by Pamela Berner – Director, NAES Environmental Services

One of the primary functions of our NAES Environmental Services (ES) group is to provide regulatory guidance  and training for the plant personnel responsible for environmental compliance. In mid-March, ES hosted training on the EPA’s 40 CFR Part 75 regulations. We had a very successful turnout of over 70 attendees, including NAES-operated plant environmental contacts, CEMS technicians and corporate environmental specialists. This year, we opened the training to non-NAES operated plants and owner representatives that had an interest in expanding their Part 75 knowledge, which brought in 12 additional attendees who joined us at a meeting facility near Old City Philadelphia.

Many NAES-operated plants are regulated under the Acid Rain Program, a federal ‘cap-and-trade’ program created by Congress in 1990 to reduce emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx), the primary causes of acid rain. Under cap-and-trade programs, emissions allowances must be obtained by each facility to cover the actual emissions released, as carefully measured, calculated and reported quarterly throughout the year. Among other things, the cap-and-trade programs require power plants to measure the air emissions they release using continuous emission monitoring systems (CEMS). CEMS are sophisticated analytical instruments and data acquisition systems that continuously sample the emissions as they exit plant stacks.

Part 75 includes the rules  on how the CEMS are to be  certified, how the data is to  be collected, which quality  assurance/quality control measures must be employed, and what recordkeeping and reporting requirements must be followed.

The first two days of training, conducted by VIM Technologies, reviewed Part 75 in detail, including monitoring requirements, Appendix D, E, and G alternate monitoring requirements, data validation and missing data substitution procedures, initial certification  and recertification requirements, ongoing QA/QC requirements, electronic data reporting and ECMPS, the online EPA emissions reporting software the plants must use to complete their reporting.  This time around, we included a third day of training presented by CEM Solutions that provided a focused look at practical implementation tips for I&E technicians as well as an overview of the Part 75 recertification and diagnostic test policy, a recertification timeline and a brief review of common sampling systems how to troubleshoot them.

We’ve also provided access to this training via NAESHARE to ensure that all the plants subject to Part 75 that were unable to attend this year would get a chance to review and hopefully benefit from it.