Utility MATS Compliance: Considerations for Emissions Testing Tyson Houchin, QSTI District Manager Avogadro Environmental, Inc. Montrose Environmental Group, Inc. ARRIPA Technical Symposium, August 20, 2014

Utility MATS Compliance: Considerations for Emissions Testing A Stack Testers Breakdown Of The Utility MATS Requirements Preparing For The Required Performance Testing

MATS: 40 CFR 63 Subpart UUUUU There is Plenty that “U” must do Reporting Recordkeeping Demonstrating Continuous Compliance Notifications and Plans Performance Testing – Initial Compliance

Reporting Semi-Annual Compliance Reports Due every January 31st and July 31st Include the total fuel use by each affected source subject to an emission limit, for each calendar month within the semiannual reporting period. Indicate whether you burned new types of fuel during the reporting period. Include the date of the most recent tune-up for each unit subject to the requirement to conduct a performance tune-up according to § 63.10021(e). Quarterly Reports Due 30 days after the applicable quarter ends. Quarterly Stack Emission Testing Results. Continuous Monitoring System (CMS) Data. Continuous Parametric Monitoring System (CPMS) Data. All reports need to be submitted via ERT/CEDRI This process can be very time consuming.

Recordkeeping Emissions Averaging Plans Site Specific Monitoring Plans Due 120 days before 4/16/2015. Site Specific Monitoring Plans Due 60 days before Initial Performance Test. Performance Test Notification Due 60 days before performance test. Initial & ongoing performance tests. Initial certifications, RATAs, RCAs, RRAs. CEMS QA/QC Plans No specific dates but, before certification. PM CEMS, Hg CEMS, HCl CEMS. Notification of Compliance Status Due 60 days after completion of performance tests and/or compliance demonstration.

Demonstrating Continuous Compliance Monitoring Quarterly stack emission testing, or Data from Continuous Monitoring System (CMS), or Data from Continuous Parametric Monitoring System (CPMS). Performance Testing – Initial Compliance Stack emissions testing, or 30 days of monitoring data from CMS or CPMS. Boiler Tune-ups Initial within 12 months of performance test. May be done before the initial compliance test. Then every 3 years (unless neural network controls - every 4 years).

Notifications and Plans Notification of Compliance Status Due 60 days after Initial Performance test. Performance Test Notification Due 60 days before Performance test. Site Specific Monitoring Plans Due 60 days before Performance Test. CEMS QA/QC Plans No specific dates – but before initial certification. Emissions Averaging Plans Can do if you have multiple similar units at a facility. Due 120 days before 4/16/2015… (that’s 12/18/14).

Anyone Feeling Overwhelmed? Let me help at least break down what you need to do for a successful stack test event!

Preparing For The Required Performance Testing Testing and Initial Compliance Requirements Performance Test Decisions Preparations For Testing Pre-compliance Testing

Testing and Initial Compliance Requirements Comply by 4-16-2015, Demonstrate within 180 days Performance tests to demonstrate compliance Stack Testing at maximum normal load (normally 90 – 110% of design capacity) 3 one-hour runs. Quarterly tests - FPM (or metals), HCl/HF. May be done in the 12 months prior to the compliance deadline. CMS - 30 boiler operating days of data. HCl, HF, Hg – CEMS or sorbent traps. SO2, PM – CEMS (or PM CPMS). Must be certified before that 30-day period. Can use CMS data with quarterly audits and annual RATA. If PM (or Metals) CPMS, must also show Continuous Compliance with a Site Specific Operating Limit (or Limits at other loads) – established during Performance Test.

Performance Test Decisions Can I use this testing to satisfy other requirements that I might have (i.e. operating permit or annual RATA requirements, etc.)? Be sure the test methods chosen will cover all the regulations and objectives. Should I try to qualify for Low Emitting EGU (LEE) status? Can’t qualify if the EGU is equipped with an acid gas scrubber and has a bypass stack. If you qualify for LEE for non-Hg, (less than 50% of limit for HCl, HF, FPM, Metals). Test frequency goes to once in 3 years. If you don’t qualify for LEE for FPM (or Metals), then must monitor. - PM CPMS, PM CEMS, or Quarterly Stack Testing. If you qualify for LEE for Hg (less than 10% of Hg limit). Test frequency goes to annual 30 BOD Method 30B testing. Not applicable if the EGU is new.

Performance Test Decisions Should I Install a PM CPMS? May reduce testing frequency; annual rather than quarterly. Must also show Continuous Compliance with an Operating Limit (or Limits at other loads) established during Performance Test. Should I Install a PM CEMS? Subject to annual certification by PS-11 and quarterly audits. PS-11 equates to about a week of testing.

Preparations For Testing Review permit, generate scope of work, testing time frame. Look at SOW in comparison to method detection limits, time frames, weather conditions, etc. Issue RFP, conduct site visit, review and answer questions. The better the SOW and RFP package, the better quality of bids received. This saves time, money and aggravation. Listen to your source testing firms on methodology issues or conflicts as these dialogs may help you avoid post-test issues. Review RFPs, qualify testing firms, set-up contract. Generate test plan; notify applicable regulatory agencies. Discuss some qualification criteria – ASTM, experience, references, who is doing the test and what is their experience?

Preparations For Testing Select The Proper Vendor! Make sure the testing firm has at least an ASTM D7306 Interim Accreditation An Accredited testing firm will have Qualified Individuals (QI) and Qualified Source Test Individuals (QSTI) on staff. QI – Have passed the necessary Group Exams for a particular set of methods. QSTI – A QI that has also been reviewed by an accrediting body to verify they also possess the necessary experience in the particular groups of study. There are hundreds of items that can potentially bias the results of a test program. An accredited testing firm is more likely to be cognizant of these issues and take steps to prevent them. Consistency is key to quality results. Follow the methods and procedures without deviation. You are ultimately responsible for the results of the testing program. Make sure the test firm that is used also uses a well qualified laboratory for the applicable analysis.

Preparations For Testing Test Site Preparation This is a critical component to a testing program that is often overlooked or under valued. If not prepared correctly, this can lead to lengthy and costly delays. It usually takes more facility resources then you would think to adequately prepare for a testing program. A qualified testing firm generally asks for more resources than other firms. This is generally due to them bringing extra equipment to support the testing program which leads to more efficient use of time and resources. Make sure test ports have been opened and cleaned prior to the test firm’s arrival. Make sure to identify any potential safety hazards and address them prior to the test firm’s arrival. This includes exceedingly long test days. This can endanger the test firms crew members as they will be working while extremely fatigued which will lead to injuries!

Preparations For Testing Coordinate testing with all internal departments; shipping/receiving, operational staff; process operators; electricians, etc. Discuss dialog with agency; notifications; role of source testing firm. Based on the process, the test program may not be the time to try out a new operator. In other words, you may want to keep the untrained person in the back room. We have all seen this guy around! On the day of test, make sure that you have all required personnel available to coordinate test program. Make it a priority to communicate with the test team. When you start a process condition and are ready for the run to start, tell the field manager.

Preparations For Testing Review process and field data as it is being generated. Stay in front of your process data. Know what it being generated as the test is occurring. If there is a process upset, it is easiest and most cost effective to add a run at the time of testing. Otherwise, it is very expensive to remobilize to get the run and/or repeat the test program. Sources are responsible for their data. The source testing firm can help obtain and/or record, but ultimately, sources are responsible for what is reported. At the end of the test program, confirm anticipated reporting dates along with any other missing information that will be needed for completion. Post-test reporting time flies by. Know what you need to provide to your stack testing firm. Check in with the assigned project manager to make sure that they have what they need. Review source test internally, and if applicable, with the testing firm to determine unforeseen difficulties in order to improve subsequent test programs. Don’t keep repeating the same mistakes.

Pre-compliance Testing Why do I need to contract pre-compliance testing This will allow the testing firm to accurately gauge the PM loading that the Hg sorbent tubes will be exposed to during the 30 BOD test event. This will also allow the testing firm to accurately determine the Hg spike levels for the sorbent tube sampling. This is important because if one test run of the 30 BOD event doesn’t pass the necessary QA, the whole event has to be re-started. This will obviously also provide a good indication of the EGU’s compliance status prior to the official test event. Will help identify any potential issues that may have otherwise arisen during the compliance test event.

Summary Decide how you want to determine continuous compliance - Quarterly tests, CEMS, CPMS, etc. Decide how to conduct performance test Stack test, CEMS, CPMS? FPM or metals, HCl or SO2, etc. Plan carefully – operations, testing schedule, notifications and reporting Quality testing will save on overall costs! Consider pre-compliance engineering tests May actually be more important than compliance tests! Make sure to make Safety a Top Priority

Questions? Tyson Houchin, QSTI District Manager Avogadro Environmental, Inc. Montrose Environmental Group, Inc. thouchin@montrose-env.com