Post on 10-Jun-2018
transcript
� Unique Reporting Challenges
� Compilation of various reporting requirements
� Electronic submittal of most data/records
� Adapting existing tools to new types of data
� Reporting Elements
� Emissions Data
� Initial/Ongoing QA Test Results
� Compliance Reports
� Other (Notifications/Monitoring Plan)
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
Still Significant Uncertainty in Reporting Requirements
� Emissions Collection and Monitoring Plan System Client Tool (ECMPS)
� Acid Rain Program/Clean Air Interstate Rule
� Electronic Reporting Tool (ERT)
� MATS Information Collection Request (ICR)
� Compliance and Emissions Data Reporting Interface (CEDRI)
� Legacy system accessed through EPA Central Data Exchange (CDX) website (cdx.epa.gov)
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
None of these Tools Fully Support MATS at this Time
� Compliance Based on 30-Boiler Operating Day (BOD) Rolling Averages
� BOD = any fuel combusted in any 24-hour period
� Calculated at the end of each BOD
� Based on all available quality assured hourly data
� No Missing Data Substitution
� No Bias Adjustment Factors
� Exclude Startup/Shutdown Periods
� Quarterly Data Reporting
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� PM CEMS/CPMS
� 30-BOD averages only
� Submit all PM data through CEDRI
� Electronic form/template for data submittal
� Deadline - 60 days after the end of the quarter
� All other CEMS/Hg Sorbent Trap Systems
� Hourly data only
� Submit data using ECMPS
� Deadline - 30 days after the end of the quarter
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
Submittal Process/Deadlines for Initial Compliance Data is Unclear
� Initial Certification/Ongoing QA Activities
� All Data Submitted Using CEDRI
� Deadline - 60 days after completion of each test
� Daily Calibration Records
� Standardized form?
� All Other QA Data
� Emissions Reporting Tool (ERT)/CEDRI
� ERT does not currently support PS-11 or Procedure 2
� Likely a Time Consuming Process
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
PM CPMS Quality Assurance Data/Records are Retained Onsite
� Initial Certification/Ongoing QA Activities
� All Data Submitted Using ECMPS
� Deadline – Prior to/concurrent with quarterly report
� SO2/CO2/O2/Flow Data Already Submitted*
� HCl/HF/Hg CEMS/Sorbent Trap Systems
� New/modified ECMPS records
� RATA Data Submitted Using ERT/CEDRI
� Deadline – 60 days after completion of testing
� Method 30B not supported by ERT
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� ECMPS/CEDRI/ERT Do Not Fully Support MATS
� Work in progress – ECMPS Draft (4/2013)
� DAHS vendors need time to implement changes
� PM CEMS Issues
� Conditionally valid data procedures
� Diluent cap
� Startup Data Exclusion
� SUSD definition not tied to control device operation
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Quarterly Stack Testing for HCl/HF/PM/TSM
� Submit using ERT/CEDRI
� Reference Methods 5, 26, 26A and 29 are supported
� ERT-compatible templates for raw data
� Unit/control device operating data
� Deadline - 60 days after completion of testing
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� HCl/HF/PM/TSM
� Same procedures as quarterly testing
� Notification of Compliance Status
� Dates of last 3 tests, results, no changes in operation
� Hg (annual)
� Reporting requirements are unclear
� Summary included in ECMPS monitoring plan records
� Detailed test results submitted through CEDRI
� ERT does not support Method 30B
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Contents
� CEMS Summary Report
� Total fuel use per calendar month
� Description of fuels/justification as non-waste
� Dates of most recent tune-up/burner inspection
� Description of excess emissions
� Breakdown of malfunction periods
� Statements of compliance with work practice standards or emissions limitations
� Report Submitted through CEDRI
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Initial Reporting Period
� Begins on compliance date and ends June 30 or December 31 (whichever first occurs after 180 days)
� Existing units:
� April 16, 2015* – December 31, 2015 (due January 31, 2016)
� Ongoing Reporting Period
� January 1 – June 30 (due July 31)
� July 1 – December 31 (due January 31)
� Title V Report Could Satisfy Requirements
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Contents
� General unit/CEMS information
� Date of latest CEMS certification or audit
� Total operating time
� Breakdown of excess emissions
� Breakdown of monitor downtime
� Changes in CEMS, process, or controls
� Much of the Content is Redundant
� Submit with Semi-Annual Compliance Report
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Contents
� CO/NOx concentrations before and after tune-up
� Correction action taken as part of tune-up
� Types and amounts of fuel used over the 12 calendar months prior to tune-up (multi-fuel units only)
� Information necessary to demonstrate that all tune-up activities were conducted
� Submittal Requirements
� Date of initial/next scheduled tune-up
� Notification of Compliance Status/Semi-Annual Report
� Submittal of tune-up report is unclear
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� Site-Specific Monitoring Plan
� Differences in Part 63/Part 75 terminology
� Part 60/75 CEMS Exempt
� Submit 60 days prior to certification (if requested)
� Submit within 21 days of compliance date for Hg CEMS/sorbent trap and HCl/HF CEMS using ECMPS
� Existing units - March 26, 2015
� Notifications
� Compliance status, performance tests, QA tests
� Deadlines may conflict with Title V requirements
RMB Consulting & Research, Inc.Providing Environmental Services to Industry
� MATS Reporting is a Work in Progress
� Reporting tool updates
� PM data requirements
� Inconsistencies on other requirements
� Timely Guidance Needed to Implement Solutions for Vendors/Utilities
� Other Issues Likely to Be Identified
� Further Rule Revisions?
� MATS Policy Manual?
RMB Consulting & Research, Inc.Providing Environmental Services to Industry