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Report to CEM Users Group. Savannah, Georgia May 4, 2005 Reynaldo Forte (Rey). 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
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Report to CEM Users Group Savannah, Georgia May 4, 2005 Reynaldo Forte (Rey)
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
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
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
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
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
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
Sources Implemented Reliable and Accurate Monitoring 2004 NBP Monitor Quality Assurance Performance (Electric Generating vs Industrial Units)
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
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
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”
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
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
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
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
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