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Update on ECMPS MATS Reporting Requirements

Update on ECMPS MATS Reporting Requirements . EPRI Conference---Denver, CO May 2014 Louis Nichols and Charles Frushour USEPA, CAMD. Background.

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Update on ECMPS MATS Reporting Requirements

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  1. Update on ECMPS MATS Reporting Requirements EPRI Conference---Denver, CO May 2014 Louis Nichols and Charles Frushour USEPA, CAMD

  2. Background • On February 16, 2012, EPA published the Mercury and Air Toxics Standards (MATS) rule (40 CFR 63, Subpart UUUUU), establishing national emissions limitations and work practice standards for certain hazardous air pollutants (HAPs) emitted from coal-fired and oil-fired electric utility steam generating units. • Compliance with the rule is required: • For existing units---by April 16, 2015 (see §63.9984(b)). • For new or reconstructed units**---by April 16, 2012 or upon startup (first-fire), whichever is later (see §63.9984(a)). • Compliance must be demonstrated, by means of performance testing (using EPA stack test methods or continuous monitoring systems), no later than 180 days after the above dates (see §63.9984(f)). _______________ **That is, units that commence construction or reconstruction after May 3, 2011 (see §63.9985).

  3. Background (cont’d) • For existing units, Table 2 of the rule specifies both heat input-based emission limits (lb/mmBtu or lb/TBtu) and electrical output-based limits (lb/MWh or lb/GWh) for all regulated pollutants. For new units, all of the emission limits in Table 1 of the rule are electrical output-based. • Affected EGUs that are required to (or elect to) demonstrate compliance by continuously monitoring Hg, SO2 , HCl, or HF emissions must report emissions data electronically using EPA’s Emissions Collection and Monitoring Plan System (ECMPS). • EPA has incorporated draft MATS ECMPS reporting instructions for these EGUs, covering three areas: (1) Monitoring Plans; (2) Quality Assurance and Certification Tests; and (3) Emissions.

  4. Mercury Monitoring Plan • For each affected unit or common stack at which Hg emissions are continuously monitored, the owner or operator must prepare and maintain a monitoring plan (see Appendix A, section 7.1.1). • The monitoring plan consists of an electronic portion and a hardcopy portion. • For Hg monitoring systems, the electronic portion must include the information specified in section 7.1.1.2 .1of Appendix A . • For auxiliary monitoring systems (stack gas flow rate, diluent gas concentration, and stack gas moisture), the electronic portion must include the applicable information in §75.53(g)(1) . • The hardcopy portion includes schematics, blueprints, test protocols, data flow diagrams, span and range calculations, and miscellaneous technical justifications (see section 7.1.1.2.2 of Appendix A and §75.53(g)(2)) .

  5. Mercury Monitoring Plan • The electronic monitoring plan information pertaining to the Hg monitoring systems and the auxiliary system(s)** must be submitted to CAMD at least 21 days prior to the applicable compliance date in §63.9984(a) or (b). Use the ECMPS Client Tool to submit the electronic portion of the monitoring plan. • All hardcopy portions of the monitoring plan shall be kept on record in accordance with section 7.1 of Appendix A _________________ **Note: The electronic and hardcopy monitoring plan information for the auxiliary monitoring systems may have been previously submitted to satisfy the requirements of the Acid Rain Program, CAIR, or RGGI. If so, no additional monitoring plan submittals are required for these systems.

  6. Certification Test Requirements for Hg and Auxiliary Monitoring Systems • All Hg CEMS, sorbent trap monitoring systems and auxiliary monitoring systems that will provide data under the MATS rule must be initially certified. • The auxiliary monitoring systems (flow rate, diluent gas, and moisture, as applicable) that are used to convert Hg concentrations from µg/scm to units of the emission standard must be certified in accordance with Part 75, Appendix A and §75.20. • The results of all required certification tests must be submitted electronically to CAMD, using the ECMPS Client Tool. • The results of auxiliary monitoring system certification tests that were previously submitted to meet Acid Rain Program, CAIR or RGGI requirements do not have to be resubmitted.

  7. QA Test Requirements for Hg and Auxiliary Monitoring Systems (cont’d) • The results of all required QA tests of the Hg monitoring systems and auxiliary monitoring systems must be submitted electronically to CAMD using the ECMPS Client Tool. • Except for daily QA tests and weekly system integrity checks, the test results must be submitted either prior to or concurrent with the relevant quarterly electronic emissions report. • The results of daily QA tests and weekly system integrity checks must be submitted in the relevant quarterly electronic emissions report. • Detailed RATA reports must also be submitted to the WebFIRE database.

  8. Hg Emissions Reporting • For affected units that demonstrate compliance using Hg CEMS or sorbent trap monitoring systems, quarterly reporting of Hg emissions is required, using ECMPS (see Appendix A, section 7.2.5). • The reports must be submitted no later than 30 days after the end of each calendar quarter. • Each emissions report must include the following information: • Date of report generation; • Facility identification information; • Operating parameter records (i.e., date and hour, operating time, gross load, etc.); • The results of daily calibration error tests and weekly system integrity checks, if Hg CEMS are used; • Hourly records of Hg concentration and the auxiliary parameters needed to convert Hg concentrations from µg/scm to units of the standard;

  9. Hg Emissions Reporting (cont’d) • A separate hourly data stream, in units of the applicable Hg emission standard (lb/TBtu or lb/GWh); • The hourly percent monitor data availability (PMA) for Hg concentration and for each monitored auxiliary parameter. • Hg emission rates will be calculated only for operating hours in which valid data are obtained for Hg concentration and all of the essential auxiliary parameters. • The hourly Hg emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. • Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. • The 30 boiler operating day rolling average Hg emission rates **will not be reported in ECMPS. ____________________ **Or, if applicable, 90 boiler operating day rolling average Hg emission rates.

  10. SO2 Emissions Reporting • Coal- and petroleum coke-fired EGUs equipped with wet or dry flue gas desulfurization (including fluidized bed boilers with limestone injection) may opt to comply with an SO2 limit in lieu of an HCl limit (§63.10000(c)(1)(v)). • If you elect to use this option, you must: • Create and maintain a monitoring plan with electronic and hardcopy portions, in accordance with §75.53(g).@ Use the ECMPS Client Tool to create the electronic portion. • Install an SO2 CEMS and any auxiliary monitoring systems that are needed to determine SO2 emission rates in the units of the applicable emission standard (lb/mmBtu or lb/MWh). • Certify, operate, maintain the SO2 and auxiliary CEMS according to Part 75.** _________________ @ See the footnote on the next slide ** The MATS rule requires one variation from Part 75 QA for the SO2 monitor. Linearity checks are required for SO2 span values of 30 ppm or less. ___________________ **Note:The MATS rule requires one variation from the QA test requirements of Part 75. If the SO2 CEMS has a span value of 30 ppm or less, you must perform linearity checks in accordance with section 2.2 of Appendix B to Part 75.

  11. SO2 Emissions Reporting (cont’d) • Conduct an initial 30 boiler operating day performance test. The notification requirements for the performance test, the window of time for completing the test, the data reduction and compliance assessment criteria are essentially the same as described above for Hg. • Report the results of all required certification, recertification, QA, and diagnostic tests of the CEMS to CAMD electronically, using the ECMPS Client Tool. • Submit quarterly electronic data reports (EDRs) to CAMD using the ECMPS Client Tool.@ Each emissions report must include the following information: • Date of report generation; • Facility identification information; • Operating parameter records (i.e., date and hour, operating time, gross load, etc.); • The results of all daily QA tests; __________________ @The monitoring plan and EDRs are basically the same as the ones required under the Acid Rain and CAIR SO2 Programs. The only new information in the monitoring plans and reports will be formulas to convert SO2 concentrations from ppm to the units of the MATS standard and hourly SO2 emission rates expressed in those units.

  12. SO2 Emissions Reporting (cont’d) • Hourly records of SO2 concentration and the auxiliary parameters needed to convert SO2 concentrations from ppm to units of the standard; • A separate hourly data stream, in units of the applicable SO2 emission standard (lb/mmBtu or lb/MWh); • The hourly percent monitor data availability (PMA) for SO2 concentration and all monitored auxiliary parameters. • SO2 emission rates will be calculated only for operating hours in which valid data are obtained for SO2 concentration and all of the essential auxiliary parameters. • The hourly SO2 emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. • Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. • Compliance with the SO2 emission limit will be assessed on a 30 boiler operating day rolling average basis, excluding startup and shutdown hours. • The rolling average SO2 emission rates will not be reported in ECMPS.

  13. HCl and HF Emissions Reporting • If CEMS are used to demonstrate compliance, you must: • Create and maintain an electronic monitoring plan, using the ECMPS Client Tool; • Install the HCl or HF CEMS and any auxiliary monitoring systems that are needed to determine HCl or HF emission rates in the units of the applicable emission standard (lb/mmBtu or lb/MWh); • Certify and quality-assure the data from the HCl or HF CEMS using procedures based on Performance Specification 15 in Part 60, Appendix B • Certify and quality-assure the data from the auxiliary monitoring systems according to Part 75; • Conduct an initial 30 boiler operating day performance test. The notification requirements for the performance test, the window of time for completing the test, the data reduction and compliance assessment criteria are essentially the same as for Hg; • Report the results of all required certification, recertification, QA, and diagnostic tests of the CEMS to CAMD electronically, using the ECMPS Client Tool.

  14. HCl and HF Emissions Reporting (cont’d) • Submit quarterly electronic data reports (EDRs) to CAMD using the ECMPS Client Tool (see Appendix B, section 11.5). Each emissions report must include the following information: • Date of report generation; • Facility identification information; • Operating parameter records (i.e., date and hour, operating time, gross load, etc.); • The results of all daily QA tests; • Hourly records of HCl or HF concentration and the auxiliary parameters needed to convert HCl or HF concentrations from ppm to units of the standard; • A separate hourly data stream, in units of the applicable HCl or HF emission standard (lb/mmBtu or lb/MWh); • The hourly percent monitor data availability (PMA) for HCl or HF concentration and all monitored auxiliary parameters.

  15. HCl and HF Emissions Reporting (cont’d) • HCl or HF emission rates will be calculated only for operating hours in which valid data are obtained for HCl or HF concentration and all of the essential auxiliary parameters. • The hourly HCl or HF emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. • Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. • Compliance with the HCl or HF emission limit will be assessed on a 30 boiler operating day rolling average basis, excluding startup and shutdown hours. • The 30 boiler operating day rolling average emission rates will not be reported in ECMPS.

  16. Draft ECMPS MATS Reporting Instructions • Initial draft instructions released April 2013 • Webinars held to review instructions • EPA hosted workshops in Chicago and Washington DC to discuss draft instructions • Several issues raised • Reporting “supplemental” data found in monitoring plan (e.g. LEE records etc.) • Reporting of sorbent trap “transition” hours

  17. Draft ECMPS MATS Reporting Instructions • Revised draft instructions released December 2013 • Webinar held to review instructions • Draft instructions will be revised further based on: • Stakeholder feedback • Revisions to PS 12B

  18. Revisions to PS 12B • Final rule (PS 12B) revisions signed January 28, 2014 • Section 12.8.3 was revised to state that when a sorbent trap is lost or accidentally broken, the Hg concentration measured by the other trap may be multiplied by 1.111 and used for reporting, provided that the trap meets four key acceptance criteria

  19. Revisions to PS 12B (cont.) • Several revisions were made to Table 12B-1 • An incorrect citation of section 12.7.1.3 was corrected to read “section 12.8.3” • The acceptance criteria for the stack gas flow rate-to sample flow rate (SFSR) ratio were made more flexible.  The new criterion is that no more than 5% of the ratios or 5 hourly ratios (whichever is less restrictive) can deviate from the reference ratio by more than 25%.  The previous criterion required all hours in the sample collection period to be within 25% of the reference ratio. • Two new “tiers” were added to the sorbent trap breakthrough criteria, to address very low Hg emitters.  The breakthrough criterion is now ≤ 10% if the average Hg concentration is ≤ 0.5 µg/m3 , and there is no breakthrough criterion when the Hg concentration is  ≤ 10% of the emission limit.

  20. ECMPS MATS Beta Releases • Three different Beta versions to be released in 2014 • Initial Beta version with MATS monitoring plan functionality released April 30th • Second Beta version with MATS monitoring plan and QA functionality, anticipated release Q3 • Third Beta version with MATS monitoring plan, QA and emission functionality, anticipated release Q4

  21. ECMPS Production Releases • Q3 2014 production release will contain MATS Monitoring Plan (MP) functionality • If CEMs are used to demonstrate compliance, MP must precede the applicable compliance date in §63.9984 (a) or (b) by at least 21 days • Q4 2014 production release will contain MATS MP, Quality Assurance (QA), and certification functionality • Q1 2015 production release will contain full MATS functionality (i.e. MP, QA, EM)

  22. Useful Links • MATS Home Page • http://www.epa.gov/mats/ • ECMPS Support • http://ecmps.camdsupport.com/ • ECMPS CAMD Home Page • http://www.epa.gov/airmarket/business/ecmps/index.html

  23. Questions? Contact Information: Louis Nichols Charles Frushour USEPA, Clean Air Markets Division nichols.louis@epa.gov frushour.charles@epa.gov

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