# Presentation: 158467

## Report to CEM Users Group

- Milwaukee, Wisconsin
- May 4, 2003
- Reynaldo (Rey) Forte

## It’s been an interesting year!

**Several regulatory initiatives affecting the power generation sector**
**A busy year in the emissions monitoring world...**

## Legislative/Regulatory Initiatives 

**Proposed Clear Skies Legislation**
**Proposed Clean Air Interstate Rule and   pending supplement **
**Proposed Mercury Supplemental Rule**
**NO****x**** SIP Call - phase II **

**Notes:**
Emissions in 1980 were 17.3 million tons going down to 10.63 in 2001.

It would be 33% from 1990 levels. (15.73 million tons)

## Possible Monitoring Implications

- Proposed Clear Skies Legislation
- National SO2, NOx, and Hg program
- SO2 - small; most sources already under Part 75
- NOx - medium; units not currently in the NOx SIP Call would go from emissions rate to mass emissions
- Hg - significant impact due to new monitoring technologies, options, and possibly some new data collection

**Notes:**
There is not argument that cap-and-trade program with a strong emissions reporting and quality assurance program is the way to go but other specifics. 

I strongly believe that everyone in this conference should feel very proud about collectively achieving this success! 

## Possible Monitoring Implications

- Proposed Clean Air Interstate Rule
- Would reduce emissions of SO2 and NOx in about 29 Eastern states
- SO2 - small; most sources already under Part 75
- NOx - small to medium; several new states would go from emissions rate to mass emissions
- Sources in the NOx SIP Call States are already reporting NOx mass emissions

**Notes:**
There is not argument that cap-and-trade program with a strong emissions reporting and quality assurance program is the way to go but other specifics. 

I strongly believe that everyone in this conference should feel very proud about collectively achieving this success! 

## Possible Monitoring Implications

- Proposed Mercury Supplemental Rule:
- National Cap and Trade program
- New technical challenges for both the power sector and the Agency
- Taking comments on two monitoring technologies and two monitoring alternatives

**Notes:**
There is not argument that cap-and-trade program with a strong emissions reporting and quality assurance program is the way to go but other specifics. 

I strongly believe that everyone in this conference should feel very proud about collectively achieving this success! 

## Possible Monitoring Implications

- Phase II of the NOx SIP Call
- Additional sources from Northern GA and Eastern MO
- EGUs, Non-EGUs, and ICEs
- Small impact: NOx emission rates to NOx mass
- ICEs are not trading or reporting under Part 75

**Notes:**
There is not argument that cap-and-trade program with a strong emissions reporting and quality assurance program is the way to go but other specifics. 

I strongly believe that everyone in this conference should feel very proud about collectively achieving this success! 

## Our report to you...

## What Have We Done Lately?

**Institutionalization of the Electronic Audit Program**
**Acid Rain and NO**x** SIP Call programs**
**Auditing all reporting quarters**
**Reducing the number of false errors**

**Notes:**
Transitioning of OTC units implies that they now must comply with  more rigorous monitoring requirements under the SIP Call.

## What Have We Done Lately?

**MDC improvements to:**
**Reduce reliance on records 697-699 in determining whether extension or exemption is applicable for linearity checks or RATAs**
**Addition of a new module that enables the generation of LME EDRs by MDC**
**Combined electronic audit and QR feedbacks**

**Notes:**
You were very supportive in our beta testing of MDC (over 50 utilities and states participated in this effort). And although we know that this is not the most friendly tool, it is a very effective mechanism to identify errors and make the data so much better. Again, thank you for working with us in accomplishing this.

MDC-hourly added the capability necessary to calculate BAF and OOC, qa test/controls on an hourly basis - Bob Vollaro

First approved PEMS petition approved for gas-fired turbine in AL

Testing on two separate sites; some delays but good results:
     good correlation between PEMS and CEMS systems for      NOx; Chesterffield,Va

     Good results with portable NOx analyzers; KUA, FL

Calibration gases audit in conjunction with OAQPS

Please attend John Schakenbach's presentation on PEMS

## What Have We Done Lately?

**First year implementation of the NO**x** SIP Call program**
**Mainly former OTC units**
**Practice year for other EGUs and non-EGUs**
**Review and approval of State’s SIPs**
**Electronic auditing of most units**

**Notes:**
Transitioning of OTC units implies that they now must comply with  more rigorous monitoring requirements under the SIP Call.

## What Have We Done Lately?

**Revision of the Policy Manual (now available on-line in searchable format)**
**First conditional approval of Subpart E Petitions (PEMS)**
**Two gas-fired turbines and one gas-fired boiler**

**Notes:**
You were very supportive in our beta testing of MDC (over 50 utilities and states participated in this effort). And although we know that this is not the most friendly tool, it is a very effective mechanism to identify errors and make the data so much better. Again, thank you for working with us in accomplishing this.

MDC-hourly added the capability necessary to calculate BAF and OOC, qa test/controls on an hourly basis - Bob Vollaro

First approved PEMS petition approved for gas-fired turbine in AL

Testing on two separate sites; some delays but good results:
     good correlation between PEMS and CEMS systems for      NOx; Chesterffield,Va

     Good results with portable NOx analyzers; KUA, FL

Calibration gases audit in conjunction with OAQPS

Please attend John Schakenbach's presentation on PEMS

## What Have We Done Lately?

**Finalization of Certification/Recertification Test Policy**
**Worked with OAQPS, ORD, and industry in supporting last year’s mercury monitoring demonstrations**

**Notes:**
You were very supportive in our beta testing of MDC (over 50 utilities and states participated in this effort). And although we know that this is not the most friendly tool, it is a very effective mechanism to identify errors and make the data so much better. Again, thank you for working with us in accomplishing this.

MDC-hourly added the capability necessary to calculate BAF and OOC, qa test/controls on an hourly basis - Bob Vollaro

First approved PEMS petition approved for gas-fired turbine in AL

Testing on two separate sites; some delays but good results:
     good correlation between PEMS and CEMS systems for      NOx; Chesterffield,Va

     Good results with portable NOx analyzers; KUA, FL

Calibration gases audit in conjunction with OAQPS

Please attend John Schakenbach's presentation on PEMS

## What Have We Done Lately?

**Development and proposal of monitoring and reporting regulatory language**
**Proposed Clean Air Interstate Rule and pending supplement**
**Proposed Mercury Supplemental Rule**

**Notes:**
You were very supportive in our beta testing of MDC (over 50 utilities and states participated in this effort). And although we know that this is not the most friendly tool, it is a very effective mechanism to identify errors and make the data so much better. Again, thank you for working with us in accomplishing this.

MDC-hourly added the capability necessary to calculate BAF and OOC, qa test/controls on an hourly basis - Bob Vollaro

First approved PEMS petition approved for gas-fired turbine in AL

Testing on two separate sites; some delays but good results:
     good correlation between PEMS and CEMS systems for      NOx; Chesterffield,Va

     Good results with portable NOx analyzers; KUA, FL

Calibration gases audit in conjunction with OAQPS

Please attend John Schakenbach's presentation on PEMS

## What Have We Done Lately?

**Development of mercury standards for gas cylinders (CAMD, OAQPS, NIST and gas vendors)**
**Implementing the conditional test method for rectangular ducts**
**Enables sources to adjust flow rates to take into account wall effects**

**Notes:**
You were very supportive in our beta testing of MDC (over 50 utilities and states participated in this effort). And although we know that this is not the most friendly tool, it is a very effective mechanism to identify errors and make the data so much better. Again, thank you for working with us in accomplishing this.

MDC-hourly added the capability necessary to calculate BAF and OOC, qa test/controls on an hourly basis - Bob Vollaro

First approved PEMS petition approved for gas-fired turbine in AL

Testing on two separate sites; some delays but good results:
     good correlation between PEMS and CEMS systems for      NOx; Chesterffield,Va

     Good results with portable NOx analyzers; KUA, FL

Calibration gases audit in conjunction with OAQPS

Please attend John Schakenbach's presentation on PEMS

## What Are We Doing Today?

**Continue to work towards minimizing the need for emissions monitoring-related enforcement actions**
**Enhancing the Electronic Audit Program**
**Increasing the number of field audits**
**Incorporating training when relevant **
**Finalization of the calibration gas audit**
**11% failure rate compared to a previous 5%**

**Notes:**
We would like to assist in providing the tools that should allow sources to self-audit their data and ensure compliance versus using the traditional enforcement approach.

Self-audit tools:
    MDC
    Field Audit Manual

## What Are We Doing Today?

**Continuing to improve our petition process**
**Working with our Market Operations Branch in the re-engineering or our data process**
**Developing methodology for calculating “F” factors for sources that burn unconventional fuels**
**Finalizing field testing of PEMS**
**Analyzing test results**

**Notes:**
Electronic-based tools: MDC Tutorial including the LME module. If you have an LME unit, you can use this module to generate almost everything you need avoiding significant expenses. This took a lot of effort on our part. We are expecting more LMEs with the SIP Call implementation. It will be available through our web site soon.

Mercury monitoring: As you well know monitoring of mercury is challenging due to its low concentration in the flue gas, speciation, and susceptibility to interferance  by other substances. 

Our colleagues in OAQPS and ORD are performing a number of activities designet to better understand the capabilities of monitoring technologies.

Our major effort is the cost effectiveness analysis of different monitoring options. We are  hoping this study will tell us whether a single technology or combination of technologies is the way to go while keeping economics in mind.

Field testing of PEMS: good tool to qa PEMS installations

## What Are We Doing Today?

**Turbine initiative: Continue to work with OAQPS in the revision of Part 60, Subpart GG**
**Direct-final rule and parallel proposal: Apr 2003**
**Direct-final rule withdrawn: May, 2003**
**Response to comments - completed**
**Final rule package has been completed; anticipate promulgation by May, 2004**
**OAQPS is working to revise the emission limits in a separate rulemaking**
**Consent decree - Proposal: Feb 05; Final: Feb 06**

**Notes:**
Electronic-based tools: MDC Tutorial including the LME module. If you have an LME unit, you can use this module to generate almost everything you need avoiding significant expenses. This took a lot of effort on our part. We are expecting more LMEs with the SIP Call implementation. It will be available through our web site soon.

Mercury monitoring: As you well know monitoring of mercury is challenging due to its low concentration in the flue gas, speciation, and susceptibility to interferance  by other substances. 

Our colleagues in OAQPS and ORD are performing a number of activities designet to better understand the capabilities of monitoring technologies.

Our major effort is the cost effectiveness analysis of different monitoring options. We are  hoping this study will tell us whether a single technology or combination of technologies is the way to go while keeping economics in mind.

Field testing of PEMS: good tool to qa PEMS installations

## What’s ahead...

**Continue to investigate ways to consolidate and simplify monitoring and reporting**
**Continue to identify and implement Part 75 enhancements**
**Work with OAQPS in amending the portable analyzer conditional test method to reflect field testing results**

**Notes:**
State audit capacity:
    Field audits
    Target lists
    Audit results are shared with States and Regions

## What’s ahead...

**Addressing public comments and finalization of the monitoring provisions in the Clean Air Interstate and Mercury supplemental rules**
**Working towards stack tester accreditation**
**Implementation of the second phase of the NOx SIP Call**

**Notes:**
State audit capacity:
    Field audits
    Target lists
    Audit results are shared with States and Regions

## What’s ahead...

**Continue to build audit capacity**
**Further training of State personnel and sources in the use of MDC**
**EDR Instructions in searchable format**
**Pursue additional field demonstrations of mercury monitoring technologies and associated QA/QC procedures**

**Notes:**
Implementation of NOx SiP Call: monitoring plans, conducting audits, processing emissions data, etc.

Stack tester acreditation: working with ASTM committee

## What’s ahead...

**Working with OAQPS, ORD, and vendors in the institutionalization of the calibration gas audit**

**Notes:**
Implementation of NOx SiP Call: monitoring plans, conducting audits, processing emissions data, etc.

Stack tester acreditation: working with ASTM committee

## And finally:

- Continue to work hard in making emissions monitoring as complete and accurate as possible without adding unreasonable burden to reporting sources