CEMTEK CEMS Users Group Meeting and Forum September 24 …

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Transcript CEMTEK CEMS Users Group Meeting and Forum September 24 …

CEMTEK CEMS Users Group Meeting and Forum
September 24-25, 2009
Santa Ana, California
RKI Specific DAHS Training and RECLAIM
Updates Presented by
Norm Iseri, RKI Engineering LLC
Agenda
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Copyright 2009.
All Rights Reserved.
Discuss RECLAIM Regulations
Present RKI PODS Screen specific to RECLAIM
Question and Answer
RKI Engineering LLC
Air Quality Regulations
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SCAQMD RECLAIM Rule 2011
SCAQMD RECLAIM Rule 2012
SCAQMD Rule 216
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EPA 40 CFR Part 60
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Not covered in this presentation
EPA 40 CFR Part 75
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Copyright 2009.
All Rights Reserved.
Not covered in this presentation
Not covered in this presentation
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SCAQMD RECLAIM NOx/SOx
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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
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SCAQMD Rule 2012, RECLAIM NOx
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Copyright 2009.
All Rights Reserved.
SO2 (ppmv), Stack Flow, SOx Lbs/hr
NOx (ppmv), Stack Flow, NOx Lbs/hr
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CEMS/DAHS
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Copyright 2009.
All Rights Reserved.
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
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RECLAIM Valid Hourly Data
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Copyright 2009.
All Rights Reserved.
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
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RECLAIM Valid 15-Minute Average
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Copyright 2009.
All Rights Reserved.
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
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RECLAIM Valid Minute Data (Part 1)
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CEMS data is invalid during:
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Emissions between 10-95% of range
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Copyright 2009.
All Rights Reserved.
Calibration in Progress
Maintenance and Quality Assure Activities
CEMS Out of Control
Stack Flow based on Fuel Flow, O2 > 19%
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
RKI Engineering LLC
RECLAIM Valid Minute Data (Part 2)
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Other reasons for invalid CEMS data
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Copyright 2009.
All Rights Reserved.
Missing Daily Calibration when Device had operated in the day
Missing Daily RTU transmission
Failed RATA and other Failed QA activates
RKI Engineering LLC
Emission Rate Calculations
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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
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Copyright 2009.
All Rights Reserved.
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
RKI Engineering LLC
Relative Accuracy Test Audit
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Determine accuracy of CEMS, Relative Accuracy
Determine Bias Adjustment Factors, 1 or greater
Semi-Annual/Annual RATA
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Failed RATA
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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
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Copyright 2009.
All Rights Reserved.
Meet Incentive – Annual RATA
Request for Variance
RECLAIM Missing Data Procedure still applies
Successful RATA is required to start collecting valid CEMS data
RKI Engineering LLC
Bias Adjustment Factors (BAF)
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NOx/SOx BAF
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Stack Flow BAF
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NOx Bias Adjust = NOx ppmv * BAF for NOx
SOx Bias Adjust = SOx ppmv * BAF for SOx
Stack Flow Bias Adjust = Stack Flow * BAF for Stack Flow
NOx/SOx Lbs/Hr BAF (Two Methods)
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Based on RATA Results
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Based on NOx/SOx BAF and Stack Flow BAF
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Copyright 2009.
All Rights Reserved.
NOx Lbs/Hr Bias Adjust = NOx Lbs/Hr * BAF for NOx Lbs/Hr
NOx Lbs/Hr Bias Adjust = NOx Bias Adjust * Stack Flow Bias
Adjust
RKI Engineering LLC
RECLAIM Missing Data Procedures
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Apply RECLAIM Missing Data Procedures (MDP)
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RECLAIM Missing Data Procedures
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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 =
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Copyright 2009.
All Rights Reserved.
Invalid NOx/SOx (ppmv)
Invalid Stack Flow
Invalid NOx/SOx Lbs/Hr: When ppmv and Stack Flow are invalid
Valid Monitoring Hours for previous 365 days/Operating Hours for
previous 365 days)
RKI Engineering LLC
RTU Reporting Requirements
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RTU – Remote Terminal Unit
Daily Transmission:
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Monthly:
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NOx/SOx Major Source Aggregate
NOx/SOx Large Source
Quarterly:
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Copyright 2009.
All Rights Reserved.
NOx/SOx Major Source
NOx/SOx
NOx/SOx
NOx/SOx
NOx/SOx
Major Source Aggregate
Large Source Aggregate
Process Units
Rule 219 Exempt Equipment
RKI Engineering LLC
RTU Deadlines
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Daily
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Monthly
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15 days after the end of the month
Quarterly
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Copyright 2009.
All Rights Reserved.
5 pm for the following day
Additional 24 hours extension due to problems related to power,
computer, or other system failure
30 days after the end of the quarter
60 days after the end of the compliance year
RKI Engineering LLC
RTU Record Identifier
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There are three (3) RTU Record Identifier
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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
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Daily RTU File Data
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Daily NOx/SOx Lbs to two decimal precision per Fuel Type for
each Major Source
Daily CEMS Status
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Copyright 2009.
All Rights Reserved.
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
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Monthly/Quarterly RTU File Data
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Copyright 2009.
All Rights Reserved.
Reported NOx/SOx Lbs to two decimal precision per Fuel Type
Aggregate NOx/SOx Lbs to two decimal precision
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RECLAIM Response Message
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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:
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Response message for bad data file:
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Copyright 2009.
All Rights Reserved.
OK_ _#####_sdddlyyjjjhhmmss
BAD_#####_[ASCII text message (up to 23 characters)]
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SCAQMD Waters Website
http://www.aqmd.gov/waters
Copyright 2009.
All Rights Reserved.
RKI Engineering LLC
RKI PODS
Screens specific to RECLAIM
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Copyright 2009.
All Rights Reserved.
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
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