Emissions Collection and Monitoring Plan System Timeline and Regulatory Update

1. Emissions Collection and Monitoring Plan System Timeline and Regulatory Update September 6, 2005 Matthew Boze, EPA

2. Adjusted Timeline • Proposed modified timeline • 2005 - 2006: Technical development • Early 2006 through mid-2006: Alpha testing • 2007: Beta testing • 2008: Transition period (EPA will accept the current EDR flat file format for existing units to provide additional time for the conversion of their DAHS to the new XML format) • 2009 - Required use of ECMPS beginning in the 1st quarter submission period for all sources

3. Details about New Timeline • Note that EPA will need for all of the data used for compliance for a given year (or season) to have been submitted using either the ETS-FTP process or the new ECMPS Client Tool process and will not be able to support annual reconciliation for a mixed set of submissions. (This applies to 2008.) • Sources who wish to transition mid-year may do so, but will need to resubmit prior quarterly data through the new process.

4. Rule Changes • Part 75 rule changes are in the final stages of being drafted • Will next go through internal reviews • Publication of the proposed rule change should be made this fall (November) • Goal is to have final rule changes published by October 2006 so that the reporting changes may be used in 2007

5. Regulatory Highlights • Allow sources who designate themselves in “long term cold storage” to suspend quarterly emissions reporting until they resume operating. • Notice requirements would be added to §75.6. • Incorporate EPA’s new policy on the application of substitute data (PQ15.5) • PMA required for all hours (including missing data periods). • PMA for each hour determines appropriate substitute data value for each individual hour.

6. Regulatory Highlights • Add to Appendix F, Equations N-1 and N-2 for calculating NOx Mass Rate (lb/hr) by creating F-26a and F-26b. (F-26 becomes F-26c) • Adopt moisture default values for natural gas. • Remove requirement that Monitoring Plan be submitted with every quarterly emissions report. • Monitoring plan updates will be submitted prior to or concurrent with the quarterly report.

7. Regulatory Highlights • Revise §75.53 • Current Monitoring Plan requirements of paragraphs (e) and (f) effective through the 2008 transition period; expire in 2009. • New proposed requirements in paragraphs (g) and (h) to become effective in 2007 for sources who “opt-in” to the new process early. • In 2009 paragraphs only the new requirements in proposed paragraphs (g) and (h) will be applicable.

8. Regulatory Highlights • Only minor edits were made to the reporting sections of § 75.57 through 75.59 • General and certification, QA/QC record keeping provisions • Many changes were fixing current errors • Other changes support changes to how the data will be collected in ECMPS • Example, Only a Component ID will be required for linearity, so the requirement for System ID is phased out.

9. Regulatory Highlights • Modifications to §75.64 “Quarterly Reports” • Modified §75.64(a) to incorporate language that will allow for the transition from the current requirements of paragraphs (a)(1), (a)(2) and (a)(8) through (a)(15) to the new requirements of (a)(3) through (a)(15). • (a)(1) and (a)(2) of the current rule are being replaced by (a)(3) through (a)(7) which better describe the planned separation of the monitoring plan and QA test information from the quarterly emissions report. • Current rule paragraphs (a)(3) through (a)(11) were renumbered as (a)(8) through (a)(15) as appropriate.

10. Examples of Monitoring Plan Revisions Include • Monitoring methods are to be identified on a monitoring location basis, rather than being based on the unit. • Identify the bypass approach within the primary monitoring location information, • Rather than listing a separate monitoring method for a given parameter for bypass situations; • Only one monitoring methodology per parameter needed.

11. Examples of Monitoring Plan Revisions Include • Revised monitoring plan format will NOT include: • Facility Short Name; • Unit Program Classification; • Unit Boiler Type; • Date of Commence Operation (SUB H); • Date of First Commence Commercial Operation (ARP); • Unit Retirement Date; Program Code; • Reporting Frequency; Program Participation Date; • State Regulation Code; State of Local Agency Code; • All EIA Cross Reference Information.

12. Examples of Monitoring Plan Revisions Include • The following data requirements are being removed: • Fuel Classification for Boiler; • Primary/Secondary control indicator; • Type of fuel associated with each monitoring methodology; • Primary/Secondary methodology indicator; and • Appendix E NOx Correlation Curve Segment Data.

13. Examples of Monitoring Plan Revisions Include • These following requirements will be revised as follows: • Component Status: replaced with Component Activation and Deactivation date/hour to better track the updates to monitoring components; • Formula Status: replaced with Formula Activation and Deactivation date/hour to track formula updates; • Submission Status of Fuel Flowmeter: replaced with Activation and Deactivation date/hour as appropriate.

14. Examples of Monitoring Plan Revisions Include • New monitoring plan data requirements will include: • For dual range monitoring components, the value at which the component switches from the normal to the secondary scale (usually low to high); • Indicator for non-load based units; • Indicator of exemption from 3-load flow RATA requirement; • For each monitoring location, a stack/duct shape code, material code, and duct indicator.

15. Diluent Cap Change • Remove provisions for applying the diluent cap to any calculation except for Nox Emission Rate. • The original purpose for implementing the diluent cap was to keep calculated Nox emission rates from approaching infinity as the diluent value approached a value representative of zero heat input. • Allowing the use of diluent cap values for HI, calculated CO2 concentration from O2 measurement, and CO2 mass complicates the data collection process, especially since the use is optional for different calculation. • Furthermore, application of the diluent cap in these instances always leads to an over-reporting situation which is not the intent of the diluent cap.

16. What’s going on now? • Draft XML Schema documents for MP, QA and emissions have been posted for review. • First round of MP test files posted • Answering questions/taking comment on the draft schema documents that have been posted, and making modifications as necessary

17. What’s going on now? • Continuing development of the ECMPS Client Tool • Developing reporting instructions structure • Beginning to develop ECMPS Client Tool testing schedule and test plan for stakeholders • Internal review of proposed rule changes

18. What’s Next! • Post first round of QA and Emissions test files (August – September) • Continue to respond to comments regarding the various XML schemas, and make modifications as necessary • Continue development of Client Tool and Reporting Instructions • Post plan and schedule for ECMPS Client Tool testing • Publish proposed rule and collect comments

19. More Information • Questions and comments about the ECMPS project? Contact me at (202) 343-9211 or boze.matthew@epa.gov • For more information regarding ECMPS, including the project overview, project schedule, technical information, ECMPS outreach and informational bulletins, go to: http://www.epa.gov/airmarkets/business/ecmps/index.html