Particulate Matter Monitoring Required by the Utility MATS Eric Swisher| | ext. 17 August 22, 2012 Presented to ARIPPA by All4 Inc.

2 Your environmental compliance is clearly our business.  Regulatory Background  Regulated Pollutants  Compliance Options for Filterable Particulate Matter (FPM) Presentation Overview

3 Your environmental compliance is clearly our business.  40 CFR Part 63, Subpart UUUUU – National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Published Final on February 16, 2012 Compliance date of February 16, 2015 Regulatory Background

4 Your environmental compliance is clearly our business. Regulated PollutantSurrogate Nonmercury Metallic HAP Filterable Particulate Matter (FPM) Acid Gases HCl or SO 2 Mercury None Regulated Pollutants

5 Your environmental compliance is clearly our business.  HCl CEMS (HCl or SO 2 )  Mercury CEMS (analyzer or sorbent trap)  FPM Quarterly Testing (FPM & Non-Hg HAP Metals) Continuous Parametric Monitoring System (CPMS) and Annual Emission Testing CEMS (FPM) Compliance Options

6 Your environmental compliance is clearly our business.  Quarterly testing for PM/Non-Hg Hap Metals FPM – U.S. EPA Reference Method 5 (RM5)  ~$15K Total Nonmecury HAP Metals – U.S. EPA Reference Method 29 (RM29)  ~$15K Quarterly Testing

7 Your environmental compliance is clearly our business.  Record parametric data during annual compliance tests.  Establish a parameter range from the parametric data collected during the annual compliance tests.  Monitor compliance using CPMS.  CMPS – PM CEMS that is not certified CPMS & Annual Testing

8 Your environmental compliance is clearly our business.  PM CEMS must be certified in accordance with 40 CFR Part 60, Appendix B, Performance Specification 11 Generation of a correlation curve between the FPM concentration and the unit load Requires at least 15 Paired samples 3 loads, 5 runs per loading level May require more than the minimum number of runs Expensive (~35k-60k) FPM Spiking Ongoing QA/QC PM CEMS

Questions Eric Swisher| | ext. 17