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Report to CEM Users Group

The report discusses significant regulatory updates in air quality management, focusing on the Clean Air Interstate Rule (CAIR) and the Clean Air Mercury Rule (CAMR). It highlights ongoing challenges such as emissions monitoring, data quality, and technological advancements in emission tracking. Collaborative efforts are emphasized to enhance monitoring systems and simplify compliance processes. The report outlines recent achievements, including the successful implementation of the NOx Budget Trading Program and improvements to the Electronic Audit Program, alongside upcoming priorities for holistic governance of emissions standards.

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Report to CEM Users Group

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  1. Report to CEM Users Group Savannah, Georgia May 4, 2005 Reynaldo Forte (Rey)

  2. 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

  3. 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

  4. 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

  5. This year’s report to you...

  6. 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

  7. 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

  8. 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

  9. Sources Implemented Reliable and Accurate Monitoring 2004 NBP Monitor Quality Assurance Performance (Electric Generating vs Industrial Units)

  10. 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

  11. 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

  12. 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”

  13. 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

  14. What Are We Doing Today? Revisions toPart 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

  15. 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

  16. What Have We Done Lately? Clean Air Interstate Rule • CAIR implements a two-phase NOx and SO2 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

  17. 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

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

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