Permitting Procedures Manual. Soil/Groundwater Remediation

Transcription

1 Permitting Procedures Manual Soil/Groundwater Remediation Revised: December 18, 2013

2 A. DESCRIPTION A typical soil and/or groundwater remediation system consists of both a vapor extraction system used to extract vapors from the contaminated area and a control device used to control emissions from the vapor extraction system. The types of systems included in this manual are in-situ soil vapor extraction systems (SVE), ex-situ soil burners, air stripping systems, ex-situ soil aeration, bioremediation projects, contaminated soil excavations, contaminated soil stockpiles, and air pollution control devices for soil and groundwater remediation. Separate permit application forms with the appropriate fees are required for the vapor extraction system and each control device used at the site. The permit application consists of form G100, form HRA100, and the appropriate supplemental forms located on the SMAQMD website ( B. PERMIT APPLICATIONS 1. Permit Application Requirements A Permit to Operate is required for each of the following pieces of equipment or ex-situ soil remediation projects: a. Portable or stationary in-situ soil vapor extraction systems, ex-situ soil burners (rotary kiln), soil aeration, or soil excavations unless exempt. b. Portable or stationary air stripping units for groundwater treatment systems including well manifold and blower motor unless exempt. (See Section B2). c. Portable or stationary air pollution control system: carbon adsorption. d. Portable or stationary air pollution control system: oxidizers/hcl scrubbers/baghouses. e. Portable or stationary air pollution control system: IC engines/three-way catalytic converters. f. Portable or stationary air strippers. g. All other mobile or stationary air pollution control systems. h. Portable internal combustion (IC) engines greater than 50 horsepower as determined by test procedure SAE J1349 or SAE J1995 or IC engines that are less than 50 horsepower and are used as an emission control device for a duration longer than 5 days. i. All ex-situ soil aeration projects unless exempt. j. Ozone injection systems or air sparge systems (unless exempt). k. Returning to a site to perform a second pilot test resulting in a cumulative onsite time of more than 5 days unless exempt. Note: Approval of the site remedial action work plan must first be obtained from the Sacramento County Environmental Management Department, Division of Hazardous Materials or the California Water Quality Control Board. XIX-2

3 2. Permit to Operate Exemptions a. A Permit to Operate is not required for an individual source if it is determined by the Air Pollution Control Officer that the soil or groundwater remediation system has total uncontrolled VOC emissions that are less than 2 lbs/day and the risk assessment for toxic air contaminants results in an excess cancer risk of less than 0.1 in one million. In addition, the acute and chronic hazard index may not exceed 1. b. Pilot tests may be exempt from permitting providing the following: the test is 5 days or less in duration, an emission control device is used during the testing period, the equipment used for testing is exempt from permitting requirements as defined in Rule 201, a soil vapor extraction system has not been operated previously at the site (unless written approval is granted by the SMAQMD on a case-by-case basis), and written approval has been given by the Air Pollution Control Officer (APCO). A written proposal for an exemption is required at least 7 working days prior to the expected test start date. The request shall include: i. The date and time of test ii. Location of test iii. Purpose of test iv. Duration of test v. A system layout vi. The manufacturer s specifications for the proposed emission control device vii. Any support equipment used during the test viii. Contaminants of concern at the site ix. Lab data for samples taken from the site x. Expected emission rates, and carbon usage rate (if applicable) In addition, the SMAQMD must be notified in writing if the test start or end dates change. An exemption for a pilot test lasting longer than 5 days and/or a second pilot test at a location with a cumulative onsite time of more than 5 days may be approved on a case-by-case basis depending on the specific circumstances requiring a longer testing period or a second test. In addition, any control device or control equipment in which the published manufacturer s specification exceeds the exemption limit set by the SMAQMD will not be exempt and will require a permit. For example, an IC engine that is rated over 50 horsepower or a gas fired oxidizer that is rated at or above 1,000,000 BTU/HR. c. Any soil aeration project involving exclusively hydrocarbons with a boiling point of 302 F or greater shall be exempt from permitting and BACT requirements. In addition, any aeration project involving gasoline contaminated soil with an average TPHg concentration of 50 ppm by weight or less or involving 5 cubic yards of soil or less per facility shall be exempt from permitting and Best Available Control Technology (BACT) requirements. However, if elevated benzene concentrations exist in the soil, a screening health risk assessment will be performed by the SMAQMD in order to determine the final status of the proposed soil aeration project. All soil aeration or soil excavation projects that are exempted from SMAQMD rules must submit a written proposal to the SMAQMD at least 7 working days before the proposed start date. All soil aeration/excavation proposals must include: i. The site address ii. The name of the property owner iii. The name of all contractors involved in the project iv. The estimated amount of soil to be aerated/excavated at the site v. The estimated amount of soil to be aerated per day (in cubic yards) XIX-3

4 vi. The type of contaminants in the soil vii. All lab analysis related to the contaminated soil viii. Emission rate calculations ix. Method of soil disposal x. And methods used to suppress fugitive emissions. Note: if the start or end dates change, the SMAQMD must receive a written notification of the new start/end date before the aeration process has started. The exposed surfaces of an excavated area will not be included in calculations that determine the volume of soil excavated. All inactive storage piles shall be kept covered with a continuous sheet of plastic 6 mils or thicker. Other material used to cover a storage pile will be considered on a case-by-case basis. All cover material seams must be sealed adequately enough to prevent fugitive emissions. Furthermore, all cover material must be securely anchored and have minimal headspace between the cover and the soil. Active storage piles shall have an exposed area only where work is being performed and must be covered immediately after work is completed or work on the pile is stopped for longer than 30 minutes. Upon approval of the proposal, permission to aerate/excavate the soil under the exemption will be granted. A permit shall be required for all other non-exempt soil aeration/excavation projects. d. All IC engines that are used to support a remediation system, that are 50 horsepower or less as determined by test procedure SAE J1349 or SAE J1995, and are not the control device shall be exempt from permitting requirements. 3. Permit Application Forms The following application forms must be completed and submitted by the applicant when applying for an Authority to Construct/Permit to Operate for any soil and/or groundwater remediation system equipment. These forms are used by the SMAQMD to characterize the type of process, size, flow rates, abatement devices, and exhaust stacks of the system. Form G100: Application for Authority to Construct and/or Permit to Operate Form G101: General Information Form HRA100: Health Risk Assessment Information The forms below must be completed for the appropriate equipment, as applicable: Form VI100: Vapor Incinerator/Afterburner Form CA100: Carbon Adsorption Unit Form ICE100: Internal Combustion Engines C. PERMIT APPLICATION COMPLETENESS A permit application is deemed complete with the submittal of the following information: 1. Completed permit application Forms G100, G101, HRA100, and any applicable forms listed in Section B3 above with the original signature of the owner/proprietor or responsible officer of the company. 2. Applicable initial permit fee (see Section D below). 3. Any additional information needed to perform a health risk assessment. 4. Soil concentration data from previous pilot testing or soil sampling. XIX-4

5 D. FEES The permit fee for each permit application is based on the applicable fee schedules of Rule 301. Fees may be adjusted annually. Please visit the SMAQMD website, for the most current version of forms and fee Rule New Units Soil Vapor Extraction / Groundwater Treatment Systems a. New installations or equipment not previously permitted: Use Schedule 1 (see Rule 301, Section 308.2). Fees are based on the rated horsepower of the electric blower motor. Use the Initial Permit Fee column for new installations or equipment not previously permitted. b. Systems using an IC engine as an emission control device and to drive a soil vapor extraction blower: Use Schedule 9 (see Rule 301, Section ). 2. Modifications to the Soil Vapor Extraction / Groundwater Treatment System a. For modifications of permitted equipment resulting in an increase in the equipment horsepower, the fee is assessed in accordance with fee Schedule 1 (Rule 301, Section 306.1). b. For modifications resulting in no increase in the equipment horsepower, the fee shall be based on Rule 301, Section Emission Control Devices a. Fuel-Fired Oxidizers/Incinerators: Use Schedule 2 (see Rule 301, Section 308.3). Fees are based on the rated fuel consumption of the equipment. Use the Initial Permit Fee column for new installations or equipment not previously permitted. b. Electric Oxidizers/Incinerators: Use Schedule 3 (see Rule 301, Section 308.4). Fees are based on the KW rating of the equipment. Use the Initial Permit Fee column for new installations or equipment not previously permitted. c. Carbon Adsorption Systems: Use Schedule 9 (see Rule 301, Section ). Use the Initial Permit Fee column for new installations or equipment not previously permitted. d. Units using an IC engine for emission control and the engine does not drive the blower: Use Schedule 7 (see Rule 301, Section 308.8). Fees are based on the rated horsepower of the engine. Use the Initial Permit Fee column for new installations or equipment not previously permitted. e. Air Strippers: Use Schedule 9 (see Rule 301, Section ). Use the Initial Permit Fee column for new installations or equipment not previously permitted. 4. Modifications to Emission Control Devices a. For modifications resulting in an increase in horsepower or rated energy input/output, the fee is assessed in accordance with fee Schedule 2, 3, or 7 (Rule 301, Sections 308.3, 308.4, or 308.8, respectively), whichever is applicable, based on the incremental increase in horsepower or rated energy input/output resulting from such change (see Rule 301, Section 306.1). b. For modifications resulting in no increase in horsepower or rated energy input/output, the fee shall be based on Rule 301, Section Equipment Installed Without an Authority to Construct a. As per Section of Rule 301, any person installing/operating regulated equipment without obtaining a permit from the SMAQMD first, will be required to pay permit renewal back fees for each year of unpermitted operation, to a maximum of 3 years, in addition to the initial permit fee. XIX-5

6 6. Initial Source Test Observation Fees a. As per Section 311 of Rule 301, a source test observation and report evaluation fee shall be charged against the owner or operator of a source that requires an initial source test to be performed and observed, and the report to be evaluated by the SMAQMD. When multiple source tests are performed and the results submitted in one consolidated report, the initial source test fee shall apply to the first 10 hours of SMAQMD work. Each additional hour or portion thereof required for reviewing the source test shall be charged the time and materials labor rate established in Section of Rule 301. E. REGULATIONS Remediation equipment operating within the jurisdiction of the SMAQMD may be subject to some or all of the following rules and regulations. The type of operation, size of source, potential to emit, and other factors will dictate which rules are appropriate for a particular remediation application. Other rules may also apply. 1. SMAQMD Rules and Regulations (please refer to the actual rules for applicability and compliance determinations): a. Rule Circumvention: This rule makes it unlawful for a person to circumvent any applicable section of the SMAQMD rules and regulations. b. Rule General Permit Requirements: This rule provides an orderly procedure for the review of new or modified sources of air pollution and operation of existing sources through the issuance of permits. c. Rule New Source Review: The purpose of this Rule is to provide for the review of new and modified stationary sources of air pollution and to provide mechanisms, including emissions offsets and BACT, by which authorities to construct such sources may be granted without interfering with the attainment or maintenance of ambient air quality standards. d. Rule Title V - Federal Operating Permit Program: This rule establishes an operating permit program consistent with the requirements of Title V of the 1990 Clean Air Act Amendments and 40 CFR, Part 70. e. Rule Limiting Potential to Emit: The purpose of this rule is to eliminate the need for small stationary sources to obtain a Title V operating permit pursuant to Rule 207. f. Rule Synthetic Minor Source Status: The purpose of this rule is to allow owner and operators of stationary sources that would otherwise be major stationary sources to request and accept enforceable emissions limits sufficient to maintain the facility's potential to emit below major source thresholds. XIX-6

7 g. Rule Federal New Source Review: The purpose of this rule is to provide for the issuance of authorities to construct and permits to operate at new and modified major stationary air pollution sources and to provide mechanisms, including emission offsets, by which authorities to construct such sources may be granted without interfering with the attainment or maintenance of ambient air quality standards. h. Rule Public Notice Requirement for Permits: The purpose of this rule is to provide an administrative mechanism for public notification and review of the issuance of authorities to construct and permits to operate at new and modified stationary air pollution sources. i. Rule Permit Fees - Stationary Source: The purpose of this rule is to establish fees to be charged to owners/operators of a stationary source to obtain a permit. j. Rule Air Toxics Fees: This rule establishes fees to be charged stationary sources subject to the Air Toxics "Hot Spot" Information and Assessment Act (H&S Code, 44300) k. Rule Ringelmann Chart: This rule limits the discharge of air contaminants into the atmosphere by limiting visible emissions. l. Rule Nuisance: The purpose of this rule is to protect the public's health and welfare from the emissions of air contaminants which constitute a nuisance. m. Rule Particulate Matter: This rule limits the discharge of particulate matter into the atmosphere from any source in excess of 0.1 grains per dry standard cubic foot of gas. n. Rule Specific Contaminants: This rule limits emissions of sulfur compounds and combustion contaminants through establishment of emission concentration limitations. o. Rule Sulfur Content of Fuels: This rule limits the sulfur content of gaseous and liquid fuels. 2. State Requirements a. California Health & Safety Code, Part 6 (commencing with section 44300) -- Air Toxics "Hot Spots Information and Assessment Act of 1987: Facilities subject to this requirement must identify and quantify emissions of toxic air contaminants. Facilities posing a potential health risk to the public must prepare a health risk assessment, if required, notify the public, and implement a risk reduction plan. b. California Health & Safety Code Permit Approval: Powers & Duties of APCO: Prior to approving an application for a permit to construct or modify a source that emits hazardous air pollutants, in which the source is located within 1,000 feet from a school site, the SMAQMD must prepare a public notice. The notice must be sent to parents or guardians of children enrolled in any school located within 1/4 mile (1320 XIX-7

8 ft) of the source and to each address within a radius of 1,000 feet of the source at least 30 days prior to taking final action on the application. In addition, IC engines locating within 1,000 feet from a school will be required to reduce hazardous air pollutant emissions and their associated health risk to the maximum extent deemed practicable. This may include, but is not limited to, emissions limitations, stack height requirements, and hours of operation restrictions. Furthermore, the applicant is responsible for paying all public notification costs. 3. Federal Requirements a. 40 CFR Part Prevention of Significant Deterioration of Air Quality (PSD): A new source or modification triggers PSD if: i. Its potential to emit any one pollutant is greater than 100 tons/year (if one of the 28 selected industrial categories, including utility plants, steel plants, refineries, boilers >250 MMBTU/hr heat input) or greater than 250 tons/year (all other categories); and ii. The project s contemporaneous emissions increase and net emissions increase for any pollutant is greater than the significance levels listed below: Pollutant Level of Significance (tons/year) CO 100 NOx 40 SOx 40 PM 25 PM10 15 PM2.5 Ozone 10 (PM2.5) or 40 (SO 2 ) or 40(NO) 40 of NOx or VOCs Lead 0.6 Fluorides 3 Sulfuric acid mist 7 H 2 S 10 Total reduced sulfur (including H 2 S) 10 Reduced sulfur compounds (including H 2 S) 10 Greenhouse Gases (CO2e) 75,000 b. 40 CFR Part 63, Subpart GGGGG National Emission Standards for Hazardous Air Pollutants: Site Remediation: Remediation activities are subject to this regulation if the remediation activities are co-located at major stationary sources that emit hazardous air pollutants (HAP) and meet the affected source definition specified for a source category that is regulated by another subpart under 40 CFR part 63 (MACT standards). Remediation activities XIX-8

9 at gas stations and remediation activities performed under the authority of CERCLA or RCRA are exempt from Subpart GGGGG. STANDARDS AND REQUIREMENTS The following standards and/or requirements must be met in order to obtain an Authority to Construct and/or a Permit to Operate: 1. SMAQMD Regulation 2 Permits a. Rule 202 New Source Review i. Best Available Control Technology (BACT) Section 301 requires a new emissions unit or modification of an existing emissions unit to apply BACT if the daily potential to emit meets or exceeds the levels specified in Section and below: Pollutant Volatile Organic Compound, VOC Nitrogen Oxides, NOx Sulfur Oxides, SOx Particulate Matter, PM10 Particulate Matter, PM2.5 Carbon Monoxide, CO BACT Trigger Level 0 lb/day 0 lb/day 0 lb/day 0 lb/day 0 lb/day 550 lb/day ii. BACT is defined as the most effective emission control device, emission limit, or technique, which has been required or used for the type of equipment or process. BACT determinations for soil and groundwater remediation systems are the following and apply to both large emission sources (>10 lb/day) and small emission sources (<10 lb/day): (a) For VOC Emissions: BACT for remediation projects is defined as attainment of set VOC control efficiencies corresponding to set influent concentration values (unless effluent VOC concentrations are less than 10 ppmv), as shown below: XIX-9

10 For VOC Concentration at Influent of Control Device (ppmv): For VOC Concentration at Effluent of Control Device (ppmv): VOC BACT for Soil and Groundwater Remediation: Required VOC Control Efficiency (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% Maximum Effluent VOC Daily Limit (B) 9.9 lb/day Typical VOC Control Technology (C) 1. Catalytic Oxidizers 2. Thermal Oxidizers 3. Carbon Adsorption 4. IC Engines (A) Based on Bay Area AQMD s BACT determination for Soil Vapor Extraction as Achieved in Practice ( ). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) Catalytic oxidizers and thermal oxidizers shall be equipped with continuous temperature monitoring equipment and carbon adsorption systems shall perform monthly carbon breakthrough monitoring to ensure that BACT destruction efficiencies are met. (b) For NOx, SOx, PM10, PM2.5, and CO Emissions: Air pollution control devices for VOC emissions from soil and groundwater remediation systems may emit secondary criteria pollutant emissions of NOx, SOx, PM10, PM2.5, and CO, but since the emission source is an air pollution control device for VOC emissions, BACT does not apply. iii. Emission Offsets Section 302 requires that applicants provide emissions offsets for new or modified stationary sources where the cumulative emission increase for the facility exceeds the following levels: Pollutant Pounds/Quarter Volatile Organic Compounds (VOC) 5,000 Nitrogen Oxides (NOx) 5,000 Sulfur Oxides (SOx) 13,650 PM10 7,300 PM TPY Carbon Monoxide (CO) 49,500 XIX-10

11 b. Rule 217 Public Notice Requirements for Permits Prior to approving and Authority to Construct application for a new or modified stationary source or emissions unit which has an increase in potential to emit exceeding any of the following limits or where emission offsets are required pursuant to Rule 202, the District must submit a preliminary decision to CARB and EPA for review and publish the preliminary decision soliciting public review and comment at least 30 days prior to final action on the application. Pollutant Pounds/Quarter Volatile Organic Compounds (VOC) 5,000 Nitrogen Oxides (NOx) 5,000 Sulfur Oxides (SOx) 9,200 PM10 7,300 PM TPY Carbon Monoxide (CO) 49, SMAQMD Regulation 4 Prohibitory Rules a. Rule 401, Section 301: Visible emissions may not exceed No. 1 on the Ringelmann Chart or 20% opacity for more than three minutes in any one hour. b. Rule 402, Section 301: A person cannot discharge pollutants which cause injury, detriment, nuisance or annoyance to any considerable number of persons or which endanger the comfort, repose, health or safety of any such person, or which may cause damage to business or property (see Nuisance - Public Health section below). c. Rule 404, Section 301: A person shall not discharge into the atmosphere from any source particulate matter in excess of 0.23 grams per dry standard cubic meter (0.1 grains per dry standard cubic foot). d. Rule 406, Section 302: i. Combustion contaminant concentration at point of discharge shall not exceed 0.1 grains per dry standard cubic foot of gas, corrected to 12% carbon dioxide. ii. Sulfur compounds in any state or combination thereof at the point of discharge shall not exceed 0.2% by volume, calculated as sulfur dioxide (SO 2 ). e. Rule 420, Section 301: i. The sulfur content of gaseous fuels shall not exceed 50 grains per 100 cubic feet of gaseous fuel calculated as hydrogen sulfide at standard conditions. ii. The sulfur content of liquid or solid fuels shall not exceed a sulfur content of 0.5% by weight. Standard CARB diesel fuel complies with this requirement at % sulfur by weight (typically not expected to be used as a fuel source). XIX-11

12 3. Nuisance Toxics Review and Toxics Best Available Control Technology (T-BACT) a. Toxics Review: Based on SMAQMD Rule 402 Nuisance, the SMAQMD evaluates the impact of a facility's toxic emissions project using the SMAQMD s guidance document, Health Risk Management Programs for Existing, Modified and New Stationary Sources. The action levels are summarized below. Please refer to the actual guidance document for more detail on how to calculate and interpret health risk: Cancer Risk: Excess Cancer Risk 0.1 per million Action Required Exempt from further toxic review. > 0.1 per million but 1 per million No significant risk; No action required. > 1 per million but 10 per million Acceptable risk; Provide T-BACT > 10 per million but 100 per million Permit denied unless the APCO makes a finding that not approving the project may result in a greater negative impact to the public than approving the project. > 100 per million Denial of permit. Non-Cancer Health Risk (Acute and Chronic): Hazard Index (HI) Action Required HI < 1 HI 1 Health risk is within acceptable range Consult OEHHA for further guidance When evaluating the cancer and non-cancer risks, the specific toxic air pollutants that need to be addressed are those that have potency values or reference exposure levels identified in the OEHHA s Health Risk Assessment Guidelines ( b. Toxics Best Available Control Technology (T-BACT): T-BACT is similar to BACT, but applies to any new or modified source of toxic air pollutants which have health risks that exceed the specified levels above. Since the toxic pollutants of concern from soil and groundwater remediation (typically, TPHg, benzene, MtBE, perchloroethylene) are VOCs, the T-BACT determination for soil and groundwater remediation will be similar to the BACT determination, as follows: Pollutant T-BACT for Soil and Groundwater Remediation Catalytic Oxidizers Volatile Organic Compound, VOC Thermal Oxidizers Carbon Adsorption IC engines XIX-12

13 4. California Environmental Quality Act (CEQA) The SMAQMD has developed a comprehensive permitting CEQA Guidance document. Project reviews conducted in accordance with the policy manuals contained therein (including this manual) have been determined to meet the CEQA criteria of ministerial and do not require additional CEQA review. In the event a project falls outside the scope of this policy manual (for example a new BACT determination or other situation already described within the CEQA guidance document), the project shall follow the steps for CEQA review as detailed in the guidance document. 5. Other Standards Direct Venting Without a Control Device In the case where a remediation system has been permitted to operate by the SMAQMD and the influent concentrations to the emission control device drop to the levels indicated below, the applicant may submit a modification application to remove the control device and vent directly to ambient air. a. Daily total uncontrolled VOC emissions from the removal of a control device does not result in a daily emissions increase requiring BACT. The daily emissions increase shall be calculated as the daily Potential to Emit minus the daily Historic Potential Emissions (Rule 202, Section 413.2). b. Total uncontrolled VOC emissions are less than 9.9 lbs/day based on at least three consecutive months of source test data. (However, it is recommended that six consecutive months or more of source test data be collected to ensure seasonal factors do not result in a VOC emissions rebound.) c. The facility-wide excess cancer risk to the maximum impacted receptors is less than or equal to 1 in one million due to any uncontrolled emissions that have been identified as toxic air contaminants. d. The facility-wide excess non-cancer hazard index to the maximum impacted receptors is less than or equal to 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. 6. Requirements for Uncontrolled Soil Aeration All contaminated soil excavation, soil stockpiling, soil bioremediation, soil stabilization and all other types of soil remediation projects are required to obtain a permit unless the Air Pollution Control Officer issues a written exemption letter. A soil aeration project will require a permit and public health screen if the project is not exempt as defined in the exemption section of this document. For permitted soil aeration projects, TPHg and benzene emission rates will be estimated using the following factors: a. The average TPHg or benzene concentration found by sampling and analysis of the soil stockpile. b. Five days of aeration. c. The total volume of soil in cubic yards. d. A soil density of 3,900 in lb/cy. XIX-13

14 The TPHg emission rate for uncontrolled aeration shall not exceed 50 lb/day. If the emission rate is above 50 lb/day or if the public health risk assessment from any carcinogenic compound is unacceptable, then more stringent BACT or T-BACT shall be applied. A person shall not aerate contaminated soil in excess of that specified in the table below. The limitations in the table below apply to the entire facility, and indicate the volume of contaminated soil that may be aerated uncontrolled. Any more soil to be added to the soil already aerating must receive prior written approval from the SMAQMD. REQUIREMENTS FOR UNCONTROLLED SOIL AERATION TABLE TPHg ppm (weight) Volume of Soil (cubic yards) <50 Exempt > Controlled Aeration: soil may be aerated at volumes exceeding the limitations in the above table provided emissions of TPHg to the atmosphere are reduced by at least 95% by weight and the results of the public health risk assessment is found to be acceptable. NOTE: Contaminated soil stockpiles shall be kept completely and securely covered at all times. 7. IC Engine Requirements An IC engine that operates as a control device is required to obtain an Authority to Construct/Permit to Operate unless the engine is rated at less than 50 hp and it operates at the site for less than 5 calendar days. 8. Ozone Remediation Systems Please contact the SMAQMD regarding the installation and operation of an ozone remediation system. XIX-14

15 G. CALCULATING EMISSIONS The sample calculations listed below show a method to calculate the volume flow rates and mass emission rates for a soil vapor extraction system with an emission control device. The applicant may use other methods as long as the results are comparable. 1. Volume Flow Rate Calculations for Natural Gas Oxidizers It is preferred to measure the stack effluent volume flow rate directly. However, the total effluent volume flow rate for oxidizers and IC engines may need to be calculated. Therefore, the following formulas are an acceptable alternative. For systems that must meet a control efficiency, the influent and effluent mass emission rates can be calculated using this method below. The effluent volume flow rate in SCFM may be calculated based on field measurements obtained from the combined well flow rate, dilution airflow, combustion airflow (if applicable), and the supplemental natural gas or propane flow rate (if applicable). Sum all influent flow rates to obtain the total effluent flow rate as follows: Sample field measurements: Influent well vapor temperature: 85 F Dilution air temperature: 70 F Natural gas temperature: 68 F Well flow rate: 65 ACFM Dilution airflow rate: 30 ACFM Natural gas flow rate: 3 SCFM Combustion airflow rate: 70 SCFM (as specified by the manufacturer) a. Correct to standard temperature of 68 F for each flow measurement as follows: Well flow rate of 65 ACFM at 85 F: SC M AC M 0 0. SC M (Formula assumes the pressure differential is insignificant) b. Dilution airflow measured as 30 ACFM at 70 degrees: SC M 0 AC M SC M c. Natural gas flow: 3 SCFM (already at standard temperature) d. Maximum Combustion Air Blower Capacity: 70 SCFM e. Effluent volume flow rate in SCFM (sum of the above flow rates): = SCFM, Total flow of stack effluent f. Flow rate conversion SCFM to m 3 /day: SC M 0 min hour hour day m. 1 feet,. m day XIX-15

16 Note: For Carbon Adsorption Systems the effluent volume flow rate may be measured directly in most cases due to low temperatures in the stack. 2. Mass Emission Rate Calculations The following formula can be used to determine the mass emission rate (lb/day) from a measured concentration (ppm): Q c = (C c) * (F) * (MW c ) * (60 minutes/hour) * (24 hours/day) (10 6 ) * (V) where: Q c = Mass Emission Rate of Contaminant c, lbs/day C c = Concentration of Contaminant c, ppmv F = Vapor Volume Flow Rate, SCFM 10 6 = Conversion from parts per million to parts per unit volume V = Molar Volume = ft 3 /lb-mol (based on Ideal Gas Law for a gas at standard conditions of 68 F and 1 atm) MW c = Molecular Weight of Contaminant c Molecular weights for common chemicals: TPHg (Weathered gasoline): Benzene: MtBE: Trichloroethylene (TCE): Ethylene Dichloride (1,2-Dichloroethane): Tetrachloroethylene (Perchloroethylene, PCE): Chloroform: Vinyl Chloride: Methylene Chloride: 100 lb/lb-mol lb/lb-mol lb/lb-mol lb/lb-mol lb/lb-mol lb/lb-mol lb/lb-mol 62.5 lb/lb-mol lb/lb-mol Sample concentration and field measurements: TPHg concentration, C c = 280 ppmv Flow Rate, F = SCFM Molar Volume, V = ft 3 /lb-mol (based on Ideal Gas Law for a gas at standard conditions of 68 F and 1 atm) Molecular Weight of TPHg, MW c = 100 lb/lb-mol Using the given concentration and flow rate, the mass emission rate is calculated as follows: Q c = (280 ppmv) * ( SCFM) * (100 g/mol) * (60 min/hr) * (24 hr/day) (10 6 ) * (385.3 ft 3 /lb-mol) Q c = 17.3 lb/day TPHg XIX-16

17 3. Combustion Emissions from Natural Gas Fired Thermal Oxidizers The following emission factors can be applied to natural gas fired thermal oxidizers: Pollutant VOC NOx SOx PM10 or PM2.5 (C) Emission Factor (A) N/A (B) (lb/mmcf) (A) Emission factors for NOx, SOx, PM10, and CO are obtained from AP-42, Table and1.4-2 (7/98). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) AP-42, Table indicates that since particulate matter emissions were assumed to be less than 1 micrometer in diameter, this emission factor may be used to estimate PM10 or PM Greenhouse Gas (GHG) Emissions a. Soil and Groundwater Remediation Systems GHG emissions are not expected from soil and groundwater remediation systems. b. Natural Gas Fired Thermal Oxidizers The following emission factor can be used to calculate GHG emissions from natural gas fired thermal oxidizers: CO (A) Emission Factor for Natural Gas Combustion GHG CO 2 e (A) lb CO 2 e/mmbtu Natural Gas GHG emission factor is the CO 2 e emission factor as per Tables C1 and C2 of Subpart C of EPA s Mandatory Reporting for Greenhouse Gases rule (40 CFR, Part 98). c. Electric Catalytic Oxidizers GHG emissions are not expected from electric catalytic oxidizers. d. Carbon Adsorption Systems GHG emissions are not expected from carbon adsorption systems. H. SOURCE TESTING/MONITORING The SMAQMD requires a compliance source test plan to be submitted to the SMAQMD 15 working days prior to the scheduled source test. The source test plan must be comprehensive enough to cover both the initial source tests and all subsequent source tests. In addition, summa canisters with a 30-minute regulator must be used for all initial and annual source tests. SMAQMD approval is required prior to implementation of the plan. 1. Source Test Plan The following procedures must be contained in a source test plan: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. XIX-17

18 B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at shall be completed for each source test, or the following information shall be recorded: 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory listed at: Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with the permitted emission limits. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. I. For carbon adsorption systems: Carbon breakthrough monitoring as specified in the Authority to Construct/Permit to Operate. Note: In the case of groundwater treatment systems, influent water samples will be required in most instances and air emission estimates will be determined assuming that all VOCs are stripped out of the water after the treatment system. XIX-18

19 2. Required Instrumentation The instrumentation listed below shall be permanently installed, unless otherwise approved by the SMAQMD, while the soil/groundwater remediation system is in operation: a. Process instrumentation to monitor the process parameters listed in Table 1. The instruments used to monitor the process parameters shall be of the type listed in Table 1. The use of any instrument not listed in this document shall be prohibited unless written approval has been given by the SMAQMD. All instruments used to monitor the process parameters shall be calibrated as specified in Table 1, installed and maintained according to manufacturer's recommendations, and permanently installed on the system unless otherwise authorized by the SMAQMD. b. Non-resettable hour meter that reads 9,999 or more and is connected to the blower circuit. c. For oxidizers: a device that records the combustion chamber temperature and/or catalyst temperature at all times during operation. XIX-19

20 Table 1 Test Parameters and Acceptable Test Equipment for Soil/Water Remediation Projects Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements will be considered calibrated. However, dated purchase documentation must be provided. XIX-20

21 Table 2 Sampling and Analytical Methods Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 Please be advised that a Notice of Violation will be issued if emission levels are exceeded in all cases with the exception of obvious laboratory errors. Inspection of the proposed equipment in the presence of an SMAQMD inspector is required at the time of initial source testing and annual source testing. XIX-21

22 3. Initial Source Testing Requirements Upon start-up of the operation, there shall be at least two compliance source tests conducted seven operational days apart from each other. Vapor samples shall be obtained and analyzed for the influent and effluent of the control device in order to verify compliance with the emission limits and VOC control efficiencies of the permit. The initial compliance source test samples shall be analyzed for the pollutants of concern within the first 96 hours from the start-up of operation. If the applicant chooses to continue operation of the system before they receive the analytical results, they will be liable for any emission levels that are exceeded. If preliminary laboratory test results have not been received by the end of the 4th calendar day from start-up, then the system shall be shut down. In addition, if the system cannot demonstrate compliance with an emission limit or the control efficiency requirement of the permit conditions, then the system shall be shut down as soon as determining non-compliance. SMAQMD approval for start-up operation must be obtained for either of the aforementioned situations. Note: The initial start-up period, as described above, is not exempt from the emission limitations specified by the permit or any applicable enforcement action, including the assessment of penalties. Acceptable sampling methods are listed in Table 2 unless otherwise approved by the Air Pollution Control Officer. 4. Ongoing Source Testing Requirements The sampling requirements and acceptable sampling equipment will be specified in the Authority to Construct/Permit to Operate. In the case of carbon adsorption control devices, vapor sampling/analysis may be required more frequently than for other pollution control devices to mitigate the risk of carbon breakthrough. However, carbon breakthrough monitoring shall be performed monthly to ensure that BACT destruction efficiencies are met, unless the SMAQMD grants written approval for an alternate monitoring frequency. 5. Carbon Breakthrough Monitoring For carbon adsorption systems, carbon breakthrough shall be monitored by the use of a Photo-Ionization Detector (PID), Flame-Ionization Detector (FID), or other method approved in writing by the Air Pollution Control Officer on a monthly basis, unless the SMAQMD grants written approval for an alternate monitoring frequency. 6. Reporting Requirements After completion of the initial compliance source tests, the applicant shall prepare and submit an initial emissions monitoring report documenting the results of the system sampling and analysis. This report must be submitted no later than 60 days after the second initial compliance source test date and shall include at least the following information (contained in the SOIL VAPOR EXTRACTION INITIAL EMISSIONS MONITORING REPORT form): A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in the Authority to Construct/Permit to Operate summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. XIX-22

23 C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. G. For carbon adsorption systems: Results of all carbon breakthrough analysis as specified in the Authority to Construct/Permit to Operate and using the SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. Sampling analysis must be performed by an independent, NELAP or ELAP certified laboratory to ensure compliance with SMAQMD Rules. The laboratory analysis report shall include all compounds that were detected for the specified test. For example, if test method EPA TO-15 was used, all detected compounds must be included in the report at the lowest detection limit for the test method. This applies to both influent and effluent samples. The SMAQMD shall be notified immediately after determining that the emission limits, the VOC control efficiency requirement, or the carbon breakthrough monitoring limits in the Authority to Construct/Permit to Operate are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. As specified in the Authority to Construct/Permit to Operate, the SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. XIX-23

24 I. OVER-THE-COUNTER PERMITS Due to the need for a site-specific health risk assessment for each individual site, over-thecounter permits will not be granted for this source category. J. EXAMPLE ENGINEERING EVALUATION See Appendix XIX-A for a sample engineering evaluation for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-B for a sample engineering evaluation for a soil vapor extraction system controlled by a carbon adsorption system. K. EXAMPLE AUTHORITY TO CONSTRUCT See Appendix XIX-C for a sample Authority to Construct for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-D for a sample Authority to Construct for a soil vapor extraction system controlled by a carbon adsorption system. L. EXAMPLE PERMIT TO OPERATE See Appendix XIX-E for a sample Permit to Operate for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-F for a sample Permit to Operate for a soil vapor extraction system controlled by a carbon adsorption system. XIX-24

25 Exhibit XIX-A Sample Engineering Evaluation Soil Vapor Extraction System Using Natural Gas Fired Thermal/Catalytic Oxidizer Exhibit XIX-A

26 777 12th Street, 3rd Floor SACRAMENTO METROPOLITAN Sacramento, CA AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT EVALUATION FACILITY NAME: COMPANY NAME APPLICATION NO.: App # DATE: EVALUATED BY: LOCATION OF EQUIPMENT: LOCATION ADDRESS, CITY, STATE ZIP CODE Date Name PROPOSAL: OPERATE A NEW SOIL VAPOR EXTRACTION SYSTEM UTILIZING A THERMAL/CATALYTIC OXIDIZER AT THE ABOVE SITE FOR THE CONTROL OF VOC EMISSIONS INTRODUCTION: COMPANY NAME was a former retail gasoline dispensing facility. The purpose of this proposal is to operate a soil vapor extraction (SVE) system and a thermal/catalytic oxidizer (or thermal oxidizer or electric catalytic oxidizer) to extract TPHg (VOC), benzene and MtBE from the contaminated area in order to clean up the soil. EQUIPMENT DESCRIPTION: The proposed remediation system consists of (specify number of wells only if source of contamination is other than typical gasoline or perchloroethylene) vapor extraction wells connected by a manifold to a 7.5 HP blower designed to extract a maximum volume flow rate of 350 scfm (add if applicable: and a dilution air blower designed to extract a maximum volume flow rate of 75 scfm, resulting in a total maximum system volume flow rate of 475 scfm). The SVE system will be vented to a 0.4 mmbtu/hr thermal/catalytic oxidizer for emission control. The stack parameters for the oxidizer are as follows: stack is 16 feet high by 20-inch diameter round exhaust, without a rain cap. (insert only for thermal/catalytic oxidizers): In catalytic mode, the minimum catalyst inlet temperature is 600 F, the minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 350 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet. In thermal mode, the minimum oxidizer inlet temperature is 1,400 F, the minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 1,000 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet).