Common Monitoring and Reporting Errors Louis Nichols Clean Air Markets US EPA March 2007

GeneratorReplacement u If an electric generator less than 25 MWe is replaced with another electric generator which has a nameplate of greater than 25 MWe, then the previously non-affected unit may become an Acid Rain Program/CAIR unit.

Definition of Commencement Commercial Operation u Sections §§96.102, , and define commence operation and commencement of commercial operation. u Reporting and certification deadlines start with these definitions.

Monitor Certification dates for Units that CCO after 1/1/2007 u Units must certify all monitoring systems 90 operating days or 180 calendar days from the commence commercial operation date. u If the monitoring systems are not provisionally certified by the certification date, the units must report substitute data from that date.

Recertification Testing u When recertifying a monitoring system, the following tests are due, according to §75.20(b)(3)(iv) : ã RATA by end of 720 operating hours starting from the probationary calibration error (CE) test. ã Linearity check by end of 168 operating hour from the CE test. ã Cycle-response by end of 168 operating hours from the CE test.

Like-Kind Gas Analyzer Replacements -- §75.20(d)(2) u When performing a like-kind gas analyzer replacement: ã Linearity check must be completed by end of 168 operating hour after the probationary calibration error (CE) test. ã Use of these analyzers I limited to 720 cumulative operating hours per calendar year at a particular unit or stack. ã To use the LK analyzer for > 720 cumulative operating hours, a RATA is required and the analyzer must be redesignated as a backup system in the monitoring plan.

Quarterly QA/QC - Part 60 vs Part 75 u Part 75 requires a linearity check (3 gas bottles) every QA operating quarter (i.e., a quarter with 168 unit or stack operating hours), even quarters in which a RATA is performed. u Part 60 does not require a cylinder gas audit in quarters that a RATA is performed, Part 75 still requires a linearity check in that quarter.

Failure to Monitor all Emissions u Holes in Ductwork ã Especially, holes prior to control devices ã Failure to maintain ductwork u Ash Handling Systems ã Some systems remove emissions ã Primarily affects Flow-concentration systems u Bypass Stacks ã Must account for emissions from bypass stacks ã No start-up, shut-down or malfunction exemptions

Expired Calibration Gases u Can be re-certified by Vendor (must be >500 psi in bottle) u Notify shipping department not to empty bottle to save transportation fees u Bottle must be >150 psi to meet protocol

Fuel Flow Monitors u Test the accuracy of each fuel flowmeter once every four fuel flowmeter QA operating quarters, unless the meter qualifies for test deadline extensions. The deadline may be extended, one quarter at a time up to a maximum of 20 calendar quarters from the last test. u For non-QA quarters in which the fuel flowmeter is used less than 168 hours; or u If the optional fuel flow-to-load test is performed and passed each quarter (Part 75, Appendix D, section 2.1.7).

Orifice, Nozzle, and Venturi-type Flowmeters u For orifice-, nozzle-, and venturi-type flowmeters perform the primary element inspection (PEI) once every 12 calendar quarters and perform the transmitter or transducer accuracy tests once every four fuel flowmeter QA quarters. u The interval between transmitter or transducer calibrations may be extended, up to 20 calendar quarters if the fuel flow-to-load test is performed and passed or if there are not enough fuel flowmeter QA quarters. u The PEI may be extended up to 20 calendar quarters only if the fuel flow-to-load test is performed and passed. (Note: Appendix D, section requires that the PEI and transmitter or transducer be performed in the same quarter.)

Readily Available Information Resources u Policy Manual ã For some monitoring plans such as subtractive stacks, multiple stacks, and others, the Part 75 Policy Manual may contain valuable reporting as well as CEMS quality assurance information – Tip : Use searchable version u Electronic Data Reporting (EDR) Instructions ã EDR Instructions contain specific reporting information for all units – Tip: Use searchable version ã ECMPS Instructions after 1/1/2008 u Use the following link: ã l

Moisture Monitoring u Moisture defaults for coal and wood in §75.11(b)(1) u Proposed moisture default for natural gas u For other fuels monitored with stack flow monitors contact CAMD