Emissions Collection and Monitoring Plan System Timeline and Regulatory Update

1
Emissions Collection and Monitoring Plan
System Timeline and Regulatory Update

• VIM Technologies Workshop
• July 20, 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
Rule Changes

• Part 75 rule changes are in the final stages of
  being drafted
• Will next go through internal reviews
• Publication of the proposed rule change should be
  made this fall (November)
• Goal is to have final rule changes published by
  October 2006 so that the reporting changes may be
  used in 2007

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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 EPAs 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.

6
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.

7
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.

8
Regulatory Highlights

• Only minor edits were made to the reporting
  sections of 75.57 through 75.59
• General and certification, QA/QC record keeping
  provisions
• Many changes were fixing current errors
• Other changes support changes to how the data
  will be collected in ECMPS
• Example, Only a Component ID will be required for
  linearity, so the requirement for System ID is
  phased out.

9
Regulatory Highlights

• Modifications to 75.64 Quarterly Reports
• Modified 75.64(a) to incorporate language that
  will allow for the transition from the current
  requirements of paragraphs (a)(1), (a)(2) and
  (a)(8) through (a)(15) to the new requirements of
  (a)(3) through (a)(15).
• (a)(1) and (a)(2) of the current rule are being
  replaced by (a)(3) through (a)(7) which better
  describe the planned separation of the monitoring
  plan and QA test information from the quarterly
  emissions report.
• Current rule paragraphs (a)(3) through (a)(11)
  were renumbered as (a)(8) through (a)(15) as
  appropriate.

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Examples of Monitoring Plan Revisions Include

• 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.

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Examples of Monitoring Plan Revisions Include

• 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.

12
Examples of Monitoring Plan Revisions Include

• 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.

13
Examples of Monitoring Plan Revisions Include

• 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.

14
Examples of Monitoring Plan Revisions Include

• 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.

15
Diluent Cap Change

• Remove provisions for applying the diluent cap to
  any calculation except for Nox Emission Rate.
• The original purpose for implementing the diluent
  cap was to keep calculated Nox emission rates
  from approaching infinity as the diluent value
  approached a value representative of zero heat
  input.
• Allowing the use of diluent cap values for HI,
  calculated CO2 concentration from O2 measurement,
  and CO2 mass complicates the data collection
  process, especially since the use is optional for
  different calculation.
• Furthermore, application of the diluent cap in
  these instances always leads to an over-reporting
  situation which is not the intent of the diluent
  cap.

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Whats going on now?

• Draft XML Schema documents for MP and QA have
  been posted for review.
• XML Schema for quarterly emissions data to be
  posted soon
• First round of MP test files posted
• Answering questions/taking comment on the draft
  schema documents that have been posted, and
  making modifications as necessary

17
Whats going on now?

• Continuing development of the ECMPS Client Tool
• Developing reporting instructions structure
• Beginning to develop ECMPS Client Tool testing
  schedule and test plan for stakeholders
• Internal review of proposed rule changes

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Whats Next!

• Draft XML Schema documents for emissions data to
  be posted soon (late July-early August)
• Post first round of QA and Emissions test files
  (August September)
• Continue to respond to comments regarding the
  various XML schemas, and make modifications as
  necessary
• Continue development of Client Tool and Reporting
  Instructions
• Post plan and schedule for ECMPS Client Tool
  testing
• Publish proposed rule and collect comments

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More Information

• Questions and comments about the ECMPS project?
  Contact me at [phone] or
  boze.matthew_at_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/inde
  x.html