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Comment / Response Document Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units 273-4000-005 Commentator Name / Address Suzanne Seppi Karen Grzywinski Group Against Smog and Pollution 1 5604 Solway Street, Room 204 Pittsburgh, PA 15217 412-325-7382 gasp@gasp-pgh.org Randy Cain Environmental Affairs Manager Allegheny Energy 2 800 Cabin Hill Drive Greensburg, PA 15601 724-838-6004 rcain2@alleghenyenergy.com Douglas L. Biden President Electric Power Generation Association 3 800 North Third Street, Suite 303 Harrisburg, PA 17102 717-909-3742 Reid T. Clemmer Environmental Supervisor PPL Services Corp. 4 Two North Ninth Street Allentown, PA 18101-1179 610-774-5475 rtclemmer@pplweb.com 1 Amy E. Earley Site Environmental Engineering Merck & Co., Inc. P.O. Box 4 5 770 Sumneytown Pike West Point, PA 19486 215-652-4247 amy_earley@merck.com 2 Comment 1: The provisions of the Compliance Assurance Policy pertaining to opacity should remain unchanged so that Pennsylvania can remain in compliance with the obligation under Section 4.2 (a) and (b) of the Pennsylvania Air Pollution Control Act (APCA) to ensure that Pennsylvania's regulations are no more stringent than federal requirements. (2, 3, 4) Response: The Department disagrees. 25 Pa. Code §123.41 relating to Visible Emissions is adopted under 40 CFR Part 52 Subpart NN in §52.2020(c) and incorporated ...
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Comment / Response Document Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units 273-4000-005
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Name / Address Suzanne Seppi Karen Grzywinski Group Against Smog and Pollution 5604 Solway Street, Room 204 Pittsburgh, PA 15217 412-325-7382 gasp@gasp-pgh.org Randy Cain Environmental Affairs Manager Allegheny Energy 800 Cabin Hill Drive Greensburg, PA 15601 724-838-6004 rcain2@alleghenyenergy.com Douglas L. Biden President Electric Power Generation Association 800 North Third Street, Suite 303 Harrisburg, PA 17102 717-909-3742 Reid T. Clemmer Environmental Supervisor PPL Services Corp. Two North Ninth Street Allentown, PA 18101-1179 610-774-5475 rtclemmer@pplweb.com
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Amy E. Earley Site Environmental Engineering Merck & Co., Inc. P.O. Box 4 770 Sumneytown Pike West Point, PA 19486 215-652-4247 amy_earley@merck.com
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Comment 1: The provisions of the Compliance Assurance Policy pertaining to opacity should remain unchanged so that Pennsylvania can remain in compliance with the obligation under Section 4.2 (a) and (b) of the Pennsylvania Air Pollution Control Act (APCA) to ensure that Pennsylvania's regulations are no more stringent than federal requirements. (2, 3, 4) Response: The Department disagrees. 25 Pa. Code §123.41 relating to Visible Emissions is adopted under 40 CFR Part 52 Subpart NN in §52.2020(c) and incorporated into the State Implementation Plan (SIP) for Pennsylvania under Section 110 of the Clean Air Act, 42 U.S.C. 7410, and 40 CFR Part 51 to meet national ambient air quality standards (NAAQS). The regulation is necessary to provide an effective enforcement method for achieving and maintaining the NAAQS for particulate matter. In response to the August 4, 1995 "Regulatory Basics Initiative" memorandum from then Department Secretary Seif, the Department completed its Review of Existing Regulations - More Stringent Than Federal Requirements Report - Bureau of Air Quality, March 29, 1996. In reviewing 25 Pa. Code Section 123.41, the Department noted that its general visible emission requirements represent the principal surveillance tool for estimating compliance with particulate emission standards required by Section 110 of the Federal Clean Air Act, and that the requirements are part of Pennsylvania's SIP strategy for achieving compliance with federal PM10 ambient air quality standards. Importantly, 25 Pa. Code Section 123.41 addresses all sources whereas federal visible emissions regulations cover relatively few. Noting that there can be situations for the same source where either a federal visible emission regulation or 25 Pa. Code Section 123.41 can be more stringent than the other, and that neither is clearly more stringent than the other, the Department concluded that 25 Pa. Code Section 123.41 is no more stringent than federal requirements. In addition, the no more stringent than provisions under Section 4.2 of the APCA apply to regulations and not policy documents like the Compliance Assurance Policy, which assists in the implementation of those regulations. Comment 2: Tolerances for opacity measurement uncertainty should be retained. (2, 3, 4) Response: Tolerances for opacity measurement uncertainty will not be provided in the final Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units. Measurement error tolerances are not included in any of the Department's other recent compliance assurance policies for continuous emission monitoring systems and are not appropriate for inclusion in the Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units. For purposes of settlement of violations according to a Compliance Assurance Policys provisions, the Department requires that data indicated by the CEMS be considered accurate, notwithstanding any measurement or calibration error that may actually have resulted in the emissions being over- or under-reported. This policy will not change the way violations are identified; only penalty considerations. As is the case with the current Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, Technical Guidance Document 273-4000-005, and the Department's other compliance assurance policies for continuous emission monitoring systems, this policy will only be used to develop civil penalty considerations. Any instance in which a report submitted for a Department-certified
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continuous opacity monitoring system identifies that a visible emission limit has been exceeded will result in a violation being identified in the processing of that submittal and the Department's subsequent quarterly source monitoring report. Performance specifications including monitoring system accuracy tolerances are established in the Continuous Source Monitoring Manual, Technical Guidance Document 274-0300-001. As stated in Section 1.III, the purpose of this policy is to establish uniform criteria for assessing penalties through agreements rather than criminal or civil penalty actions. The various leniency factors built into this policy, including consideration of the value of amicable settlement as opposed to litigation, will be applicable only to settlement agreements. The policy will establish thresholds and procedures for discretionary forgiveness of small calculated penalties, criteria and procedures for the adjustment of any penalty when warranted, and a requirement that the Department consider all relevant factors including those unique to the owners or operator of the source or facility, when determining a penalty to be assessed. Unique circumstances in which an owner or operator can demonstrate that an indication of a violation may be incorrect due to monitoring system inaccuracy are within the purview and discretion of the Department during the course of the regional office's review and resolution of the violations. Comment 3: Tolerances for gas measurement uncertainty should be retained. (2, 3, 4) Response: Tolerances for gas measurement uncertainty will not be provided in the Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units. Measurement error tolerances are not included in any of the Department's other recent compliance assurance policies for continuous emission monitoring systems and are not appropriate for inclusion in the Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units. A Compliance Assurance Policy provides a means and criteria for amicable resolution of violations indicated by continuous source monitoring. The various leniency factors in the policy and other benefits, including certainty in determining penalty liabilities, are limited to violations within the Departments discretion for which owners and operators are prepared to attest to the acceptability of the data for settlement purposes, notwithstanding any measurement or calibration error that may actually have resulted in the emissions being over- or under-reported. This policy revision will not change the way violations are identified - only penalty considerations. As is the case with the current Enforcement Policy - CEMS and Coal Sampling/Analysis Systems Technical Guidance Document 273-4000-005, and all the Department's other compliance assurance policies for continuous emission monitoring systems, this policy will only be used to develop civil penalty considerations. Any instance in which a report for a Department-certified continuous emission monitoring system identifies that an emission limit has been exceeded results in a violation being identified in the processing of that submittal and the Department's quarterly source report. Performance specifications including monitoring system accuracy tolerances are established in the Continuous Source Monitoring Manual, Technical Guidance Document 274-0300-001.
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As stated in Section 1.III, the purpose of this policy is to establish uniform criteria for assessing penalties through agreements rather than criminal or civil penalty actions. The various leniency factors built into this policy, including consideration of the value of amicable settlement as opposed to litigation, will be applicable only to settlement agreements. Comment 4: It is appropriate that the tolerances have been removed. They have been litigated in another region and judged illegal. (1) Response: The Department generally agrees, though the federal court decision in Sierra Club et al. vs. TVA is not entirely relevant to the Department's treatment of violations under compliance assurance policies. Comment 5: The allowance for de minimis daily excess opacity emissions should be retained, and the Department is incorrect in its interpretation that the federal court decision in Sierra Club et al. vs. TVA regarding stipulated penalty forgiveness is germane to a government agency's use of enforcement discretion. (2, 3, 4) Response: No allowance for de minimis daily excess opacity emissions will be provided in the final Compliance Assurance Policy for Continuous Emission Monitoring Systems (CEMS) on Combustion Units. Express tolerance for violations is not appropriate in a Compliance Assurance Policy. While the Department generally agrees that the federal court decision in Sierra Club et al. vs. TVA, 430 F.3d 1337 (11th Cir. 2005), regarding stipulated penalty forgiveness is not directly relevant to the Department's exercise of enforcement discretion under compliance assurance policies, the decision does raise questions regarding the extent to which such express tolerance may be legally defensible. At issue are exclusions from penalty calculation, for daily excess emissions totaling not more than 15 minutes in excess of the 20% opacity standard and not more than 7 minutes in excess of the 60% opacity standard, that have been provided in Section 3.III.A.2.a. of the Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, Technical Guidance Document 273-4000-005. In practice, no penalties are presently calculated and displayed in the Departments quarterly source monitoring reports for these excepted periods. This is principally the same way that measurement error tolerance is applied under the Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, and measurement error tolerance is also slated for omission from the revised policy. The allowances for penalty adjustment minutes that are also provided in the Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, and revised in the proposed policy revision, are treated differently in that penalties are calculated and displayed in quarterly reports prior to and subsequent to adjustment. This provides a uniform means of calculating penalties for those periods in case the Department may determine that proposal of settlement of those penalties is warranted, during the course of the regional office's review and resolution of the violations.
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The commentators express concern that the cost of collecting penalties for de minimis violations might outweigh the benefits to the Commonwealth. The Department does not share this concern since penalties for these periods will be aggregated with any other penalties indicated in a source report, and criteria and procedures for discretionary adjustment or forgiveness of penalties are established elsewhere in the policy. Comment 6: The adjustment time for opacity emissions should be retained at 1.5% and not reduced to 0.5%. The commentators also note that there are federal exemptions for start-up, shutdown and malfunction to consider as well. (2, 3, 4) Response: The final policy will reduce the adjustment time to 0.5%. A reduction in available adjustment time from 1.5% to 0.5% of operating hours, in conjunction with the elimination of both the 10% measurement tolerance and the tolerance for de minimis daily excess emissions, will have the appropriate impact on penalty derivations for non-compliant sources while continuing to represent the equitable, technically achievable level of visible emission control. As part of the policy revision process, the Department reviewed recent compliance performance of air contamination sources as indicated by Department-certified Continuous Opacity Monitoring Systems (COMS). Both general and source classification specific trends were considered, toward the goal of establishing a level of excess visible emissions that allows for an equitable opacity penalty adjustment mechanism while providing a significant driver for source compliance. The Department found that a very small number of air contamination sources exceed opacity limits routinely, while consistently using most or all the allowable adjustment time, whereas most sources operate in full compliance with opacity limits on a continuous basis. Similar sources among identical source classifications display consistent ability to operate in complete compliance, or maintain a generally high rate of compliance while using a small portion of allowable adjustment time to offset occasional violations that occurred during normal operations such as start up, shut down, minor malfunctions and soot blowing. The Department intends to increase penalties for sources that continue to violate standards in excess of 0.5% of operating time. Up to three minutes per hour of opacity equal to or greater than 20% and less than 60% are allowed by 25 Pa. Code §123.41 relating to Visible emissions . The Department continues to recognize that some level of adjustment is warranted for occasional and unavoidable excess emissions associated with soot blowing, start-up, shutdown and malfunction. Based on the analyses conducted, the Department believes the proposed reduction in available adjustment time will significantly affect source compliance rates without resulting in the calculation of gratuitous penalties that might impair the policy's value as a uniform means of settling occasional violations. The Department can authorize use of exempt codes in quarterly reporting, in cases where a strictly applicable regulation, Plan Approval, Permit or Order of the Department provides an exemption for start-up, shutdown or defined malfunctions. The Departments report processing software is designed so that it treats exempt time correctly for determination of compliance in consideration of either state-only or federal exemption rules. Exemptions in federal rules only
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apply to federal standards as specified. An exception is provided in 25 Pa. Code §123.41(1) for opacity greater than or equal to 20% and less than 60%, for periods aggregating less than three minutes per hour, in consideration of the need for periodic soot blowing, maintenance, start-up, shutdown or malfunction. No exception is provided in law, relative to the 60% opacity limit in 25 Pa. Code §123.41(2). Comment 7: If there were to be some allowance for modest exceedance time (much less than what is being proposed) perhaps this could be correlated with good performance on quarterly average opacity. It might alternatively be correlated to comparative performance of similar plants, for example, the worst performing plant of similar type plants for a particular emission should receive 50% of normally available adjustment time or some increased penalty. (1) Response: The Department has determined that the proposed level of adjustment time for violations of visible emission limitations, in conjunction with elimination of allowances for measurement tolerance and de minimis excess emissions, will produce appropriate penalty derivations for non-compliant sources while continuing to represent the equitable technically achievable level of visible emission control. A provision such as that which is suggested would be difficult to implement using the Department's Continuous Emissions Monitoring Data Processing System (CEMDPS), considering the number of variables already considered in the processing of quarterly reports. At present, there are at least 1,083 continuous source monitoring systems proposed or operating under the Department's Air Quality program, of which at least 773 are certified, monitoring more than 20 pollutants and parameters for hundreds of different standards. The number and diversity of systems and standards are growing rapidly, with the proliferation of new emission standards and continuous source monitoring system certification requirements. Comment 8: The reductions in adjustment times for opacity, while in the appropriate direction, are still remarkably lenient. Allowing for some down time, taking a reduced number of operating hours for example, a typical facility might qualify for 85.5 minutes of allowable 60% opacity for a quarter - about 1 minute per day - and 484.5 minutes of visible emissions in excess of a 20% opacity standard in a quarter - about 5 minutes per day. (1) Response: Five minutes per day and one minute per day are reasonable, based on the Departments review. The Department continues to recognize that some level of adjustment is warranted for occasional and unavoidable excess emissions associated with soot blowing, start-up, shutdown and malfunction. Based on the Departments review, a further reduction would not significantly affect source compliance rates, and would likely result in calculation of gratuitous penalties that would impair the policy's utility in providing a uniform means of settling occasional violations for a broad variety and number of air contamination sources. As part of the policy revision process, the Department reviewed recent compliance performance of air contamination sources as indicated by Department-certified Continuous Opacity Monitoring Systems (COMS). Both general and source classification specific trends were
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considered, toward the goal of establishing a level of excess visible emissions that allows for an equitable opacity penalty adjustment mechanism while providing a significant driver for source compliance. The Department found that a high percentage of air contamination sources comply with opacity limits on a continuous basis, which indicates that penalty liability is not typically a significant driver in performance relative to violations, for those sources. A second group of sources maintains a generally high rate of compliance while using a small portion of allowable adjustment time to offset occasional violations that occurred during normal operations such as start up, shut down, minor malfunctions and soot blowing. A third group, comprised of a very small number of sources, exceed opacity limits routinely, while consistently using most or all the allowable adjustment time, and those same sources operate consistently within the 10% measurement tolerance allowed by the present policy. The Department has identified that this third group should be the primary focus of any reduction in adjustment minutes, and bear the brunt of the changes brought about by this revision. Comment 9: Reliant Cheswick has generally demonstrated more minutes of violation than several similar state plants in Pennsylvania (partially explained by the fact that it is not operated as a base plant as some of the others are), yet it never has reached violation minutes as large as the 9.5 hours adjustment time (using the example of some down time 1900 hours) in violation minutes since monitoring from the 4th quarter 2004. Other similar plants had considerably less violation minutes than Reliant Cheswick, some quarterly violations in the single digits. It is unlikely that most plants need this high level of excused time adjustment. This excused time is not pushing these plants to compliance but accepting pollution as inevitable which it is not. If other plants are operating at even higher violation minute levels, it would seem from the example of the above plants that they should be required and are capable of performing better. GASP sees no reason for such a high level of excused violation time even though it is lower than the former Policy and recommends no excused time beyond the forgiven three minutes/hour of the 20% opacity standard. This is consistent with the standard. By not requiring compliance with the standard, the companies leave themselves open for legal action as has occurred with the Bruce Mansfield facility. (1) Response: Some level of adjustment is warranted for occasional and unavoidable excess emissions associated with soot blowing, start-up, shutdown and malfunction. Based on the Departments review, a further reduction in adjustment time would not significantly affect source compliance rates, and would likely result in calculation of gratuitous penalties that would impair the policy's utility in providing a uniform means of settling occasional violations for a broad variety and number of air contamination sources. The policy must provide some measure of consideration for understandable circumstances that may lead to violations, or its utility will be entirely negated.
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Reliant Cheswick is under the jurisdiction of the Allegheny County Health Department. As a result, the Department is not involved in the continuous emission monitoring program for that facility. Comment 10: The equation in Section 2, IV.A.1.g seems to disproportionately penalize units with lower emission standards. (5) 20 A 1 B = $100 * 2 ⎡⎢⎣⎜⎝⎛ S −⎟⎠⎞⎦⎤⎥ Response: The equation in and of itself does not disproportionately penalize units with lower emission standards. It determines a penalty based on the percentage by which an emission value exceeds an applicable standard. The base penalty determined by this equation is subsequently adjusted during summing of total daily penalties for emission violations, by application of the Source Factor (F). The Source Factor reflects the air contamination source's gross heat input capacity or throughput capacity, which provides some reflection of presumed exhaust volume. For standards other than pure mass emission limits, including concentration limits and those based on mass emissions per unit heat input, there is no other known coefficient in the report data or penalty calculations, to account for exhaust volume or pollutant severity. A percent-over-standard basis is the only reasonable method the Department has been able to identify to calculate equitable and effective penalties for the broad variety of source-pollutant-standard combinations to which the equation will be applied. Other than the adjustment of the base dollar amount, the equation has been applied with consistent success to an extensive variety of standards, pollutants and air contamination sources for more than 23 years, under the Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, Technical Guidance Document 273-4000-005, and it has achieved the desired effect on source compliance throughout that time. In the event that a situation is identified where application of a penalty provision does produce a disproportionate and inequitable result, the Department will be required under Section 9.1 of the Air Pollution Control Act and the provisions of this policy to consider any information to that effect that a source owner operator brings to the Department's attention during the course of the regional office staff's review and resolution of the violations. Procedures and criteria for penalty mitigation are established in the policy. Of course, the equation will have no impact on sources that comply with applicable emission limits. Comment 11: When A/S = 1.25, the quarterly emission average is 25% above the standard. It does not seem reasonable that a violation of this degree, especially a violation of a standard where averaged values are used, should be considered for this type of agreement policy. This should trigger additional enforcement under maximum penalties but anything near this level seems excessive for a simple fine. (1) Response: The Department disagrees. Among the contaminants to which this provision will apply are carbon monoxide and oxides of nitrogen, both of which may typically be emitted at
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rates above their permit limits, during fairly normal startups, shutdowns, malfunctions and maintenance operations. The formula has effectively been applied to excess emissions of sulfur dioxide through the provisions of the Enforcement Policy - CEMS and Coal Sampling/Analysis Systems, Technical Guidance Document 273-4000-005, since 1985, other than the new increase in penalty coefficient for inflation. It has been widely successful and equitable in achieving desired reductions in excess emissions of sulfur dioxide. The policy expressly recommends that additional enforcement action beyond the imposition of the penalty calculated under the policy's provisions be considered whenever a maximum penalty is determined. In order that it may effectively fulfill its desired function of providing a uniform means of settling occasional violations for a broad variety and number of air contamination sources, the policy must provide some measure of consideration for understandable circumstances that may lead to violations. Comment 12: Making the policy a predictable monetary event may not achieve the goal of compliance assurance. The result might be "putting the probable pollution costs into the company budget as an accepted business expense". Because enforcement might rely heavily on this Policy approach, it is critical to establish a penalty program forceful enough to drive improved performance even at levels that do not trigger more severe enforcement actions through the Disclaimer Section and Section 1 I.B. Enforcement action should be taken beyond this policy whenever needed to achieve compliance and a drive toward no violations/exceedances of air quality regulations. Looking into the "why" of every violation/exceedance is critical. Quarterly emission reports often identify the cause of emission problems in a tagged identifier, but that does not really identify accountability or improvement plans for that problem. Requiring a written plan of improvement on violation/exceedance issues even at modest to low levels and a time line would push facilities toward better performance. The enforcement agency should provide resources targeted to these specific violation/exceedance issues, including targeted technical assistance, best practice information and opportunities for peer collaboration. Some pollution issues may trigger legal solutions or consent agreements, but other issues such as average levels of minutes of violation for opacity seem to occur month after month. Lesser but ongoing pollution violations should not simply be fined and disregarded, but also addressed through a plan that will reduce pollution occurrences. (1) Response: The Department generally agrees, with some reservations. In order to effectively provide a uniform means of settling occasional violations for a broad variety and number of air contamination sources, the policy must provide some measure of consideration for understandable circumstances that may lead to violations. The policy is not intended to be the sole means of addressing violations, especially those that are recurrent or indicate a greater problem. The Department strives continually to improve source performance through all its programs, including the Plan Approval and Operating Permit process, energy technology deployment, compliance assistance outreach, and of course, enforcement. Actions beyond monetary penalties are explicitly encouraged in the policy under certain circumstances, and new, specific reservations of the right to take enforcement action beyond that specified in the policy have been added at Section 1.I.B. The Department frequently
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pursues enforcement action beyond the scope of Compliance Assurance Policies in its response to violations. Appropriate actions can vary considerably from case to case. As stated in Section 1.III relating to Purpose , a Consent Order and Agreement will generally be used when corrective steps are needed, such as operational hardware changes or new CEMS installations. A Consent Order and Agreement includes requirements and specified actions according to a binding timetable to resolve the violations it addresses. As also stated in Section 1.III, Pennsylvania's Air Pollution Control Act requires the Department to consider specified factors when determining a penalty to resolve a violation. Among those, the provisions of this policy applied during the processing of quarterly reports will take into account the size and nature of the source; the severity and duration of the violation; whether the violation was voluntarily reported; the degree of cooperation in resolving the violation; deterrence of future violations; and the speed with which compliance is achieved. Remaining case-specific factors considered by regional staff during their review and resolution of the violations will include willfulness of the violation; compliance history; damage to air, soil, water or other natural resources of the Commonwealth or their uses; financial benefit of non-compliance; cost to the Department; other factors unique to the owners or operator of the source or facility; and other relevant factors. The penalty provisions of a CAP enable the Department to exert an influence on the actions of a source owner or operator by the assessment of a penalty, and by requiring the admission and formal addressing of a violation. When neither of these produces the desired result, which is the elimination of violations or a reduction to a level and frequency that the Department deems suitable for settlement, other enforcement avenues are typically pursued. To ensure oversight and peer review, the Bureau of Air Quality generates quarterly summaries of enforcement activity associated with continuous source monitoring systems, which it posts on its internal CEMS web page. The Department provides these summaries, together with copies of all continuous source monitoring systems quarterly reports, to the United States Environmental Protection Agency (EPA) on a quarterly basis. The Department coordinates with EPA in its Timely and Appropriate (T&A) Enforcement Response program for High Priority Violators (HPV). The Department's Continuous Emissions Monitoring Data Processing System (CEMDPS) automatically identifies every instance in which an HPV threshold is exceeded in a quarterly source report, notice is subsequently provided to EPA, and the Department treats that violation in accordance with applicable T&A /HPV criteria. The Department has also instituted provisions to ensure consistent resolution of violations indicated by continuous monitoring systems, in accordance with the Department's Guidelines for Identifying, Tracking and Resolving Violations for Air Quality, Technical Guidance Document Number 273-4110-001. Violations determined on the basis of reporting of continuous source monitoring, and associated enforcement actions, are reported to the Department's Environment, Facility, Application, Compliance Tracking System (eFACTS) database system, and that information is available for review at the Department's public eFACTS web page.
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