CEMS Users Group Meeting

EPRI Conference---Raleigh, NCMay 2013

Reynaldo (Rey) Forte, Jr.USEPA

A Few Statistics / Trends

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ARP Annual Generation (MWh) by Fuel Type

3Gas generation was 39% of total 2012 generation.

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ARP Annual Generation (MWh) by Fuel Type

Daily (2012) Generation•ARP daily gas-fired generation approximated coal-fired generation in spring and fall of 2012 for the first time.

ARP Annual Generation

ARP Annual Generation (MWh) by SO2 Control Type

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•Uncontrolled generation continued to fall in 2012

•FGD generation was displaced by gas

ARP/CAIR Annual Gas-Fired Generation (MWh) by NOx Control Type

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SCR is also the predominant control at gas-fired units with a 73% share by generation (MWh)

ARP/CAIR Program Annual Emissions

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December 30 - The U.S. Court of Appeals for the D.C. Circuit issued its ruling to stay the CSAPR pending judicial review.

August 21, 2012 - The U.S. Court of Appeals for the D.C. Circuit issued a decision to vacate CSAPR and remand it back to EPA. The Court also ordered that CAIR remain in place pending promulgation of a valid replacement.

January 24, 2013 - The U.S. Court of Appeals for the D.C. Circuit denied all the petitions for rehearing of its August 2012 decision to vacate CSAPR.

March 29, 2013 - The U.S. Solicitor General petitioned the Supreme Court to review the D.C. Circuit Court's decision on CSAPR.

April 8 and April 17, 2013 – EPA held meetings with the states to discuss a path forward on addressing interstate air pollution.

Cross-State Air Pollution Rule

Part 75 –Related Activities

Part 75 Revisions

• EPA is developing a proposed rule revision:

– Will remove update or outdated provisions, and make technical corrections and other changes to Parts 72 (definitions) and 75.

– Should make Parts 72 and 75 more compatible with CAIR and easier to understand and implement.

– Expected Federal Register publication date for proposed rule in late 2013.

– There will be a 30 day comment period once the proposed rule is published.

Revisions to Definitions• Updating and clarifying several definitions in 72.2• Adding several new definitions

Updates to Incorporation by Reference• Several new or updated ASTM standards• New AGA standards• Revised EPA Traceability Protocol for Gaseous Calibration

Standards

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Part 75 Revisions

Correction of Errors• Minor changes in 75.17 for monitoring NOX emission rate from

common, bypass, and multiple stacks• Minor changes in 75.19 low mass emitters• Calculating maximum potential concentration for natural gas• Recordkeeping in 75.57• Minor deadline corrections in 75.74• Correction of other errors

Removal of Outdated Provisions• Several outdated provisions throughout Part 75 are being

removed, e.g., provisions that were only effective up to a certain date that has passed

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Part 75 Revisions

Addition of New Provisions• Alternative performance specifications for low emitters• Calculating site-specific SO2 emission rates for LME• QA/QC options in 75.20• New provisions in appendices

Clarification of Certain Provisions• Certification / recertification• Low mass emitters• Monitoring NOx emission rates• Recertification of alternative monitoring systems• Calibration gas• Use of conditional data• Timing of various submittals• Ozone season-only reporting• Substitute data• Appendices

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Part 75 Revisions

Protocol Gas Verification Program

• The Emission PGVP commenced on September 26, 2011.

• Helps ensure that accurate CEMS calibration gases are used by Part 75 sources.

• Accomplished by annually procuring a blind sample of cylinders from any company providing gases to Part 75 sources, having the National Institute of Standards and Technology analyze those cylinders, and posting the results.

• The final rule, a list of participating gas vendors, ECMPS reporting information, and the latest audit results which may be useful when selecting gas vendors are at: http://www.epa.gov/airmarkets/emissions/pgvp-detail.html

• Questions may be addressed to John Schakenbach (schakenbach.john@epa.gov, 202-343-9158)

Air Emission Testing Bodies

• The Part 75 minimum competency requirements for AETBs commenced on March 27, 2012.

• Helps ensure that any stack test company performing Part 75 stack tests (RATAs, App E, and LME tests) has a quality system in place and provides Qualified Individuals on-site for stack tests.

• Accomplished by requiring stack test company compliance with ASTM D7036-04 (available at: http://www.astm.org/Standards/D7036.htm).

• The final rule and ECMPS reporting information are at: http://www.epa.gov/airmarkets/emissions/aetb.html

• Questions may be addressed to John Schakenbach (schakenbach.john@epa.gov, 202-343-9158)

• Last Final Version posted was October 2003• Draft versions were posted in April 2010 and May 2012• Comments have been addressed and final version will be posted

May 2013• Will provide redline version showing edits from 2012 draft as well

as clean version• New version incorporates January 24, 2008, March 28, 2011, and

August 12, 2011 amendments to Part 75• Removes references to old (pre-2009) EDR records• Includes new questions and answers on AETB and PGVP issues• Will still take comments on all questions

Part 75 Policy Manual Revision

• New Checks since May 2012:– Added noncritical Leak checks of positive displacement type Stack flow monitors – Added noncritical Daily Interference Checks for Stack Flow Monitors– These checks will changed to Critical Level 1 in second and third quarters of 2013

• New PGVP Gas Type Codes  implemented in first quarter 2013– Submissions, including resubmissions, of all data including prior quarters should use

new codes.

• No new significant new checks planned at this time.

Emissions Collection and Monitoring Plan System (ECMPS) Update

• We’re seeing shorter durations of questionable data in the control chart analysis.

• We’re still identifying units with this issue every year.

• Most software vendors have incorporated this check into their DAHS – if you haven’t, you should consider it.

• False positives have decreased substantially.

Control Chart Audit Update

• Target Tool for Field Audits (TTFA)

– It highlights suspect data based on statistics and a set of criteria designed to identify unexpected data results, trends or characteristics

– Used for targeting facilities for field audits

• Wind Tunnel Audits

– CAMD audits wind tunnels used for calibrations of sampling probes for use in EPA flow methods 2F and 2 G

– CAMD, generally, audits about half of the wind tunnel testing facilities every 2 years

– None conducted since last year

Other Audits

Mercury and Toxics Standards (MATS)

• On December 16, 2011, EPA signed the final Mercury and Air Toxics

Standards, the first national standards to reduce emissions of

mercury and other toxic air pollutants from new and existing coal- and

oil-fired power plants

• Published in the Federal Register on Thursday, February 16, 2012

• EPA reconsidered portions of the MATS and Utility NSPS and signed

the finalized revision on March 28th.

• Standards will reduce emissions of:

• Metals, including mercury (Hg), arsenic, chromium, and nickel

• Acid gases, including hydrogen chloride (HCl) and hydrogen fluoride (HF)

• Particulate matter

Mercury and Air Toxics Standards

Coal units (approximately 1,100 covered)• Separate mercury standards set for two subcategories of coal-fired power

plants • Sets numeric emissions limits for mercury, acid gases and non-mercury

metallic toxic pollutants• Sets work practice standards for organic air toxics, including dioxin

Oil units (approximately 300 covered)• Sets separate standards for 3 subcategories of oil-fired power plants:

• Limited-use oil-fired units• Non-continental oil-fired units• All other oil-fired units

• Sets numeric emissions limits for metal air toxics including mercury and for acid gases

• Sets work practice standards for organic air toxics, including dioxin

MATS Emissions Limits

• Data from Hg, SO2, HCl, and HF CEMS and sorbent trap systems, as well as any auxiliary monitoring systems needed to convert pollutant concentrations to units of the standard, will be reported using the ECMPS system of EPA’s Clean Air Markets Division (CAMD)

• The SO2 CEMS (if used) and any auxiliary monitoring systems (i.e., flow rate, CO2, O2, and/or moisture) must meet the requirements of 40 CFR 75.

• The results of all performance stack tests using test methods on the ERT web site and CEMS relative accuracy test audits (RATAs) will be submitted to EPA’s WebFIRE database, using the Compliance and Emissions Data Reporting Interface (CEDRI)

MATS Monitoring and Reporting

• Part 75 revision is coming up.

• Posting of revised Part 75 Policy Manual later this month.

• EPA is committed to working closely with you to achieving effective and smooth implementation of the Mercury and Toxics Standards rule.

Concluding Remarks

THANKS!

Don’t forget to visit our EPA booth.