GCI TECH NOTES ©
“Area Sources” are not subject to opacity limitations under PC MACT and hence do not have to conduct opacity monitoring or demonstrate initial compliance to the opacity limitation as a part of their performance testing.
For “major sources” the PC MACT rule requires owners or operators to execute an initial performance test (these tests are to be repeated every 30 months) demonstrating compliance with the opacity limitation requirements for gases discharged from kiln or kiln/in-line raw mills (main stack and as applicable by-pass stack) and clinker coolers using a COM (see §63.1349(b) (1) (v)). There are however provisions for allowing Method 9 Visual Opacity Testing where it is not feasible to install a COM (see §63.1349(b) (1) (iv)).
Also the regulation in §63.1349(b) (2) requires that the execution of an initial performance test (and subsequent performance tests) include “any affected source subject to limitation on opacity” not already addressed by §63.1349(b) (1) above. For “major sources” the Method 9 test must be performed for each of the dust emission points identified in §63.1346 though 1348. This includes such devices as: raw material dryer, raw mills and finish mills; raw material, clinker, or finished product storage bin, conveying system transfer point, bagging system and bulk loading or unloading system.
This is a substantial amount of work to be done as a part of these performance tests (initial and future performance test). The following outlines the protocol for conducting the visual opacity portion of the performance tests.
SAMPLING POINT DESCRIPTIONS
A list of sampling points is necessary and should match the list of sampling points detailed in the Operation and Maintenance Plan required by §63.1350 (a). This list should identify each sampling point with a unique identifier as well as a brief description of the sampling point location and the material being managed.
Note: In the settlement agreement between APCA and USEPA the visible emissions monitoring requirements have been amended. Of particular interest is the exclusion of totally and partially enclosed transfer points from the Method 22 test requirements of the Monitoring Requirements (63.1350(a)(4)). When Joe Wood of the EPA was asked if this also means that these totally and partially enclosed transfer points are excluded from the Performance Test Requirements of 63.1349(b)(2). The answer was: "… this change never made it into the SA (settlement agreement), and did not become a proposed amendment either. You should comment on this when the proposal comes out. Otherwise, the rule stays as is."
OPACITY MEASUREMENT PROCEDURES
For kiln or kiln/in-line raw mills (main and by-pass stacks) and clinker coolers that are monitored using Method 9, rather than a COM as allowed by the regulation, the following opacity measurement procedure is utilized during the performance test.
1. Conduct a USEPA Method 9 opacity determination procedure concurrent with the execution of the Method 5 particulate emissions test runs (i.e. the owner/operator is to perform 3 – 1 hour Method 9 tests for each emission point).
2. Conduct test under “representative performance conditions” per 40CFR 63.7(e) (i.e. normal operating conditions ).
For each of the other listed sample points (i.e. the raw material dryer, raw mills and finish mills; raw material, clinker, or finished product storage bin, conveying system transfer point, bagging system and bulk loading or unloading system) the owner/operator will use the following opacity measurement procedure.
1. Conduct a USEPA Method 9 opacity determination procedure.
2. Conduct test under “representative performance conditions” per 40CFR 63.7(e) (i.e. normal operating conditions ). (Note these tests do not have to be performed at the same time as the other performance tests (D/F, particulate or THC) required by the regulation.
3. The duration of the testing shall be 3 hours (i.e., 30 – 6 minute averages). This may be reduced to 1 hour if both of the following conditions are met.
a. There are no individual readings greater than 10 percent in the first 1-hour period.
b. There are no more than 3 readings equal to 10 percent for the first 1-hour period.
QUALITY ASSURANCE PROCEDURES
A “Qualified Observer” must conduct each test. This observer must be certified by a smoke school or training program following the certification procedure outlined in Method 9. The certification must be no more than 6 months old at the time of the test. A copy of the certification document should be attached to the test report submitted to the agency.
RECORDS TO BE GENERATED DURING THE TESTING
For each sample point tested the following information will be collected:
Facilities which are “major sources” may have 20 or more emission points. Consequently the manpower needed to conduct all of these Method 9 observations during the initial performance test will be substantial as noted in the introduction. Further, unless it is the facility’s intent to have these performance test observations (not to mention the routine visual opacity observations required by the Operations and Maintenance Plan) performed by a contractor the facility must have Qualified Observers trained and certified in advance of the performance test. Fortunately the regulation does not require all of these tests to be executed during the same time period as the performance test period for the D/F or particulate emissions testing.