Presentation on theme: "RECLAIM Monitoring, Recordkeeping and Reporting (MRR)"— Presentation transcript:
1RECLAIM Monitoring, Recordkeeping and Reporting (MRR) Peter MooreYorke Engineering, LLC
2Outline The language of RECLAIM What are you monitoring? Continuous Emissions Monitoring (CEMS)What records do you keep?ReportingSchedule
3Language of RECLAIM REgional CLean Air Incentives Market Cycle 1/Cycle 2Cycle 1 compliance year is from Jan – DecCycle 2 compliance year is from Jul – JunZonesCoastalInlandRECLAIM Trading Credits (RTC)Four “flavors”: combinations of Cycles 1/2 and Inland/Coastal
4Language of RECLAIM Major Source Large Source Boiler >40 MMBTU/hr I.C. Engine >1000 bhp operated > 2190 hr/yearGas Turbine >2.9 MWAny NOx source or process unit that uses a CEMSLarge SourceBoiler MMBTU/hrI.C. Engine bhpGas Turbine MW
5Language of RECLAIM Process Unit Pretty much everything else that is not major, large, and is subject to permit requirementsContinuous Emissions Monitoring System (CEMS)SensorsData Acquisition System (DAS)Relative Accuracy Test Audit (RATA)
6What Are You Monitoring? NOx (SOx) emissionsRelated parameters (for example…)Natural gas flow or meter readingsEngine timersPower generatedAmmonia injection rates for SCR systemsAnything that documents compliance with permit conditions or rules
7Continuous Emissions Monitoring System (CEMS) Required only for major sourcesContinuously measures:NOx concentrationOxygen (O2) concentrationStack gas volumetric flow rateEither measure directly; orCalculate using fuel flow rateOther variablesStrip chart recorder in parallel
8CEMS Calibration Must be calibrated daily Unsuccessful calibration results in missing dataCalibration records must be keptCalibration gases must be certifiedAnnual certification of entire measurement system by RATA test
9CEMS Permit applications are required for QA/QC Plan Initial certificationModificationQA/QC PlanRequired for certificationFollow it!
10CEMS – Missing DataEach 1-hour reading must be based on four valid 15-minute readingsOne missing 15-min data point means the whole hour is missingExcept for calibration & maintenance times when as few as two 15-min points are acceptableHow do you know you have missing data?Look at the data for obvious gaps and inconsistencies
11CEMS – Missing Data Fill in missing data using missing data procedures Calculate percent availabilityThis can be >100%!For >95% availability and short gaps, use 1N ProcedureFor <95% availability or longer gaps, use highest hourly NOx rate for last 30 days, or 365 daysFor <90% availability, use highest hourly NOx rate since equipment was commissioned!
12NOx Emission Reports Daily (Major Sources) Electronic report via CEMS/DAS and modemMonthly (Major & Large Sources)Electronic report via modemQuarterly (All sources)Paper report signed and mailed to SCAQMDAnnualSigned certification mailed to SCAQMDReconciliation of actual usage by RTC allocation
13Report Schedule Daily Monthly Quarterly Certification By 5:00 PM the next dayMonthly15 days after end of the monthQuarterly Certification30 days after end of the quarterAnnual Permit Emissions Program (APEP)60 days after end of the compliance year
14Electronic Reporting Use SCAQMD website to report ERS Web ReportingUse any computer with a modemHyperterminalSend a text file with a strict formatCheck format with test number( )Submit valid data( )
15Confirm Electronic Reporting Web Access to Electronic Reporting System (WATERS)Data Acceptance CheckTransmission checkType in facility ID and passwordNote that if the report was late, it will NOT show up in WATERS, but will show up in Transmission Check
16Source Test Reports Major Large sources Process units CEMS RATA testing every 6 or 12 monthsLarge sourcesEvery three years for NOxAnnual source test for CO (boilers)Process unitsEvery five years to verify concentration limits
17Breakdown ReportingYou are required to report breakdowns (Rule 2004(i))Call the SCAQMD within one hour of breakdown or within one hour of when you should have reasonably known! (800-CUT-SMOG)Write down the report number and operator name/numberSubmit report to SCAQMD 7 days after correction but no later than 30 days from initial date of breakdown
18Peter Moore Yorke Engineering, LLC Dealing with Audits, Notices to Comply (NTC) Notices of Violation (NOV)Peter MooreYorke Engineering, LLC
19Dealing with Audits, NTCs, NOVs PreparationWhen the Inspector ComesDealing with Notices to ComplyDealing with Notices of Violation
20Preparation: Self-Audits Conduct systematic self-audits to identify potential problemsGo through each permit requirementGo through each rule requirementDocument your findingsMake corrections!
21Preparation: Get Organized Have a copy of your current permit in a 3 ring binderKeep all current and previous permits organized in filesCreate a facility map showing equipment locationsKeep organized files of submitted reportsOrganize your recordsElectronic and hardcopy
22Preparation: Organize Records RECLAIM reportsAPEP, QCER, Monthly, Daily (CEMS)Annual Emission ReportsNatural gas billsTune-up records for boilersMaintenance recordsSource test reports
23Preparation: Organize Records CEMS recordsCalibration recordsElectronic transmissionsCalculation of CEMS missing data; What days, how you calculatedMaintenance recordsCalibration gas certificates
24When the Inspector Comes Inspectors do have a legal basis to inspect equipment and recordsTreat the inspector with respect and understanding for their jobProvide documents quicklyMake copies of any requested records
25Dealing with Notices to Comply Understand the problemUnderstand the specific rule or regulatory requirementFollow deadlines providedFix the problem and document complianceGet help if you need!
26Dealing With Notices of Violation Understand the problemUnderstand the specific rule or regulatory requirementFollow deadlines providedYou may have to shut down equipment to avoid further violations or increased finesApply for a variance if you need to continue operatingGet professional help (i.e. an attorney)
27Resources for Help Talk to your Account Executive (AE) For permitting assistanceFor equipment informationFor incentive programsCall The Gas Company’s Air Quality AnswerLine with any combustion related air quality question!800-GAS-2000 or