CleanAir is a global provider of technical products and services for sustainability and resource management. We specialize in emissions reduction, energy management, common sense and a lot more.
At CleanAir, our aim is to support the growth, profit and sustainability goals of our clients by delivering innovative solutions with 10x value.
We do this first and foremost by gaining a deep understanding of our client’s needs and business objectives and leveraging our technical knowledge, innovative thinking, and vast equipment resources. From air quality management and emissions measurement, to thermal performance and efficiency determination, CleanAir delivers the results.
About CleanAir Consulting
CleanAir has provided its emissions measurement knowledge, engineering expertise, and experience with EPA regulatory processes on many occasions to help industries solve problems similar to those now affecting the coke industry. CleanAir is often involved with clients having permit or regulatory issues with local, state, and regional EPA agencies. In many instances, CleanAir acts as the client's technical expert in agency discussions and negotiations. Several refinery/petrochemical clients, such as Marathon Petroleum, have engaged CleanAir to be part of their team responsible for negotiating consent decree settlements. In the case of Marathon, CleanAir was part of the team that negotiated their consent decree settlement on flaring, providing technical support on flare operation and testing issues. We were able to persuade EPA to allow a simpler approach to flare management that benefitted both Marathon and the environment. The following paragraphs summarize some relevant case studies of CleanAir's role as an industry advocate.
ICR Guidance Documents
The EPA submitted an ICR to the electric utility industry in 2009 that required emissions testing at over 1000 electricity generating units (EGUs). The required emissions tests included a wide array of measurements which were unfamiliar to most power plant operators. Many of the test methodologies required by the EGU ICR were the same ones now being proposed for the coke ovens ICR. Just like the coke industry now, the utilities had concerns about site preparation, logistics, costs, and potential data quality issues related to the ICR.
The Electric Power Research Institute (EPRI) contracted CleanAir to prepare a series of guidance documents to address concerns related to the emissions testing requirements of the ICR for EGUs. These documents were designed to assist power plant owners and stack testing contractors in identifying appropriate technical resources, developing test plans, streamlining testing, selecting appropriate sampling and analytical methods, and avoiding common errors. Result: The guidance documents provide technical information that were used by power plants and stack testing companies to collect and report measurements that were accurate, unbiased, and representative of the sources tested.
Faulty EPA Rulemaking Assumptions
In their proposed Refinery MACT revisions, EPA penalized affected sources flaring a combination of olefins and hydrogen. The basis for this penalty was an analysis conducted by EPA that when olefins and hydrogen react together in a flame, complete combustion is more difficult than with either compound separately or with other hydrocarbons. If this penalty were to be promulgated into the final rule, affected sources would have to add additional assist gas to improve combustion.
The American Petroleum Institute (API) contracted CleanAir to investigate EPA's claims. CleanAir's analysis revealed there was absolutely no scientific evidence to support EPA's claims that all olefins exhibited this property. We concluded that EPA attempted to interpret random noise in the data as evidence for their claim. CleanAir prepared a technical white paper outlining its finding and participated with industry in face-to- face negotiations with EPA's Office of Air Quality Planning and Standards (OAQPS) on this issue.
EPA withdrew the penalty in the final rule. One client estimated that the penalty, if left intact, would have cost their facility at least $20 million per year. Inaccurate AP-42 Factors
In a recent revision to EPA's emission factor document AP-42, EPA proposed to increase its factor for NOx emissions from refinery flares by a factor of 30. This would have put most, if not all, affected facilities out of compliance with their NOx limits. CleanAir Involvement: Clean Air was contracted by API to research EPA's basis for this factor. After a thorough analysis of the data used by EPA, CleanAir uncovered several issues that would make the data invalid for use in developing emission factors. This included lack of adequate calibration of the measurement instruments and improper statistical analysis to eliminate data outliers. CleanAir prepared an extensive technical white paper on its findings and participated with industry in face-to- face meetings on the issue with EPA.
After initial reluctance, EPA agreed to withdraw the NOx factor revision.
Hydrogen is an excellent fuel. However, it has a low net heating value on a volumetric basis. EPA did not account for this in various rulemakings and, in effect, penalized plants with significant concentrations of hydrogen in their flare vent gas. CleanAir Involvement: CleanAir worked with refinery and chemical clients to develop a “hydrocarbon equivalent” heating value for hydrogen. CleanAir promoted this approach by producing technical white papers explaining the approach, making presentations to industry groups and participating in face-to- face discussions with US EPA. Result: EPA allowed the use of this approach in its consent decrees and adopted it in the Refinery MACT rule despite initially having opposed the idea. Using this approach potentially saves affected sources millions of dollars per year in avoided natural gas costs.
Test Method Bias
Many of EPA's air emission test methods were developed in the 1970's and 1980's when emission rates were much higher. As a result, some of these methods are not reliable when used to measure today's much lower pollutant concentrations. CleanAir Involvement: The Electric Power Research Institute contracted CleanAir to conduct extensive laboratory tests of EPA Methods 26 and 26A for the measurement of HCl. CleanAir designed and built a system to replicate the combustion exhaust of a coal- fired boiler and allowed us to vary key parameters such as HCl and water concentrations and to spike the system with potential bias causing compounds. These tests were conducted with HCl concentrations as low as 0.2 ppm.
CleanAir's research found significant bias when using these methods at low HCl concentrations. EPRI has provided this data to its members to allow them to better negotiate permit limits and lobby EPA for modifications to these test methods.
Consulting with the Coke Industry
The EPA recently issued the Coke Industry an Information Collection Request related to updating the Coke Ovens NESHAP. The ICR requires both by-product and heat and non-recovery coke oven facilities to conduct extensive stack testing and fenceline monitoring for a wide variety of hazardous air pollutants. Besides the immense scale of the testing effort being requested, many of the sources under consideration were not designed for conventional manual EPA sampling methodologies. In addition, application of conventional manual methods is complicated by the batch and intermittent nature of many of the process operations.
CleanAir was hired as a consultant to the industry to provide comments to the EPA regarding the feasibility of the ICR and to recommend alternative solutions to some of the more difficult data requests.
CleanAir's expertise in emissions measurements and regulatory requirements helped the industry and EPA craft a better ICR approach. The final ICR addressed many of the technical concerns with the testing and is better suited to the industry's needs while still meeting the EPA's objectives. Part of this effort required convincing the EPA that the proposed draft of the ICR could not be implemented safely or practically, and could in fact yield data of unacceptable quality for rule-making purposes.
Cooling Tower Testing Capabilities
The Clean Air staff is well qualified to perform this work. CleanAir is licensed by CTI to conduct both Thermal and Drift emissions testing. CleanAir's test personnel have conducted hundreds of cooling tower tests in accordance with CTI test codes. In order to stay abreast of industry needs and developments, we are very active in both CTI and ASME test code-writing committees. Our personnel served on the latest committees for both the CTI and ASME cooling tower performance test codes, the CTI ATC-128 Sound Test code, the ATC-150 plume abatement code and recently chaired the ATC-140 Cooling Tower Drift Emissions Test code, the ATC-105 Thermal Test code and ATC-107 Air Cooled Steam Condensers test code.
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