Report to CEM Users Group

1. Report to CEM Users Group Phoenix, Arizona May 9-11, 2007 Reynaldo Forte (Rey)

2. Acid Rain and NOx Budget Programs • Near perfect compliance • RATAs are averaging less than 3% relative accuracy • Over 98% monitoring availability • Data transparency/credibility • Reasonable and fair petitions/responses • Competent implementation - environment of trust • Unquestionable environmental integrity • Cost effective environmental and health benefits • OMB statement: “largest quantified human health benefits of any federal regulatory program in the last 10 years, with annual benefits exceeding costs by > 40 to 1.” • This has become the model for other programs

3. SO2 emissions from power plants down by 5.5 million tons since 1990 17.3 15.7 11.9 11.2 10.2 Acid rain cut by 25 – 35% Major Reductions in SO2 Emissions and Acid Rain Million Tons of SO2 Sulfate (Acid Rain) Concentrations Substantial health, visibility, and other benefits provided

4. Major Result in SO2 Emission Reductions

5. Summertime NOx Emission Reductions • 2005 NBP states’ ozone season reductions (May 1 – September 30) • 72% from 1990 baseline • 57% from 2000 baseline • 11% from 2004 Daily Emission Trends for NOx Budget Trading Program Units in 2003, 2004 and 2005 Total NBP Ozone Season NOx Emissions NOx Emissions (Thousand Tons) Source: EPA, 2006

6. Clean Air Interstate Rule (CAIR) CAIR & CAMR Implementation • Reduces sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions which contribute to particle matter (PM2.5) and ground level ozone. • All 29 affected jurisdictions are expected to trade. • The most important step EPA can take now to improve air quality.

7. Clean Air Mercury Rule (CAMR) CAIR & CAMR Implementation • Builds on CAIR to allow power industry to address mercury, SO2 and NOx emissions in a coordinated effort. • Expected to make reductions in emissions that are transported regionally and deposited domestically, and it will reduce emissions that contribute to atmospheric mercury worldwide. • 50 States, DC and two Tribes are affected. • About 36 CAMR-affected jurisdictions are expected to trade • Part 75 Hg monitoring and reporting is required for both trading and non-trading approach

8. CAIR & CAMR Implementation CAIR & CAMR Implementation • CAMD continues to use a good deal of its resources for the coordination and implementation of CAIR/CAMR • Monitoring and reporting implementation activities include: • Development of CAIR NOx certification guidance • Hg reporting as part of new re-engineered data systems • Development of Reporting Instructions • Development of electronic audits for Hg (MDC equivalent) • Update of Field Audit Manual, Policy Manual, and other guidance • Development of workshop and training materials • EDR vs. ECMPS reporting for CAMR & CAIR SO2 in 2008 • Training of Regions, States, and Sources

9. CAIR & CAMR Implementation Workshop – Atlanta, GA • CAIR/CAMR Update • Designated Representative and Establishing Allowance Accounts • CAIR Monitoring Requirements and Options • Ongoing Quality Assurance for NOx and SO2 CEMS • Low Mass Emitter (LME) Monitoring Option • How to Avoid Common Monitoring and Reporting Problems • Annual Reconciliation • Mercury Monitoring, Options and Requirements

10. CAIR & CAMR Implementation • Next Workshops • Chicago: June 6-7 • Dallas: July 18-19 • Kansas City: Mid August • Denver: Fall of 2007 • Others to follow • Chicago’s Workshop Registration & Information is available at: http://epa.gov/airmarkets/workshops/index.html

11. Mercury Monitoring - CAMR The Agency continues its commitment to developing a complete and timely mercury monitoring capability under CAMR • Strong Agency Team: OAQPS, ORD & CAMD • Strong collaboration with EPRI, RMB, vendors, WRI, NIST, EERC, and others • Substantial funding and time commitment

12. Mercury Monitoring - CAMR Issues relating to the following items are still being worked out: • Reference methods • NIST traceability • Monitor certification • Providing stack testers with all the necessary tools

13. Mercury Monitoring – Other Issues • Allow time for adequate installation and certification of monitors • If you’re planning on reporting emissions using LME, make sure your unit qualifies • If you’re installing an FGD and new stack(s) in 2009, consider petitioning the Agency for some relief

14. Revisions to Part 72 and 75 • Revisions to clarify, simplify, modify or correct mistakes in existing requirements • Support or streamline reporting under ECMPS • Add Predictive Emissions Monitoring Systems (PEMS) to rule • Add stack testing certification requirement • Add protocol gas audit program • Step vs. block approach for missing data substitution • Add some flexibility to the use of substitute data for controlled units • Add EPA Method 29 as an alternative to the OH • Expecting finalization by late summer

15. Proposed Stack Testing Accreditation “ Any Air Emission Testing Body conducting RATAs of CEMS or sorbent trap monitoring systems, or Appendix E testing, or deriving default emission rates for LME units under this part must conform to the requirements of ASTM D 7036-04”

16. Proposed Protocol Gas Verification Program “Any specialty gas company advertising, distributing, or certifying gas as “EPA Protocol Gas” must participate in the Protocol Gas Verification Program”

17. Electronic Auditing Program • All Appendix D & E-reporting units have been successfully audited • Continue to add checks to software application used to identify suspect data • Issues with probe leaks are of particular interest

18. Harmonization of Part 60 & Part 75 • The purpose of this effort is to harmonize, to the extent possible, the CEM provisions of Parts 60 and Part 75, for sources subject to both sets of regulations. • A couple of years ago we had success with Subpart GG for turbines. • With the recent signing of the revisions to NSPS Subparts Da, Db, and Dc, we got most of it done for boilers regulated under Da and Db, where there was direct overlap and/or conflict with Part 60 and Part 75 CEM data validation and QA/QC requirements. • However, two key questions that did not get addressed in this rulemaking are: • (1) Should EPA extend the option of following Part 75 QA procedures to other sources subject to Appendix F of Part 60?; and • (2) Do we need more consistent and realistic CEM performance specification for low emitters? • We’re looking at options to get these remaining issues and a few others addressed in the near future.

19. Emission Collection & Monitoring Plan System (ECMPS) ECMPS is smoothly moving forward for those who are engaged. If you have reporting responsibilities and are not engaged, you should be!

20. EPA Booth • EPA’s Louis Nichols, Laurel DeSantis, Craig Hillock and others, and contractors David Ward and Drew Price will be available to assist with: • CAIR NOx Guidance • CAIR applicability • CAIR Unit Registrations • Designated Representative Registrations • MDC/electronic audits questions • ECMPS • CAMD Business System • ETS-FTP • SecurRemote Software • and others

21. Closing Remarks • Your expertise, dedication, and ability to handle complex issues have been fundamental to making cap and trade programs extremely effective. • Those same qualities are producing the desired results for CAIR and CAMR, particularly mercury monitoring. • However, significant challenges remain… • As we improve our programs, significant changes become necessary. We, as a community, need to stay on top of these changes to maintain the record of excellence achieved so far. • (e.g., mercury monitoring, ECMPS, stack tester certification, gas audit program, Part 60/Part 75 harmonization, electronic audits, etc.)