Report to CEM Users Group

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Report to CEM Users Group

• Columbus, Ohio
• May 3-5, 2006
• Reynaldo Forte (Rey)

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Clean Air Interstate Rule (CAIR)

• Reduces sulfur dioxide (SO2) and nitrogen oxide
  (NOx) emissions which contribute to fine particle
  pollution (PM2.5) and ground level ozone.
• Provides substantial human health and
  environmental benefits the largest benefits for
  any Clean Air Act rule in the last 10 years.
• Helps cities and states in the East meet new,
  more stringent national ambient air quality
  standards for ozone and fine particles.
• Emission reductions occur while economic strength
  is preserved. U.S. maintains both low electricity
  prices and fuel diversity.
• The most important step EPA can take now to
  improve air quality.

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CAIR Health and Environmental Benefits Benefits
over 25 Times Greater than Costs

• By 2015, CAIR will result in 85-100 billion in
  health benefits each year, preventing
• 17,000 premature deaths
• 22,000 non-fatal heart attacks
• 12,300 hospital admissions
• 1.7 million lost work days
• 500,000 lost school days.
• Almost 2 billion in improved visibility benefits
  each year.
• Other non-monetized benefits- reductions of
  mercury emissions, acid rain, nitrification,
  eutrophication, and more.

4
Clean Air Mercury Rule (CAMR)

• CAMR significantly cuts emissions of mercury from
  power plants and

• Builds on EPAs Clean Air Interstate Rule (CAIR)
  to allow power industry to address mercury, SO2
  and NOx emissions in a coordinated effort.
• Along with CAIR, will help protect public health
  and the environment without interfering with the
  steady flow of affordable energy for American
  consumers and business.
• Along with CAIR, is expected to make reductions
  in emissions that are transported regionally and
  deposited domestically, and it will reduce
  emissions that contribute to atmospheric mercury
  worldwide.

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CAIR CAMR Implementation

• Represents the main focus for CAMD most of our
  Division resources are going into the
  coordination and implementation of these rules
  with the Regions, States and sources
• States in the CAIR region are embracing
  cap-and-trade CAIR, and more than halve of the
  states are embracing cap-and-trade CAMR
• Part 75 Hg monitoring is expected whether States
  pursue cap-and-trade or other control strategy
• Up coming implementation activities include
• Hg reporting as part of new re-engineered data
  systems
• Development of XML EDR Instructions
• Development of electronic audit for Hg (MDC
  equivalent)
• Update of Field Audit Manual, Policy Manual, and
  other guidance
• Development of workshop and training materials
• Training of Regions, States, and sources

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Mercury Monitoring - CAMR

• Full commitment from EPAs CAMD, OAQPS and ORD
• Most of the Emissions Monitoring Branch is
  involved with the implementation of a successful
  mercury monitoring program
• We continue to allocate our largest amount of
  resources to CEMS sorbent trap field
  demonstrations, development of an instrumental
  reference method, and development of calibration
  gas standards
• EPRI and others who represent your interest have
  stepped forward and made a big difference
• The question is no longer whether CEMS or sorbent
  traps can measure mercury but how to reliably
  achieve this over time
• Progress is happening and is significant, and
  despite the appearance of availability of plenty
  of time to solve remaining issues, challenges
  remain

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Mercury Monitoring (contd)

• Instrumental Reference Method
• Strong join EPRI/EPA program
• We are in the process of identifying test sites
  to test several candidate reference instruments
• EPA has drafted and circulated a conceptual
  instrumental reference method
• Planning for first test site in collaboration
  with Lehigh University, EPRI, and others
• Calibration Gas Standards
• Pursuing a strong join EPA/NIST program
• We have just committed additional funding
• Commerce Science Fellow from NIST on detail to
  CAMD

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Revisions to Parts 72 and 75

• Main driver Support or streamline reporting
  under the re-engineering of our data systems
  (ECMPS)
• Revisions to clarify, simplify, modify or correct
  mistakes in existing requirements
• Add PEMS to rule
• Add stack testing certification requirement
• Step vs. block approach for missing data
  substitution
• Add some flexibility to the use of substitute
  data for controlled units
• Revisions to strengthen and clarify Hg monitoring
  provisions
• Add EPA Method 29 as an alternative to the OH

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Emissions Data Auditing

• We continue to strive for the highest level of
  data quality that can be reasonably achieved
  while being sensitive to potentially overburden
  the sources
• Weve just implemented the auditing of units that
  report under App. D E of the rule
• Weve also developed software that allows us to
  identify certain suspicious data
• We believe that this provides for a leveled
  playing field and results in more accurate data

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Other Activities

• Processing most petitions in less than 60 days
  (exceptions driven by complexity or certain
  petitions)
• Review and approval of close to a dozen PEMS
  petitions
• Development and publishing of the Plain English
  Guide to Part 75
• Continue to work jointly with our Market
  Operations Branch in the re-engineering of our
  data systems

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Part 60 vs. Part 75 Harmonization

• On February 28, 2005, EPA proposed amendments to
  the SO2 , NOx , and PM emission limits in three
  NSPS boiler regulations---Subparts Da, Db and Dc.
• As part of that rule package, the Agency also
  proposed revisions to
• Certain CEM provisions in Subparts D, Da, Db, and
  Dc 60.13(h) of the NSPS General Provisions and
  Appendices B and F of Part 60.
• The purpose of these additional rule changes was
  to harmonize, to the extent possible, the CEM
  provisions of Parts 60 and 75, for sources
  subject to both sets of regulations.

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Part 60 vs. Part 75 Harmonization (contd)

• The proposed revisions would
• Make the method of calculating hourly emissions
  averages from CEMS data consistent between Parts
  60 and 75
• Allow Part 75 span values to be used for Part 60
  monitoring applications
• Allow the 7-day calibration drift test in Part 60
  to be done on 7 consecutive unit operating days,
  rather than 7 consecutive calendar days
• Allow the more stringent CEMS Quality Assurance
  provisions of Part 75, Appendix B to be
  substituted for the procedures in Part 60,
  Appendix F.

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Part 60 vs. Part 75 Harmonization (contd)

• Comments received on the proposed CEMS rule
  changes were generally supportive.
• However, a number of adverse comments were
  received on the proposed revisions to the Subpart
  Da, Db and Dc emission limits.
• Issues regarding the impact of the emission
  limits were also raised by the Office of
  Management and Budget (OMB) and the Department of
  Energy (DOE).
• But EPA was under a court-ordered deadline to
  finalize the Subpart Da, Db, and Dc emission
  limits by February 9, 2006.

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Part 60 vs. Part 75 Harmonization (contd)

• Therefore, to meet the deadline, the Agencys
  legal and technical staff focused exclusively on
  resolving the controversy over the Subpart Da,
  Db, and Dc emission limits
• Consequently, there was insufficient time to
  properly review the CEMS amendments, and they
  were not included in the final rule that appeared
  in the Federal Register on February 27, 2006.
• However, EPA still intends to finalize the CEMS
  amendments as a separate rulemaking, hopefully
  within the next few months.

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Part 60 vs. Part 75 Harmonization (contd)

• Based on comments received and internal
  discussion and deliberation within the Agency
  during the rulemaking process, the final CEM rule
  revisions will likely differ somewhat from the
  proposal.
• Despite this, EPA believes that the revisions
  will accomplish the intended purpose, which is to
  simplify and reduce the cost of compliance for
  sources currently subject to disparate and
  duplicative continuous monitoring requirements
  under Parts 60 and 75.

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Closing Remarks

• Promulgation of CAIR and CAMR represents an
  environmental milestone and brings new challenges
  and demands to our community
• We are in the right path to achieving the
  necessary CAMR mercury monitoring capability but
  additional work remains
• Upcoming rulemaking proposal should enable a
  stronger, more coherent monitoring program while
  facilitating the reengineering of the current
  data systems
• EPAs commitment to harmonize Part 60 and Part 75
  CEM requirements remains strong
• Transparent, complete, and accurate emissions
  data is the cornerstone of program success