POWER July 2016 - 30

ENVIRONMENTAL ISSUES
■ Understand the ways to establish the PM
CPMS operating limits.
■ Understand what triggers corrective action.
■ Understand how operational variables affect
PM emissions (PM CPMS output).
■ Are aware that operating limits are reset
every year or when an exceedance occurs.
Using measurement results and what's
known about the effects of unit operation on
(new or existing units), this is the operating
limit. It may be useful to adjust operating
parameters to produce PM emissions
closer to the MATS limit.
■ If the PM performance test results are below
but close or equal to 75% of MACT
limit (new units only are candidates for
extrapolation), there may be no benefit
to extrapolating to 75%. It may be useful
to adjust operating parameters to produce
PM monitors must be evaluated for each
source over a range of operating conditions.
the CPMS output, source owners can develop
a strategy for setting source-specific operating
limits that provide the facility with the
most flexibility to operate the source.
The strategy selected will depend on how
close emissions are to the PM MATS limit
under normal operations. As an example, the
following scenarios could shape the strategy
for setting the source-specific operating
limit:
■ If the PM performance test results are
above or equal to 75% of MACT limit
PM emissions closer to the MATS limit.
■ If the PM performance test results are well
below the 75% of MACT limit, extrapolate
to 75% (if the unit is a candidate) or adjust
operating parameters to produce PM emissions
closer to the MATS limits when setting
the source-specific operating limit.
Many source owners set the source-specific
operating limits near the MACT limit
because it provides more room for operational
variations, reduces the need for APCD
maintenance, and can avoid costly corrective
action exercises. But this can lead to complications.
For
example, when annual compliance
and operational limit reset time comes
around, this strategy relies on being able
to set the unit near the same emission rate
(same monitor output) for each annual test.
If the PM CPMS calibration (correlation
between the monitor output and the actual
PM emission rate) stays the same, this is
not an issue, but if it changes, there is a
chance that the facility will fail the performance
test.
This strategy usually requires some inhouse
or preliminary PM testing to verify or
confirm that the PM CPMS output as compared
to actual PM emission limits is still accurate,
especially if the target is a value very
near the MACT limit.
Cost Comparison
In addition to compliance risk, it's also important
to understand the costs associated
with each of the three approaches described.
Table 2 provides a comparison of the three
options for demonstrating compliance with
the PM standard.
FIRE YOUR WAY TO TOP
PERFORMANCE AND EFFICIENCY
Each of these approaches has advantages
and disadvantages that must be considered
when determining a MATS compliance
strategy. Working with an expert air pollution
monitoring firm allows fossil fuel-fired
power generators to develop a compliance
strategy based on sound measurement data.
Prudent power generators will capitalize on
the choice that the MATS regulations provide
when determining compliance. The source
can select a surrogate for a class of HAPs
(acid gases and non-Hg HAP metal). The
source can then choose if it wants to comply
by using manual testing methods or a pollutant
monitor and, in the case of using PM as
a surrogate for non-Hg metals and using a
PM monitor to demonstrate compliance, the
owner can choose how to use the PM monitor-as
a CEMS or a CPMS.
The success of any compliance strategy is
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POWER | July 2016
proven over time. As more data are generated
and operators understand how fuel variations
and operating parameter changes affect the
compliance status of a unit, the compliance approach
and strategy for a facility will be refined.
The U.S. industrial and regulatory communities
are investing heavily in the goal
of reducing power plant HAP emissions
through MATS. This investment and subsequent
operating history may be creating the
road map for other countries to accomplish
the same goals. ■
-Rick Krenzke (rkrenzke@trcsolutions.
com) is a project director in TRC Companies
Inc.'s Air Measurement Services
Practice in Austin, Texas.
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POWER July 2016

Table of Contents for the Digital Edition of POWER July 2016
