Report to CEM Users Group

1. Report to CEM Users Group Columbus, Ohio May 3-5, 2006 Reynaldo Forte (Rey)

2. Clean Air Interstate Rule (CAIR) • Reduces sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions which contribute to fine particle pollution (PM2.5) and ground level ozone. • Provides substantial human health and environmental benefits – the largest benefits for any Clean Air Act rule in the last 10 years. • Helps cities and states in the East meet new, more stringent national ambient air quality standards for ozone and fine particles. • Emission reductions occur while economic strength is preserved. U.S. maintains both low electricity prices and fuel diversity. The most important step EPA can take now to improve air quality.

3. CAIR Health and Environmental Benefits: Benefits over 25 Times Greater than Costs • By 2015, CAIR will result in $85-100 billion in health benefits each year, preventing: • 17,000 premature deaths • 22,000 non-fatal heart attacks • 12,300 hospital admissions • 1.7 million lost work days • 500,000 lost school days. • Almost $2 billion in improved visibility benefits each year. • Other non-monetized benefits- reductions of mercury emissions, acid rain, nitrification, eutrophication, and more.

4. Clean Air Mercury Rule (CAMR) CAMR significantly cuts emissions of mercury from power plants and: • Builds on EPA’s Clean Air Interstate Rule (CAIR) to allow power industry to address mercury, SO2 and NOx emissions in a coordinated effort. • Along with CAIR, will help protect public health and the environment without interfering with the steady flow of affordable energy for American consumers and business. • Along with CAIR, is expected to make reductions in emissions that are transported regionally and deposited domestically, and it will reduce emissions that contribute to atmospheric mercury worldwide.

5. CAIR & CAMR Implementation • Represents the main focus for CAMD; most of our Division resources are going into the coordination and implementation of these rules with the Regions, States and sources • States in the CAIR region are embracing cap-and-trade CAIR, and more than halve of the states are embracing cap-and-trade CAMR • Part 75 Hg monitoring is expected whether States pursue cap-and-trade or other control strategy • Up coming implementation activities include: • Hg reporting as part of new re-engineered data systems • Development of XML EDR Instructions • Development of electronic audit for Hg (MDC equivalent) • Update of Field Audit Manual, Policy Manual, and other guidance • Development of workshop and training materials • Training of Regions, States, and sources

6. Mercury Monitoring - CAMR • Full commitment from EPA’s CAMD, OAQPS and ORD • Most of the Emissions Monitoring Branch is involved with the implementation of a successful mercury monitoring program • We continue to allocate our largest amount of resources to CEMS & sorbent trap field demonstrations, development of an instrumental reference method, and development of calibration gas standards • EPRI and others who represent your interest have stepped forward and made a big difference • The question is no longer whether CEMS or sorbent traps can measure mercury but how to reliably achieve this over time • Progress is happening and is significant, and despite the appearance of availability of plenty of time to solve remaining issues, challenges remain

7. Mercury Monitoring (cont’d) • Instrumental Reference Method • Strong join EPRI/EPA program • We are in the process of identifying test sites to test several candidate reference instruments • EPA has drafted and circulated a conceptual instrumental reference method • Planning for first test site in collaboration with Lehigh University, EPRI, and others • Calibration Gas Standards • Pursuing a strong join EPA/NIST program • We have just committed additional funding • Commerce Science Fellow from NIST on detail to CAMD

8. Revisions to Parts 72 and 75 • Main driver: Support or streamline reporting under the re-engineering of our data systems (ECMPS) • Revisions to clarify, simplify, modify or correct mistakes in existing requirements • Add PEMS to rule • Add stack testing certification requirement • Step vs. block approach for missing data substitution • Add some flexibility to the use of substitute data for controlled units • Revisions to strengthen and clarify Hg monitoring provisions • Add EPA Method 29 as an alternative to the OH

9. Emissions Data Auditing • We continue to strive for the highest level of data quality that can be reasonably achieved while being sensitive to potentially overburden the sources • We’ve just implemented the auditing of units that report under App. D & E of the rule • We’ve also developed software that allows us to identify certain suspicious data • We believe that this provides for a leveled playing field and results in more accurate data

10. Other Activities • Processing most petitions in less than 60 days (exceptions driven by complexity or certain petitions) • Review and approval of close to a dozen PEMS petitions • Development and publishing of the “Plain English Guide to Part 75” • Continue to work jointly with our Market Operations Branch in the re-engineering of our data systems

11. Part 60 vs. Part 75 Harmonization • On February 28, 2005, EPA proposed amendments to the SO2 , NOx , and PM emission limits in three NSPS boiler regulations---Subparts Da, Db and Dc. • As part of that rule package, the Agency also proposed revisions to: • Certain CEM provisions in Subparts D, Da, Db, and Dc; §60.13(h) of the NSPS General Provisions; and Appendices B and F of Part 60. • The purpose of these additional rule changes was to harmonize, to the extent possible, the CEM provisions of Parts 60 and 75, for sources subject to both sets of regulations.

12. Part 60 vs. Part 75 Harmonization (cont’d) • The proposed revisions would: • Make the method of calculating hourly emissions averages from CEMS data consistent between Parts 60 and 75 • Allow Part 75 span values to be used for Part 60 monitoring applications; • Allow the 7-day calibration drift test in Part 60 to be done on 7 consecutive unit operating days, rather than 7 consecutive calendar days • Allow the more stringent CEMS Quality Assurance provisions of Part 75, Appendix B to be substituted for the procedures in Part 60, Appendix F.

13. Part 60 vs. Part 75 Harmonization (cont’d) • Comments received on the proposed CEMS rule changes were generally supportive. • However, a number of adverse comments were received on the proposed revisions to the Subpart Da, Db and Dc emission limits. • Issues regarding the impact of the emission limits were also raised by the Office of Management and Budget (OMB) and the Department of Energy (DOE). • But EPA was under a court-ordered deadline to finalize the Subpart Da, Db, and Dc emission limits by February 9, 2006.

14. Part 60 vs. Part 75 Harmonization (cont’d) • Therefore, to meet the deadline, the Agency’s legal and technical staff focused exclusively on resolving the controversy over the Subpart Da, Db, and Dc emission limits • Consequently, there was insufficient time to properly review the CEMS amendments, and they were not included in the final rule that appeared in the FederalRegister on February 27, 2006. • However, EPA still intends to finalize the CEMS amendments as a separate rulemaking, hopefully within the next few months.

15. Part 60 vs. Part 75 Harmonization (cont’d) • Based on comments received and internal discussion and deliberation within the Agency during the rulemaking process, the final CEM rule revisions will likely differ somewhat from the proposal. • Despite this, EPA believes that the revisions will accomplish the intended purpose, which is to simplify and reduce the cost of compliance for sources currently subject to disparate and duplicative continuous monitoring requirements under Parts 60 and 75.

16. Closing Remarks • Promulgation of CAIR and CAMR represents an environmental milestone and brings new challenges and demands to our community • We are in the right path to achieving the necessary CAMR mercury monitoring capability but additional work remains • Upcoming rulemaking proposal should enable a stronger, more coherent monitoring program while facilitating the reengineering of the current data systems • EPA’s commitment to harmonize Part 60 and Part 75 CEM requirements remains strong • Transparent, complete, and accurate emissions data is the cornerstone of program success