1. CEMS Users Group Meeting
EPRI Conference---Raleigh, NC
May 2013
Reynaldo (Rey) Forte, Jr.
USEPA

2. A Few Statistics / Trends

3. ARP Annual Generation (MWh) by Fuel Type
Gas generation was 39% of total 2012 generation.

4. ARP Annual Generation (MWh) by Fuel Type
Daily (2012) Generation
ARP daily gas-fired generation approximated coal-fired generation in spring and fall of 2012 for the first time.

5. ARP Annual Generation (MWh) by SO2 Control Type
Uncontrolled generation continued to fall in 2012
FGD generation was displaced by gas

6. ARP/CAIR Annual Gas-Fired Generation (MWh) by NOx Control Type
SCR is also the predominant control at gas-fired units with a 73% share by generation (MWh)

7. ARP/CAIR Program Annual Emissions

8. Cross-State Air Pollution Rule
December 30 - The U.S. Court of Appeals for the D.C. Circuit issued its ruling to stay the CSAPR pending judicial review. August 21, The U.S. Court of Appeals for the D.C. Circuit issued a decision to vacate CSAPR and remand it back to EPA. The Court also ordered that CAIR remain in place pending promulgation of a valid replacement. January 24, 2013 - The U.S. Court of Appeals for the D.C. Circuit denied all the petitions for rehearing of its August 2012 decision to vacate CSAPR. March 29, 2013 - The U.S. Solicitor General petitioned the Supreme Court to review the D.C. Circuit Court's decision on CSAPR. April 8 and April 17, 2013 – EPA held meetings with the states to discuss a path forward on addressing interstate air pollution.

9. Part 75 –Related Activities

10. Part 75 Revisions EPA is developing a proposed rule revision:
Will remove update or outdated provisions, and make technical corrections and other changes to Parts 72 (definitions) and 75.
Should make Parts 72 and 75 more compatible with CAIR and easier to understand and implement.
Expected Federal Register publication date for proposed rule in late
There will be a 30 day comment period once the proposed rule is published.

11. Part 75 Revisions Revisions to Definitions
Updating and clarifying several definitions in 72.2
Adding several new definitions
Updates to Incorporation by Reference
Several new or updated ASTM standards
New AGA standards
Revised EPA Traceability Protocol for Gaseous Calibration Standards

12. Part 75 Revisions Correction of Errors Removal of Outdated Provisions
Minor changes in for monitoring NOX emission rate from common, bypass, and multiple stacks
Minor changes in low mass emitters
Calculating maximum potential concentration for natural gas
Recordkeeping in 75.57
Minor deadline corrections in 75.74
Correction of other errors
Removal of Outdated Provisions
Several outdated provisions throughout Part 75 are being removed, e.g., provisions that were only effective up to a certain date that has passed 12

13. Part 75 Revisions Addition of New Provisions
Alternative performance specifications for low emitters
Calculating site-specific SO2 emission rates for LME
QA/QC options in 75.20
New provisions in appendices
Clarification of Certain Provisions
Certification / recertification
Low mass emitters
Monitoring NOx emission rates
Recertification of alternative monitoring systems
Calibration gas
Use of conditional data
Timing of various submittals
Ozone season-only reporting
Substitute data
Appendices 13

14. Protocol Gas Verification Program
The Emission PGVP commenced on September 26, 2011.
Helps ensure that accurate CEMS calibration gases are used by Part 75 sources.
Accomplished by annually procuring a blind sample of cylinders from any company providing gases to Part 75 sources, having the National Institute of Standards and Technology analyze those cylinders, and posting the results.
The final rule, a list of participating gas vendors, ECMPS reporting information, and the latest audit results which may be useful when selecting gas vendors are at:
Questions may be addressed to John Schakenbach )

15. Air Emission Testing Bodies
The Part 75 minimum competency requirements for AETBs commenced on March 27, 2012.
Helps ensure that any stack test company performing Part 75 stack tests (RATAs, App E, and LME tests) has a quality system in place and provides Qualified Individuals on-site for stack tests.
Accomplished by requiring stack test company compliance with ASTM D (available at:
The final rule and ECMPS reporting information are at:
Questions may be addressed to John Schakenbach )

16. Part 75 Policy Manual Revision
Last Final Version posted was October 2003
Draft versions were posted in April 2010 and May 2012
Comments have been addressed and final version will be posted May 2013
Will provide redline version showing edits from 2012 draft as well as clean version
New version incorporates January 24, 2008, March 28, 2011, and August 12, 2011 amendments to Part 75
Removes references to old (pre-2009) EDR records
Includes new questions and answers on AETB and PGVP issues
Will still take comments on all questions

17. Emissions Collection and Monitoring Plan System (ECMPS) Update
New Checks since May 2012:
Added noncritical Leak checks of positive displacement type Stack flow monitors
Added noncritical Daily Interference Checks for Stack Flow Monitors
These checks will changed to Critical Level 1 in second and third quarters of 2013
New PGVP Gas Type Codes  implemented in first quarter 2013
Submissions, including resubmissions, of all data including prior quarters should use new codes.
No new significant new checks planned at this time.

18. Control Chart Audit Update
We’re seeing shorter durations of questionable data in the control chart analysis.
We’re still identifying units with this issue every year.
Most software vendors have incorporated this check into their DAHS – if you haven’t, you should consider it.
False positives have decreased substantially.

19. Other Audits Target Tool for Field Audits (TTFA) Wind Tunnel Audits
It highlights suspect data based on statistics and a set of criteria designed to identify unexpected data results, trends or characteristics
Used for targeting facilities for field audits
Wind Tunnel Audits
CAMD audits wind tunnels used for calibrations of sampling probes for use in EPA flow methods 2F and 2 G
CAMD, generally, audits about half of the wind tunnel testing facilities every 2 years
None conducted since last year

20. Mercury and Toxics Standards (MATS)

21. Mercury and Air Toxics Standards
On December 16, 2011, EPA signed the final Mercury and Air Toxics Standards, the first national standards to reduce emissions of mercury and other toxic air pollutants from new and existing coal- and oil-fired power plants
Published in the Federal Register on Thursday, February 16, 2012
EPA reconsidered portions of the MATS and Utility NSPS and signed the finalized revision on March 28th.
Standards will reduce emissions of:
Metals, including mercury (Hg), arsenic, chromium, and nickel
Acid gases, including hydrogen chloride (HCl) and hydrogen fluoride (HF)
Particulate matter

22. MATS Emissions Limits Coal units (approximately 1,100 covered)
Separate mercury standards set for two subcategories of coal-fired power plants
Sets numeric emissions limits for mercury, acid gases and non-mercury metallic toxic pollutants
Sets work practice standards for organic air toxics, including dioxin
Oil units (approximately 300 covered)
Sets separate standards for 3 subcategories of oil-fired power plants:
Limited-use oil-fired units
Non-continental oil-fired units
All other oil-fired units
Sets numeric emissions limits for metal air toxics including mercury and for acid gases

23. MATS Monitoring and Reporting
Data from Hg, SO2, HCl, and HF CEMS and sorbent trap systems, as well as any auxiliary monitoring systems needed to convert pollutant concentrations to units of the standard, will be reported using the ECMPS system of EPA’s Clean Air Markets Division (CAMD)
The SO2 CEMS (if used) and any auxiliary monitoring systems (i.e., flow rate, CO2, O2, and/or moisture) must meet the requirements of 40 CFR 75.
The results of all performance stack tests using test methods on the ERT web site and CEMS relative accuracy test audits (RATAs) will be submitted to EPA’s WebFIRE database, using the Compliance and Emissions Data Reporting Interface (CEDRI)

24. Concluding Remarks Part 75 revision is coming up.
Posting of revised Part 75 Policy Manual later this month.
EPA is committed to working closely with you to achieving effective and smooth implementation of the Mercury and Toxics Standards rule.

25. THANKS! Don’t forget to visit our EPA booth.