Alternate Visible Emissions Methods

Transcription

1 Alternate Visible Emissions Methods Presented by: Jody Monk Eastern Technical Associates, Inc. Raleigh, NC (919)

2 Topics 40 CFR part 60 Subpart OOO Standards of Performance for Nonmetallic Mineral Processing EPA ALT-082 Digital Camera Operating Technique (DCOT) Q and A

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4 VE Observer Certification Today US EPA Reference Method 9 is the compliance method. Visible Emissions Training and Certification is required by the U.S. Environmental Protection Agency. EPA only recognizes certified observers as being qualified to perform observations of stationary emissions sources. Visible emissions observers include federal, state, and local regulatory agencies and impacted private industries.

5 VE Observer Certification Today Important: The legal validity of emissions observations is dependent upon adherence to the regulations and guidelines set forth in Federal Reference Method 9. These regulations cover: Smoke School Program requirements Observer Certification Observer documentation and procedures Field certification is valid for 6 months.

6 Who should attend a VE Certification Program? Any persons responsible for environmental compliance at your facility Any operator of a visible emission source at your facility Environmental consultants, private emissions observers, and stack testers All federal, state, and local air quality inspectors Air quality permit writers

7 40 CFR part 60 Subpart OOO Standards of Performance for Nonmetallic Mineral Processing Plants Source: 74 Final Rule April 28, 2009 EPA Technology Transfer Network (TTN)

8 Method 9 (Visible Emissions Observations) Used to evaluate: Smoke, Dust, Aerosols, Vapors, Fumes, and Mists Title 40 CFR part 60 Subparts Subpart OOO

9 Define: Nonmetallic Mineral Processing Plants Any combination of equipment used to crush or grind nonmetallic minerals Material defined as less than 50% metallic

10 Nonmetallic Mineral Processing Affected Facilities Crushed/Broken Stone Sand and Gravel Clay Rock Salt Gypsum Sodium Compounds Pumice Gilsonite Talc Boron, Borax, Kernite Barite Fluorspar Feldspar Diatomite Perlite Vermiculite Mica Kanite, Andalusite, Topaz

11 Subpart OOO 2009 Amendments Additional testing and monitoring requirements for facilities that commence construction or modification after April 22, 2008 Exemptions for wet material processing. Simplify Notification requirements. Definition changes and various clarifications.

12 Subpart OOO Amendments Standards for particulate matter (PM) Table 2 Stack Emissions for Affected Facilities with Capture Systems - Establishes PM Concentration and Opacity limits Table 3- Fugitive Emission Limits - Establishes Opacity Limits

13 Subpart OOO Amendments Standards for particulate matter (PM) Table 2 Stack Emissions for Affected Facilities with Capture Systems Commenced construction or modification after August 31, 1983 but before April 22, 2008 Opacity Limit is 7%

14 Subpart OOO Amendments Standards for particulate matter (PM) Table 2 Stack Emissions for Affected Facilities with Capture Systems Commenced construction or modification after April 22, 2008 Opacity Limit - Not Applicable (Except an Opacity Limit of 7% for individual enclosed storage bins.)

15 Subpart OOO Amendments Standards for particulate matter (PM) Table 3- Fugitive Emission Limits Commenced construction or modification after August 31, 1983 but before April 22, 2008 Opacity Limit of 10% - grinding, screening, transfer etc. Opacity Limit of 15% crushers with no capture system.

16 Subpart OOO Amendments Standards for particulate matter (PM) Table 3- Fugitive Emission Limits Commenced construction or modification April 22, 2008 Opacity Limit of 7% - grinding, screening, transfer etc. Opacity Limit of 12% crushers with no capture system.

17 Subpart OOO Amendments Monitoring of Operations Wet Suppression Control monthly periodic inspections. As a M22 alternate: Set forth criteria for utilization of a Bag House Leak Detection System - Performance - Installation - Operation - Reporting and Recording

18 Subpart OOO Amendments Test Methods and Procedures Fugitive Emissions compliance per source can be determined using M9 for 30 minutes. (versus 1hr) Single Observer can observer up to 3 points simultaneously. - Must be within 70 degrees of one another - All points must be below applicable limit

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21 Subpart OOO Test Methods and Procedures Minimum distance = 15 feet Select a position that minimizes interference from other fugitive emission sources, such as road dust If water mist is present as a control, select an observation point where the mist is no longer visible

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25 Digital Camera Opacity Technique (DCOT) Approved by US EPA February 12, 2012 as a broadly applicable alternate test method. Can be used in lieu of Method 9 to determine compliance with opacity limits. Utilizes ASTM D with specified limitations.

26 Digital Camera Opacity Technique (DCOT) Specified Limitations Used for Federal Opacity regulations under any subpart to 40 CFR Part 60,61,63 regulating ducted emission sources. Utilized for any stack that has an internal diameter that does not exceed 7ft.

27 Digital Camera Opacity Technique (DCOT) DCOT the technique of capturing images of plumes from stationary sources and analyzing them in an approved opacity determination software to derive the opacity value. Each vendor has to certify their system (specific camera and software) to meet ALT 082 requirements.

28 Digital Camera Opacity Technique (DCOT) To become a Digital Still Camera Operator: Digital Still Camera Operator Certification Course

29 Digital Camera Opacity Technique (DCOT) Necessary equipment. Certified Camera Nikon d3100, d3200 w/ 200mm and 300mm lens Canon G11, G12 Remote Timer Tripod

30 Digital Camera Opacity Technique (DCOT) Annual Software as a Service (SaaS) agreement. Third Party opacity analysis and reporting of images. Certification is maintained by successfully uploading at least 4 sets of images per year. If this is done correctly, certification is automatically renewed.

31 Operator captures quality images of plumes

32 Upload Images and Supportive Info Using DOCS II web Start a new observation or open an existing one.

33 Source Layout Note: The sun icon will blink if sun Location is outside the 140 degree sector.

34 Emission Point

35 Upload Image Files Browse local folders for images and select images to upload.

36 Droid Method 9 App Data Collection

37 Opacity Analysis 75 The analyst defines the measurement location and background. DOCS II determines the opacity value by utilizing an algorithm that compares pixel strength of the plume to a comparable background in the image.

38 Image Analysis Forensic Data Report

39 Report

40 Method ALT 082 Digital Camera Opacity Technique (DCOT) For more information on training, certification, certified cameras, necessary equipment and pricing please visit: Click on the Camera Tab

41 Alternate Visible Emissions Methods Presented by: Jody Monk Eastern Technical Associates, Inc. Raleigh, NC (919)