023, EPA is proposing to include electric generating units in 25 states in the Cross-State Air Pollution Rule (CSAPR) NOX Ozone Season Group 3 Trading Program, which would be revised and strengthened for the 2015 ozone NAAQS. And, beginning in 2026, EPA is proposing emissions standards for certain industrial sources in 23 states that have a significant impact on downwind air quality.

EPA’s proposed limits on NOX pollution from power plants would build upon the demonstrated success of existing CSAPR trading programs by including additional features that promote consistent operation of emission controls to enhance public health and environmental protection for the region and for local communities. These features include daily emissions rate limits on large coal-fired units to promote more consistent operation and optimization of emissions controls, limits on “banking” of allowances, and annual updates to the emission budgets starting in 2025 to account for changes in the generating fleet.

EPA is proposing emissions standards for new and existing emissions units in these selected industries:

  • reciprocating internal combustion engines in Pipeline Transportation of Natural Gas;
  • kilns in Cement and Cement Product Manufacturing;
  • boilers and furnaces in Iron and Steel Mills and Ferroalloy Manufacturing;
  • furnaces in Glass and Glass Product Manufacturing; and
  • high-emitting, large boilers in Basic Chemical Manufacturing, Petroleum and Coal Products Manufacturing, and Pulp, Paper, and Paperboard Mills.

 

This proposal implements the Clean Air Act’s “good neighbor” or “interstate transport” provision, which requires each state to submit a State Implementation Plan (SIP) that ensures sources within the state do not contribute significantly to nonattainment or interfere with maintenance of the NAAQS in other states. Each state must make this new SIP submission within 3 years after promulgation of a new or revised NAAQS.

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New CSAPR NOx Regulations

March 23, 2022

The EPA is proposing a federal plan that would cut pollution from power plants and industrial sources that significantly contribute to unhealthy levels of ground-level ozone, or smog, for millions of Americans who live downwind.

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2021 Power Plant Emissions for NOx, SO2, Hg

February 22, 2022

The U.S. Environmental Protection Agency (EPA) released publicly available, annual data on 2021 emissions of nitrogen oxides (NOX), sulfur dioxide (SO2), carbon dioxide (CO2), and mercury from power plants in the lower 48 states.

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EPA Proposes Utilizing 2016 IRIS Value for EtO Emissions

February 15, 2022

The U.S. Environmental Protection Agency (EPA) is proposing to reconsider ethylene oxide (EtO) emissions the August 2020 National Emission Standards for Hazardous Air Pollutants (NESHAP) for chemical plants that fall under the Miscellaneous Organic Chemical Manufacturing source category , 40C CFR Part 63 Subpart FFFF.

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Stationary Combustion Turbines Stay Lifted on Formaldehyde Compliance

Environmental Source Samplers, Inc.

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Stationary Combustion Turbines Stay Lifted on Formaldehyde Compliance

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The U.S. EPA signed an amendment to the rule on February 28, 2022 that removes the stay of the formaldehyde limit for lean premix and diffusion flame gas-fired units that were constructed or reconstructed after January 14, 2003. In light of the issues concerning the legality of the 2004 stay and the uncertainty concerning the timing and outcome of the EPA’s final decision on the delisting petition, the EPA is taking final action now to remove the stay of the standards for new lean premix and diffusion flame gas-fired turbines.The rule was published in the federal register on March 9, 2022.

Major HAP sources with lean premix and diffusion flame gas-fired units that were constructed or reconstructed after January 14, 2003 must demonstrate compliance with the 91 parts per billion (ppb) formaldehyde emissions limit in Table 1 of the NESHAP within 180 days of the publication of the amended rule.

This may put facilities in a time crunch if stack testing results are over the limit. Facilities over the limit will need controls such as oxidation catalysts added to their process. It is imperative to schedule stack testing immediately to determine compliance with the 91 ppb emission limit if your facility is affected. Contact ESS for a quote and scheduling.

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LEED Indoor Air Quality Assessments

December 21, 2021

ESS assists LEED builders and property owners globally by providing Air testing utilizing EPA, ISO and ASTM methodologies and Blower Door testing in accordance with ANSI/ASTM-E779-03 Standard test method for determining air leakage rate by fan pressurization.

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Forensic Analysis of Condensable PM (CPM)

Environmental Source Samplers, Inc.

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Forensic Analysis of Condensable Particulate (CPM)

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EPA Method 202 defines condensable particulate matter (CPM) as material that is vapor phase at stack conditions, but which condenses and/or reacts upon cooling and dilution in the ambient air to form solid or liquid PM immediately after discharge from the stack. Note that all CPM, if present from a source, is typically in the PM2.5 size fraction and, therefore, all of it is a component of both primary PM2.5 and primary PM10.

That still does not answer the most basic question: “What’s in my CPM?”. Many compounds can condense and form particulate matter at ambient conditions. Identifying which compound is most prevalent can help in determining control measures to reduce CPM.

Analysis can be conducted to identify likely organic or inorganic compounds in the rinse residue. A problem arises when there is no known compound in the gas stream that could cause high results. Forensic technologies such as scanning electron microscopy combined with energy dispersive x-ray spectrometry (SEM-EDS) utilize automated particle recognition followed by chemical analysis of each particle in the form of EDS Spectrum. This technology allows us to determine what kind of particles are in the samples as well as the chemical composition of the particles without narrowing the scope to known compounds. The same analysis can be conducted on filterable particulate collected by EPA Method 5 or EPA Method 201a.

If your emission source is struggling with particulate matter emission limits, contact ESS for a detailed review of your permit, past emissions test, and a plan of action to achieve compliance. 

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2021 Power Plant Emissions for NOx, SO2, Hg

Environmental Source Samplers, Inc.

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2021 Power Plant Emissions for NOx, SO2, Hg

ESS conducting a RATA on a high pressure source using specialty equipment.
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The U.S. Environmental Protection Agency (EPA) released publicly available, annual data on 2021 emissions of nitrogen oxides (NOX), sulfur dioxide (SO2), carbon dioxide (CO2), and mercury from power plants in the lower 48 states. Emissions in 2021 were higher than 2020, reflecting a rebound in coal-fired generation as natural gas prices and energy demand increased. However, compared to 2019, 2021 emissions fell between 3% and 11%, reflecting the long-standing trend of decreasing annual emissions. 

Compared to 2020, the 2021 data show a 6% increase in NOx emissions, a 20% increase in SO2  emissions, a 7% increase in CO2 emissions, and a 13% increase in mercury emissions. Additionally, ozone season (May 1 to September 30) NOX  emissions increased by 5%. Overall, based on the first 11 months of 2021, electricity demand increased by 3% compared to 2020.

Long-term declines in emissions are due primarily to changes in the mix of fuels used in electricity generation. While data from 2021 showed a one-year 16% increase in coal generation and a 3% decrease in natural gas generation, there is a shift underway from higher emitting to lower and zero emitting generation.

EPA collects detailed SO2, NOX, CO2, and mercury emission data and other information from power plants across the country, as part of ARP, the CSAPR Programs, and the Mercury and Air Toxics Standards (MATS). Emissions data collected through these programs are posted online and accessible to the public in summary form. 

To find out more about how to save money on emission testing required for Power Plants, including the Acid Rain Program, Cross-State Air Pollution Rule (CSAPR and RCU) and Mercury and Air Toxics Standards (MATS) contact ESS.  

Recent Blogs

ESS: Experts on Stack Testing for RICE Engines

July 29, 2021

ESS began regularly stack testing stationary reciprocating internal combustion engines (RICE) in 2010 due to the promulgation of 40 CFR 63 Subpart ZZZZ on March 3rd, 2010. Since then, ESS has conducted over 600 stack tests on RICE engines.

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PFAS to be Added to Water Contaminate List

July 22, 2021

On July 12, 2021 the EPA published a draft list of current drinking water contaminants that may occur in public water systems and are not currently regulated. The Draft Contaminant Candidate list 5 (CCL 5) includes three chemical groups: per- and polyfluoroalkyls substances (PFAS), cyanotoxins, and disinfection byproducts (DBPs).

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Opacity Audits and Preventative Maintenance

July 15, 2021

ESS is the experienced team when it comes to source emissions whether you need stack testing, monitoring systems maintenance and audits, or monitoring and control equipment commissioning. For more than 40 years ESS has provided annual opacity audits by 40 CFR 60 Appendix B Performance Specification 1 (40CFR60 PS-1).

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EPA Proposes Utilizing 2016 IRIS Value for EtO Emissions

Environmental Source Samplers, Inc.

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EPA Proposes Utilizing 2016 IRIS Value EtO Emissions

Emissions Testing by ESS
Emissions Testing by ESS
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The U.S. Environmental Protection Agency (EPA) is proposing to reconsider ethylene oxide (EtO) emissions the August 2020 National Emission Standards for Hazardous Air Pollutants (NESHAP) for chemical plants that fall under the Miscellaneous Organic Chemical Manufacturing source category , 40C CFR Part 63 Subpart FFFF. The NESHAP for the miscellaneous organic chemical (MON) manufacturing industry established emission limits and work practice standards for new and existing miscellaneous organic chemical manufacturing process units, wastewater treatment and conveyance systems, transfer operations, and associated ancillary equipment and implemented section 112(d) of the Clean Air Act (CAA) by requiring all major sources to meet hazardous air pollutants (HAP) emission standards to reflect application of the maximum achievable control technology (MACT).

EPA’s peer-reviewed value showed that ethylene oxide (EtO) was significantly more toxic than previously understood. The agency is proposing this action because the 2016 ethylene oxide Integrated Risk Information System (IRIS) assessment remains the best available science.

In this reconsideration action, EPA is addressing these two issues and is proposing the following:

  • To not change its decision to use EPA’s 2016 IRIS value for ethylene oxide when assessing risk for the source category in the 2020 MON final rule, as the 2016 ethylene oxide IRIS assessment remains the best available science;
  • To decline to use the TCEQ risk value for ethylene oxide instead of the EPA’s 2016 IRIS value, after careful consideration of the TCEQ risk value for ethylene oxide.

As such, EPA is not proposing any changes to our risk assessment for the 2020 MON final rule. 

EPA is moving ahead with actions under the Clean Air Act that will address air emissions of ethylene oxide.  The agency is currently undertaking a review of a rule for commercial sterilizers, which will consider risk, and expects to issue a proposal in 2022. EPA intends to use the 2016 IRIS value in the upcoming proposed rule for sterilizers.  The agency has been collecting information about the source category, including Information Collection Requests (ICR) under the Clean Air Act.  The deadline for commercial sterilizers to submit their most recent ICR response was November 2021. EPA is evaluating that data now.

Learn more:  40 CFR Part 63 Subpart FFFF

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EPA to Release Air Toxics Data Annually

July 6, 2021

Since 2002 the EPA has released the national air toxics data and risk assessment every 3-4 years. The goal of this change to policy announced on June 23rd, 2021 is to provide communities with more complete information about their air quality in a timely manner.

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New Greenhouse Gas Reduction Goals

June 7, 2021

During the recent virtual Leaders Summit on Climate, President Biden announced his goal to cut greenhouse gas (GHG) emissions by 50-52% from 2005’s levels by the year 2030. This more than doubles the previous US goals set in 2015 to cut emissions by 26-28% by the year 2025.

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Modern Waste-to-Energy

May 21, 2021

From recovery units in North Carolina landfills to elephant litter in Kentucky, ESS has experience with testing various technologies for converting waste-to-energy (WTE). ESS has tested multiple types of gasification units fired with chicken, pig, and elephant litter as well as shipboard units fired with trash.

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PFAS from Stationary Sources by OTM-45

May 1, 2021

The EPA is leading the national effort to understand PFAS and reduce PFAS risks to the public through implementation of its PFAS Action Plan and through active engagement and partnership with other federal agencies, states, tribes, industry groups, associations, local communities, and the public.

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Fenceline, Ambient, and Indoor Air Monitoring

April 10, 2021

ESS has been proudly supporting global air concerns by conducting routine tests around the world for the United Nations and World Health Organization. From fenceline monitoring in Haiti to LEED certification in Vietnam ESS has the knowledge base on international air methods and regulations.

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Condensable Particulate Matter: Understanding Stack Test Results – Blank Analysis

Environmental Source Samplers, Inc.

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Condensable Particulate Matter: Understanding Stack Test Results 

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Condensable Particulate Matter emission limits have been on the rise in multiple states and are affecting many industries. EPA Method 202 was written to quantify particulates that condense at ambient conditions and has been revised numerous times to reduce interference and increase effectiveness. Even still, ESS is regularly contacted by facilities across the country who struggle to produce accurate condensable results.

There are several things facilities should watch out for if they receive unexpected results. In this series ESS will look at condensable particulate matter stack test practices in depth. While increasing the number of blank analyses can be costly, it is important to understand the importance of each blank in determining accurate condensable particulate matter.

·         Field Train Recovery Blanks: The intent of field train recovery blanks is to measure the lowest achievable mass contribution background resulting from the entire Method 202 sampling and analysis process. Is the value less than 2.0 mg? If yes, then that means there was minimal contamination from contributors such as field reagents, sampling train carry-over, sample recovery and analysis. If no, then further analyses must be conducted.

·         Field Train Proof Blanks: The intent of field train proof blanks is to measure the lowest achievable mass contribution background resulting from the entire Method 202 sampling and analysis process. This blank is regularly archived and analyzed if the recovery blank value exceeds 2.0 mg. The proof blank should always be conducted if it is not possible to bake all glassware associated with the sampling train. If the proof blank exceeds 2.0 mg catch weight, then carry-over contamination has occurred or field reagents are contaminated.

·         Field Reagent Blanks: Field reagent blanks differ from laboratory reagent blanks since they are collected in the field from the wash bottle used onsite. The field reagent blank should be no greater than 0.1mg heavier than the laboratory reagent blank. The field reagent blank quantifies the amount of residual mass contributed to the sample from the reagents, the wash bottles, and that these mass contributions were maintained at a low level during testing.

 

Look for our next Condensable Particulate Matter overview to understand the next steps to understanding your EPA Method 202 stack test results. Contact us at [email protected] to get a quote.

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