CEMTEK CEMS Users Group Meeting and Forum September 24-25, 2009 Santa Ana, California RKI Specific...

CEMTEK CEMS Users Group Meeting and Forum

September 24-25, 2009Santa Ana, California

RKI Specific DAHS Training and RECLAIMUpdates Presented by

Norm Iseri, RKI Engineering LLC

Copyright 2009.All Rights Reserved. RKI Engineering LLCRKI Engineering LLC

Agenda Discuss RECLAIM Regulations Present RKI PODS Screen specific to RECLAIM Question and Answer


Air Quality Regulations SCAQMD RECLAIM Rule 2011 SCAQMD RECLAIM Rule 2012 SCAQMD Rule 216

Not covered in this presentation EPA 40 CFR Part 60

Not covered in this presentation EPA 40 CFR Part 75

Not covered in this presentation


SCAQMD RECLAIM NOx/SOx RECLAIM – REgional CLean Air Incentives Market Started January 1, 1994 Businesses that beat their reduction targets can

trade their credits on the open market. Using market forces allows pollution to be cut in the most economical way.

Move away from traditional command-and-control rules

SCAQMD Rule 2011, RECLAIM SOx SO2 (ppmv), Stack Flow, SOx Lbs/hr

SCAQMD Rule 2012, RECLAIM NOx NOx (ppmv), Stack Flow, NOx Lbs/hr


CEMS/DAHS

Continuous Monitoring of emissions Perform Daily Calibration Perform other QA Activities, i.e. RATA Identify problems for alarming Display emissions for control, if required Insure valid emissions data is being collected Apply appropriate Missing Data Procedures


RECLAIM Valid Hourly Data Four (4) Valid 15-Minute Period Only four (4) Maintenance/QA Hour are valid were

the hour has between 2-3 valid 15-minute periods Maintenance/QA Hour with 2-3 valid 15-minute

periods beyond the first four hours are invalid


RECLAIM Valid 15-Minute Average Only one valid minute data is required to calculate a

valid 15-minute period All valid CEMS data are used in the 15-Minute

Average regardless of operations


RECLAIM Valid Minute Data (Part 1) CEMS data is invalid during:

Calibration in Progress Maintenance and Quality Assure Activities CEMS Out of Control Stack Flow based on Fuel Flow, O2 > 19%

Emissions between 10-95% of range Invalid when emissions is greater than 95% range Emissions limited to 10% of range when emission

drops below 10% Spike Test can be used to certify analyzer below 10%

range


RECLAIM Valid Minute Data (Part 2) Other reasons for invalid CEMS data

Missing Daily Calibration when Device had operated in the day

Missing Daily RTU transmission Failed RATA and other Failed QA activates


Emission Rate Calculations NOx Lbs/Hr = 0.1195*NOx (ppmvd)*Stack Flow

(mscfh) SOx Lbs/Hr = 0.1662*SO2 (ppmvd)*Stack Flow

(mscfh) NOx and SO2 are directly measured Stack Flow can be measured directly or calculated Calculated Stack Flow

Can be used with consistent fuel type, i.e. Natural Gas Based on fuel flow, Higher Heating Value (HHV), Fd,

O2 For natural gas, HHV default is 1050 and Fd is 8710


Relative Accuracy Test Audit Determine accuracy of CEMS, Relative Accuracy Determine Bias Adjustment Factors, 1 or greater Semi-Annual/Annual RATA

Meet Incentive – Annual RATA Failed RATA

Invalid CEMS data RECLAIM Missing Data Procedure is applied Successful RATA is required to start collecting valid

CEMS data RATA not completed within the required quarter

Request for Variance RECLAIM Missing Data Procedure still applies Successful RATA is required to start collecting valid

CEMS data


Bias Adjustment Factors (BAF) NOx/SOx BAF

NOx Bias Adjust = NOx ppmv * BAF for NOx SOx Bias Adjust = SOx ppmv * BAF for SOx

Stack Flow BAF Stack Flow Bias Adjust = Stack Flow * BAF for Stack

Flow NOx/SOx Lbs/Hr BAF (Two Methods)

Based on RATA Results NOx Lbs/Hr Bias Adjust = NOx Lbs/Hr * BAF for NOx

Lbs/Hr Based on NOx/SOx BAF and Stack Flow BAF

NOx Lbs/Hr Bias Adjust = NOx Bias Adjust * Stack Flow Bias Adjust


RECLAIM Missing Data Procedures Apply RECLAIM Missing Data Procedures (MDP)

Invalid NOx/SOx (ppmv) Invalid Stack Flow Invalid NOx/SOx Lbs/Hr: When ppmv and Stack Flow are

invalid RECLAIM Missing Data Procedures

1N Procedure Max value for previous 30 days Max value for previous 365 days Max value for the service of the CEMS

MDP Method applied is based on duration of missing data period and the % Availability

% Availability = Valid Monitoring Hours for previous 365 days/Operating Hours

for previous 365 days)


RTU Reporting Requirements RTU – Remote Terminal Unit Daily Transmission:

NOx/SOx Major Source Monthly:

NOx/SOx Major Source Aggregate NOx/SOx Large Source

Quarterly: NOx/SOx Major Source Aggregate NOx/SOx Large Source Aggregate NOx/SOx Process Units NOx/SOx Rule 219 Exempt Equipment


RTU Deadlines Daily

5 pm for the following day Additional 24 hours extension due to problems related to

power, computer, or other system failure Monthly

15 days after the end of the month Quarterly

30 days after the end of the quarter 60 days after the end of the compliance year


RTU Record Identifier There are three (3) RTU Record Identifier

ADD: 1 UPDATE: 2 DELETE: 3

The initial reported CEMS data is identified with an ADD RTU record identifier

Any subsequent ADD RTU records are rejected An UPDATE RTU record is used to correct previously

transmitted RTU record A DELETE RTU record is used in removing erroneously

RTU records


Daily RTU File Data Daily NOx/SOx Lbs to two decimal precision per Fuel

Type for each Major Source Daily CEMS Status

Valid Data - All hours are valid Calibration – Calibration was performed Offline – CEMS was in maintenance/shutdown Alternative Data – Other forms of emission recording Fuel switch – Multiple Fuel Type 10% - Reported emission using 10% range limit Below 10% - Reported emissions below 10% range limit Non-operational – Process was off


Monthly/Quarterly RTU File Data Reported NOx/SOx Lbs to two decimal precision per

Fuel Type Aggregate NOx/SOx Lbs to two decimal precision


RECLAIM Response Message Response Packet: Upon receipt of the data file, the

host will send a response packet which indicates that the data file was good, or that it was bad.

Response message for good data file: OK_ _#####_sdddlyyjjjhhmmss

Response message for bad data file: BAD_#####_[ASCII text message (up to 23 characters)]


SCAQMD Waters Website

http://www.aqmd.gov/waters


RKI PODSScreens specific to RECLAIM

RTU Transmit Status RTU Transmitted Data Major Source CEMS/RTU Reports Major Source CEMS/RTU Daily Scan Major Source Substitute Emissions Other Source RTU Reports

CEMTEK CEMS Users Group Meeting and Forum September 24-25, 2009 Santa Ana, California RKI Specific...

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