­­­­­
Forwarded
by
Walt
Stevenson/
RTP/
USEPA/
US
on
04/
28/
2006
03:
58
PM
­­­­­

Walt
Stevenson/
RTP/
USEPA/
US
04/
26/
2006
05:
47
PM
To
etoy@
omb.
eop.
gov
cc
RobertJ
Wayland/
RTP/
USEPA/
US@
EPA,
Rick
Vetter/
RTP/
USEPA/
US@
EPA,
Peter
Tsirigotis/
RTP/
USEPA/
US@
EPA
Sub
ject
LMWC
Rule
//
MWC
CEMS
text
Edmond
Here
is
the
revised
CEMS
text
that
has
been
cleared
by
the
EPA
enforcement
office.

Walt
ps
­
we
will
fix
the
text
K.
What
comments
were
received
on
the
expanded
use
of
CEMS
technology,

and
how
were
the
comments
addressed
in
the
final
rule?

In
the
proposal,
EPA
allowed
the
optional
use
of
particulate
matter
CEMS
and
requested
comment
on
the
optional
use
of
mercury
CEMS,

multi­
metal
CEMS,
hydrogen
chloride
CEMS,
and
semi­
continuous
dioxin
monitoring.
EPA
carefully
reviewed
the
comments
received.
EPA
is
supportive
of
technical
development
and
application
of
these
technologies.
In
the
final
rule,
EPA
is
allowing,
as
optional
test
methods,
the
use
of
particulate
matter
CEMS
and
mercury
CEMS.
EPA
is
not,
however,
mandating
the
use
of
these
CEMs
and
acknowledges
that
they
have
not
been
validated
on
MWCs
in
the
US.
EPA,
nevertheless,
believes
that
it
is
appropriate
to
make
this
option
available
to
MWC
owners
or
operators
and
encourages
its
use.
EPA
supports
the
installation
and
use
of
these
systems
because
of
their
ability
to
facilitate
reliable
and
accurate
performance,
as
well
as
compliance,
on
a
continuous
basis.
EPA
is
confident
that
this
option
will
be
fully
viable
by
the
implementation
date
of
these
revised
emission
guidelines.

Performance
specifications
are
available
for
these
CEMS.
The
90
percent
and
95
percent
CEMS
data
availability
requirements
do
not
apply
to
particulate
matter
CEMS
or
mercury
CEMS
use
for
the
first
2
years
of
application.
For
the
other
CEMS
(
multi­
metal,
hydrogen
chloride,
and
semi­
continuous
dioxin
monitoring),
their
optional
use
is
allowed
after
their
respective
performance
specifications
are
adopted
by
EPA.
No
dates
for
adoption
are
currently
scheduled.
­­­­­
Forwarded
by
Walt
Stevenson/
RTP/
USEPA/
US
on
04/
28/
2006
04:
00
PM
­­­­­

Walt
Stevenson/
RTP/
USEPA/
US
04/
27/
2006
02:
44
PM
To
etoy@
omb.
eop.
gov
cc
RobertJ
Wayland/
RTP/
USEPA/
US@
EPA,
Rick
Vetter/
RTP/
USEPA/
US@
EPA
Sub
ject
CEMS
/
30
day
notice
Edmond
Attached
is
the
text
with
the
edits
you
suggested.
Does
this
work
for
you
??

Walt
K.
What
comments
were
received
on
the
expanded
use
of
CEMS
technology,

and
how
were
the
comments
addressed
in
the
final
rule?

In
the
proposal,
EPA
allowed
the
optional
use
of
particulate
matter
CEMS
and
requested
comment
on
the
optional
use
of
particulate
matter
CEMS,
multi­
metal
CEMS,
hydrogen
chloride
CEMS,
and
semicontinuous
dioxin
monitoring.
Some
commenters
stated
the
CEMS
have
not
been
validated
on
MWC
units;
that
PM
CEMS
have
not
been
installed
in
any
MWC
in
the
United
States;
and
the
use
of
PM
CEMS
on
MWCs
in
Europe
are
not
indicative
of
the
appropriateness
of
their
use
in
the
United
States,
because
of
differences
in
how
CEMS
are
used
for
enforcement.

While
PM
CEMS
are
used
in
the
United
States
on
other
types
of
sources,

there
could
be
some
operational
differences
between
these
sources
and
MWCs
that
affect
the
performance
of
PM
CEMS
on
MWCs.
In
the
final
rule,
EPA
is
allowing,
as
optional
test
methods,
the
use
of
particulate
matter
CEMS
and
mercury
CEMS,
since
performance
specifications
are
available
for
these
CEMS.
In
the
regulations,
the
owners
or
operators
of
an
MWC
would
provide
EPA
a
30
day
notice
before
starting
to
use
the
CEMS
and
provide
a
30
day
notice
if
they
elect
to
discontinue
the
use
of
the
CEMS.
As
an
incentive
for
the
optional
application
of
CEMS
in
the
MWC
context,
EPA
is
modifying
the
monitoring
availability
requirements.
The
90
percent
and
95
percent
CEMS
data
availability
requirements
do
not
apply
to
particulate
matter
CEMS
or
mercury
CEMS
use
for
the
first
2
years
of
application.
For
the
other
CEMS
(
multi­
metal,
hydrogen
chloride,
and
semi­
continuous
dioxin
monitoring),
their
optional
use
is
allowed
after
their
respective
performance
specifications
are
adopted
by
EPA.
No
dates
for
adoption
are
currently
scheduled.
Walt
Stevenson/
RTP/
USEPA/
US
04/
26/
2006
05:
57
PM
To
etoy@
omb.
eop.
gov
cc
Rick
Vetter/
RTP/
USEPA/
US@
EPA,
RobertJ
Wayland/
RTP/
USEPA/
US@
EPA,
Brian
Shrager/
RTP/
USEPA/
US@
EPA
Sub
ject
LMWC
Cost
text
Edmond
Here
is
revised
text
for
the
cost
issue.
This
text
is
satisfactory
to
EPA.
Do
we
have
any
remaining
issues
??

Walt
IV.
Impacts
of
the
Final
Amendments
for
Existing
Units
The
EPA
projects
the
final
amendments
will
have
no
additional
impacts
to
air,
water,
or
energy
since
the
final
emission
limits
can
be
achieved
using
the
same
air
pollution
control
technology
that
was
used
to
comply
with
the
current
emission
limits.
Similarly,
EPA
expects
minimal
cost
and
no
economic
impact
for
the
same
reason.
Existing
large
MWC
units
will
continue
to
use
their
existing
MACT
control
technology
to
meet
the
emission
limits,
and
will
not
incur
costs
to
retrofit
equipment.
In
addition,
EPA
does
not
believe
that
the
revised
limits
will
result
in
any
increase
in
operating
or
maintenance
costs.

The
same
conclusions
apply
to
new
MWC
units
since
EPA
expects
that
new
MWC
units
will
be
equipped
with
the
same
control
technology
used
to
comply
with
the
1995
NSPS.
V.
Statutory
and
Executive
Order
Reviews
