steve norfleet, pe rmb consulting & research, inc. · steve norfleet, pe rmb consulting &...

Steve Norfleet, PESteve Norfleet, PESteve Norfleet, PESteve Norfleet, PE

RMB Consulting & Research, Inc.RMB Consulting & Research, Inc.

Energy, Utility and Environmental ConferenceEnergy, Utility and Environmental Conference

Phoenix, Arizona Phoenix, Arizona -- February 3February 3--5, 20145, 2014

�� MATS Applies to Coal and OilMATS Applies to Coal and Oil--fired EGUs fired EGUs

�� Notification of Applicability was Due 8/14/12Notification of Applicability was Due 8/14/12

�� PM, Hg, and PM, Hg, and HClHCl (or SO(or SO22) Limits/Monitoring) Limits/Monitoring

�� Reporting Requirements:Reporting Requirements:

�� NotificationsNotifications�� NotificationsNotifications

�� Monitoring and QA PlansMonitoring and QA Plans

�� QA Test ResultsQA Test Results

�� Monitored EmissionsMonitored Emissions

�� Excess Emissions and Excess Emissions and

Deviation ReportsDeviation Reports

�� MATS Rule and Part 63 General ProvisionsMATS Rule and Part 63 General Provisions

RMB Consulting & Research, Inc.RMB Consulting & Research, Inc.Providing Environmental Services to Industry

�� Must Qualify Using CEMS or Test DataMust Qualify Using CEMS or Test Data

�� Same Subcategory and Same FacilitySame Subcategory and Same Facility

Due: 120 days before 4/16/15Due: 120 days before 4/16/15(submittal upon requested)(submittal upon requested)

§§ 63.10009(f)63.10009(f)

�� Same Subcategory and Same FacilitySame Subcategory and Same Facility

�� Same Basis for Group (lb/MMBtu or lb/MW)Same Basis for Group (lb/MMBtu or lb/MW)

�� Allow Units that “OverAllow Units that “Over--Controlled” to Controlled” to Compensate for “UnderCompensate for “Under--Controlled” UnitsControlled” Units

�� Deadline Does Not Seems to Allow Later Deadline Does Not Seems to Allow Later Choice of this Option Choice of this Option


�� Differs from Part 75 Monitoring PlanDiffers from Part 75 Monitoring Plan

Due: 60 Days before Initial Due: 60 Days before Initial Performance Evaluation Performance Evaluation (submittal upon requested)(submittal upon requested)

§§ 63.10000(d)(1)63.10000(d)(1)

�� Differs from Part 75 Monitoring PlanDiffers from Part 75 Monitoring Plan

�� Sampling Location & Control DevicesSampling Location & Control Devices

�� Performance Specifications & SchedulePerformance Specifications & Schedule

�� QA, Operation and Maintenance ProceduresQA, Operation and Maintenance Procedures

�� RecordRecord--Keeping and Reporting ProceduresKeeping and Reporting Procedures

�� Compliance Between Performance TestsCompliance Between Performance Tests


Due: 60 days before Due: 60 days before performance testperformance test

§§ 63.7(b)63.7(b)

�� Initial and Ongoing Performance TestsInitial and Ongoing Performance Tests


Due: 60 days beforeDue: 60 days beforeperformance evaluationperformance evaluation

§§ 63.8(e)(2)63.8(e)(2)

�� Initial Certification, RATAs, RCAs, RRAsInitial Certification, RATAs, RCAs, RRAs

�� PM CEMS, Hg CEMS and HCl CEMSPM CEMS, Hg CEMS and HCl CEMS

Due: No SpecificDue: No Specific -- Before Before certificationcertification

e.g., e.g., §§5.4.3.2, App 5.4.3.2, App A for Hg sorbent A for Hg sorbent trap systemstrap systems

�� “Step“Step--byby--Step” Procedures for QA/QC and Step” Procedures for QA/QC and Preventive MaintenancePreventive Maintenance

�� Data Recording, Calculations, and ReportingData Recording, Calculations, and Reporting

�� Corrective Action Program for MalfunctionsCorrective Action Program for Malfunctions

�� For Hg CEMS, Must Detail Ongoing Procedures For Hg CEMS, Must Detail Ongoing Procedures to Maintain Calibrator NISTto Maintain Calibrator NIST--TraceabilityTraceability


�� Test Program SummaryTest Program Summary

Due: 60 calendar days before Due: 60 calendar days before performance test performance test (submittal upon request)(submittal upon request)

§§ 63.7(b) and (c)63.7(b) and (c)

�� Test Program SummaryTest Program Summary

�� Test ScheduleTest Schedule

�� Data Quality ObjectivesData Quality Objectives

�� Internal & External QA ProgramsInternal & External QA Programs

�� Assessment of Test Data PrecisionAssessment of Test Data Precision

�� Include Blind Audit Samples (When Available)Include Blind Audit Samples (When Available)


Due: 60 days prior to Due: 60 days prior to scheduled performance scheduled performance evaluationevaluation(submittal upon request)(submittal upon request)

§§ 63.8(e)(3)63.8(e)(3)

�� SiteSite--Specific Performance Evaluation Plans forSpecific Performance Evaluation Plans for

Certification Tests, RATAs, RCAs, RRAsCertification Tests, RATAs, RCAs, RRAs

�� Program Summary & ScheduleProgram Summary & Schedule

�� Data Quality ObjectivesData Quality Objectives

�� Internal and External QA program DetailsInternal and External QA program Details


�� Source/Controls/Fuels DescriptionSource/Controls/Fuels Description

Due: 60 days after completion Due: 60 days after completion of performance test and/or of performance test and/or compliance demonstrationcompliance demonstration

§§ 63.9(h)63.9(h)§§ 63.9,63.10030(e)63.9,63.10030(e)§§ 63.10031(f)(4)63.10031(f)(4)

�� Source/Controls/Fuels DescriptionSource/Controls/Fuels Description

�� Performance Tests Results SummaryPerformance Tests Results Summary

�� Methods Used to Determine ComplianceMethods Used to Determine Compliance

�� Summary of Deviations /Summary of Deviations / “Operational “Operational changes...that could increase emissions"changes...that could increase emissions"

�� Certifications Signed by “Responsible Official”Certifications Signed by “Responsible Official”


�� Submitted via ERT/CEDRISubmitted via ERT/CEDRI

Due: 60 days after the date of Due: 60 days after the date of completing each performance completing each performance test or evaluationtest or evaluation

§§ 63.10031(f)63.10031(f)

�� Submitted via ERT/CEDRISubmitted via ERT/CEDRI

�� Performance Tests, RATA, RCA and RRA dataPerformance Tests, RATA, RCA and RRA data

�� Duplicative Reporting (RATAs also Reported Duplicative Reporting (RATAs also Reported Using ECMPS)Using ECMPS)

�� ERT ERT -- Problematic Format and Unnecessary Problematic Format and Unnecessary Level of DetailLevel of Detail


�� Electronic Report Submitted via CEDRIElectronic Report Submitted via CEDRI

�� Source and Monitoring IdentificationSource and Monitoring Identification

Due: Every 7/31 or 1/31Due: Every 7/31 or 1/31FirstFirst Report: Report: 1/31/161/31/16

§§ 63.10031(a)(1)63.10031(a)(1)

�� Source and Monitoring IdentificationSource and Monitoring Identification

�� Emission Limitations (lb/MMBtu or lb/MW)Emission Limitations (lb/MMBtu or lb/MW)

�� QA/QC and Operating SummaryQA/QC and Operating Summary

�� Date of Recent and Next Scheduled TuneDate of Recent and Next Scheduled Tune--upup

�� Excess Emissions/Monitoring Downtime Excess Emissions/Monitoring Downtime

�� Duration/Reason and Action CodesDuration/Reason and Action Codes

�� Report for Each ParameterReport for Each ParameterRMB Consulting & Research, Inc.RMB Consulting & Research, Inc.

Providing Environmental Services to Industry

�� SOSO22, Hg and HCl CEMS or Sorbent Trap Data , Hg and HCl CEMS or Sorbent Trap Data Reported via ECMPSReported via ECMPS

Due: 30 Days after the End of Due: 30 Days after the End of each Quartereach Quarter

§§ 63.10031(f)63.10031(f)

Reported via ECMPSReported via ECMPS

�� Draft MATS ECMPS Reporting Instructions Draft MATS ECMPS Reporting Instructions and XML Schemasand XML Schemas

�� Initial Drafts Initial Drafts –– April 2013April 2013

�� Reporting Instruction Revisions 12/13 and 1/14Reporting Instruction Revisions 12/13 and 1/14

�� Sorbent Traps Transitions / Optional RecordsSorbent Traps Transitions / Optional Records

�� Upcoming Webinar Upcoming Webinar –– 2/6/142/6/14


�� All Data All Data –– Including Startup/ShutdownIncluding Startup/Shutdown

�� Hourly (lb/MMBtu or lb/MWh)Hourly (lb/MMBtu or lb/MWh)

�� Auxiliary Parameters (e.g., Diluent, Moisture)Auxiliary Parameters (e.g., Diluent, Moisture)

�� Currently No Diluent Cap Except for HgCurrently No Diluent Cap Except for Hg

�� BAF and Missing Data Do Not ApplyBAF and Missing Data Do Not Apply�� BAF and Missing Data Do Not ApplyBAF and Missing Data Do Not Apply

�� QA/QC Including Weekly Integrity ChecksQA/QC Including Weekly Integrity Checks

�� Hourly Gas Flow Meter Records for Each Trap Hourly Gas Flow Meter Records for Each Trap Sorbent Trap Monitoring System Documenting Sorbent Trap Monitoring System Documenting Sample/Stack Flow RatioSample/Stack Flow Ratio

�� HCl QA Still Not Well Defined in DraftsHCl QA Still Not Well Defined in Drafts


�� Reporting Emissions (PM CEMS/CPMS)Reporting Emissions (PM CEMS/CPMS)

�� 3030--boiler Operating Day Rolling Average values boiler Operating Day Rolling Average values derived from PM CMS or PM CPMSderived from PM CMS or PM CPMS

�� Submit within 60 days Following Each QuarterSubmit within 60 days Following Each Quarter

�� Utilize CEDRI or Other Approved Electronic FormatUtilize CEDRI or Other Approved Electronic Format�� Utilize CEDRI or Other Approved Electronic FormatUtilize CEDRI or Other Approved Electronic Format

�� No No Hourly Hourly DData Submittal (Currently)ata Submittal (Currently)

�� DiluentDiluent Cap Not Permitted (Currently)Cap Not Permitted (Currently)

�� CEDRI Forms Not Yet Available for PM DataCEDRI Forms Not Yet Available for PM Data


�� MATS Introduces Many New Reporting and MATS Introduces Many New Reporting and Recordkeeping RequirementsRecordkeeping Requirements

�� Documentation of Compliance ActivitiesDocumentation of Compliance Activities

�� Electronic Reporting Applied to Compliance Electronic Reporting Applied to Compliance Data and New EmissionsData and New EmissionsData and New EmissionsData and New Emissions

�� EPA Behind with Reporting Details EPA Behind with Reporting Details

�� ERT Problematic ERT Problematic –– Alternative Reporting Alternative Reporting NeededNeeded

�� Startup/Shutdown Reconsideration IssuesStartup/Shutdown Reconsideration Issues

�� Electronic Reporting Changes PossibleElectronic Reporting Changes PossibleRMB Consulting & Research, Inc.RMB Consulting & Research, Inc.

Providing Environmental Services to Industry

steve norfleet, pe rmb consulting & research, inc. · steve norfleet, pe rmb consulting &...

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