Report to CEM Users Group by cja13487


									Report to CEM Users Group

      Columbus, Ohio
      May 3-5, 2006
      Reynaldo Forte (Rey)
      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
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,
   • 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.
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.
    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
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
    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
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
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
Other Activities
   Processing most petitions in less than 60 days
    (exceptions driven by complexity or certain
   Review and approval of close to a dozen PEMS
   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
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
Part 60 vs. Part 75 Harmonization
   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.
Part 60 vs. Part 75 Harmonization
   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.
Part 60 vs. Part 75 Harmonization
   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
   Consequently, there was insufficient time to properly
    review the CEMS amendments, and they were not
    included in the final rule that appeared in the Federal
    Register on February 27, 2006.
   However, EPA still intends to finalize the CEMS
    amendments as a separate rulemaking, hopefully within
    the next few months.
Part 60 vs. Part 75 Harmonization
   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.
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

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