Particulate Matter Monitoring Required by the Utility MATS

Eric Swisher| eswisher@all4inc.com | 610-933-5246 ext. 17August 22, 2012

Presented to ARIPPA by All4 Inc.

2 Your environmental compliance is clearly our business.

Regulatory Background Regulated Pollutants Compliance Options for Filterable Particulate

Matter (FPM)

Presentation Overview

3 Your environmental compliance is clearly our business.

40 CFR Part 63, Subpart UUUUU – National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units

• Published Final on February 16, 2012• Compliance date of February 16, 2015

Regulatory Background

4 Your environmental compliance is clearly our business.

Regulated Pollutant Surrogate

Nonmercury Metallic HAP Filterable Particulate Matter (FPM)

Acid GasesHCl orSO2

Mercury None

Regulated Pollutants

5 Your environmental compliance is clearly our business.

HCl• CEMS (HCl or SO2)

Mercury• CEMS (analyzer or sorbent trap)

FPM• Quarterly Testing (FPM & Non-Hg HAP Metals)• Continuous Parametric Monitoring System (CPMS) and

Annual Emission Testing• CEMS (FPM)

Compliance Options

6 Your environmental compliance is clearly our business.

Quarterly testing for PM/Non-Hg Hap Metals• F PM – U.S. EPA Reference Method 5 (RM5)

~$15K• Total Nonmecury HAP Metals – U.S. EPA Reference

Method 29 (RM29) ~$15K

Quarterly Testing

7 Your environmental compliance is clearly our business.

Record parametric data during annual compliance tests.

Establish a parameter range from the parametric data collected during the annual compliance tests.

Monitor compliance using CPMS. CMPS – PM CEMS that is not certified

CPMS & Annual Testing

8 Your environmental compliance is clearly our business.

PM CEMS must be certified in accordance with 40 CFR Part 60, Appendix B, Performance Specification 11• Generation of a correlation curve between the FPM

concentration and the unit load• Requires at least 15 Paired samples• 3 loads, 5 runs per loading level• May require more than the minimum number of runs• Expensive (~35k-60k)• FPM Spiking• Ongoing QA/QC

PM CEMS

Questions

Eric Swisher| eswisher@all4inc.com | 610-933-5246 ext. 17