PADEP Bureau of Air Quality

CEMS Certification
Hitesh Suri Continuous Emission Monitoring Section (717) 772-3963 hsuri@state.pa.us

CEMS Certification
System approval Quality assurance Equipment changes Department audits Revision 8 of the Manual

Applicability
Monitoring required pursuant to 40 CFR, Pt. 64 Monitoring required pursuant to 40 CFR, Pt. 70 Monitoring required pursuant to only 25 PA Code, Chapter 145 Monitoring required pursuant to 40 CFR, Pt. 75 Approval of alternatives to certain criteria in Manual

Terminology Change
Legacy DEP Terminology Relative Accuracy Test Calibration Error Test 24-Hr Zero and Calibration Drift Test Response Time Test Pt. 75 Compatible Terminology Relative Accuracy Test Audit (RATA) Linearity Test 7-Day Calibration Error Test Cycle Time Test

Trading Programs
Separate programs Identify submittals appropriately Acid Rain Program (40 CFR, Part 75)
Approvals administered by EPA Accepted as approval under NOx Trading Programs

Trading Programs
NOx Trading Programs
Approvals administered by PADEP Ozone Transport Commission (PADEP Chapter 123) NOx SIP Call (PADEP Chapter 145) Many references to 40 CFR, Part 75 More trading programs on horizon Haze, metals, greenhouse gases

Continuous Source Monitoring Manual (Manual)

Revision 8 of the Manual, finalized on December 2, 2006 and will be implemented for all CEMSs 25 Pa. Code Section 139.101 Continuous Emission Monitoring Homepage: http://www.dep.state.pa.us/dep/deputate/airw aste/aq/cemspage/cemshome.htm

CEM Approval Process

Initial application (Phase I) Performance testing (Phase II) Final approval (Phase III)

Initial Application (Phase I)

Is proposed monitoring adequate? The Manual provides specifications Quality assurance (Q/A) manuals & electronic checklists required

Performance Specifications
High Range (PPM): 0 to the maximum expected emission (MEE) and 1.25 times the highest emission standard Low Range (PPM): 0 to 1.25 times the highest emission standard for this range

Performance Specifications (Cont.)

Example:
Max. expected emissions = 500 PPM Highest emission standard for the lower range = 75 PPM Average emission conc. ~ 30 PPM High Range = 500*1.25 = 625 PPM Low Range = 1.25*75 = 94 ~ 100 PPM

Span Value
Terms are found in the specification tables, used in the determination of daily zero and calibration drift Span = 2 times lowest emission standard or as specified in Federal regulations (Revision 6 sources) Use of a span value was removed in Revision 7 of the Manual

Emission Standard Equivalent

The % of lowest monitored emission standard equivalent is now utilized for determination of zero and upscale calibration error The Applicability Determination Document requires Revision 6 sources to demonstrate compliance with the 7-day calibration error requirements under Revision 8 of the Manual

Emission Standard Equivalent (Cont.)

For example: SO2 Emission standards: PPM Lbs/hr Lbs/MBtu500 59.4 0.6

Emission Standard Equivalent (Cont.) Example:

SO2 lbs/hr = Emission standard = 59.4 lbs/hr SO2 (lbs/hr) = SO2 (conc.) (PPM)*flow (Qn) (dscfh)*1.663E-7 59.4 = SO2 (PPM) * 4,800,000 * 1.663E-7 SO2 (PPM) ~ 75

Emission Standard Equivalent (Cont.)

SO2 lbs/MBtu = Emission standard = 0.6 lbs/MBtu Fuel type = Natural gas = Fd = 8710 Diluent = Oxygen (O2) = 8% SO2 (lbs/MBtu) = SO2 (conc.) (PPM)*1.660E7*Fd[20.9/(20.9-%O2d)] 0.6 = SO2 (conc.) (PPM) )*1.660E-7 *8710 [20.9/(20.9-8.0)] SO2 (PPM) ~ 256

Emission Standard Equivalent (Cont.)

Summary: We have 3 emission standards/equivalents; 75 PPM, 256 PPM, and 500 PPM Therefore: The % of lowest monitored emission standard equivalent (LMESE) should be based on 75 PPM for the optional lower range The % of lowest monitored emission standard equivalent (LMESE) should be based on 256 PPM for the highest range

Performance Testing (Phase II)

Show us it works Follow Attachments 1, and 2 of the Manual, as appropriate Tables I - XIII provide specifications Entire system must be operational

Phase II (Cont.)
Typical CEMS (Gases)
Operational Test Period Cycle Time Zero Calibration Error Test Upscale Calibration Test Linearity Relative Accuracy Test Audit (RATA) Data Acquisition System (DAS) Accuracy Verification

Phase II (Cont.)
Typical CEMS (Opacity)
Operational Test Period Response Time Check Zero Calibration Drift Test Upscale Calibration Drift Test Calibration Error Check Averaging Period Calculation and Recording Check Optical Alignment Assessment Data Acquisition System (DAS) Accuracy Verification

Phase II (Cont.)
Coal Sampling/Analysis System (CSAS)
Operational Test Period Weight of hourly increment Variation of actual factor of proportionality Precision of sample preparation Linearity of percent error for % Sulfur Precision of analysis for % Sulfur Precision of analysis for Btu/lb

Gas Cylinder Certification

Must comply with the current 40 CFR, Pt. 75, Appendix A, or as specified in an applicable Federal regulation Multicomponent mixtures acceptable Zero air material must comply with definitions Section of 40 CFR, Part 72 except for the measurement of gases other than SO2, NOx, THC, CO or CO2. Alternative procedures may be utilized

Initial Calibration Testing

Calibration error determined in accordance with 40 CFR, Part 75, Appendix A Zero and upscale calibration error tests required 2 levels calibration (zero and upscale)
0 30% of range of measurement device 40 100% of range of measurement device

The Manual provides some flexibility in calibration gas concentration selection

Linearity (Gasses)
Challenge analyzer with 3 non-sequential injections at each of the 3 gas levels The 3 gas levels should be selected as follows:
0 30% of range (low) 40 60% of range (mid) 80 100% of range (high)

The Manual provides some flexibility in calibration gas concentration selection

Calibration Error Testing (Opacity)

Must follow ASTM 6216 (design and manufacturers performance specification requirements) Challenge analyzer 5-times non-consecutively at each of the 3 filter levels The 3 levels should be selected as follows: 0 30% (low) 40 60% (mid) 80 100% (high) Alternate filter values may be acceptable

DAS Accuracy Verification Test

All CEMS Verify 9, 1-hour averages Opacity/Temp CEMS An additional 60, 1-minute averages are required

Fuel F-Factor Verification

For uniform fuels with published values, required during initial certification For non-uniform fuels, more frequent verification required (as per the Manual) Fuel sampling must be in accordance with the Departments Source Testing Manual.
Minimal frequency every hour Analysis of separate composite for each test run

F-Factor Sampling Plan

Non-uniform fuel sources Daily sampling with weekly analysis Analysis frequency may be decreased depending on results Details contained in the Manual, Quality Assurance Section, H-2

Relative Accuracy Test Audit (RATA)

Verifies CEMS data Source Testing Manual details methods Operate at representative levels Pretest protocols required (45 days) 9 12 test runs required CEMS averages determined by the DAS

RATA (Cont.)
RATAs must be conducted once every four operating quarters in which the source operates for 168 hours or more or within 720 source operating hours after the close of such four quarters During the RATA, RM volumetric flow may be determined as follows:
Using fuel flow data from the Company CEMS for determination of mass emissions (must follow 40 CFR, Part 75, App. D, Paragraphs 2.1.5 and 2.1.6) Use a method independent of the Company CEMS

Time Limits (For completion of Phase II)

210 days from startup and/or..60 days from achieving normal process capacity 10-days post testing notification required EDRs 844 and 848 must be submitted with 10 days of completion of applicable testing

Final Approval (Phase III)

Submit test report within 60 days after completion of the performance testing Sample disk required for format review Approval date provided in the Phase III Approval Letter

Quality Assurance (Periodic Testing)

Daily Calibration Check Periodic Self-Audit and Quarterly Linearity/Calibration Error Test Fuel Sampling Analysis (Manual)

Equipment Changes
Submit a Revised Phase I Only information that represents a change from a previously approved submittal will need to be submitted Retro-active approvals will be considered, as appropriate Require testing in accordance with Attachment No. 5 of the Manual (Recertification Guidance) Contact CEMS Section for specific guidance if change is not addressed in the Recertification Guidance

Questions?