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Emissions Collection and Monitoring Plan System Timeline and Regulatory Update

Emissions Collection and Monitoring Plan System Timeline and Regulatory Update. Stakeholder Meeting May 2, 2005 Matthew Boze, EPA. Adjusted Timeline. Proposed modified timeline 2005 - Spring 2006: Continue initial development of the ECMPS client tool;

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Emissions Collection and Monitoring Plan System Timeline and Regulatory Update

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  1. Emissions Collection and Monitoring Plan System Timeline and Regulatory Update Stakeholder Meeting May 2, 2005 Matthew Boze, EPA

  2. Adjusted Timeline • Proposed modified timeline • 2005 - Spring 2006: Continue initial development of the ECMPS client tool; • Fall/Winter 2005: Limited alpha testing of web services, queuing, and check engine functionality; • Mid 2006 - 2007: First user beta-testing in parallel to the current ETS-FTP process; • 2007: Early opt-in to ECMPS process as the official submission allowed; • 2008: Official release of the Client Tool and start of ECMPS transition period; • 2009: All sources must submit using ECMPS Client Tool

  3. Details about New Timeline • Sources who wish to opt-in to using the ECMPS process as the official submission rather than the current ETS-FTP process in 2007 (considered a testing year) will need to notify CAMD. • Note that EPA will need for all of the data used for compliance for a given year (or season) to have been submitted using either the ETS-FTP process or the new ECMPS Client Tool process and will not be able to support annual reconciliation for a mixed set of submissions. (This applies to 2007 and 2008.) • Sources who wish to transition mid-year may do so, but will need to resubmit prior quarterly data through the new process.

  4. Regulatory Highlights • Allow sources who designate themselves in “long term cold storage” to suspend quarterly emissions reporting until they resume operating. • Notice requirements would be added to §75.6. • Incorporate EPA’s new policy on the application of substitute data (PQ15.5) • PMA required for all hours (including missing data periods). • PMA for each hour determines appropriate substitute data value for each individual hour.

  5. Regulatory Highlights • Add to Appendix F, Equations N-1 and N-2 for calculating NOx Mass Rate (lb/hr) by creating F-26a and F-26b. (F-26 becomes F-26c) • Adopt moisture default values for natural gas. • Remove requirement that Monitoring Plan be submitted with every quarterly emissions report. • Monitoring plan updates will be submitted prior to or concurrent with the quarterly report.

  6. Regulatory Highlights • Revise §75.53 • Current Monitoring Plan requirements of paragraphs (e) and (f) effective through the 2008 transition period; expire in 2009. • New proposed requirements in paragraphs (g) and (h) to become effective in 2007 for sources who “opt-in” to the new process early. • In 2009 paragraphs only the new requirements in proposed paragraphs (g) and (h) will be applicable.

  7. Monitoring Plan Content Revisions • Monitoring methods are to be identified on a monitoring location basis, rather than being based on the unit. • Identify the bypass approach within the primary monitoring location information, • Rather than listing a separate monitoring method for a given parameter for bypass situations; • Only one monitoring methodology per parameter needed.

  8. Monitoring Plan Content Revisions • Revised monitoring plan format will NOT include: • Facility Short Name; • Unit Program Classification; • Unit Boiler Type; • Date of Commence Operation (SUB H); • Date of First Commence Commercial Operation (ARP); • Unit Retirement Date; Program Code; • Reporting Frequency; Program Participation Date; • State Regulation Code; State of Local Agency Code; • All EIA Cross Reference Information.

  9. Monitoring Plan Content Revisions • Removed data will be collected and maintained by the: • Certificate of Representation form; • Account Certificate of Representation form; and • CAMD Business System. • Reporting requirements for each monitoring system re-certification, maintenance, or other events (RT556) is being moved from the monitoring plan structure to an appropriate quality assurance portion of rule (§75.59)

  10. Monitoring Plan Content Revisions • The following data requirements are being removed: • Fuel Classification for Boiler; • Primary/Secondary control indicator; • Type of fuel associated with each monitoring methodology; • Primary/Secondary methodology indicator; and • Appendix E NOx Correlation Curve Segment Data.

  11. Monitoring Plan Content Revisions • These following requirements will be revised as follows: • Component Status: replaced with Component Activation and Deactivation date/hour to better track the updates to monitoring components; • Formula Status: replaced with Formula Activation and Deactivation date/hour to track formula updates; • Submission Status of Fuel Flowmeter: replaced with Activation and Deactivation date/hour as appropriate.

  12. Monitoring Plan Content Revisions • New monitoring plan data requirements will include: • For dual range monitoring components, the value at which the component switches from the normal to the secondary scale (usually low to high); • Indicator for non-load based units; • Indicator of exemption from 3-load flow RATA requirement; • For each monitoring location, a stack/duct shape code, material code, and duct indicator.

  13. Monitoring Plan Content Revisions • The monitoring component type code will be simplified into the following three codes: • Component type code (CO2, SO2, NOx, etc.); • Analyzer range code (H, L, A); • Moisture measurement basis code (wet or dry).

  14. Other Issues - Optional Records • We would especially like feedback on the following “other” issues: • We are proposing to not collect the following optional data in the new XML reporting format: • Total SO2 mass emissions for the hour (current RT305, column 35); • Total CO2 mass emissions for the hour (current RT330, Column 33); • NOX mass emission rate during unit operation (current RT328, Column 22); • Do sources still want/need RT550 to report reasons for monitoring system downtime?

  15. Other Issues • Change the Total NOX mass emissions for the hour (lb) (current RT328, Column 32) to a Hourly NOX mass emission rate (lb/hr) to be consistent with the reporting requirements for SO2 and CO2. • Report the Diluent Cap value in the data stream • Simplifies the reporting and calculations when diluent cap is used; • Would require that when the cap value is used, it be used for all calculations in that hour.

  16. More Information • Questions and comments about the ECMPS project? Contact me at (202) 343-9211 or boze.matthew@epa.gov • For more information regarding ECMPS, including the project overview, project schedule, technical information, ECMPS outreach and informational bulletins, go to: http://www.epa.gov/airmarkets/business/ecmps/index.html

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