Rob Barton RMB Consulting & Research, Inc. EPRI CEM User Group Conference May 8, 2013

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Dinah Lawson
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1 Rob Barton EPRI CEM User Group Conference May 8, 2013

Reporting Elements Emissions Data Initial/Ongoing QA Test Results Compliance Reports

2 Unique Reporting Challenges Compilation of various reporting requirements Electronic submittal of most data/records Adapting existing tools to new types of data Reporting Elements Emissions Data Initial/Ongoing QA Test Results Compliance Reports Other (Notifications/Monitoring Plan) Still Significant Uncertainty in Reporting Requirements

3 Emissions Collection and Monitoring Plan System Client Tool (ECMPS) Acid Rain Program/Clean Air Interstate Rule Electronic Reporting Tool (ERT) MATS Information Collection Request (ICR) Compliance and Emissions Data Reporting Interface (CEDRI) Legacy system accessed through EPA Central Data Exchange (CDX) website (cdx.epa.gov) None of these Tools Fully Support MATS at this Time

Compliance and Emissions Data Reporting Interface (CEDRI) Legacy system accessed through EPA

4 Compliance Based on 30-Boiler Operating Day (BOD) Rolling Averages BOD = any fuel combusted in any 24-hour period Calculated at the end of each BOD Based on all available quality assured hourly data No Missing Data Substitution No Bias Adjustment Factors Exclude Startup/Shutdown Periods Quarterly Data Reporting

on all available quality assured hourly data No Missing Data Substitution No

5 PM CEMS/CPMS 30-BOD averages only Submit all PM data through CEDRI Electronic form/template for data submittal Deadline - 60 days after the end of the quarter All other CEMS/Hg Sorbent Trap Systems Hourly data only Submit data using ECMPS Deadline - 30 days after the end of the quarter Submittal Process/Deadlines for Initial Compliance Data is Unclear

other CEMS/Hg Sorbent Trap Systems Hourly data only Submit data using ECMPS Deadline -

6 Initial Certification/Ongoing QA Activities All Data Submitted Using CEDRI Deadline - 60 days after completion of each test Daily Calibration Records Standardized form? All Other QA Data Emissions Reporting Tool (ERT)/CEDRI ERT does not currently support PS-11 or Procedure 2 Likely a Time Consuming Process PM CPMS Quality Assurance Data/Records are Retained Onsite

All Other QA Data Emissions Reporting Tool (ERT)/CEDRI ERT does not currently support PS-11

7 Initial Certification/Ongoing QA Activities All Data Submitted Using ECMPS Deadline Prior to/concurrent with quarterly report SO 2 /CO 2 /O 2 /Flow Data Already Submitted* HCl/HF/Hg CEMS/Sorbent Trap Systems New/modified ECMPS records RATA Data Submitted Using ERT/CEDRI Deadline 60 days after completion of testing Method 30B not supported by ERT

Submitted* HCl/HF/Hg CEMS/Sorbent Trap Systems New/modified ECMPS records RATA Data

8 ECMPS/CEDRI/ERT Do Not Fully Support MATS Work in progress ECMPS Draft (4/2013) DAHS vendors need time to implement changes PM CEMS Issues Conditionally valid data procedures Diluent cap Startup Data Exclusion SUSD definition not tied to control device operation

CEMS Issues Conditionally valid data procedures Diluent cap

9 Quarterly Stack Testing for HCl/HF/PM/TSM Submit using ERT/CEDRI Reference Methods 5, 26, 26A and 29 are supported ERT-compatible templates for raw data Unit/control device operating data Deadline - 60 days after completion of testing

supported ERT-compatible templates for raw data

10 HCl/HF/PM/TSM Same procedures as quarterly testing Notification of Compliance Status Dates of last 3 tests, results, no changes in operation Hg (annual) Reporting requirements are unclear Summary included in ECMPS monitoring plan records Detailed test results submitted through CEDRI ERT does not support Method 30B

Reporting requirements are unclear Summary included in ECMPS monitoring plan

11 Semi-Annual Compliance Report CEMS Summary Report Tune Up Report

12 Contents CEMS Summary Report Total fuel use per calendar month Description of fuels/justification as non-waste Dates of most recent tune-up/burner inspection Description of excess emissions Breakdown of malfunction periods Statements of compliance with work practice standards or emissions limitations Report Submitted through CEDRI

Description of excess emissions Breakdown of malfunction periods Statements of

13 Initial Reporting Period Begins on compliance date and ends June 30 or December 31 (whichever first occurs after 180 days) Existing units: April 16, 2015* December 31, 2015 (due January 31, 2016) Ongoing Reporting Period January 1 June 30 (due July 31) July 1 December 31 (due January 31) Title V Report Could Satisfy Requirements

31, 2015 (due January 31, 2016) Ongoing Reporting Period January 1 June 30 (due

14 Contents General unit/cems information Date of latest CEMS certification or audit Total operating time Breakdown of excess emissions Breakdown of monitor downtime Changes in CEMS, process, or controls Much of the Content is Redundant Submit with Semi-Annual Compliance Report

emissions Breakdown of monitor downtime Changes in CEMS, process, or

15 Contents CO/NO x concentrations before and after tune-up Correction action taken as part of tune-up Types and amounts of fuel used over the 12 calendar months prior to tune-up (multi-fuel units only) Information necessary to demonstrate that all tuneup activities were conducted Submittal Requirements Date of initial/next scheduled tune-up Notification of Compliance Status/Semi-Annual Report Submittal of tune-up report is unclear

necessary to demonstrate that all tuneup activities were conducted Submittal Requirements Date of

16 Site-Specific Monitoring Plan Differences in Part 63/Part 75 terminology Part 60/75 CEMS Exempt Submit 60 days prior to certification (if requested) Submit within 21 days of compliance date for Hg CEMS/sorbent trap and HCl/HF CEMS using ECMPS Existing units - March 26, 2015 Notifications Compliance status, performance tests, QA tests Deadlines may conflict with Title V requirements

for Hg CEMS/sorbent trap and HCl/HF CEMS using ECMPS Existing units - March 26, 2015

17 MATS Reporting is a Work in Progress Reporting tool updates PM data requirements Inconsistencies on other requirements Timely Guidance Needed to Implement Solutions for Vendors/Utilities Other Issues Likely to Be Identified Further Rule Revisions? MATS Policy Manual?

Guidance Needed to Implement Solutions for Vendors/Utilities Other

Guidance and Reporting Instructions on Temporary E-reporting for the MATS Rule

Guidance and Reporting Instructions on Temporary E-reporting for the MATS Rule As explained in the interim MATS e-reporting rule, which was signed by the Administrator on March 9, 2015, the EPA plans to