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ECMPS and Regulatory Update Matthew G. Boze U.S. EPA Clean Air Markets Division
ECMPS Time Line • Industry Alpha Testing: Early 2006 - Mid 2006 • Implement Alpha Testing Changes: Mid 2006 - End of 2006 • Industry Beta Testing Session 1: April 2007 - June 2007 • Implement Session 1 Changes: July 2007 • Industry Beta Testing Session 2: August 2007- December 2007 • LME Beta Testing: End of November 2007- End of January 2008 • Implement Session 2 Changes: End of 2007 - February 2008
ECMPS Time Line • Develop Other Functionality and Implement LME Testing Changes: End of 2007 - February 2008 • Release Version 1 of Client Tool: April 1, 2008 • 2008 Industry Testing Session: May 2008 - September 2008 • Complete Development: May 2008 - December 2008 • Client Tool Training: 2008 - 2009 • Required Use by All Sources: First Quarter 2009
Preparing for the Transition to ECMPS in 2008 • Perform Client Tool testing. • Register to Officially Switch to ECMPS in 2008 for all Submissions. • Understand the Relationship Between the CAMD Business System (CBS) and ECMPS. • Add ECMPS Agents. • Download the Production Software. • Update Your Monitoring Plan. • Use all available ECMPS resources. • Work with your Vendor (if applicable).
Version 1 • Version 1 of the Client Tool was made available to registered users on April 1, 2008. • Within 3 hours of posting the Client Tool, submissions were made to the EPA Host System. • Officially switched to ECMPS for first quarter 2008. • 15 registrants • 21 facilities • ## new registrants for second quarter 2008. • Insert number of registrants so far
Registration Deadlines • Register to Officially Switch to ECMPS in 2008 for All Submissions • In 2008, you MUST register to officially switch to ECMPS. • Registration for 2009 will not be necessary since all sources are required to use ECMPS. QuarterDeadline to Register 2008 Quarter 3 August 1, 2008 2008 Quarter 4 November 1, 2008 • http://www.epa.gov/airmarkets/business/ecmps/registration.html
Monitoring Plan Transition Tips! • Updating the Monitoring Plan is a significant task • DO NOT wait until April 2009! • Use the test environment in 2008 to identify what changes are required and keep notes • Begin submitting monitoring plan updates officially in March 2009 if not earlier!
January 24, 2008 Final Rule • Included: • Revisions necessary to support or streamline reporting under ECMPS • Revisions to clarify, simplify, modify or correct mistakes in existing requirements • Revisions to strengthen and clarify Hg monitoring provisions (note, the Agency is currently pursuing the re-promulgation of the Hg monitoring provisions under authority independent from CAMR)
Reference Methods • Adopt revised Part 60 Reference Methods with certain exceptions • No calibration gasses prepared by dilution in field using method 205 (must use EPA Protocol Gasses only) • No using multi-holed probes (without prior approval) in lieu of traversing stack • No using “Dynamic Spiking” in lieu of the interference and system bias checks of the method. • Method 7E required for Appendix E testing of turbines • 12 point traverse located per Method 1 • See Part 75, Appendix E, Section 2.1.2
Stack Tester Accreditation (AETB) • Add requirements for individuals or companies performing stack testing to be certified as Air Emission Testing Bodies (AETB) in accordance with ASTM D7036-04 • ASTM D7036-04 “Standard Practice for Competence of Air Emission Testing Bodies” is a consensus standard developed to ensure stack testing is conducted by qualified individuals • The following Part 75 test will be subject to this standard: • RATA’s • Appendix E & LME NOs emission rate tests • Hg emission rate tests for Hg LME units • Required after January 1, 2009
PGVP • Protocol Gas Verification Program • Require vendors of EPA Protocol Gas to participate in this Protocol Gas Audit Program • Required after January 1, 2009
Missing Data Substitution • Make “Stepwise” approach the required approach rather than “Block” approach • Substitute Data for Controlled Units • Remove requirement to petition for controlled maximum value under §75.34(c)(3) – [Tier 3] • Add Provision to allow MEC/MCR in lieu of MPC/MER whenever controls are documented to be operating properly [Tier 4 and unmonitored bypass stack hours]
NOx Mass and Heat Input • Limit Monitoring Plan to only one active NOx mass methodology at a time • Revised the linearity and RATA QA requirements for ozone season only (OSO) reporters • Linearities are now required in April and July • RATA are required between January 1 and April 30 preceding the ozone season. (Note: for 2008 EPA will accept RATA’s done prior to January 1 due to the timing of the rule change) • Require that either a CO2 or O2 monitoring system be identified and QA’s whenever heat input is calculated from stack flow and diluent (CO2 or O2)
Save a Tree! • EPA has removed the requirement for the Certification Application Paper Form EPA Form 7610-14