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.
10 Part 75 Revisions EPA is developing a proposed rule revision: Will remove update or outdated provisions, and make technical corrections and other changes to Parts 72 (definitions) and 75.Should make Parts 72 and 75 more compatible with CAIR and easier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 lateThere 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 72.2Adding several new definitionsUpdates to Incorporation by ReferenceSeveral new or updated ASTM standardsNew AGA standardsRevised 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12 Part 75 Revisions Correction of Errors Removal of Outdated Provisions Minor changes in for monitoring NOX emission rate from common, bypass, and multiple stacksMinor changes in low mass emittersCalculating maximum potential concentration for natural gasRecordkeeping in 75.57Minor deadline corrections in 75.74Correction of other errorsRemoval of Outdated ProvisionsSeveral outdated provisions throughout Part 75 are being removed, e.g., provisions that were only effective up to a certain date that has passed12
13 Part 75 Revisions Addition of New Provisions Alternative performance specifications for low emittersCalculating site-specific SO2 emission rates for LMEQA/QC options in 75.20New provisions in appendicesClarification of Certain ProvisionsCertification / recertificationLow mass emittersMonitoring NOx emission ratesRecertification of alternative monitoring systemsCalibration gasUse of conditional dataTiming of various submittalsOzone season-only reportingSubstitute dataAppendices13
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 2003Draft versions were posted in April 2010 and May 2012Comments have been addressed and final version will be posted May 2013Will provide redline version showing edits from 2012 draft as well as clean versionNew version incorporates January 24, 2008, March 28, 2011, and August 12, 2011 amendments to Part 75Removes references to old (pre-2009) EDR recordsIncludes new questions and answers on AETB and PGVP issuesWill 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 monitorsAdded noncritical Daily Interference Checks for Stack Flow MonitorsThese checks will changed to Critical Level 1 in second and third quarters of 2013New PGVP Gas Type Codes implemented in first quarter 2013Submissions, 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 characteristicsUsed for targeting facilities for field auditsWind Tunnel AuditsCAMD audits wind tunnels used for calibrations of sampling probes for use in EPA flow methods 2F and 2 GCAMD, generally, audits about half of the wind tunnel testing facilities every 2 yearsNone conducted since last year
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 plantsPublished in the Federal Register on Thursday, February 16, 2012EPA 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 nickelAcid 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 plantsSets numeric emissions limits for mercury, acid gases and non-mercury metallic toxic pollutantsSets work practice standards for organic air toxics, including dioxinOil units (approximately 300 covered)Sets separate standards for 3 subcategories of oil-fired power plants:Limited-use oil-fired unitsNon-continental oil-fired unitsAll other oil-fired unitsSets 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.