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The recently published MATS reporting final regulations contained a special submission requirement for those facilities that are using PM CEM systems to demonstrate compliance. In Table 8 (Reporting Requirements), Item #13 is for PM CEM systems and states, “A test report for the PS 11 correlation test of your PM CEMS, in accordance with 40 CFR 63.10031(j).” Furthermore, “If, prior to November 9, 2020, you have begun using a certified PM CEMS to demonstrate compliance with this subpart, use the ECMPS Client Tool to submit the report, in a PDF file, no later than 60 days after that date.”

Sixty (60) days after November 9, 2020 is January 8, 2021. After reviewing 40 CFR 63.10031(j), I recommend a submission package should be prepared in a PDF format and submitted using ECMPS Client tool if the following information has not been submitted to the agency previously.

In the PDF formatted file, I would submit the data related to:

  1. The information requested from section 7.2.4 of Appendix C, along with;
  2. The applicable reference method data listed in sections 17-31 of Appendix E.
  3. The spreadsheets (actual PS-11 data and results) used to develop and select the Correlation Curves. This spreadsheet is the “USEPA Approved Evaluation Spreadsheet for PS-11 PM CEM RCAs & RRAs.”
  4. A cover letter explaining the contents of the package and what date and hour the data system began using the correlation curve to adjust the raw PM data recorded by the DAHS. I would normally expect the date and hour that the curve is first applied would be the hour following the completion of the last correlation data run.


Many of the current PM CEM systems were initially certified and operated in compliance under the terms and conditions of various consent decrees, and entered into between the facilities and the USEPA. It is my belief that the agency is gathering the appropriate certification, recertification and other quality assurance data to assure itself that these systems are up to date with all the appropriate credentials for demonstrating compliance under the MATS program.

40 CFR 63.10031(j) says,

(j) If you elect to use a certified PM CEMS to monitor PM emissions continuously to demonstrate compliance with this subpart and have begun recording valid data from the PM CEMS prior to November 9, 2020, you must use the ECMPS Client Tool to submit a detailed report of your PS 11 correlation test (see Appendix B to Part 60 of this chapter) in a PDF file no later than 60 days after that date. For a correlation test completed on or after November 9, 2020, but prior to January 1, 2024, you must submit the PDF report no later than 60 days after the date on which the test is completed. For a correlation test completed on or after January 1, 2024, you must submit the PDF report according to section 7.2.4 of Appendix C to this subpart. The applicable data elements in paragraph (f)(6)(i) through (xii) of this section must be entered into ECMPS with the PDF report.


For questions, suggestions, or for a general chat, do not hesitate to contact me.

 

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Jon Konings

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