Ongoing Quality Assurance for NOx and SO 2 CEMS

1. Ongoing Quality Assurance for NOx and SO2 CEMS Louis Nichols US EPA, Clean Air Markets Division (CAMD) December 2007

2. Focus • Quality Assurance tests • Ongoing quality assurance (QA) requirements • Recertification Events

3. Post Certification (Ongoing)Quality Assurance • Schedules for daily, quarterly, semiannual or annual quality assurance assessments are set starting with the date of provisional certification • A system is considered to be Out-of-control (OOC) from the moment of any QA failure until the test is successfully completed • A system may also be considered OOC in the absence of a required test

4. Quality Assurance Tests for CEM Systems • 7-day Calibration Error Test • Linearity Check • Cycle Time Tests • Relative Accuracy Test Audit (RATA) • Bias Test

5. Daily QA App B, §2.1 • Calibration Error Test (all monitors) • To be completed daily at least every 26 clock hours • Must be conducted online, unless offline demonstration is completed • Off-line calibrations must be followed by an online calibration within 26 unit op hrs • Daily Flow Interference Check for stack flow monitoring systems • See §2.2.2.2 of Part 75, Appendix A

6. Daily Data ValidationApp B, §2.1.4 • NOX and SO2 monitors • CE < 5.0% of span, or • |R – A| < 5.0 ppm if span < 50 ppm, or • |R – A| < 10.0 ppm if span >50 & < 200 ppm • Diluent monitors (CO2 & O2) • |R – A| < 1.0 % CO2 or O2 • Flow monitor • CE < 6.0% of span, and • Interference check must pass

7. Quarterly QA App B, §2.2 • Required each QA operating quarter (> 168) • Linearity Checks (each SO2, NOX, & diluent monitor) • Leak Checks (differential pressure stack flow monitors) • Flow-to-Load Ratio, or Gross Heat Rate evaluations (stack flow monitoring systems)

8. Data Validation App B, §2.2.3 • NOX and SO2 monitors • LE < 5.0% of reference value, or • |R – A| < 5.0 ppm if span < 200 ppm, or • Diluent monitors (CO2 & O2) • LE < 5.0% of reference value, or • |R – A| < 0.5 % CO2 or O2

9. Grace Periods App B, §2.2.4 • When a linearity or leak check is not completed by the end of a QA operating quarter in which it is due, a grace period of 168 consecutive unit operating hours is provided. • If at the end of the 168 hour grace period the required check has not been completed, the data is invalidated starting with operating hour 169 • A “make up” check performed in the grace period does not count as the quarterly check for the current quarter • 30 days, if possible, should be given before performing the current check

10. Semiannual and Annual QA App B, §2.3 • Relative Accuracy Test Audit (RATA) • Required semiannually (within 2 QA operating quarters), unless; • Unit qualifies for annual RATA frequency (every 4 QA operating quarters) under part 75, Appendix B § 2.3.1.2 • not to exceed 8 calendar quarters • RATA’s are performed on a system basis • NOX and NOX emission rate RATA’s are to be performed at normal load

11. Flow RATA Load LevelsApp B, §2.3.1.3(c) • A 3-load RATA is required at initial certification, whenever the monitor is re-linearized, and once every 5 years • Otherwise a 2-load RATA is required annually • To be performed at the two most frequently used load levels (important! RT 536) • Single load flow RATA is permitted when • > 85% of the unit operating hours at a single load • Must submit a RT 695 (Single-load Flow RATA claim)

12. Data Validation App B, §2.3.2 • Each RA < 10.0% to pass (< 7.5% for annual frequency) • If a RATA is aborted at any level the system is then considered to be out-of-control until that RATA level is passed

13. RATA Grace Period App B, §2.3.3 • A grace period of 720 unit operating hours exists when: • A required RATA is not completed in the QA operating quarter in which it is due, or • When 5 consecutive calendar years have elapsed without a 3-load flow RATA • If after 720 unit op hrs the RATA is not completed data from the system is invalidated (starting at hr 721) • Upon completing the “make up” RATA the next RATA deadline is set as 4 QA operating quarters following the quarter that the RATA was originally due • Not to be less than 2 operating quarters

14. Appendix D QAApp D, §2.1.6 • Fuel flowmeter accuracy test • Required once every four fuel flowmeter QA operating quarters, or • At least once every 20 calendar quarters • An optional quarterly fuel flow-to-load evaluation may be used in any QA operating quarter to extend the fuel flowmeter accuracy test deadline up to 20 calendar quarters • A visual inspection of the primary element for an orifice, nozzle, or venturi meter is required at least once every 3 years

15. Quality Assurance for Ozone Season Only Reporters(Current Regulation) §75.74(c) Note that on August 22, 2006 EPA proposed extensive revisions to this section. If these revisions are finalized, follow only the new rule as finalized. EPA hopes to have new rules in place by the 2008 Ozone Season.

16. Ozone Season Only Reporters • Report only 2nd and 3rd quarter reports • Must follow a modified QA schedule (§75.74(c)) • This schedule includes QA requirements for both before and during the ozone season • All tests performed outside the ozone season are reported in the 2nd quarter report. • Once pre-season QA is conducted all daily QA activities must continue • Standard Part 75 grace periods do not apply!

17. Daily Calibrations/Flow Interference Checks • Pre-season: • Required each operating day beginning with the date and hour that either the pre-season RATA or Linearity is completed • In-season: • Required each day, same as the standard Part 75 daily calibration requirements

18. Linearity Checks • Pre-season: • Required once during the pre-ozone season period (10/1 - 4/30) • If not completed by 4/30, a 168 op hr grace period may apply if: • The linearity was passed during the last ozone season, and • The unit operated <336 hours in the last ozone season • In-season: • Linearity required each QA operating Quarter • No grace periods allowed!

19. Pre-Season RATAs • Not required if RATA from previous ozone season is able to validate all or part of the current season • If required and not completed prior to 4/30, a 720 operating hour grace period is allowed if: • A RATA was passed in the previous year, and • The unit operated <336 hours in the last ozone season • Conditional Data Validation may be used when the RATA is not completed prior to 4/30, and the 720 operating hour grace period is not allowed.

20. Ozone Season RATAs • Required when a pre-ozone season RATA or RATA from last ozone season is not able to QA data for the entire current season • You may opt to perform only in-season RATAs if: • You qualify for annual frequency, and • You perform daily calibrations throughout the non-ozone season (10/1 - 4/30)

21. Quality Assurance for Ozone Season Only Reporters(Proposed Revised Regulation) §75.74(c)

22. Daily Calibrations/Flow Interference Checks • No changes here! • Pre-season: • Required each operating day beginning with the date and hour that either the pre-season RATA or Linearity is completed • In-season: • Required each day, same as the standard Part 75 daily calibration requirements

23. Linearity Checks • There would no longer be a separate Pre-season and 2nd quarter Linearity requirement: • Pre-season/2nd quarter linearity is required by April 30 • If not completed by 4/30, up to 168 op hours of conditional data validation may be used to validate data until the test is completed. • No grace period. • 3rd quarter requirement: • The third quarter linearity would be due by July 30 • If not completed by 7/30, up to 168 op hours of conditional data validation may be used to validate data until the test is completed. • Conditional data periods must be resolved no later than October 30th otherwise substitute data must be used. • No grace period.

24. Pre-Season RATAs • RATA from previous ozone season will no longer be accepted • RATA’s may be done anytime from Jan 1 through April 30 for that years ozone season. • If not completed prior to 4/30, conditional data validation may be used to validate up to 720 operating hours • Conditional data periods must be resolved no later than October 30th otherwise substitute data must be used. • No grace period.

25. Quality Assurance TestingSubmittal & Review • CAMD • Receives and reviews QA records electronically • Presently in the quarterly EDR (RT 600) • In ECMPS by electronic submission in a QA file • Sends feedback to Source, State, and EPA Region • State and Region • Receive and review hardcopy RATA test reports

26. Recertification Events

27. Recertification Events §75.20(b) • Recertification is required whenever there is a replacement, modification or change in: • A certified CEM that may significantly affect accuracy of that CEMS • To the flue gas handling system or the unit operation that may significantly change the flow or concentration profile. • Examples include: • Permanent replacements of analyzers and/or monitoring systems • Change of probe or probe location • Change in monitoring methodology • No compliance deadline, however data is not considered to be valid until all recertification test are completed (Use substitute data)

28. Recertification Reporting • A certification event record (currently RT556) must be filed outlining each recertification event • A recertification application is to be submitted within 45 days of completing all recertification tests • Emissions data during the recertification period shall be reported by either: • Applying the appropriate standard missing data procedures from §§75.33 through 75.37, or • Using actual CEMS data and following the conditional data validation procedures §75.20(b)(3)

29. Conditional Data Validation Timelines § 75.20(b)(3)(iv) • Each required test is to be completed no later than the following number of unit operating hours after the probationary calibration. • Linearity Check; 168 unit operating hours • RATA; 720 unit operating hours • 7-day calibration tests; 21 consecutive unit operating days

30. Conditional Data Validation Rules • Only routine adjustments following a daily calibration error check are allowed during the recertification period • If all test are completed without failure, and within the specified time period, then all conditional data hours are validated. • If any test is failed • All previous conditional data validation is lost, a new conditional data period may be initiated following a new probationary calibration error check following the “fix” • The test required in the new test period include any test which were not previously successfully completed and any tests which are required as a result of the “fix”

31. Conditional Data Validation Rules • If a recertification test is completed after the specified time period • The data is to be invalidated starting with the hour following the expiration of the test period. • If the test is passed, the conditional data is retained • If the test is failed, the conditional data is lost

32. Recertification Application Submittal (Current EDR Process) • Electronic Portions (100, 500, 600, 900 RTs) • Send Electronic Certification Test Data in EDR v2.1 format to CAMD • Submit electronically via either e-mail or by using MDC-FTP: WEB http://www.epa.gov/airmarkets/monitoring/arp/certemail.html • Copy EPA Region and State with hardcopy submittal

33. Recertification Application Submittal (ECMPS Process) • Submit QA tests and a certification application record using the ECMPS client tool

34. Certification Application Submittal (cont.) • Hardcopy Portions • Submit to EPA Region and State • Includes (as applicable): • Test strategy/protocol • Detailed test report for each Reference Method performed for certification • DAHS verification • 7-Day calibration test data • Linearity report with protocol gas certifications • Cycle Time test results

35. The End Questions?