EPRI Hazardous Air Pollutants Information Collection Request Data Review Summary

Transcription

1 EPRI Hazardous Air Pollutants Information Collection Request Data Review Summary June 30, 2010 (revised July 1) Paul Chu, Naomi Goodman, Babu Nott, Chuck Dene, George Offen, Christina Kemp

2 Webcast Presenters Paul Chu (EPRI) Naomi Goodman (EPRI) Project Team Doug Orr, Katherine Dombrowski (URS) Ralph Roberson (RMB) 2

3 EPRI Background Conducted hazardous air pollutants (HAPs) power plant measurements since early 90s EPRI, DOE: developed database for the initial EPA HAPs report to Congress 2000 Mercury Information Collection Request (ICR): EPRI assisted with the measurements as well as data analyses More recently: focus on control technologies 3

4 HAPs ICR Background Utility HAPs Information Collection Request (ICR) ~500 coal/oil units: stack and fuel testing Potential Maximum Available Control Technology (MACT) standards for mercury and all HAPs (metals, acid gases, organics) Implications: controls/upgrades may be needed at many units PM, carbon injection, flue gas desulfurization Final EPA rule by November 2011 Proposed EPA rule by March

5 ICR Part III Data Evaluation Issue Bad data may be used to set MACT standards due to short timeframe Compile and evaluate ICR Part III stack data before submitted to EPA ICR data due to EPA starting July ~5 through Sept ~5 Address or identify data issues to eliminate bad data from MACT database Improved data quality to support MACT standard 5

6 Targeting 100% Participation Potentially almost 500 ICR reports ~50%: July ~5 ~20%: August ~5 ~30%: September ~5 Too many for detailed review Screen for outliers, then select reports for detailed review 6

7 ICR Data Evaluation Approach Collect, receive ICR data confidentially Screen for outliers Conduct detailed evaluation on outliers Feedback to host power plant Power plant chooses how to act upon EPRI feedback and submits data to EPA Once data are submitted to EPA, EPRI will treat data as publicly available Conduct additional analyses of all ICR data 7

8 Current Approach to Data Reviews All reports are receiving both initial and detailed review Inter-run outlier evaluation Method gotchas Quality control review Calculations and detection limit checks Not enough data collected for intersite comparison yet Feedback to facility notes Critical and Non-Critical issues 8

9 What are Critical and Non-Critical Issues? Critical Issues Sampling or analytical problems that could lead to a significant low or high bias Emissions or detection limits out of expected range Calculation errors (emissions, detection limits) Electronic reporting errors Non-Critical Issues Minor deviations from method procedures Outlier values that appear valid Failure to meet method QC criteria, if it would not have a significant impact on the result 9

10 Common Critical Issues EPA Reporting Tools ERT File ERT test report will not appear or ERT will not calculate emissions Missing SEC Code no F Factor selected Runs, parameters with no values entered Gas volumes not entered EPA Emissions Spreadsheet Missing parameters (e.g., Method 30B, HCN) Note: 3 versions of Emissions spreadsheet use the most recent if possible! 10

11 Common Critical Issues: Acid Gases/HCN Combined Method 26A/CTM-033 Train ph < 12 in impingers (low bias for HCN ) Very high detection limits for HCN and acids Probe temperature <248ºF (low bias) CTM-033 EPA Emissions Spreadsheet not completed Poor recovery of matrix spikes 11

12 Common Critical Issues: Mercury and Non-Mercury Metals Mercury by Method 30B Results not entered into EPA Emissions spreadsheet Paired samples or spike recoveries do not meet method criteria (invalid sample) Metals by Method 29 Front and back half values not entered in Comment field of ERT 12

13 Common Critical Issues: Particulate Matter (PM) Methods Total PM, Total PM2.5 not calculated correctly Wrong fractions included in totals Values entered as wrong parameter Method 5/29 PM data not reported Method 5 filter temperatures incorrect Run with Method 29 or OTM-27: use normal filter temperature of 248± 25ºF Run with OTM-28 for a wet stack: use 320± 25ºF (equivalent to Method 5B) 13

14 Common Critical Issues: Dioxin/Furan/PCBs Other dioxin/furans not reported Sum of congeners in a group that are not chlorinated at the 2,3,7,8- position, e.g., Other-PCDD. Labs don t report this you need to calculate it from Totals toxic congeners PCBs elevated in method or field blanks: blank-subtract or at least flag these data 14

15 Common Critical Issues: Potential Organic Surrogates Method 25A (Total Hydrocarbons) Zero gas readings sample readings Detection limits not reported Sampling line temperature too low or not reported Method 18 (Methane) Detection limits not reported for bag analyses Data not entered into EPA Emissions spreadsheet 15

16 Common Critical Issues: Detection Limit Reporting EPA detection flags (ADL, BDL, DLL) not entered or incorrect ADL: above detection limit BDL: below detection limit DLL: detection level limited (for methods w/multiple fractions) Detection limit values coded incorrectly in EPA Emissions Spreadsheet ( < rather than [<] ) Note: Derivation of detection limits usually not provided 16

17 Entering Non-Detect Values Entering Nondetects into the ERT Entering Nondetects into the EPA Emissions Spreadsheet 17

18 Improving the ICR Database: Whose Job? EPRI Identify issues Publicize common and critical problems Calculation errors Reporting errors Field or laboratory issues ICR Facilities Follow up with testers/labs on EPRI findings Revise electronic files if necessary Document rationale for revision EPA indicated they will accept revised data until Sept ~5? Send corrected files to EPRI after submittal to EPA 18

19 EPRI Public Website: 19

20 Schedule: Time is of the Essence Tier 1 Reports to EPA: July ~5 Tier 2 Reports to EPA: August ~5 Tier 3 Reports to EPA: September ~5 20

21 How to Participate in EPRI Data Review Voluntary No cost to participate Send to Facilities reporting (ORIS Code, Units) Test dates and ICR due dates Expected dates of transmittal to EPRI Contact information EPRI will respond with Instructions for file transfer List of files required Terms and conditions 21

22 Together Shaping the Future of Electricity 22