# Presentation: 158466

## Report to CEM Users Group

**Savannah, Georgia**
**May 4, 2005**
**Reynaldo Forte (Rey) **

## A new set of challenges!

- Clean Air Interstate Rule - signed
- Clean Air Mercury Rule – signed
- Clear Skies Legislation – hearings continue
- Best Available Retrofit Technology – June 05
- Turbine Initiative – Subpart GG
- Proposed NSPS Revisions – Subparts Da, Db, Dc, §60.13, and Appendix F

## Same level of commitment

- Continue working with you to maintain the degree of success already achieved in the Acid Rain and NOx Budget Trading programs
- Achieve a smooth CAIR implementation
- Overcome the challenges presented by mercury monitoring
- Continue to strive for best possible data quality and completeness

## In retrospect

- We’ve been here before, i.e., SO2 monitoring
- Challenges looked insurmountable – many thought that it couldn’t be done
- But you succeeded!
- We want to continue listening to your concerns,
- And do our best to jointly overcome obstacles

## This year’s report to you...

## What Have We Done Lately?Continue to improve MDC

**Added new functionality to support the conditional test method for rectangular ducts**
**Added new fuel types, e.g., tire-derived**
**Removal of a few bugs**
**Adding QA checks for Appendix D units**

**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? Electronic Audit Program

**From highly difficult and confusing to routine implementation**
**Close to 100% of the emissions are audited every quarter**
**Number of errors continues to decrease dramatically**
**Expanding capability to other Part 75 monitoring methods**

**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? NOx Budget Trading Program

**Successful first year implementation**
**Includes EGUs and non-EGUs**
**All units were audited**
**Non-EGUs catching up quickly with Part 75 monitoring**

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

## Sources Implemented Reliable and Accurate Monitoring

**2004 NBP Monitor Quality Assurance Performance (Electric Generating vs Industrial Units)**

## What Have We Done Lately?

**Three conditional approvals of Subpart E Petitions (PEMS)**
**Two gas-fired turbines and one gas-fired boiler**
**Five new PEMS petitions under review**
**EDR Instructions in searchable format -available through the EPA’s website**

**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 We Have Done Lately? Petition process

**Improving the petition process**
**Recently, the processing of several petitions has taken longer due to the workload associated with CAIR and CAMR**
**Managed to expeditiously process those that had an impact on emission levels (true up)**
**Developed and implemented a Petition Tracking System to simplify the management of this process**

**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?

**Continue to work towards minimizing the need for emissions monitoring-related enforcement actions**
**Enhancing the Electronic Audit Program**
**Strengthening the criteria/targeting for field audits**
**Pursuing the institutionalization of the calibration gas audit**
**Working with OAQPS, NIST, EPRI, and others**
**Finalizing “Plain English Guide to Part 75”**

**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?Re-Engineering

**Jointly with the Markets Operations Branch, implementing the re-engineering of our emissions data processes**
**Developing a Client Tool that combines the functionality of the submissions process, ETS and MDC checks into a highly effective, flexible, and simple-to-use tool**
**Moving away from flat files**
**Consolidating the ETS and MDC feedbacks**

## What Are We Doing Today?  Revisions to Part 75

**Most revisions are driven by the re-engineering process**
**In addition to re-engineering revisions:**
**Match EPA’s policy on the application of substitute data (PQ15.5)**
**Adopt moisture default values for natural gas**
**Predictive Emissions Monitoring Systems**
**F-factors for various fuel types**

## What Are We Doing Today? Harmonization of Part 60 and Part 75

**Turbine initiative**
**Revisions to Subpart GG were finalized in July 2004**
**Part 60 vs. Part 75 compliance is simplified for hundreds of combustion turbines**
**Assisting states with implementation guidance**
**Beyond combustion turbines**
**Proposed harmonization of Part 60 and Part 75 for boilers affected by NSPS, Subparts Da, Db, and Dc**
**Addresses: CEM quality-assurance and data validation provisions**
**Comment period closed on 29 April 2005**

**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 Have We Done Lately? Clean Air Interstate Rule

**CAIR implements a two-phase NOx and SO****2**** emission reduction program with declining caps, affecting a total of 28 States and DC**
**States may adopt model rules to implement the mandated CAIR reductions (or use another approach)**
**EPA will administer these cap and trade programs**
**All programs requires Part 75 monitoring**

**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? Clean Air Mercury Rule

**Monitoring and reporting requirements**
**Builds on the Part 75 infrastructure**
**Allows two alternative monitoring technologies**
**Designed to provide flexibility while maintaining essential data quality**
**Working with OAQPS, ORD, EPRI, RMB, NIST, and others: **
**Field monitoring demonstrations **
**Enabling the advancement of monitoring systems to overcome design and operational issues**
**Development of an instrumental reference method**
**Assessing implementation issues**

**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

##  We’ve been listening to you, and will continue to do so!