cED
    FEB
    022009
    IN
    THE
    MATTER
    OF:
    L1tt
    OF
    Control
    ILLINOIS
    Board
    PROPOSED
    NEW 35
    ILL. ADM.
    CODE
    225,
    CONTROL
    OF EMISSIONS
    FROM
    LARGE
    COMBUSTION
    SOURCES
    (MERCURY
    MONITORING)
    NOTICE
    OF
    FILING
    To:
    Those
    Individuals
    Listed on
    Attached
    Service List
    Please take
    notice
    that on
    February
    2, 2009,
    the
    undersigned
    caused to
    be
    filed
    with
    the
    Clerk
    of the Illinois
    Pollution
    Control
    Board the Testimony
    of David
    Nuckols
    on behalf
    of
    Kincaid
    Generation
    LLC, copies
    of which
    are
    herewith
    David
    L. Rieser
    Brad
    Daniels
    McGuireWoods
    LLP
    77
    West Wacker,
    Suite
    4100
    Chicago,
    IL
    60601
    Telephone:
    312/849-8100
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    R09-010
    (Rulemaking
    — Air)
    One
    \7363650. I

    CEVE
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    CLERKS
    OFFICr
    IN
    THE
    MATTER
    OF:
    )
    No.
    R09-O1O
    FEB
    022009
    )
    (Rulemaking
    -AirTATE
    OFILLIN
    PROPOSED
    NEW
    35
    ILL.
    ADM.
    CODE
    225
    )
    llUtiOfl
    Controj
    CONTROL
    OF
    EMISSIONS
    FROM
    )
    LARGE COMBUSTION
    SOURCES
    (MERCURY
    )
    MONITORING)
    TESTIMONY
    OF
    DAVID
    NUCKOLS
    KINCAID
    GENERATION
    LLC
    My
    name
    is
    David
    Nuckols
    and
    I
    am
    Manager
    of Dominion’s
    Emissions
    Monitoring
    Support
    Group.
    Dominion
    is one
    of the
    nation’s
    largest
    producers
    of
    energy
    with
    a
    portfolio
    of
    approximately
    27,000
    megawatts
    of
    generation.
    Dominion
    owns
    and
    operates
    electric
    generating
    facilities
    in eleven
    states,
    including
    the
    1250
    megawatt
    coal-fired
    Kincaid
    Generation
    LLC
    power
    plant,
    located
    in
    Kincaid,
    Illinois.
    Dominion
    also
    owns
    a
    50%
    interest
    in
    the
    1400-
    megawatt
    natural
    gas-fired
    Elwood
    Energy,
    LLC
    combustion
    turbine
    plant,
    located
    in
    Elwood,
    Illinois. Dominion
    has
    also
    announced
    plans
    to build
    300
    megawatts
    of
    wind
    turbines
    in
    Central
    Illinois.
    The
    project,
    Prairie
    Fork
    Wind
    Farm,
    will
    include 150
    to
    200
    wind
    turbines
    in Christian
    and
    Montgomery
    Counties.
    My
    group
    provides
    support
    for
    the
    continuous
    emissions
    monitors
    at
    most
    of
    the
    Dominion
    power
    plants,
    including the
    two
    units
    at
    Kincaid.
    We
    also
    provide
    test
    services
    for
    many
    of
    the
    Dominion
    sites
    and
    have
    interim
    accreditation
    as
    an
    Air
    Emissions
    Testing
    Body
    (AETB)
    by
    the
    Stack
    Testers
    Accreditation
    Council
    (STAC).
    I received
    my
    B.S.
    in
    Engineering
    from
    Virginia
    Tech
    in
    1975
    and
    am
    licensed as
    a Professional
    Engineer in
    the
    State
    of
    Virginia.
    During
    my
    33-
    year
    career
    at
    Dominion,
    I
    have
    worked at
    several
    power plants
    and
    as
    Staff
    Engineer
    for
    the
    engineering
    groups
    that
    support
    power
    plant
    operation and
    construction.
    I have
    worked
    in
    the

    area
    of continuous
    emissions
    monitoring
    systems
    since
    1992
    and
    have
    served
    in
    my
    current
    role
    since
    2001.
    Introduction
    We
    believe
    IEPA
    has
    been
    very
    receptive
    to
    Dominion
    concerns
    regarding
    the
    proposed
    monitoring
    rules.
    Dominion
    provided
    comment
    on the
    draft
    proposal
    last
    July
    as part
    of
    the
    TEPA
    stakeholder outreach
    efforts.
    Several
    very
    important
    changes
    were
    made
    to the
    proposal
    during
    that
    round
    of
    comment
    including:
    o The
    removal
    of
    the
    “data
    substitution”
    provisions based
    on the
    40
    CFR
    Part
    75
    rules,
    which
    were
    developed
    to
    support
    an
    emissions
    trading
    program.
    The
    Illinois
    mercury
    rule
    is
    more
    of a “command
    and control”
    regulation
    with
    a
    “hard”
    emissions
    limit.
    Therefore,
    certain
    aspects
    of
    40
    CFR
    Part
    75
    are
    inappropriate
    for
    inclusion
    in
    the
    Illinois
    regulation,
    including
    the
    missing
    data
    substitution
    procedures
    for
    mercury
    continuous
    emissions monitors
    (75.38)
    and
    for
    sorbent
    trap
    monitoring
    systems
    (75.39).
    JEPA
    agreed
    with
    this proposed
    change
    and withdrew
    these
    provisions.
    o The
    removal
    of the
    bias
    adjustment
    factor,
    also
    based
    on
    USEPA’s
    Part
    75
    rules.
    In
    our
    July
    comments,
    Dominion
    recommended
    IEPA
    withdraw
    the bias
    adjustment
    factor
    provided
    for in
    §2.3.4
    of Appendix
    D
    of
    40
    CFR
    Part
    75.
    USEPA’s
    Part
    75 rules
    require
    that
    the monitor
    values
    be
    adjusted
    upward
    when
    the
    readings
    are
    lower
    than
    the
    reference
    method
    results.
    However,
    USEPA
    does
    not
    allow
    the
    values
    to
    be adjusted
    downward
    when
    the
    readings
    are
    higher
    than
    the
    reference
    method
    results.
    USEPA
    describes
    its
    unidirectional
    of the
    bias
    test
    as a
    policy
    decision,
    consistent
    with
    an
    emission
    trading
    program. Again,
    IEPA
    agreed
    to
    withdraw
    the bias
    adjustment
    factor.
    -2-

    o A
    decrease
    in
    the
    data
    availability
    requirements
    from
    80%
    to 75%.
    Dominion,
    and
    others,
    stated
    that
    it
    would
    be difficult to
    achieve
    an
    80%
    data
    availability
    given
    the
    current
    state
    of the
    mercury
    monitoring
    technology.
    JEPA
    responded
    by
    lowering
    the
    data
    availability
    from
    80%
    to
    75%.
    While
    this
    is a
    good
    start,
    as
    I discuss
    below,
    we
    reconunend
    that
    further
    flexibility be added
    to
    this
    requirement.
    Dominion
    supports
    these
    changes and
    applauds
    IEPA’s
    cooperative,
    practical
    consideration
    of
    Dominion’s and
    the other
    affected
    companies’
    comments
    during
    the
    stakeholder
    process.
    Nevertheless,
    our experience
    is
    that it
    will
    be
    extremely
    difficult
    to
    operate
    these
    monitors
    and to
    keep
    them
    operating
    for
    sufficient
    periods
    of time
    to
    ensure
    compliance
    with
    the
    proposed
    monitoring
    provisions.
    We
    have
    been
    operating
    these
    monitors
    at
    a number
    of
    our facilities
    for
    over
    a year
    and
    are well
    qualified to testify
    to
    the
    reliability
    and
    maintenance
    issues
    involved
    in
    the
    day-to-day
    operations
    of these
    systems.
    Because
    of the
    problems
    associated
    with
    the
    current
    state
    of
    this technology, Dominion
    urges
    the
    Illinois
    Pollution
    Control
    Board
    to adopt
    as
    much
    flexibility
    as
    possible
    in
    these
    rules.
    We
    have
    included
    in this
    testimony
    several
    suggestions
    on
    how
    that
    might
    be accomplished.
    I. Background
    Dominion
    Resources,
    Inc.
    owns
    and
    operates
    electric
    generating
    facilities
    in
    eleven
    states,
    including
    the
    1250
    megawatt coal-fired
    Kincaid
    Generation LLC
    power
    plant,
    located
    in
    Kincaid,
    Illinois.
    The
    company’s
    assets
    include
    about
    27,000
    megawatts
    of
    power
    generation,
    6,000
    miles
    of electric
    transmission,
    14,000
    miles
    of
    natural
    gas
    transmission
    pipeline
    and
    the
    nation’s
    largest
    natural
    gas
    storage system,
    with
    more
    than
    975
    billion
    cubic
    feet
    of storage
    capacity.
    -3-

    The Kincaid
    plant
    has compiled
    an
    exemplary
    environmental
    compliance
    record.
    Since
    Dominion
    purchased
    the plant
    in 1998, the
    plant has
    received
    no
    environmental
    violations
    and
    has
    cut sulfur
    dioxide and
    nitrogen
    oxide
    emissions
    drastically
    from
    pre-1998
    levels.
    Kincaid
    was awarded
    the
    2007 Illinois
    Association
    of Water
    Pollution
    Control
    Operators
    (IAWPCO)
    Wastewater
    Treatment
    Plant
    ofthe
    Year award
    in the Industrial
    or
    Class K
    division.
    This
    honor
    is
    given, in
    conjunction
    with
    the
    Illinois
    Environmental
    Protection
    Agency
    (IEPA),
    at
    the annual
    IAWPCO
    conference.
    Kincaid
    Station
    was
    nominated
    for
    the
    award
    by
    the IEPA
    as
    one of four
    finalists
    out
    of the
    1,594
    industrial
    wastewater
    treatment
    facilities
    in the
    State
    of
    Illinois.
    Kincaid
    Station was
    recognized
    for excellence
    in
    operating
    the
    facility
    resulting
    in no
    permit
    excursions
    in
    2006.
    In 2008,
    Kincaid applied
    for and received
    a
    permit
    from
    the
    JEPA
    to
    construct
    activated carbon
    injection
    (ACI)
    equipment
    for
    mercury
    emissions
    control
    at both
    Kincaid
    units.
    That
    construction
    is progressing
    and we expect
    the ACI
    installation
    to
    be complete
    during
    March,
    2009, well
    before the
    July
    1, 2009
    deadline
    for compliance
    with
    the
    Illinois
    mercury
    rules.
    II. Discussion
    of Dominion
    experience
    with mercury
    monitors
    The available
    suppliers
    of
    mercury CEMS
    (continuous
    emissions
    monitoring
    systems)
    monitors
    are
    very
    limited.
    Currently,
    only
    two companies
    provide
    most of
    the
    mercury
    CEMS
    installed
    at
    utility
    plants, Thermo
    Fisher
    Scientific
    and
    Tekran
    Instrument
    Corp.
    After evaluating
    both
    systems,
    including
    temporary
    installations
    of
    the
    systems
    at
    Dominion
    power
    plants, we
    have
    chosen
    the Tekran
    system
    for
    all
    of
    our
    continuous
    monitoring
    sites.
    -4-

    Dominion
    has since
    installed
    12
    mercury
    CEMS
    and
    three
    sorbent
    trap
    systems
    in
    response
    to
    state
    requirements
    or for
    compliance
    with
    the
    now vacated
    Clean
    Air
    Mercury
    Rule
    (CAMR).
    My group
    provided
    technical
    oversight
    and startup
    support
    for the
    installation
    projects.
    We
    also
    participated
    in
    the
    mercury
    calibrator
    study conducted
    by
    RMB
    Consulting
    for USEPA
    and EPRI
    (Electric
    Power
    Research
    Institute)
    with two
    systems.
    My
    group
    owns
    and
    operates
    four
    Reference
    Method
    30B
    systems
    and
    has
    conducted
    mercury
    testing
    at
    most
    of Dominion’s
    sites.
    Although
    we
    have
    been
    generally
    successful
    in
    installing
    and
    operating
    the mercury
    CEMS,
    there
    are
    significant
    issues
    and
    challenges
    for
    us
    and
    the utility
    community
    to
    overcome.
    Much
    of the
    hardware
    used
    for these
    systems
    is
    new
    and
    unproven.
    Many
    of
    the
    components
    are
    modified
    for conventional
    CEMS,
    but are
    much
    more
    complex
    and
    operating
    under
    much
    more
    demanding
    requirements. CEMS
    for
    S02, NOx
    and
    C02 are
    comparatively
    simple,
    consisting
    of
    a
    dilution
    probe,
    unheated
    umbilical,
    analyzer,
    sample
    controller,
    and
    calibration
    gas
    cylinders.
    The
    pollutants
    are
    relatively
    high
    level
    in
    parts
    per
    million
    or
    percent
    of
    volume
    and
    generally
    non
    reactive
    with
    many
    materials.
    Mercury
    is
    very
    reactive
    with
    most
    metals
    typically
    used
    for
    probes
    and
    filters,
    so everything
    in contact
    with
    the
    sample
    must be
    glass
    coated
    or PFA
    TEFLON.
    Mercury
    is
    present
    in
    much
    lower
    concentrations
    than
    the
    other regulated
    gases
    (1
    ug/m
    3
    is
    approximately
    120 parts
    per
    trillion)
    and
    is
    present
    in two
    forms,
    elemental
    (Hg°) and
    oxidized
    (Hg
    generally
    HgC1
    2
    ).
    If
    the sample
    is
    not
    kept
    very hot
    the
    oxidized
    Hg
    will stick
    to
    the
    transport
    materials
    and
    not
    make
    it
    to
    the
    analyzer.
    Also,
    all the
    Hg
    must
    be converted
    to
    elemental
    Hg
    to
    be
    measured
    by
    the
    Hg
    analyzer.
    Because
    of the
    reactive
    nature
    of Hg,
    calibration
    gas
    cylinders
    are
    not
    stable
    and
    very
    expensive,
    so
    the system
    must
    generate
    its
    own
    calibration
    gases.
    Inert
    gases,
    such
    as
    ultra-pure
    Argon
    or
    nitrogen
    and
    de-ionized
    water
    are
    -5-

    needed to
    carry
    and
    wash
    the
    sample.
    These
    issues
    make
    the
    Hg
    CEMS
    a
    complex
    system
    of
    many
    components
    that
    must
    work
    precisely
    together
    to obtain
    accurate
    measurements.
    The
    complexity
    of
    the
    measurement
    requirements
    and
    the
    multitude
    of
    components
    needed
    to
    make
    it
    all
    work,
    make
    the
    systems
    fragile
    and
    difficult
    to maintain.
    The
    following
    is
    a
    list
    of
    some
    of
    the
    significant
    issues
    we
    have
    encountered:
    1)
    Umbilical
    Failures:
    The
    bundle of
    tubes
    and
    wires
    that
    transport
    the
    mercury
    sample
    collected from
    the
    power
    station
    smoke
    stack
    to
    the
    mercury
    analyzer
    housed
    on
    the
    ground is called
    an
    “umbilical”.
    A heater
    strip
    runs
    beside
    the
    tubes
    to
    keep
    the
    sample
    inside the
    tubes
    hot,
    and
    the
    whole
    bundle
    is
    insulated.
    Most
    of
    the
    umbilicals
    are
    installed up
    the
    outside
    of the
    stack
    in
    cable
    trays
    and
    are
    200
    feet
    to
    450
    feet
    in
    length.
    It
    is
    the
    single-most
    difficult
    and
    expensive
    component
    of the
    mercury
    CEMS
    to
    replace.
    Five
    of
    the
    thirteen
    umbilicals
    that
    Dominion
    has
    placed
    in
    service
    have
    experienced
    fatal
    failures and
    had
    to
    be
    replaced.
    Umbilicals
    used
    in
    the
    Tekran
    systems
    have
    PFA
    TEFLON
    tubes
    and
    Tekran
    originally
    recommended
    that
    they
    be
    operated
    at
    180°C,
    (356
    °F)
    which
    is very
    near
    the
    melting
    point
    of
    PFA.
    Due
    to
    the
    number
    of
    failures,
    however,
    Tekran
    has
    withdrawn
    this
    recommendation
    but
    has
    not
    developed
    an
    alternative
    operational
    temperature.
    Several
    of
    these
    failures
    occurred
    after
    nearly
    a
    year
    of
    operation.
    They
    are
    engineered
    and
    manufactured
    for
    specific
    site
    specifications
    and
    delivery
    is
    typically
    4 to
    12
    weeks.
    Installation
    requires
    specialized
    equipment
    and
    craft
    to
    remove
    the
    damaged
    umbilicals
    and
    re-pull
    and
    hang
    the
    replacement.
    Assuming
    weather
    is
    not
    an
    issue,
    this
    typically
    will
    take
    a
    week
    to
    complete.
    In
    anticipation
    of this
    potentially
    extended
    downtime
    for
    umbilical
    failure,
    Dominion
    has
    installed a
    “spare
    -6-

    backup”
    umbilical
    at
    all
    sites,
    however
    we
    had
    one
    of
    our
    backup
    umbilicals
    also
    fail
    and
    the
    system
    was
    down
    for
    weeks.
    2)
    Umbilical
    Temperature
    Control:
    In
    addition to
    the
    umbilical
    failures,
    we
    are
    having
    problems
    with
    temperature
    control
    along
    the
    length
    of
    the
    umbilical.
    We
    installed
    multiple
    sensors in
    the
    length
    of
    the
    umbilical
    and
    see
    differences
    of
    as much
    as
    40°C
    between
    points. The
    sample
    temperature
    has
    to
    be
    maintained
    high
    enough
    to
    prevent loss
    of oxidized
    Hg
    sample.
    We
    are
    currently
    working
    with
    the
    vendors
    to
    resolve
    this
    issue.
    3)
    Probe
    Heater
    Failure: We
    had
    one
    probe
    heater
    fail,
    which
    had
    to
    be
    returned
    to
    the
    manufacturer
    for
    repair. The
    system
    has
    been
    down
    since
    mid-December
    2008
    and
    we
    do
    not
    have
    the
    repaired parts
    yet.
    Another
    probe
    overheated
    and
    melted
    the
    filter
    and
    gaskets
    resulting in
    more
    than
    a
    week
    of
    downtime.
    4)
    Oxidized
    Mercury Calibrator:
    Dominion
    also
    had
    an
    oxidized
    mercury
    calibrator
    fail
    at
    one
    of
    our
    sites
    and
    it
    had
    to be
    returned to
    the
    manufacturer.
    That
    system
    has
    been
    operating
    without
    conducting
    system
    integrity
    tests
    since
    late
    September
    2008
    and
    the
    calibrator had
    to
    be
    sent
    to
    Canada
    and
    has
    not
    yet
    been
    returned.
    5)
    Sample
    Pump
    Failure:
    Sample
    pumps
    were
    not
    recommended
    as
    spare
    parts;
    and
    the
    pump
    took
    a
    week
    to
    be
    shipped
    from
    Canada.
    6)
    System
    Contamination:
    Problems
    with
    the
    argon
    and
    water
    supply
    caused
    contamination.
    It
    took
    almost
    5
    days
    to
    return
    to
    service.
    7)
    Failed
    System
    Integrity Tests:
    The
    System
    Integrity
    Test
    was
    the
    most
    failed
    QA
    test
    for
    the
    units
    that
    conduct
    them.
    We
    recorded
    from
    80
    to
    150
    hours
    downtime
    per
    system
    in
    -7-

    2008
    due to
    failed integrity tests. The
    technicians
    manually
    control the test
    each week to
    make sure they work properly and
    to minimize
    downtime.
    There
    are
    very limited vendor resources to
    support these
    systems.
    With
    the
    vacatur
    of CAMR,
    the
    mercury
    CEMS market is very
    unclear and vendors do
    not
    appear
    to
    be
    willing
    to
    invest in
    sufficient qualified personnel. Additionally, they
    have a captive
    market, where
    there
    is
    virtually
    no competition or other source of
    expertise. Most service must be
    scheduled
    weeks in
    advance
    and with the technicians traveling on Mondays and
    Fridays,
    they
    provide only 3 days
    of work per
    week.
    The
    mercury CEMS are new and relatively
    complex
    systems,
    primarily due to
    the reactive nature
    of mercury and the extremely low levels of
    concentrations in utility
    boiler exhaust gases.
    It has
    taken at least
    a
    year for competent, trained technicians
    that work on
    mercury CEMS
    consistently
    to be able to do non-routine diagnostics
    on these systems. Most
    technicians,
    unless dedicated to
    operating and maintaining these systems, will not be
    able
    to
    perform
    more than routine
    maintenance,
    and
    will
    require outside
    expertise
    to
    diagnose and
    repair
    non-routine
    problems.
    III. Dominion urges the IPCB to incorporate as much
    flexibility as
    possible into the Illinois
    mercury
    monitoring rules.
    Because of the experiences we have described above, we have
    concerns
    about
    our ability to
    maintain compliance with the current mercury
    monitoring proposal. Our
    experience indicates
    that
    failures with these systems
    can
    result in
    weeks of downtime and
    will result in our inability to
    demonstrate compliance.
    We offer the
    following suggestions:
    -8-

    A. Data
    availability
    should
    be based
    on
    a
    12-month
    period.
    Section
    225.260
    specifies
    that
    monitor
    availability
    be
    determined
    on
    a
    calendar
    quarter
    basis
    in accordance
    with
    Section
    1.8
    of
    Appendix
    B
    following initial
    certification
    of the
    required
    C02,
    02,
    flow
    monitor,
    or
    mercury
    concentration
    or moisture
    monitoring
    system(s)
    at
    a particular
    unit
    or stack
    location.
    We
    do
    not
    believe
    demonstration
    of
    compliance
    with
    a
    12-month
    rolling
    average
    emissions standard
    should
    be
    based
    on data
    availability
    calculated
    over
    only
    one
    fourth
    of
    the
    compliance
    period.
    It
    should
    be based
    on
    the
    availability
    over
    the
    compliance
    period.
    The
    acid
    rain
    monitoring program,
    under
    40 CFR
    Part
    75
    and which
    much
    of
    the
    Illinois
    proposed
    mercury
    monitoring
    program
    is based,
    calculates
    data
    availability
    for
    missing
    data
    purposes
    over
    8760
    operating
    hours,
    or
    3
    years.’
    The
    40
    CFR
    Part
    60
    rules
    (relating
    to
    monitoring
    requirements
    for
    new
    or
    modified
    sources)
    generally
    require
    75%
    data
    capture
    over
    the averaging period
    for
    long
    term
    rolling
    averages,
    (such
    as
    22
    days
    of
    a
    30
    day
    average).
    We
    believe
    the
    compliance determination
    for
    the monitoring
    systems
    should
    be
    based
    on
    the
    same
    period
    as
    the mercury
    emissions
    standard,
    which
    is a
    12-
    month
    rolling
    average.
    2
    We
    also
    recommend
    that
    special
    consideration
    should
    be
    offered
    for
    the
    first
    12 months
    of
    operation
    which
    is
    likely
    to be
    the
    most
    difficult
    period
    to
    achieve
    reliable
    operation. This
    can
    be accomplished
    by
    removing
    any
    specific
    data
    availability for the
    first
    12
    months.
    Until
    a full
    12 months
    of data
    is
    collected,
    the
    number
    40
    CFR
    Part
    75.32,
    “Determination of
    monitor
    data
    availability for
    standard
    missing
    data procedures”
    2
    Title
    35,
    Subtitle
    B,
    Chapter
    I,
    Subchapter
    c,
    Part
    225
    “Control
    of
    Emissions
    from
    Large
    Combustion
    Sources”,
    Section
    225.230,
    “Emission
    Standards
    for
    EGUs
    at Existing
    Sources.”
    -9-

    of
    possible
    hours
    in
    the
    calculation
    is
    smaller,
    giving
    each
    hour
    of downtime
    more
    weight,
    making
    it
    more
    difficult to
    meet
    an
    availability
    requirement.
    There
    would
    be
    strong incentive
    to achieve
    high
    availability,
    since
    these
    hours
    would
    be
    used
    in
    calculating
    the
    rolling
    availability
    following
    the
    first
    12
    months.
    Dominion
    believes
    there
    is
    strong
    justification
    to
    change
    this
    quarterly
    data availability
    calculation
    and
    recommends
    the
    Board
    adopt
    changes
    to
    the
    rule
    that
    would
    align
    this
    data
    availability
    calculation
    with
    the
    mercury
    emissions
    limitation
    averaging
    scheme.
    We
    offer
    the
    following
    wording
    changes:
    225.APPEND
    IX
    B
    Continuous
    Emission
    Monitoring
    Systems
    for
    Mercury
    Section 1.8
    Determination
    of
    monitor data
    availability
    a)
    Following
    initial
    ccrtJication
    and
    up
    to
    the
    first
    12
    months
    of
    operation
    of
    the
    required
    CU
    2
    ,
    02
    ,flow
    monitoring
    systems(s),
    Hg
    concentration,
    or
    moisture
    monitoring
    system(s)
    at
    a
    particular
    unit
    or
    stack
    location
    (i.E.,
    the
    date
    and
    time
    at
    which
    quality-assured
    data
    begins to
    be
    recorded
    by
    the
    CEMS(s)
    at
    that
    location),
    the
    owner or
    operator
    must
    begin
    calculating
    the
    percent
    monitor
    data
    availability
    as
    described
    in
    paragraph (a)(1)
    ofthis
    Section, by
    means
    of
    the
    automated
    data
    acquisition
    and
    handling
    system,
    and
    the
    percent
    monitor
    data
    availability
    for
    each
    monitored
    parameter.
    1)
    Following
    initial
    certfi
    cation, the
    owner
    or
    operator
    must
    use
    Equation
    8
    to
    calculate,
    hourly, percent
    monitor
    data
    availability
    for
    each
    calendar
    quarter
    12
    month
    period.
    -10-

    Total
    unit
    operating
    hours
    Percent
    For
    which
    quality-assured
    data
    monitor
    data
    was
    recorded
    for
    the
    for
    the
    calendar
    quarter
    12-month
    period
    X
    100
    (Eq.
    8)
    availability
    Total
    unit
    operating
    hours
    for
    the
    calendar
    quarter
    12-month
    period
    B.
    The
    final
    percent
    data
    availability
    standard
    should
    be
    phased
    in
    to
    75%.
    Section
    225.260
    of
    the
    JEPA
    mercury
    rules
    (“Out
    of Control
    Periods
    and
    Data
    Availability for
    Emission
    Monitors”)
    requires
    “[c}ompliance
    with
    the
    percent
    reduction
    standard in Section
    225.230(a)(1)(B)
    or
    225.237(a)(1)(B)
    or
    the
    emissions
    concentration
    standard in
    Section
    225.230(a)(1)(A)
    or
    225.237(a)(1)(A)
    can
    only
    be
    demonstrated
    if
    the
    monitor
    data
    availability
    is
    equal
    to
    or greater
    than
    75
    percent;
    that
    is,
    quality
    assured
    data
    must
    be
    recorded
    by a
    certified
    primary
    monitor,
    a
    certified
    redundant
    or
    non-redundant
    backup
    monitor,
    or reference method
    for
    that
    unit
    at
    least
    75
    percent
    of
    the
    time
    the
    unit
    is
    in
    operation.”
    3
    As
    we
    have
    stated
    previously, we
    recognize
    this
    represents a
    favorable
    change
    from
    the
    IEPA
    initial
    draft
    of these
    rules.
    However,
    given
    the
    difficulty
    Dominion has
    encountered,
    as described
    here,
    during
    the
    initial
    phases
    of implementation
    of our
    mercury
    monitoring program,
    we believe a phase-in
    of
    the
    75%
    data
    availability
    requirement
    is
    warranted. We
    suggest
    the
    JEPA
    program
    begin
    with
    a
    65%
    data
    availability
    requirement
    in
    July
    2010
    rising
    to
    a
    75%
    standard in July
    2011.
    We
    offer
    the
    following
    wording changes:
    Section 225.260
    “Out
    of
    Control
    Periods
    and
    Data
    Availability
    for
    Emission
    Monitors”
    IBID,
    Section
    225.260(b)
    —11—

    b)..
    “Compliance
    with
    the
    percent
    reduction
    standard
    in
    Section
    225.230(a)
    (1) (B),
    225.233(d) (1) (B)
    or
    (d)(2)(B),
    225.237(a)
    (1)
    (B)
    or
    225.294(c)
    (2),
    or the
    emissions
    concentration
    standard
    in
    Section
    225.230(a)
    (1)
    (A)
    or
    225.237(a)
    (1) (A)
    can
    only
    be
    demonstrated
    fthe
    monitor
    data
    availability
    is equal
    to
    or greater
    than
    65
    percent
    following
    the
    first year
    the
    rule
    is
    effective
    (July],
    2010)
    and
    increasing
    to
    75 percent
    the
    next
    year
    starting
    July],
    201];
    that
    is, quality
    assured
    data
    must
    be recorded
    by
    a
    certfiedpriinary
    monitor,
    a
    cerqfied
    redundant
    or
    non-redundant
    backup
    monitor,
    or
    reference
    methodfor
    that
    unit
    at
    least
    65
    percent
    for
    the
    first
    year
    (July],
    2010
    through
    June
    30,
    20]])
    and
    75 percent
    ofthe
    time
    the
    unit is
    in
    operation
    after
    that
    first
    year.”
    C. The
    January
    14,
    2009
    revision
    to Appendix
    B Section
    1.7
    added
    weekly
    system
    integrity
    tests
    as
    an “out-of-control
    period”.
    Exhibit
    B of
    Appendix
    B
    Section
    2.6
    also
    specifies
    failed
    integrity
    tests
    as
    an “out-of-control
    period”.
    These
    tests
    are
    difficult
    to
    pass
    and we
    ask
    the
    Board
    to
    consider
    less
    stringent
    criteria.
    We
    have
    found
    the
    system
    integrity
    test
    to
    be very
    difficult
    to
    meet
    on a
    weekly
    basis
    and
    believe
    it
    will
    create
    significant
    additional
    out-of-control
    periods
    with
    the
    current
    technology.
    This
    test
    is different and much
    more
    difficult
    than
    the
    linearity
    because
    it
    requires
    oxidized
    Hg
    standards.
    Based
    on
    our experience, we
    request
    more
    reasonable
    criteria
    than
    the
    10%
    of the
    reference
    value
    or
    0.8
    ug/m
    3
    absolute
    difference
    specified
    in
    the
    Section
    3.2(c)
    of Exhibit A to
    Appendix
    B for
    weekly
    checks.
    We
    recommend
    expanding
    the
    requirements to
    allow
    these
    limits
    to
    be
    considered
    a
    “maintenance
    limit”
    and having
    the
    out-of-control
    limits
    at twice
    the linearity
    standard
    or 20%
    and
    1.6
    ug/m
    3
    .
    We
    also
    recommend
    that additional
    time
    be
    allowed
    between
    tests
    before
    the
    system
    is
    -12-

    considered
    out-of—control.
    The
    weekly
    criteria
    are
    specified
    as
    168
    operating
    hours,
    which does
    not
    allow
    for
    flexibility
    in running
    the
    tests.
    We
    typically
    manually
    initiate
    the
    test
    to
    make sure
    the
    system
    operates
    correctly
    and
    so
    that
    they
    can
    take
    immediate
    action
    if
    there
    are
    problems.
    They
    would
    have
    to
    be
    available
    the
    same
    day
    and
    hour
    each
    week
    to
    keep
    the
    system
    on
    the
    same
    schedule.
    This
    request
    is
    similar to
    having 26
    hours
    to
    conduct
    a daily
    calibration.
    We
    suggest the
    following
    change
    to
    Section
    2.6
    of
    Exhibit B
    Appendix
    B:
    2.6
    System
    Integrity
    Checks
    for
    Mercury
    Monitors
    For
    each
    mercury
    concentration
    monitoring
    system
    (except
    for
    a
    mercury
    monitor
    that
    does
    not
    have
    a converter),
    perform
    a
    single-point
    system
    integrity
    check
    weekly,
    i.e.,
    approximately
    at
    least
    once
    every 168
    unit
    or stack
    operating
    hours,
    using
    a
    NIST
    traceable
    source of
    oxidized
    mercury.
    Perform
    this
    check
    using
    a
    mid-
    or
    high-level
    gas
    concentration,
    as
    defined
    in
    Section
    5.2
    of
    Exhibit A
    to
    this
    Appendix.
    The
    measurement
    error
    must
    not
    exceed
    twice
    the
    performance
    specIcations
    in subsection
    (3)
    ofSection
    3.2
    of
    Exhibit
    A
    to this
    Appendix
    must
    be
    met,
    otherwise
    the
    monitoring
    system
    is
    considered
    out-of-control,
    from
    the
    hour
    of
    the
    failed
    check
    until
    a subsequent
    system
    integrity check
    is passed. If
    a
    required
    system
    integrity
    check
    is
    not
    performed
    and
    passed
    within
    4-68-216
    unit
    or
    stack
    operating
    hours of
    last
    successful
    check,
    the
    monitoring
    system
    will
    also
    be
    considered
    out
    of
    control,
    beginning
    with
    the
    469
    th
    217th
    unit
    or
    stack
    operating
    hour
    after
    the
    last
    successful
    check,
    and
    continuing
    until
    subsequent
    system
    integrity check
    is
    passed.
    This
    weekly
    check
    is
    not
    required
    if
    the
    daily
    -13-

    calibration
    assessments
    in
    Section
    2.1.1
    of
    this
    Exhibit
    are
    performed
    using
    a
    NIST
    traceable
    source
    of
    oxidized
    mercury.
    D.
    Much
    of
    the
    JEPA
    Quality
    Assurance
    Procedures
    included
    in
    this
    rulemaking
    refer
    to
    monitors
    for
    SO
    2
    ,
    NON,
    C0
    2
    ,
    and
    flow.
    These
    should
    be
    removed.
    Dominion
    recommends
    IEPA
    remove all
    quality
    assurance
    references to
    monitoring
    procedures
    that
    are
    not
    relevant to
    mercury
    monitors.
    Duplication
    of
    these
    requirements
    will
    cause
    confusion and
    errors
    when
    the
    40 CFR
    Part
    75
    or the
    IEPA
    rules
    are
    updated
    and
    any
    requirement
    is changed.
    This
    will
    eliminate
    major
    portions
    of
    Exhibit
    B,
    Exhibit
    C
    and
    Exhibit
    D
    of Appendix
    B,
    and
    minimize
    the
    duplication of
    QA
    requirements already
    specified
    in Part
    75
    regulations.
    We
    will
    provide
    recommended
    strikethrough
    language
    of
    the
    duplicated QA
    text
    if requested.
    E.
    The
    USEPA
    has
    removed
    the
    requirements
    for
    accreditation
    of
    Air
    Emissions
    Testing
    Bodies
    (AETB)
    conducting
    relative
    accuracy
    testing
    for
    CEMS
    and
    sorbent
    traps
    from
    the
    40
    CFR
    Part
    75
    rules,
    pending
    litigation.
    4
    The
    IEPA
    rules
    referring
    to
    AETB
    should
    also
    be
    removed.
    Section
    6.1.2
    of Exhibit
    A
    to Appendix
    B
    of
    the
    JEPA
    proposed
    rules
    set
    out
    requirements
    for
    AETB
    conducting
    QA
    emissions
    testing
    on
    mercury
    CEMS.
    USEPA has
    withdrawn
    this
    portion
    of the
    40
    CFR
    Part
    75
    rules
    while
    the
    agency
    reviews
    legal
    issues
    that
    have
    been
    raised.
    The
    TEPA
    rules
    should
    withdraw
    73
    Fed.
    Reg.65554, November 4,
    2008.
    -14-

    these
    provisions
    as
    well. We
    therefore
    suggest
    the
    following
    change
    to
    Section
    6.1.2
    of
    Exhibit
    A to
    Appendix
    B:
    A..
    .
    (a)
    On
    and
    aftcr
    January],
    2009,
    any
    Air
    Emission
    Testing
    body
    (AETB)
    conducting
    relative accuracy
    test
    audits
    ofGEMS
    and
    sorbent
    trap
    monitoring
    systems
    under
    Part
    225,
    Subpart
    B,
    must
    conform to
    the
    requirements
    ofASTMD7O36
    04
    (incorporated
    by
    reference
    under
    Section
    225.1
    1Q.
    This
    Section
    is
    not
    applicable
    to
    to
    daily
    operation,
    daily
    calibration
    error
    checks,
    daily
    flow
    interference
    checks,
    quarterly
    linearity
    checks
    or
    routine
    maintenance
    of
    CEMS.
    b)
    The
    AETB
    must
    provide
    to
    the
    affected
    source(s)
    certcation
    that
    the
    AETB operates
    in
    conformance
    with,
    and
    that
    data
    submitted
    to
    the
    Agency
    has
    been
    collected
    in
    accordance
    with, the
    requirements
    ofASTMD7O36
    04
    (incorporated
    by
    reference
    under
    Section
    225.1 lOf
    This
    certification
    may
    be
    provided
    in
    the
    form of
    A
    certflcate
    of
    accreditation
    of
    relevant scope
    issued
    by
    a
    recognized,
    national
    accreditation
    body;
    or
    A letter of
    certcation
    signed by
    a
    member
    of
    the
    senior
    management
    staff
    ofthe
    AETB.
    (c)
    The
    AETB must
    either
    provide
    a
    Qualified
    individual
    on
    site
    to
    conduct
    or
    must
    oversee
    all
    relative accuracy
    testing
    carried out
    by
    the
    AETB as
    required
    in
    ASTM
    D7036 04
    (incorporated by
    reference
    under
    section
    225.1
    10,.
    The
    Qual/Ied
    Individual
    -15-

    provide
    the
    affected sour
    credentials
    relevant to
    tcstiiw
    con.
    F.
    The
    Quality Assurance
    Procedures
    for
    sorbent
    trap
    monitors
    contains
    a
    provision
    to
    multiply
    the
    results
    from
    one
    sorbent
    trap
    when
    one
    of
    the
    two
    traps
    fails.
    This
    is
    unnecessarily
    stringent
    and
    should
    be
    removed.
    Exhibit D
    to
    Appendix
    B,
    Section
    8.0
    “Quality
    Assurance
    and
    Quality
    Control”
    provides
    performance
    criteria
    for
    validating
    mercury
    emissions
    data
    from
    sorbent
    trap
    monitoring
    systems.
    For
    situations
    when
    one
    trap
    fails,
    data
    from
    the
    other
    trap
    may
    be
    used
    but
    the
    values
    must
    be
    multiplied
    by
    a
    factor of
    1.111.
    This
    is
    another
    holdover
    from
    the
    federal
    mercury
    monitoring
    program,
    designed
    for
    allowance
    trading and
    should
    be
    deleted
    for
    the
    Illinois
    rules.
    5
    We
    offer
    the
    following
    wording
    to
    effect these
    changes:
    “Exhibit
    D to
    appendix
    B
    — Quality
    assurance
    and
    Operating
    Procedures
    for
    Sorbent
    Trap
    monitoring
    Systems
    ***
    [FN**]
    Note:
    If
    both
    traps
    fail
    to meet
    the
    acceptance
    criteria,
    the
    data
    from
    the
    pair
    of
    traps
    are
    invalidated.
    However,
    f
    only
    one
    of
    the
    paired
    traps
    fails
    to meet
    this
    particular
    acceptance
    criterion and
    the
    other
    sample
    meets
    all
    of
    the
    applicable
    QA
    criteria,
    the
    results
    40
    CFR
    Part
    75.1
    5(h)(2)
    “Special
    provisions
    for
    measuring
    Hg
    mass
    emissions
    using
    the
    excepted
    sorbent
    trap
    monitoring methodology”
    -16-

    of
    the
    valid
    trap
    may
    be
    used
    for
    reporting
    under
    this
    part,
    provided
    that
    the
    measured
    Hg
    concentration
    is
    multiplied
    by
    afactor of].
    111....”
    G.
    Dominion
    supports
    the
    inclusion
    of
    an
    alternative
    to
    continuous
    emissions
    monitoring
    for
    compliance
    demonstrations,
    but
    asks
    the
    Board
    to
    make the
    alternative
    a
    permanent
    option. The
    JEPA
    rules
    include
    at section
    225
    .239
    periodic
    emissions
    testing
    as
    an
    alternative
    to the
    continuous
    emissions
    monitoring
    requirement.
    We
    are
    supportive
    of
    such
    an
    alternative
    but
    urge the
    JEPA
    to
    adopt
    this
    option
    as
    a
    permanent
    alternative
    rather
    than
    making it
    available
    only
    until
    2012.
    For
    many
    of
    the
    reasons
    we
    have
    presented
    here
    provide
    justification
    to
    make
    this
    alternative
    permanent,
    or
    extended
    to
    2015
    or
    later.
    We
    also
    suggest
    IEPA
    consider
    how
    an
    affected
    facility
    could
    “opt
    in”
    to
    this
    alternative
    after
    they
    have
    determined,
    following
    a
    good
    faith
    effort,
    that
    a
    continuous
    emissions
    monitoring
    option
    simply
    will
    not
    work
    for
    their
    application.
    These
    changes
    could
    be
    accomplished
    by
    the
    following:
    “Section
    225.239
    Periodic
    Emissions
    Testing
    Alternative
    Requirements
    a)
    ‘“‘
    3
    The
    alternative
    method
    of
    compliance
    provided
    under
    this
    subsetion
    may
    only
    be
    used
    until
    June
    30,
    2012,
    after
    which
    a
    GEMS
    (or
    an
    excepted
    /sicj
    monitoring
    system
    certified
    in
    accordance
    with
    Section
    225.250
    of
    this
    Subpart
    B
    must
    be
    used.”
    Or,
    f
    the
    alternative
    is
    extended
    to
    2015:
    -17-

    a)
    ** *
    3. The alternative
    method ofcompliance
    provided
    under
    this
    subsection
    may
    only
    be
    used until
    June 30,
    2012
    2015,
    after which
    a
    CEMS (or
    an
    excepted
    [sic]
    monitoring
    system)
    certf
    led in
    accordance with Section
    225.250
    of
    this Subpart
    B must be used.”
    Conclusion
    For the reasons
    listed above Kincaid
    requests
    this
    Board to
    adopt
    the
    changes
    we have
    identified in
    this testimony
    so
    that
    affected
    facilities
    can proceed
    expeditiously
    with
    plans for
    compliance
    with
    the
    IEPA
    rules.
    -18-

    CERTIFICATE
    OF
    SERVICE
    I,
    David
    L.
    Rieser,
    one
    of
    the
    attorneys
    for
    Kincaid
    Generation
    LLC,
    certify
    that
    I
    served a
    copy
    of
    Testimony
    of
    David
    Nuckols
    to
    thOse
    persons
    listed on
    the
    attached
    Notice
    of
    Filing
    on
    February
    2,
    2009
    electronically
    and
    by
    First
    Class
    Mail,
    postage
    prepaid.
    ets
    David
    L.
    Rieser
    Brad
    Daniels
    McGuireWoods
    LLP
    77
    West
    Wacker,
    Suite 4100
    Chicago,
    Illinois
    60601
    Telephone: 312/849-8100
    \7363650.1

    SERVICE
    LIST
    (R09-1O)
    Timothy Fox
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    100
    West
    Randolph,
    Suite
    11-500
    Chicago,
    Illinois
    60601
    foxt@ipcb.state.il.us
    JohnJ.
    Kim
    Charles F.
    Matoesian
    Dana
    Vetterhoffer
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand
    Avenue,
    East
    P.O.
    Box
    19276
    Springfield,
    Illinois
    62794-9276
    john.i
    .kim(i1linois.gov
    charles.matoesian(i11inois
    .gov
    S. David
    Farris,
    Manager,
    Environmental,
    Health
    and
    Safety
    City
    of Springfield,
    City
    Water
    Light
    &
    Power
    dana.vetterhoffer(illinois.
    gov
    201
    East
    Lake
    Shore
    Drive
    Springfield,
    Illinois 62757
    dfarris@cwlp.com
    Kathleen
    C.
    Bassi
    Stephen
    J.
    Bonebrake
    Joshua
    R.
    More
    SCHIFF
    HARDIN,
    LLP
    6600
    Sears
    Tower
    233
    South
    Wacker
    Drive
    Chicago,
    IL
    60606
    kbassi(schifthardin.com
    j
    more(schifthardin.com
    \73
    63650.1

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