BAQ 2006 Yogyakarta, Indonesia SW18 Standards and Monitoring for Stationary Sources

1. BAQ 2006 Yogyakarta, Indonesia SW18 Standards and Monitoring for Stationary Sources Stack Monitoring of Industrial Sources in the Philippines Presented by: Jeff Burdette TRC Environmental Corporation, USA December 14, 2006

2. Overview MMAQISDP Overview The overall MMAQISDP included • Comprehensive testing of industrial sources (with a separate project performing QA and oversight) • Ten station ambient monitoring network (with a separate project performing QA and oversight) • Institutional strengthening and capacity building • Establishment of a governing board • Motor vehicle testing and road improvement

3. Overview Stack Testing Project Scope of Work Primary objectives • Perform 960 facility surveys and provide necessary instruction to modify sources for testing (test ports, platforms, ladders) • Perform 6,048 individual test runs (the equivalent of 960 sources) for PM, SOx, NOx, H2SO4, CO, H2S and metals • Generate representative emission test data in comparison with the Philippine Clean Air Act standards • Produce EPA-quality test reports suitable for EMB regulatory follow-up actions (NONC, Technical Conference, CAP)

4. Overview OSP Project Team The OSP team included: • TRC Environmental Corp (USA-based) provided the project design, equipment procurement, management, technical direction, training • TEEM (Philippines-based) provided the testing personnel, laboratory analytical services, project coordination with DENR and industry, facilities

5. Overview Project Design In order to accomplish the OSP Scope of Work • Four test teams of 4 persons each • Each team has one vehicle, two sets of equipment • Centralized location for mobilization and demobilization of equipment and samples • Reporting, coordination and laboratory staff dedicated to the project • Analytical laboratory for PM, SOx, NOx, H2SO4, CO and H2S

7. Status Project Accomplishments

8. Standards Source Emission Standards The primary emission standards are: • PM 150 mg/Ncm (urban/industrial) 200 mg/Ncm (rural) • SOx 1,500 mg/Ncm (existing) 700 mg/Ncm (new) • NOx 2,000 mg/Ncm (existing steam generating) 1,500 mg/Ncm (diesel electric) 1,000 mg/Ncm coal (new) 500 mg/Ncm oil (new) • CO 500 mg/Ncm (all sources) • Opacity 20% (all sources) • Metals Range from 5 to 100 mg/Ncm

9. Status Stack Test Results Of the 850 stacks reported, 417 are above the PCAA standard for at least one parameter: • 302 stacks are failing for SOx • 177 stacks are failing for PM • 86 stacks are failing for CO • 28 stacks are failing for NOx • 1 stack is failing for lead • 0 stacks are failing for H2S

11. Status General Observations The following are some of the typical observations: • Sources firing bunker C fuel oil (boilers, gensets, heaters) are exceeding the SOx and PM emission limits • Gensets (compression engines) are exceeding the NOx emission limit • Solid fuel-fired units are exceeding the CO emission limit • Only 1 source was exceeding the lead emission limit • No sources have exceeded the mercury (or other metal) emission limits

12. Status Equipment Returned to DENR At the conclusion of the project OSP provides DENR over $230,000 worth of equipment (project budget is US$ 2.3M) • 7 vehicles (3 Revos and 4 Kia Vans) • Testing equipment (meter boxes, sample probes, impingers, etc) • Laboratory equipment (analytical balance, spectrophotometer, support equipment) • Office equipment, computers and printers • 4 cabinets of test reports with supporting data

13. Supplemental Items OSP Supplemental Items Although not required by our contract, the OSP has provided the following support (at the request of DENR): • Extensive regulatory and policy guidance and support (CEMS, accreditation, methodology questions, emission averaging, mass emission rates, correction factors, etc) • Established test port and platform standards with industry • Created culture of safety in stack testing • Training (test procedures, laboratory procedures, test report review, regulatory follow-up, PCO workshops) • Survey and testing of large sources outside the Airshed

14. Value Primary Goal “Improve air quality over the medium term” • Of the 850 stacks that have been reported, 417 (49%) are failing (without DENR applying the appropriate dilution correction factors). This leads to issuance of NONC and presentation of compliance plan by the industries. • For sources that pass, the report generally provides the necessary data to make that compliance sustainable • The vast source data should now be used to re-evaluate, and where necessary, tighten the emission standards

15. Follow-on Actions Recommendations DENR should consider the following follow-on actions: • Prioritize and advance air quality permitting as the primary regulatory tool (focused on the large/high priority sources) • Adopt oxygen correction factors • Adopt long-term strategy for Emission Testing in the Philippines by completing private company accreditation • Standardize the complaint investigation to focus on best environmental outcome (not on testing only) • Adopt CEMS regulation clarifications and audit/require routine QA/QC measures to ensure data is valid

16. Lessons Learned Lessons Learned For future similar programs the following should be considered: • The Institutional strengthening, capacity building and training may need to pre-date other program elements • Regulations may need to be clarified or modified prior to significant regulatory action • Simultaneous projects often resulted in “competition” for limited DENR resources and support • Agency should engage industry groups in the standard development and regulatory decision-making