Rob Barton RMB Consulting & Research, Inc. EPRI CEM …rmb-consulting.com/papers/MATSReporting.pdf · Rob Barton RMB Consulting & Research, Inc. EPRI CEM User Group Conference May

Rob Barton

RMB Consulting & Research, Inc.

EPRI CEM User Group Conference

May 8, 2013

� 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)


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


� 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


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


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


� 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


� 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


� 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


� Semi-Annual Compliance Report

� CEMS Summary Report

� Tune Up Report

� 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


� 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


� 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


� 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


� 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


� 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?


Documents

Rob Barton RMB Consulting & Research, Inc. EPRI CEM …rmb-consulting.com/papers/MATSReporting.pdf · Rob Barton RMB Consulting & Research, Inc. EPRI CEM User Group Conference May