RECLAIM Monitoring, Recordkeeping and Reporting (MRR)

1. RECLAIMMonitoring, Recordkeeping and Reporting (MRR) Peter Moore Yorke Engineering, LLC

2. Outline • The language of RECLAIM • What are you monitoring? • Continuous Emissions Monitoring (CEMS) • What records do you keep? • Reporting • Schedule

3. Language of RECLAIM • REgional CLean Air Incentives Market • Cycle 1/Cycle 2 • Cycle 1 compliance year is from Jan – Dec • Cycle 2 compliance year is from Jul – Jun • Zones • Coastal • Inland • RECLAIM Trading Credits (RTC) • Four “flavors”: combinations of Cycles 1/2 and Inland/Coastal

4. Language of RECLAIM • Major Source • Boiler >40 MMBTU/hr • I.C. Engine >1000 bhp operated > 2190 hr/year • Gas Turbine >2.9 MW • Any NOx source or process unit that uses a CEMS • Large Source • Boiler 10 - 40 MMBTU/hr • I.C. Engine 200 -1000 bhp • Gas Turbine 0.2 - 2.9 MW

5. Language of RECLAIM • Process Unit • Pretty much everything else that is not major, large, and is subject to permit requirements • Continuous Emissions Monitoring System (CEMS) • Sensors • Data Acquisition System (DAS) • Relative Accuracy Test Audit (RATA)

6. What Are You Monitoring? • NOx (SOx) emissions • Related parameters (for example…) • Natural gas flow or meter readings • Engine timers • Power generated • Ammonia injection rates for SCR systems • Anything that documents compliance with permit conditions or rules

7. Continuous Emissions Monitoring System (CEMS) • Required only for major sources • Continuously measures: • NOx concentration • Oxygen (O2) concentration • Stack gas volumetric flow rate • Either measure directly; or • Calculate using fuel flow rate • Other variables • Strip chart recorder in parallel

8. CEMS Calibration • Must be calibrated daily • Unsuccessful calibration results in missing data • Calibration records must be kept • Calibration gases must be certified • Annual certification of entire measurement system by RATA test

9. CEMS • Permit applications are required for • Initial certification • Modification • QA/QC Plan • Required for certification • Follow it!

10. CEMS – Missing Data • Each 1-hour reading must be based on four valid 15-minute readings • One missing 15-min data point means the whole hour is missing • Except for calibration & maintenance times when as few as two 15-min points are acceptable • How do you know you have missing data? • Look at the data for obvious gaps and inconsistencies

11. CEMS – Missing Data • Fill in missing data using missing data procedures • Calculate percent availability • This can be >100%! • For >95% availability and short gaps, use 1N Procedure • For <95% availability or longer gaps, use highest hourly NOx rate for last 30 days, or 365 days • For <90% availability, use highest hourly NOx rate since equipment was commissioned!

12. NOx Emission Reports • Daily (Major Sources) • Electronic report via CEMS/DAS and modem • Monthly (Major & Large Sources) • Electronic report via modem • Quarterly (All sources) • Electronic report via modem • Paper report signed and mailed to SCAQMD • Annual • Signed certification mailed to SCAQMD • Reconciliation of actual usage by RTC allocation

13. Report Schedule • Daily • By 5:00 PM the next day • Monthly • 15 days after end of the month • Quarterly Certification • 30 days after end of the quarter • Annual Permit Emissions Program (APEP) • 60 days after end of the compliance year

14. Electronic Reporting • Use SCAQMD website to report • ERS Web Reporting • http://www.aqmd.gov/waters/ • Use any computer with a modem • Hyperterminal • Send a text file with a strict format • Check format with test number • (909-396-3947) • Submit valid data • (877-727-1117)

15. Confirm Electronic Reporting • Web Access to Electronic Reporting System (WATERS) • Data Acceptance Check • www.aqmd.gov/waters/waters.html • Transmission check • www.aqmd.gov/waters/erslogin.asp • Type in facility ID and password • Note that if the report was late, it will NOT show up in WATERS, but will show up in Transmission Check

16. Source Test Reports • Major • CEMS RATA testing every 6 or 12 months • Large sources • Every three years for NOx • Annual source test for CO (boilers) • Process units • Every five years to verify concentration limits

17. Breakdown Reporting • You 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/number • Submit report to SCAQMD 7 days after correction but no later than 30 days from initial date of breakdown

18. Dealing with Audits,Notices to Comply (NTC)Notices of Violation (NOV) Peter Moore Yorke Engineering, LLC

19. Dealing with Audits, NTCs, NOVs • Preparation • When the Inspector Comes • Dealing with Notices to Comply • Dealing with Notices of Violation

20. Preparation: Self-Audits • Conduct systematic self-audits to identify potential problems • Go through each permit requirement • Go through each rule requirement • Document your findings • Make corrections!

21. Preparation: Get Organized • Have a copy of your current permit in a 3 ring binder • Keep all current and previous permits organized in files • Create a facility map showing equipment locations • Keep organized files of submitted reports • Organize your records • Electronic and hardcopy

22. Preparation: Organize Records • RECLAIM reports • APEP, QCER, Monthly, Daily (CEMS) • Annual Emission Reports • Natural gas bills • Tune-up records for boilers • Maintenance records • Source test reports

23. Preparation: Organize Records • CEMS records • Calibration records • Electronic transmissions • Calculation of CEMS missing data; What days, how you calculated • Maintenance records • Calibration gas certificates

24. When the Inspector Comes • Inspectors do have a legal basis to inspect equipment and records • Treat the inspector with respect and understanding for their job • Provide documents quickly • Make copies of any requested records

25. Dealing with Notices to Comply • Understand the problem • Understand the specific rule or regulatory requirement • Follow deadlines provided • Fix the problem and document compliance • Get help if you need!

26. Dealing With Notices of Violation • Understand the problem • Understand the specific rule or regulatory requirement • Follow deadlines provided • You may have to shut down equipment to avoid further violations or increased fines • Apply for a variance if you need to continue operating • Get professional help (i.e. an attorney)

27. Resources for Help • Talk to your Account Executive (AE) • For permitting assistance • For equipment information • For incentive programs • Call The Gas Company’s Air Quality AnswerLine with any combustion related air quality question! • 800-GAS-2000 or • 562-803-7428