Planned Revisions to 40 CFR Parts 72 and 75 Matthew G. Boze U.S. EPA Clean Air Markets Division

Types of Revisions Proposed uRevisions necessary to support or streamline reporting under ECMPS uRevisions to clarify, simplify, modify or correct mistakes in existing requirements uRevisions to strengthen and clarify Hg monitoring provisions

Definitions §72.2 uAdding Definitions for: ãLong-term cold storage ãEPA Protocol Gas Verification Program ãAir Emission Testing Body (AETB) ãQualified Individual uRevising Definitions for: ãCapacity Factor ãEPA Protocol Gas ãExcepted Monitoring Systems

General Provisions uUpdating Incorporated References uAdd Default Moisture Value for Natural Gas (14.0% and 18.0%) uAllowing use of F-23 default SO 2 emission rate for low sulfur fuels without requiring SO 2 CEMS. uRemove requirement for EPA to publish each Alternative Monitoring System (PEMS) approval in the Federal Register

Reference Methods uAdopt revised Part 60 Reference Methods with certain exceptions ãNo calibration gasses prepared by dilution in field using method 205 (must use EPA Protocol Gasses only) ãNo using multi-holed probes (without prior approval) in lieu of traversing stack ãNo using “Dynamic Spiking” in lieu of the interference and system bias checks of the method. uAllow use of EPA Method 29 as an alternative to the Ontario Hydro Method for Hg.

Stack Tester Accreditation (AETB) uAdd requirements for individuals or companies performing stack testing to be certified as Air Emission Testing Bodies (AETB) in accordance with ASTM D uASTM D “Standard Practice for Competence of Air Emission Testing Bodies” is a consensus standard developed to ensure stack testing is conducted by qualified individuals uThe following Part 75 test would be subject to this standard: ãRATA’s ãAppendix E & LME NO s emission rate tests ãHg emission rate tests for Hg LME units

Missing Data Substitution uMake “Stepwise” approach the required approach rather than “Block” approach uSubstitute Data for Controlled Units ãRemove requirement to petition for controlled maximum value under §75.34(c)(3) – [Tier 3] ãAdd 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]

Recordkeeping and Reporting uRevisions to general and specific monitoring plan recordkeeping requirements ãSupport transition to XML format ãAdding WAF reporting requirements for Rectangular Ducts uRevisions to QA/QC recordkeeping requirements for transition to XML format uRevisions to Quarterly Reports requirements for transition to XML format

Other Reporting Issues uProvision to allow “long term cold storage” units to suspend quarterly reporting uNew requirement to report the certification deadline date needed to know when to start counting allowances by §72.9 uRelax initial monitoring plan submittal deadline from 45 days to 21 days prior to initial certification uRemove requirement for EPA Form uAllow reporting of steam load in units of mmBtu/hr uSeparate reporting requirements for MP, QA, and Emissions – (New Reengineering Process)

NO x Mass and Heat Input uLimit Monitoring Plan to only one active NOx mass methodology at a time uRevise and Simplify the linearity and RATA QA requirements for ozone season only (OSO) reporters uClarify that peaking status for OSO reporters is based on 3,672 hours and not 8,760 uRequire that either a CO 2 or O 2 monitoring system be identified and QA’s whenever heat input is calculated from stack flow and diluent (CO 2 or O 2 )

Appendix A uAllow CO 2 spans less than 6.0 percent with technical justification provided in the monitoring plan uRequire vendors of EPA Protocol Gas to participate in a Protocol Gas Audit Program uClarify applicability of Linearity Exemption uAlternative stability specifications for performing cycle time tests for low span analyzers uCorrect Part 60 cross references

Appendix B uHarmonize 5 year requirement for 3-load flow RATAs with other 5 year testing requirements (make 5 years = 20 calendar quarters) uSimplify the requirement for determining RATA deadlines after completing a grace period RATA. uClarify and extend provisions for range specific data validation wrt linearities and daily calibration error checks uClarify requirements and limitations for data validation using off-line calibrations

Appendix D & E uUpdate references uRelax qualification requirements for pipeline natural gas uRemove requirements for vendor to split and save oil samples uSpecify substitute data requirement for when the Appendix E correlation curve expires (use maximum emission rate)

Appendix F uAdd equations N-1 and N-2 to rule and modify NOx Mass equations to support reporting hourly data in lb/hr rather than lbs. uLimit use of diluent cap to NO x calculations only to simplify reporting uSpecify substitution requirements for negative emission calculations for certain equations (HI, CO2) uProcedures for prorating F-factors uAdd standard F-factors to rule for Petroleum Coke and Tire Derived Fuels

LME (SO 2 & NO x ) uDefault Emission Rates ãAllow use of permit sulfur limits to calculate a lower SO 2 default emission rate than is provided by rule ãClarify that Part 60 CEMS data may be used to establish a fuel and unit specific default NO x emission rate uClarify ãHow to calculate hourly, quarterly, and cumulative NO x emission rates ãThat the LME provisions of §75.19 must be used for all parameters (SO 2, NO x, CO 2 ) if used for any one uRemove requirement for hardcopy LME certifications to CAMD

Hg uAdd requirements to provide 21 day notice and provide testing results upon request for periodic Hg LME emission tests ãThese requirements are consistent with requirements for Hg emission tests used to certify and QA Hg CEMS uAdd heat input monitoring provision ãInadvertently omitted from previous Hg monitoring rule uCorrect error in requirements for weekly system integrity checks uHarmonize the linearity and system integrity specifications with alternate specifications uOther technical corrections and changes to reflect ECMPS