ECMPS Reporting Requirements under the MATS Rule Stakeholder Meeting---Raleigh, NC May 2013 Charles Frushour USEPA, CAMD

Background On February 16, 2012, EPA published the Mercury and Air Toxics Standards (MATS) rule (40 CFR 63, Subpart UUUUU), establishing national emissions limitations and work practice standards for certain hazardous air pollutants (HAPs) emitted from coal-fired and oil-fired electric utility steam generating units. Compliance with the rule is required: For existing units---by April 16, 2015 (see §63.9984(b)). For new or reconstructed units**---by April 16, 2012 or upon startup (first-fire), whichever is later (see §63.9984(a)). Compliance must be demonstrated, by means of performance testing (using EPA stack test methods or continuous monitoring systems), no later than 180 days after the above dates (see §63.9984(f)). _______________ ** That is, units that commence construction or reconstruction after May 3, 2011 (see §63.9985).

Background (cont’d) For existing units, Table 2 of the rule specifies both heat input-based emission limits (lb/mmBtu or lb/TBtu) and electrical output-based limits (lb/MWh or lb/GWh) for all regulated pollutants. For new units, all of the emission limits in Table 1 of the rule are electrical output-based. Affected EGUs that are required to (or elect to) demonstrate compliance by continuously monitoring Hg, SO2 , HCl, or HF emissions must report emissions data electronically using EPA’s Emissions Collection and Monitoring Plan System (ECMPS). EPA has incorporated draft MATS ECMPS reporting instructions for these EGUs, covering three areas: (1) Monitoring Plans; (2) Quality Assurance and Certification Tests; and (3) Emissions.

Mercury Compliance Options Existing coal-fired (or petroleum coke-fired) EGUs may attempt to qualify as Low-Emitting EGUs (LEEs). This compliance option is described in §63.10005(h). It is not available for new EGUs; and It may not be used for existing coal-fired EGUs with acid gas scrubbers, if the exhaust configuration consists of a main stack and bypass stack. To obtain Hg LEE status for an existing EGU (or a group of EGUs that share a common stack), a 30 boiler operating day performance test using EPA Method 30B is required. The test results must show that the average Hg emissions are less than 10 percent of the applicable limit in Table 2 (expressed in either lb/TBtu or lb/GWh), or that the potential Hg mass emissions are less than 29.0 lbs per year** (see §63.10005(h)(3)(iii)(C)). __________________ ** For common stack configurations, if testing is done at the common stack, the potential annual Hg mass emissions must not exceed 29.0 lb times the number of units that share the stack.

Mercury Compliance Options (cont’d) To maintain LEE status, the 30 boiler operating day performance test must be repeated annually. The owner or operator must identify qualifying coal- or petroleum coke-fired LEEs in the electronic monitoring plan by including “Monitoring Method Data” and “Monitoring Qualification Data “ records. For each 30 boiler operating day performance test, a detailed report that includes the raw data, calculations, and summarized test results must be submitted to EPA’s WebFIRE database, within 60 days after completing the test (see §63.10031(f)). If the results of an annual performance test show that the unit (or group of units) no longer qualifies for LEE status, the owner or operator must install and certify a Hg CEMS or sorbent trap monitoring system within 6 months (see §63.10006(b)(2)).

Mercury Compliance Options (cont’d) All existing coal- or petroleum coke-fired EGUs that do not qualify as LEEs, and all new coal- or petroleum coke-fired units, must continuously monitor Hg emissions using Hg CEMS or sorbent trap monitoring systems (see §63.10000(c)(1)(vi)). The Hg monitoring provisions are found in Appendix A of the MATS rule. New EGUs must comply with an electrical output-based Hg emission limit (lb/GWh). Existing EGUs have the option of complying with a heat input-based Hg emission limit (lb/TBtu) or an electrical output-based limit. Compliance with the applicable Hg emission limit will be assessed on a 30 boiler operating day rolling average basis.** Depending on the Hg monitoring method selected and the standard that is to be met, certain auxiliary parameters must be monitored to convert hourly Hg concentrations from µg/scm to units of the standard. For the lb/TBtu standard, the diluent gas (CO2 or O2) concentration and (in some cases) the stack gas moisture content must be monitored (see Appendix A, section 6.2.1). ** If emissions averaging is used, compliance is determined on a 90 boiler operating day basis (see §63.10009). __________________

Mercury Compliance Options (cont’d) For the lb/GWh standard, the stack gas flow rate, electrical output (MW), and (in some cases) the stack gas moisture content must be monitored (see Appendix A, section 6.2.2). All auxiliary monitoring systems must be installed, certified, maintained, and operated according to 40 CFR Part 75. Liquid oil-fired EGUs have the following compliance options for Hg: The owner or operator may install, certify, operate, and maintain Hg CEMS or sorbent trap monitoring systems; or Performance testing may be conducted to determine whether the EGU qualifies as a LEE, either for Hg individually, for total HAP metals (including Hg), or for total filterable PM, as a surrogate for total HAP metals (including Hg). To qualify as a LEE for Hg individually, a 30 boiler operating day performance test using Method 30B must be conducted initially and then repeated annually to retain LEE status. If an annual performance test shows that Hg LEE status has been lost, the owner or operator must install and certify a Hg CEMS or sorbent trap monitoring system within 6 months. If the continuous emission monitoring and LEE compliance options are not implemented, quarterly stack testing is required (see §63.10000(c)(2)).

Mercury Monitoring Plan For each affected unit or common stack at which Hg emissions are continuously monitored, the owner or operator must prepare and maintain a monitoring plan (see Appendix A, section 7.1.1). The monitoring plan consists of an electronic portion and a hardcopy portion. For Hg monitoring systems, the electronic portion must include the information specified in section 7.1.1.2 .1of Appendix A . For auxiliary monitoring systems (stack gas flow rate, diluent gas concentration, and stack gas moisture), the electronic portion must include the applicable information in §75.53(g)(1) . The hardcopy portion includes schematics, blueprints, test protocols, data flow diagrams, span and range calculations, and miscellaneous technical justifications (see section 7.1.1.2.2 of Appendix A and §75.53(g)(2)) .

Mercury Monitoring Plan The electronic monitoring plan information pertaining to the Hg monitoring systems and the auxiliary system(s)** must be submitted to CAMD at least 21 days prior to the applicable compliance date in §63.9984(a) or (b). Use the ECMPS Client Tool to submit the electronic portion of the monitoring plan. All hardcopy portions of the monitoring plan shall be kept on record in accordance with section 7.1 of Appendix A ** Note: The electronic and hardcopy monitoring plan information for the auxiliary monitoring systems may have been previously submitted to satisfy the requirements of the Acid Rain Program, CAIR, or RGGI. If so, no additional monitoring plan submittals are required for these systems. _________________

Certification Test Requirements for Hg and Auxiliary Monitoring Systems All Hg CEMS, sorbent trap monitoring systems and auxiliary monitoring systems that will provide data under the MATS rule must be initially certified. The certification test requirements for Hg monitoring systems are found in section 4.1 of Appendix A. For a Hg CEMS, the required certification tests include: a 7-day calibration error test, a linearity check using elemental Hg standards, a 3-level system integrity check using oxidized Hg standards (if the CEMS has a converter), a cycle time test (except for CEMS that use integrated batch sampling), and a RATA. For a sorbent trap monitoring system, only a RATA is required; however, the monitoring system must be continuously operated and maintained according to Performance Specification 12B in 40 CFR Part 60, Appendix B. The performance specifications for initial certification of Hg CEMS are found in Table A-1 of Appendix A. These specifications are identical to the ones that were originally developed for the Clean Air Mercury Regulation (CAMR).** The RATA performance specifications for sorbent trap monitoring systems are the same as those for Hg CEMS. _____________________ ** The CAMR rule was vacated by the DC Court of Appeals in 2008.

Certification Test Requirements for Hg and Auxiliary Monitoring Systems (cont’d) The auxiliary monitoring systems (flow rate, diluent gas, and moisture, as applicable) that are used to convert Hg concentrations from µg/scm to units of the emission standard must be certified in accordance with Part 75, Appendix A and §75.20. Auxiliary monitoring systems that have been previously certified according to Part 75 for the Acid Rain Program, CAIR , and/or RGGI do not have to be recertified for the MATS rule, provided that the systems are continuing to meet the quality-assurance test requirements of Part 75, Appendix B. The results of all required certification tests must be submitted electronically to CAMD, using the ECMPS Client Tool. The results of auxiliary monitoring system certification tests that were previously submitted to meet Acid Rain Program, CAIR or RGGI requirements do not have to be resubmitted.

QA Test Requirements for Hg and Auxiliary Monitoring Systems All Hg monitoring systems and auxiliary monitoring systems that will provide data under the MATS rule must undergo periodic on-going quality-assurance (QA) testing. The QA test requirements for Hg monitoring systems are found in Appendix A, sections 5.1 (for Hg CEMS) and 5.2 (for sorbent trap monitoring systems). For Hg CEMS, daily calibration error tests, weekly single-level system integrity checks (for CEMS with converters), quarterly linearity checks (or 3-level system integrity checks), and annual RATAs are required. For sorbent trap monitoring systems, annual RATAs are required. The monitoring systems must also continue to be operated and maintained according to Performance Specification 12B. The performance specifications for the required QA tests of Hg CEMS are found in Table A-2 of Appendix A. These specifications are identical to the ones that were originally developed for the Clean Air Mercury Regulation (CAMR).

QA Test Requirements for Hg and Auxiliary Monitoring Systems (cont’d) Sorbent trap monitoring systems must continue to meet the QA specifications in Table 12B-1 of Performance Specification 12B. The RATA performance specifications for sorbent trap monitoring systems are the same as those for Hg CEMS. The auxiliary monitoring systems (flow rate, diluent gas, and moisture, as applicable) that are used to convert Hg concentrations from µg/scm to units of the emission standard must meet the applicable QA test requirements and performance criteria in Part 75, Appendix B. Grace periods are available for the linearity checks, 3-level system integrity checks and RATAs of Hg CEMS and for RATAs of sorbent trap systems. The grace period is 168 operating hours for linearity checks and 3-level system integrity checks, and 720 operating hours for RATAs (see section 5.1.3 of Appendix A). There is no grace period for weekly system integrity checks. Use of conditional data validation is allowed for certification, recertification and diagnostic testing of Hg CEMS (see section 5.1.5 of Appendix A).

QA Test Requirements for Hg and Auxiliary Monitoring Systems (cont’d) The results of all required QA tests of the Hg monitoring systems and auxiliary monitoring systems must be submitted electronically to CAMD using the ECMPS Client Tool. Except for daily QA tests and weekly system integrity checks, the test results must be submitted either prior to or concurrent with the relevant quarterly electronic emissions report. The results of daily QA tests and weekly system integrity checks must be submitted in the relevant quarterly electronic emissions report. Detailed RATA reports must also be submitted to the WebFIRE database.

Hg Performance Test Requirements for Units Using CMS If you are required to (or elect to) demonstrate initial compliance with the applicable Hg emissions limit using continuous monitoring systems (CMS), i.e., Hg CEMS or sorbent trap monitoring systems, a performance test is required. A Notification of Intent to conduct the performance test must be submitted at least 30 days before the performance test is scheduled to begin (see §63.10030(d)). The performance test consists of 30 boiler operating days@ of quality-assured data obtained with certified Hg and auxiliary monitoring systems. The test must be completed no later than 180 days after the applicable compliance date in §63.9984(a) or (b).** ________________ @ If emissions averaging is used, the initial averaging period is 90 operating days. ** That is, no later than180 days after April 16, 2015 (for existing units) and no later than180 days after the later of April 16, 2012 or unit startup (for new units).

Hg Performance Test Requirements for Units Using CMS (cont’d) If the Hg monitoring system and all required auxiliary monitoring systems are certified prior to the compliance date in §63.9984(a) or (b), the performance test period may either be: The first 30 boiler operating days after the compliance date; or The 30 boiler operating days immediately preceding the compliance date (see §63.10005(b)(2)). A Hg emission rate, expressed in the units of the standard, is calculated for each operating hour of the test period in which quality-assured values for Hg concentration and all necessary auxiliary parameters are obtained. The hourly Hg emission rates are averaged arithmetically over the 30 boiler operating day test period, excluding values obtained during unit startup and shutdown. Initial compliance is achieved if the average Hg emission rate for the performance test period meets the applicable emission limit. Following the initial performance test, continuous compliance with the Hg emission limit is assessed on a 30 boiler operating day rolling average basis.** ____________________ ** 90 boiler operating days if emissions averaging is used.

Hg Emissions Reporting For affected units that demonstrate compliance using Hg CEMS or sorbent trap monitoring systems, quarterly reporting of Hg emissions is required, using ECMPS (see Appendix A, section 7.2.5). The reports must be submitted no later than 30 days after the end of each calendar quarter. Each emissions report must include the following information: Date of report generation; Facility identification information; Operating parameter records (i.e., date and hour, operating time, gross load, etc.); The results of daily calibration error tests and weekly system integrity checks, if Hg CEMS are used; Hourly records of Hg concentration and the auxiliary parameters needed to convert Hg concentrations from µg/scm to units of the standard;

Hg Emissions Reporting (cont’d) A separate hourly data stream, in units of the applicable Hg emission standard (lb/TBtu or lb/GWh); The hourly percent monitor data availability (PMA) for Hg concentration and for each monitored auxiliary parameter. Hg emission rates will be calculated only for operating hours in which valid data are obtained for Hg concentration and all of the essential auxiliary parameters. The hourly Hg emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. The 30 boiler operating day rolling average Hg emission rates **will not be reported in ECMPS. ____________________ ** Or, if applicable, 90 boiler operating day rolling average Hg emission rates.

SO2 Emissions Reporting Coal- and petroleum coke-fired EGUs equipped with wet or dry flue gas desulfurization (including fluidized bed boilers with limestone injection) may opt to comply with an SO2 limit in lieu of an HCl limit (§63.10000(c)(1)(v)). If you elect to use this option, you must: Create and maintain a monitoring plan with electronic and hardcopy portions, in accordance with §75.53(g).@ Use the ECMPS Client Tool to create the electronic portion. Install an SO2 CEMS and any auxiliary monitoring systems that are needed to determine SO2 emission rates in the units of the applicable emission standard (lb/mmBtu or lb/MWh). Certify, operate, maintain the SO2 and auxiliary CEMS according to Part 75.** _________________ @ See the footnote on the next slide ** The MATS rule requires one variation from Part 75 QA for the SO2 monitor. Linearity checks are required for SO2 span values of 30 ppm or less. ___________________ ** Note: The MATS rule requires one variation from the QA test requirements of Part 75. If the SO2 CEMS has a span value of 30 ppm or less, you must perform linearity checks in accordance with section 2.2 of Appendix B to Part 75.

SO2 Emissions Reporting (cont’d) Conduct an initial 30 boiler operating day performance test. The notification requirements for the performance test, the window of time for completing the test, the data reduction and compliance assessment criteria are essentially the same as described above for Hg. Report the results of all required certification, recertification, QA, and diagnostic tests of the CEMS to CAMD electronically, using the ECMPS Client Tool. Detailed RATA reports must also be submitted to the WebFIRE database. Submit quarterly electronic data reports (EDRs) to CAMD using the ECMPS Client Tool.@ Each emissions report must include the following information: Date of report generation; Facility identification information; Operating parameter records (i.e., date and hour, operating time, gross load, etc.); The results of all daily QA tests; __________________ @ The monitoring plan and EDRs are basically the same as the ones required under the Acid Rain and CAIR SO2 Programs. The only new information in the monitoring plans and reports will be formulas to convert SO2 concentrations from ppm to the units of the MATS standard and hourly SO2 emission rates expressed in those units.

SO2 Emissions Reporting (cont’d) Hourly records of SO2 concentration and the auxiliary parameters needed to convert SO2 concentrations from ppm to units of the standard; A separate hourly data stream, in units of the applicable SO2 emission standard (lb/mmBtu or lb/MWh); The hourly percent monitor data availability (PMA) for SO2 concentration and all monitored auxiliary parameters. SO2 emission rates will be calculated only for operating hours in which valid data are obtained for SO2 concentration and all of the essential auxiliary parameters. The hourly SO2 emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. Compliance with the SO2 emission limit will be assessed on a 30 boiler operating day rolling average basis, excluding startup and shutdown hours. The rolling average SO2 emission rates will not be reported in ECMPS.

HCl and HF Emissions Reporting The owner or operator has the following options to demonstrate compliance with the HCl and HF emission limits in Tables 1 and 2 of the rule:** Install, certify, operate and maintain HF and/or HCl CEMS, in accordance with Appendix B to Subpart UUUUU; For existing EGUs, conduct performance testing to determine whether the unit qualifies for LEE status for HCl and/or HF (see §63.10005(h)); If the CEMS and LEE options are not implemented, perform quarterly emission testing for HF and/or HCl; or For liquid oil-fired EGUs, measure the moisture content of the oil. If the CEMS option is selected, you must: Create and maintain an electronic monitoring plan, using the ECMPS Client Tool; Install the HCl or HF CEMS and any auxiliary monitoring systems that are needed to determine HCl or HF emission rates in the units of the applicable emission standard (lb/mmBtu or lb/MWh); __________________________ ** Note that only liquid oil-fired EGUs have HF limits---there are no HF standards for coal- or petroleum coke-fired EGUs.

HCl and HF Emissions Reporting (cont’d) Certify and quality-assure the data from the HCl or HF CEMS using procedures based on Performance Specification 15 in Part 60, Appendix B.** The use of conditional data validation is permitted and grace periods are available for quarterly gas audits and RATAs (see Subpart UUUUU, Appendix B, sections 5.1.1 through 5.1.3, 5.3.2 and 5.3.4). Certify and quality-assure the data from the auxiliary monitoring systems according to Part 75; Conduct an initial 30 boiler operating day performance test. The notification requirements for the performance test, the window of time for completing the test, the data reduction and compliance assessment criteria are essentially the same as described above for Hg. Report the results of all required certification, recertification, QA, and diagnostic tests of the CEMS to CAMD electronically, using the ECMPS Client Tool@; ____________________ ** Note that PS 15 applies only to FTIR analyzers. EPA intends to issue a technology-neutral performance specification for HCl CEMS and to amend Appendix B accordingly (see Appendix B, section 3.1). @ Currently the draft ECMPS instructions does not identify all of the QA information described in PS 15 and sections 5.1.1 through 5.1.3 of Appendix B to Subpart UUUUU. Special records will have to be created for this purpose.

HCl and HF Emissions Reporting (cont’d) Submit detailed RATA reports to the WebFIRE database; Submit quarterly electronic data reports (EDRs) to CAMD using the ECMPS Client Tool (see Appendix B, section 11.5). Each emissions report must include the following information: Date of report generation; Facility identification information; Operating parameter records (i.e., date and hour, operating time, gross load, etc.); The results of all daily QA tests; Hourly records of HCl or HF concentration and the auxiliary parameters needed to convert HCl or HF concentrations from ppm to units of the standard; A separate hourly data stream, in units of the applicable HCl or HF emission standard (lb/mmBtu or lb/MWh); The hourly percent monitor data availability (PMA) for HCl or HF concentration and all monitored auxiliary parameters.

HCl and HF Emissions Reporting (cont’d) HCl or HF emission rates will be calculated only for operating hours in which valid data are obtained for HCl or HF concentration and all of the essential auxiliary parameters. The hourly HCl or HF emission rate will not be calculated if any of the parameters used in the emission rate equation is a substitute data value. Only unadjusted hourly values will be used in the calculations---no bias adjustment factors (BAFs) will be applied. Compliance with the HCl or HF emission limit will be assessed on a 30 boiler operating day rolling average basis, excluding startup and shutdown hours. The 30 boiler operating day rolling average emission rates will not be reported in ECMPS.

Useful Links MATS Home Page ECMPS Support ECMPS CAMD Home Page http://www.epa.gov/mats/ ECMPS Support http://ecmps.camdsupport.com/ ECMPS CAMD Home Page http://www.epa.gov/airmarket/business/ecmps/index.html

Questions? Charles Frushour USEPA, Clean Air Markets Division Contact Information: Charles Frushour USEPA, Clean Air Markets Division frushour.charles@epa.gov (202) 343-9847