Presentation on theme: "General Monitoring Requirements and Options"— Presentation transcript:
1 General Monitoring Requirements and Options Louis NicholsUS EPA, Clean Air Markets Division (CAMD)December 2007Hello,My name is Matthew Boze,I am an Engineer with the US EPA’s Clean Air Markets Division’s Emissions Monitoring Branch.I am also the monitoring contact for Regions 2 and 9.In this session we are going to discuss the general monitoring requirements and options for NOx Mass monitoring under Subpart H of Part 75.
2 Monitoring DeadlinesDeadlines for Initial Certification for existing units:Annual NOx Trading Program - January 1, 2008SO2 Trading Program – January 1, 2009Ozone Season NOx Trading Program – May 1, 2008First, there is the State Implementation Plan which will have the basic requirements outlining the NOx Budget Trading Program for your state.This includes Applicability requirements, Initial Certification Deadlines, and various record keeping requirements.There should also be a section on monitoring and reporting which will pull in the monitoring requirements of Part 75
3 Monitoring Regulations 40 CFR Part 72.2Basic Definitions referred to throughout Part 7540 CFR Part 75 - Continuous Emissions MonitoringMonitoring ProvisionsOperation and Maintenance RequirementsMissing Data Substitution ProceduresRecord Keeping and Reporting RequirementsBefore discussing Part 75, it is worth first mentioning the importance of Part 72.§72.2 contains the basic definitions that you will need to understand the specific meaning of many of the phrases that we use in Part 75.40 CFR Part 75 is the monitoring rule for both the Acid Rain Program, and now the NOx Budget Trading Program.It contains monitoring provisions, Operation and maintenance requirements, Substitute Data procedures and comprehensive monitoring record keeping and reporting requirements.Subpart H of part 75 contains the NOx Mass Emissions Provisions of the monitoring Rule.
4 Monitoring Regulations 40 CFR Part 75 - AppendicesApp A, Specifications and Test ProceduresApp B, Quality Assurance and Quality Control ProceduresApp F, Equations, F-factorAlso, it is important to understand the importance, or at least the existence, of the Appendices to Part 75Appendix A, contains the Specifications and Test Procedures for certifying emissions monitoring equipment for the programs.Appendix B, contains the ongoing Quality Assurance and Quality Control Procedures.Appendix F, provides equations for calculating data in the required units.
5 Monitoring Requirements SO2 Mass Emissions (lb/hr)Heat Input (mmBtu/hr)NOx Mass Emissions (lb/hr) – Subpart H (§§ )So what is it that we are trying to measure?Obviously, NOx Mass Emissions need to be measured since this is the traded commodity. NOx Mass is reported hourly as lb/hr and then summed to give the total Mass in Tons/Ozone season.Heat Input monitoring is also almost always required.If the unit is using NOx Emission Rate times HI to determine NOx Mass, then obviously HI is required.If not you need to look closely at the State SIP rule to see if there are any exceptions to heat input monitoring.There are a few exceptions to this requirement in some of the SIPs
6 Reporting Requirements - Subpart H NOx Monitoring Annual ReportingSubmit quarterly Electronic Data Reports (EDR or ECMPS)Only the NOx mass data from the Ozone Season is used for emissions trading for ozone season trading programFollow standard Part 75 QA/QC timelines and data validation proceduresA must for Acid Rain unitsMay be required by the State rule (check with state)Ozone Season Only ReportingOnly submit 2nd and 3rd quarterly electronic reportsFollow special QA/QC timelines and data validation procedures described in §75.74(c)This option is a choice not a requirementDo not get same grace period as annual reportersSo what is it that we are trying to measure?Obviously, NOx Mass Emissions need to be measured since this is the traded commodity. NOx Mass is reported hourly as lb/hr and then summed to give the total Mass in Tons/Ozone season.Heat Input monitoring is also almost always required.If the unit is using NOx Emission Rate times HI to determine NOx Mass, then obviously HI is required.If not you need to look closely at the State SIP rule to see if there are any exceptions to heat input monitoring.There are a few exceptions to this requirement in some of the SIPs
7 Monitoring Options for Determining NOx Mass Emissions NOx Concentration (ppm) & Stack Flow Rate (scfh)NOx Emission Rate (lb/mmBtu) & Heat Input Rate (mmBtu/hr)CAIR_NOx_Monitoring_Final_ pdfThis slide describes the two most basic methods for determining NOx Mass.You may take NOx Concentration in PPM and combine it with the stack flow rate in SCFH using a formula from appendix F to get NOx mass in lb/hrOr, you may use a NOx emission rate system which tracks the lb of NOx per mmBtu of heat input and combine that with the hourly heat input rate to get the NOx mass.
8 SO2 Mass Monitoring Options SO2 and Stack flow monitor, orPart 75, Appendix D (for gas or oil fired peaking units)LME Method §75.19
9 NOx Emission Rate Monitoring Options NOx-Diluent CEMS, orPart 75, Appendix E (for gas or oil fired peaking units)LME Default NOx Emission RateThere are various options from monitoring the NOx Emission Rate and Heat InputNOx Emission Rate can be determined either by using a NOx-Diluent CEMS (includes both a NOx concentration and Diluent concentration analyzer to determine the NOx rate).Or you may qualify to use the Part 75, Appendix E methodology if you are a gas or oil fired peaking unit.Or if you qualify as an Low Mass Emissions Unit (LME) you may use a Default NOx Emission Rate.
10 NOx-Diluent CEMS Two components NOx Concentration Analyzer & CO2 or O2 Concentration Analyzer as the DiluentPart 75, Appendix F, section 3, provides the equations that are used to compute NOx emission rate (lb/mmBtu) given:NOx concentrationCO2 or O2 concentrationF-factor for the fuel combusted
11 Part 75, Appendix EMay be used in lieu of a NOx-diluent CEMS for determining hourly NOx emission rate (lb/mmBtu)Applicable only to Gas and Oil-Fired Peaking Units
12 Part 75, Appendix E Peaking unit (§ 72.2 - Definitions) An average capacity factor of no more than 10.0% during the previous three calendar years andA capacity factor of no more than 20.0% in each of those three calendar yearsOzone season only reporters can qualify on an ozone season only basis §75.74(c)(11)Initial qualification for peaking status byThree years (or ozone season) of historical capacity factor data, orFor newer or new units, a combination of all historical capacity factor data available and projected capacity factor information
13 Part 75, Appendix EFor units that make a change in capacity factor may qualify by:Collecting three calendar years of data following the change to meet the historical capacity factor specification, orCollect one calendar year of data following the change showing a capacity factor of less than 10.0% and provide a statement that the change is considered permanent
14 Part 75, Appendix EUnits that hold peaking status must continue to meet both the 10% three year and 20% single year (or ozone season) criteria to retain peaking statusIf a unit fails to meet the criteria it must install & certify a NOx CEM by January 1 of the year after the year for which the criteria are not metA unit may then re-qualify only by providing three new years (or ozone seasons) of qualifying capacity factor data
15 Part 75, Appendix EThe average NOx emission rate (lb/mmBtu) is determined fromPeriodic fuel specific NOx emission rate testing at four, equally spaced load levelsBoilersMethod 7E for NOxMethod 3A for the diluentStationary gas turbines
16 Part 75, Appendix E Plot the NOx Emission Rate vs. Heat Input Rate Use the graph of the baseline correlation results to determine the NOx emission rate corresponding to the heat input rate for the hourLinearly interpolate between reference points to the nearest lb/mmBtu using heat input values rounded to the nearest 0.1 mmBtu/hr
18 Heat Input Rate Monitoring Options Stack Flow & *Diluent (%CO2 or O2) CEMS, orFuel flow monitoring via Part 75, Appendix D, orLME Long term fuel flow or Max Rated HI*Note: If the diluent is on dry basis must correct for moistureThe Heat Input may be determined from either using a stack flow measurement and a diluent concentration measurement.Or you may qualify to use Appendix D Fuel Flow Monitoring.Or if you qualify for LME there are a couple of other options. (LONG TERM FUEL FLOW & Max Rated HI
19 Heat Input Rate from Stack Flow and Diluent System Components for a Stack Flow-Diluent Heat Input SystemStack Flow Monitor &CO2 or O2 Concentration Analyzer as the DiluentMoisture monitor if necessaryPart 75, Appendix F § 5, provides the equations that are used to compute the heat input rate (mmBtu/hr) given:Volumetric Stack flowCO2 or O2 concentrationF-factor for the fuel combustedMoisture correction
20 Part 75, Appendix D Fuel Flow Monitoring ApplicabilityMay be used in lieu of flow monitoring systems for the purpose of determining the hourly heat input rate and SO2 mass emissionsGas and Oil fired units onlyHeat input rate (mmBtu/hr) is determined from the:Fuel Flow Rate (fuel flowmeter), andGross Calorific Value (GCV) of the fuelSulfur content of fuel
21 Part 75, Appendix D Fuel Flowmeters Must meet the fuel flowmeter accuracy specification for initial certification (App D § 2.1.5)Visual inspection of orifice, nozzle, and venturi meters every 3 yearsMust pass a fuel flowmeter accuracy test at least once every four QA operating quarters (App D § 2.1.6)Fuel flowmeter accuracy < 2% of the flowmeter’s upper range value
22 Part 75, Appendix D others Fuel Flowmeters Certified by Design Orifice PlateNozzleVenturiFuel Flowmeters Certified by Accuracy testingCoriolisAnnubarsVortexTurbine metersothers
23 Appendix D Basic Fuel Sampling Options Oil SamplingFlow proportional/weekly compositeDaily manual samplingStorage tank sampling (after each addition)As delivered (sample from delivery vessel)Gas SamplingMonthly Samples (pipeline natural gas, or natural gas, or any gaseous fuel having demonstrated a “low GCV or sulfur variability”)Daily or Hourly Samples (any gaseous fuel not having a “low GCV or sulfur variability”)Lot sampling (upon receipt of each lot or shipment)
24 Low Mass Emissions Units §75.19 LME Monitoring OptionLow Mass Emissions Units§75.19
25 Overview of the Certification Process Submit an initial monitoring plan and notification of initial certification testing 45 days prior to starting certification testing (§75.61 & §75.62)Conduct all required testing for the system(s) to be certifiedDAHS Verification7-day Calibration ErrorCycle TimeLinearityRATA & Bias Test
26 Overview of the Certification Process (cont.) Upon successful completion of all certification tests, the system(s) are provisionally certifiedThe completed certification application is submitted within 45 days after completing all initial certification testsPermitting Authority has 120 days after receipt of a complete certification application to review the application and approve or disapprove certification
27 Initial Certification Timeline Submit Monitoring Plan & Certification Test NotificationCertification Application Submitted (Electronic and Hardcopy)Start of the Certification Test PeriodDeadline for Certification ApprovalDate of Provisional CertificationCertification Testing DeadlineAll Certification Testing CompletedNo later than 120 Days after receipt of completed Certification Application PackageFirst certification test performed45 Days Prior to the first day of Initial Certification TestingNo later than 45 days after completion of Certification TestingMonitoringDeadline in SIP(January 1, 2008 Annual NOxMay 1, Ozone Season NOxJanuary 1, 2009 SO2)
28 Required Certification Tests for NOx and SO2 Concentration Systems 7-day Calibration Error TestLinearity CheckRATABias TestCycle Time TestDAHS Verification
29 Required Certification Tests for NOx-Diluent Systems 7-day Calibration Error Test performed on both the NOx Concentration and Diluent componentsLinearity Check performed on both the NOx Concentration and Diluent componentsRATA and Bias TestCycle Time Test performed on both the NOx Concentration and Diluent components; cycle time for the system is the highest of the componentsDAHS Verification
30 Types of Electronic Reports Initial Monitoring PlansCertification ApplicationQuarterly Electronic Data Report*Includes:Most up-to-date version of the Monitoring PlanLatest Certification and/or QA Tests information* ECMPS is different