CEMTEK CEMS Users Group Meeting and Forum September 24-25, 2009 Santa Ana, California RKI Specific DAHS Training and RECLAIM Updates Presented by Norm Iseri, RKI Engineering LLC

Agenda Discuss RECLAIM Regulations Present RKI PODS Screen specific to RECLAIM Question and Answer Copyright 2009. All Rights Reserved. RKI Engineering LLC

Air Quality Regulations SCAQMD RECLAIM Rule 2011 SCAQMD RECLAIM Rule 2012 SCAQMD Rule 216 Not covered in this presentation EPA 40 CFR Part 60 EPA 40 CFR Part 75 Copyright 2009. All Rights Reserved. RKI Engineering LLC

SCAQMD RECLAIM NOx/SOx RECLAIM – REgional CLean Air Incentives Market Started January 1, 1994 Businesses that beat their reduction targets can trade their credits on the open market. Using market forces allows pollution to be cut in the most economical way. Move away from traditional command-and-control rules SCAQMD Rule 2011, RECLAIM SOx SO2 (ppmv), Stack Flow, SOx Lbs/hr SCAQMD Rule 2012, RECLAIM NOx NOx (ppmv), Stack Flow, NOx Lbs/hr Copyright 2009. All Rights Reserved. RKI Engineering LLC

CEMS/DAHS Continuous Monitoring of emissions Perform Daily Calibration Perform other QA Activities, i.e. RATA Identify problems for alarming Display emissions for control, if required Insure valid emissions data is being collected Apply appropriate Missing Data Procedures Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Valid Hourly Data Four (4) Valid 15-Minute Period Only four (4) Maintenance/QA Hour are valid were the hour has between 2-3 valid 15-minute periods Maintenance/QA Hour with 2-3 valid 15-minute periods beyond the first four hours are invalid Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Valid 15-Minute Average Only one valid minute data is required to calculate a valid 15-minute period All valid CEMS data are used in the 15-Minute Average regardless of operations Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Valid Minute Data (Part 1) CEMS data is invalid during: Calibration in Progress Maintenance and Quality Assure Activities CEMS Out of Control Stack Flow based on Fuel Flow, O2 > 19% Emissions between 10-95% of range Invalid when emissions is greater than 95% range Emissions limited to 10% of range when emission drops below 10% Spike Test can be used to certify analyzer below 10% range Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Valid Minute Data (Part 2) Other reasons for invalid CEMS data Missing Daily Calibration when Device had operated in the day Missing Daily RTU transmission Failed RATA and other Failed QA activates Copyright 2009. All Rights Reserved. RKI Engineering LLC

Emission Rate Calculations NOx Lbs/Hr = 0.1195*NOx (ppmvd)*Stack Flow (mscfh) SOx Lbs/Hr = 0.1662*SO2 (ppmvd)*Stack Flow (mscfh) NOx and SO2 are directly measured Stack Flow can be measured directly or calculated Calculated Stack Flow Can be used with consistent fuel type, i.e. Natural Gas Based on fuel flow, Higher Heating Value (HHV), Fd, O2 For natural gas, HHV default is 1050 and Fd is 8710 Copyright 2009. All Rights Reserved. RKI Engineering LLC

Relative Accuracy Test Audit Determine accuracy of CEMS, Relative Accuracy Determine Bias Adjustment Factors, 1 or greater Semi-Annual/Annual RATA Meet Incentive – Annual RATA Failed RATA Invalid CEMS data RECLAIM Missing Data Procedure is applied Successful RATA is required to start collecting valid CEMS data RATA not completed within the required quarter Request for Variance RECLAIM Missing Data Procedure still applies Copyright 2009. All Rights Reserved. RKI Engineering LLC

Bias Adjustment Factors (BAF) NOx/SOx BAF NOx Bias Adjust = NOx ppmv * BAF for NOx SOx Bias Adjust = SOx ppmv * BAF for SOx Stack Flow BAF Stack Flow Bias Adjust = Stack Flow * BAF for Stack Flow NOx/SOx Lbs/Hr BAF (Two Methods) Based on RATA Results NOx Lbs/Hr Bias Adjust = NOx Lbs/Hr * BAF for NOx Lbs/Hr Based on NOx/SOx BAF and Stack Flow BAF NOx Lbs/Hr Bias Adjust = NOx Bias Adjust * Stack Flow Bias Adjust Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Missing Data Procedures Apply RECLAIM Missing Data Procedures (MDP) Invalid NOx/SOx (ppmv) Invalid Stack Flow Invalid NOx/SOx Lbs/Hr: When ppmv and Stack Flow are invalid RECLAIM Missing Data Procedures 1N Procedure Max value for previous 30 days Max value for previous 365 days Max value for the service of the CEMS MDP Method applied is based on duration of missing data period and the % Availability % Availability = Valid Monitoring Hours for previous 365 days/Operating Hours for previous 365 days) Copyright 2009. All Rights Reserved. RKI Engineering LLC

RTU Reporting Requirements RTU – Remote Terminal Unit Daily Transmission: NOx/SOx Major Source Monthly: NOx/SOx Major Source Aggregate NOx/SOx Large Source Quarterly: NOx/SOx Large Source Aggregate NOx/SOx Process Units NOx/SOx Rule 219 Exempt Equipment Copyright 2009. All Rights Reserved. RKI Engineering LLC

RTU Deadlines Daily Monthly Quarterly 5 pm for the following day Additional 24 hours extension due to problems related to power, computer, or other system failure Monthly 15 days after the end of the month Quarterly 30 days after the end of the quarter 60 days after the end of the compliance year Copyright 2009. All Rights Reserved. RKI Engineering LLC

RTU Record Identifier There are three (3) RTU Record Identifier ADD: 1 UPDATE: 2 DELETE: 3 The initial reported CEMS data is identified with an ADD RTU record identifier Any subsequent ADD RTU records are rejected An UPDATE RTU record is used to correct previously transmitted RTU record A DELETE RTU record is used in removing erroneously RTU records Copyright 2009. All Rights Reserved. RKI Engineering LLC

Daily RTU File Data Daily NOx/SOx Lbs to two decimal precision per Fuel Type for each Major Source Daily CEMS Status Valid Data - All hours are valid Calibration – Calibration was performed Offline – CEMS was in maintenance/shutdown Alternative Data – Other forms of emission recording Fuel switch – Multiple Fuel Type 10% - Reported emission using 10% range limit Below 10% - Reported emissions below 10% range limit Non-operational – Process was off Copyright 2009. All Rights Reserved. RKI Engineering LLC

Monthly/Quarterly RTU File Data Reported NOx/SOx Lbs to two decimal precision per Fuel Type Aggregate NOx/SOx Lbs to two decimal precision Copyright 2009. All Rights Reserved. RKI Engineering LLC

RECLAIM Response Message Response Packet: Upon receipt of the data file, the host will send a response packet which indicates that the data file was good, or that it was bad. Response message for good data file: OK_ _#####_sdddlyyjjjhhmmss Response message for bad data file: BAD_#####_[ASCII text message (up to 23 characters)] s = system# (alpha/num.) ddd = Ldev (MDI port#) (alpha/num.) l = Leaf/Modem no. (port Modem#) (alpha/num.) yy = Year (num.) jjj = Julian day of year record sent to PDN (001 - 365) hh = Hour (00 - 23) mm = Minutes (00 - 59) ss = Seconds (00 - 59) Copyright 2009. All Rights Reserved. RKI Engineering LLC

SCAQMD Waters Website http://www.aqmd.gov/waters RKI Engineering LLC Copyright 2009. All Rights Reserved. RKI Engineering LLC

RKI PODS Screens specific to RECLAIM RTU Transmit Status RTU Transmitted Data Major Source CEMS/RTU Reports Major Source CEMS/RTU Daily Scan Major Source Substitute Emissions Other Source RTU Reports Copyright 2009. All Rights Reserved. RKI Engineering LLC