State of Florida Periodic Monitoring Examples
This document is intended to help permitting authorities and Title V sources in assessing
and establishing requirements to implement periodic monitoring in the state of Florida. Recently,
the state of Florida amended Rule 62-213.440, Florida Administrative Code (F.A.C.) to be
compatible with the federal authority under 40 CFR 70.6(a)(3)(i)(B).
The department’s website contains this document along with additional resources to
evaluate periodic monitoring. The department’s guidance and USEPA’s Periodic Monitoring
Technical Reference Document are posted on the web site. Final Title V permits posted on the
website may also be helpful.
This document summarizes examples of periodic monitoring approved by the department
and USEPA. Periodic monitoring determinations are always case-by-case. The examples in this
document are not mandatory, even for the same type of emissions unit, because other relevant
criteria may be different. This document is not intended to be an exclusive list of examples of
periodic monitoring. Additional examples will be periodically added.
EXAMPLE 1 – Oil-fired SIP Utility Boilers
Oil fired boilers regulated under the state of Florida’s state implementation plan (SIP) are
subject to opacity, particulate matter, and sulfur dioxide emission limits.
a. Continuous Opacity Monitor Systems (COMS).
For opacity, one approach to periodic monitoring is to utilize a COMS that may already be
required. SIP utility boilers regulated under acid rain were required to install, operate, and
maintain COMS. The following permit condition requires the owner or operator to maintain and
operate the COMS and to make and maintain records of the readings for purposes of periodic
monitoring:
X.#. COMS for Periodic Monitoring. The owner or operator is required to install continuous
opacity monitoring systems (COMS) pursuant to 40 CFR Part 75. The owner or operator
shall maintain and operate COMS and shall make and maintain records of opacity measured
by the COMS, for purposes of periodic monitoring.
[Rule 62-213.440, F.A.C.]
b. Particulate Matter Testing Frequency.
SIP utility boilers regulated under Rule 62-296.405, F.A.C., are subject to a steady-state PM
(particulate matter) emission limit of 0.1 lb/mmBtu and 0.3 lb/mmBtu for soot blowing. One
factor in determining the testing frequency for particulate matter emissions is historical average
test results. The department has determined that sources with historical emissions less than half
the standard are required to test annually, sources with historical emissions less than three
quarters of the standard required to test semi-annually, and the remaining sources required to test
quarterly. The averaging period for historical emissions is determined on a case-by-case basis.
The following justification is added to the statement of basis for a source with historical PM test
results half of the standard:
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The Department has determined that the appropriate particulate matter testing frequency for
the fossil fuel steam generators is annually whenever fuel oil is used for more than 400 hours
in the preceding year. This frequency is justified by the low emission rate documented in
previous emissions tests while firing fuel oil. These units are subject to a steady-state PM
emission limit of 0.1 lb/mmBtu and 0.3 lb/mmBtu for soot blowing.
The applicant has presented historical PM test results, which show that the steady state and
soot blowing average results are less than half the applicable standards. The Department has
determined that sources with emissions less than half of the standard shall test annually. A
five year average of results of particulate matter emission testing in lb/mmBtu for Unit #1 are
0.055 (steady-state) and 0.057 (soot-blowing).
c. Sulfur Dioxide.
Oil fired SIP utility boilers regulated under Rule 62-296.405, F.A.C., are subject to a sulfur
dioxide emission limit.
1) Continuous Emissions Monitoring System (CEMS).
Oil-fired SIP boilers demonstrating compliance with a continuous emissions monitoring system
(CEMS) for sulfur dioxide standards satisfies periodic monitoring.
2) Fuel Sampling and Analysis.
Boilers demonstrating compliance with fuel oil sulfur limits by fuel sampling is sufficient
periodic monitoring. When fuels with different sulfur contents are blended: (1) fuel sampling
and analysis is only required if the fuels are blended on-site and one shipment is above the limit.
If fuels are blended off-site or all of the shipments are below the limit, the as-received analysis
shows compliance. (2) daily fuel analysis is not required. If a fuel shipment is above the limit
and put in a tank with fuel already on-site (i.e., blended to meet the limit), then a single sample
and analysis will show that all of the fuel in the tank is in compliance. Further sampling and
analysis is not required until a new shipment above the limit is received. The fuel analysis shall
be performed by the vendor or the permittee upon delivery.
EXAMPLE 2 – Combustion Turbines
For simple-cycle and combined-cycle combustion turbine units without COMS, each unit
shall have a Method 9 visible emissions test conducted upon exceeding 400 hours of operation on
fuel oil, and every 150 hours of operation on fuel oil thereafter, in any given federal fiscal year.
The following example justification is added to the statement of basis supporting such a testing
frequency, specifically referring to the low historical operational use of fuel oil and the difficulty
of scheduling VE tests for remote-started simple-cycle turbines units:
The Department has determined that the appropriate VE testing frequency for the simple-
cycle turbines is a VE test upon exceeding 400 hours of operation on fuel oil, and every 150
hours of operation on fuel oil thereafter, in any given federal fiscal year (October 1 through
September 30). This frequency is justified by the low historical operational use of fuel oil for
these units and the previous VE tests which documented compliance while firing fuel oil.
The units have fired fuel oil a total of 30 hours in 1994, 7 hours in 1995, 2 hours in 1996, 4
hours in 1997, and 5 hours in 1998.
The following condition is added to the permit:
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X.#. Visible Emissions Testing Required. The owner or operator shall conduct testing for
visible emissions, using EPA Method 9, while the combustion turbine is operating at 90-100
percent of its capacity, according to the following schedule.
The owner or operator shall conduct testing for visible emissions while firing fuel oil for each
simple-cycle turbine unit upon that turbine's exceeding 400 hours of operation on fuel oil, and
every 150 hours of operation on fuel oil thereafter, in any given federal fiscal year (October 1
through September 30). Such tests shall be performed within 15 days of exceeding such
operating hours, to allow for prior notification of the tests.
Regardless of the number of hours of operation on fuel oil, at least one compliance test shall
be conducted on all combustion turbines every five years, coinciding with the term of the
operation permit for these turbines.
[Rule 62-213.440, F.A.C.]
EXAMPLE 3 – Coal Fired SIP Boilers
For coal-fired utility boilers with COMS, add-on PM controls and an opacity limit of
40%, each unit shall have a Method 5 particulate matter test conducted following any calendar
quarter in which more than 5% of the COMS readings show 20% or greater opacity. The
following example justification is added to the statement of basis supporting such a testing
frequency, specifically referring to the low historical PM emission test results:
Periodic monitoring for particulate matter will be through the use of COMS. For any
calendar quarter in which more than five percent of the COMS readings on units -001 and
-002 show 20% or greater opacity, a steady-state particulate matter stack test will be
required to be performed and submitted within the following calendar quarter. If the unit
does not operate in the following quarter, it shall be tested within 20 days of coming back
on-line. These units are subject to a steady-state PM emission limit of 0.1 lb/MMBtu and
0.3 lb/MMBtu for soot blowing. They are also subject to an opacity standard of 40%.
The applicant has presented historical PM test results, which show that the steady state
and soot blowing average results are significantly, less than the applicable standards. A
five year average of results of particulate matter emission testing, in lb/MMBtu, for this
facility is given below:
Unit # Steady-state Soot-blowing
1 0.023 0.0336 (example)
2 0.014 0.022
Given the historically low documented PM emissions combined with the company’s
agreement to conduct a PM stack test following any quarter in which their COMS data
shows that more than 5% of the readings are greater than half of their opacity limit, The
Department believes that periodic monitoring for particulate matter is more than
reasonably addressed. The 20% opacity benchmark was chosen as a reasonable level
because it is one-half of the opacity standard and because past testing shows low PM
emission rates at opacity levels near 20%.
The following condition is added to the permit:
#.##. Periodic Monitoring Requirements. Periodic monitoring for particulate matter shall be
COMS. For any calendar quarter in which more than five percent of the COMS readings show
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20% or greater opacity (excluding start-up, shut-down and periods of COMS outages), a steady
state particulate matter stack test shall be performed and submitted within the following calendar
quarter. The stack test shall comply with all of the testing and reporting requirements contained
in the preceding specific conditions and, where practicable, shall be performed while operating at
conditions representative of those showing greater than 20% opacity. Units are not required to be
brought on-line solely for the purpose of performing this special compliance test. If the unit does
not operate in the following quarter, the special compliance test may be postponed until the unit is
brought back on-line. Once back on-line, the special test shall be performed within 20 days.
[Rule 62-213.440(4), F.A.C.]
Last updated: 11/29/99
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