1. General Monitoring Requirements and Options
Louis Nichols
US EPA, Clean Air Markets Division (CAMD)
December 2007
Hello,
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 Deadlines
Deadlines for Initial Certification for existing units:
Annual NOx Trading Program - January 1, 2008
SO2 Trading Program – January 1, 2009
Ozone Season NOx Trading Program – May 1, 2008
First, 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 72.2
Basic Definitions referred to throughout Part 75
40 CFR Part 75 - Continuous Emissions Monitoring
Monitoring Provisions
Operation and Maintenance Requirements
Missing Data Substitution Procedures
Record Keeping and Reporting Requirements
Before 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 - Appendices
App A, Specifications and Test Procedures
App B, Quality Assurance and Quality Control Procedures
App F, Equations, F-factor
Also, it is important to understand the importance, or at least the existence, of the Appendices to Part 75
Appendix 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 Reporting
Submit 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 program
Follow standard Part 75 QA/QC timelines and data validation procedures
A must for Acid Rain units
May be required by the State rule (check with state)
Ozone Season Only Reporting
Only submit 2nd and 3rd quarterly electronic reports
Follow special QA/QC timelines and data validation procedures described in §75.74(c)
This option is a choice not a requirement
Do not get same grace period as annual reporters
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

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_ pdf
This 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/hr
Or, 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, or
Part 75, Appendix D (for gas or oil fired peaking units)
LME Method §75.19

9. NOx Emission Rate Monitoring Options
NOx-Diluent CEMS, or
Part 75, Appendix E (for gas or oil fired peaking units)
LME Default NOx Emission Rate
There are various options from monitoring the NOx Emission Rate and Heat Input
NOx 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 Diluent
Part 75, Appendix F, section 3, provides the equations that are used to compute NOx emission rate (lb/mmBtu) given:
NOx concentration
CO2 or O2 concentration
F-factor for the fuel combusted

11. Part 75, Appendix E
May 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 and
A capacity factor of no more than 20.0% in each of those three calendar years
Ozone season only reporters can qualify on an ozone season only basis §75.74(c)(11)
Initial qualification for peaking status by
Three years (or ozone season) of historical capacity factor data, or
For newer or new units, a combination of all historical capacity factor data available and projected capacity factor information

13. Part 75, Appendix E
For 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, or
Collect 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 E
Units that hold peaking status must continue to meet both the 10% three year and 20% single year (or ozone season) criteria to retain peaking status
If 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 met
A unit may then re-qualify only by providing three new years (or ozone seasons) of qualifying capacity factor data

15. Part 75, Appendix E
The average NOx emission rate (lb/mmBtu) is determined from
Periodic fuel specific NOx emission rate testing at four, equally spaced load levels
Boilers
Method 7E for NOx
Method 3A for the diluent
Stationary 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 hour
Linearly interpolate between reference points to the nearest lb/mmBtu using heat input values rounded to the nearest 0.1 mmBtu/hr

17. Operating Level 4 Operating Level 1 Operating Level 3
Segment 4
Segment 3
Operating Level 4
Operating Level 1
Segment 2
Operating Level 3
Segment 1
Operating Level 2

18. Heat Input Rate Monitoring Options
Stack Flow & *Diluent (%CO2 or O2) CEMS, or
Fuel flow monitoring via Part 75, Appendix D, or
LME Long term fuel flow or Max Rated HI
*Note: If the diluent is on dry basis must correct for moisture
The 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 System
Stack Flow Monitor &
CO2 or O2 Concentration Analyzer as the Diluent
Moisture monitor if necessary
Part 75, Appendix F § 5, provides the equations that are used to compute the heat input rate (mmBtu/hr) given:
Volumetric Stack flow
CO2 or O2 concentration
F-factor for the fuel combusted
Moisture correction

20. Part 75, Appendix D Fuel Flow Monitoring
Applicability
May be used in lieu of flow monitoring systems for the purpose of determining the hourly heat input rate and SO2 mass emissions
Gas and Oil fired units only
Heat input rate (mmBtu/hr) is determined from the:
Fuel Flow Rate (fuel flowmeter), and
Gross Calorific Value (GCV) of the fuel
Sulfur 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 years
Must 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 Plate
Nozzle
Venturi
Fuel Flowmeters Certified by Accuracy testing
Coriolis
Annubars
Vortex
Turbine meters
others

23. Appendix D Basic Fuel Sampling Options
Oil Sampling
Flow proportional/weekly composite
Daily manual sampling
Storage tank sampling (after each addition)
As delivered (sample from delivery vessel)
Gas Sampling
Monthly 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 Option
Low 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 certified
DAHS Verification
7-day Calibration Error
Cycle Time
Linearity
RATA & Bias Test

26. Overview of the Certification Process (cont.)
Upon successful completion of all certification tests, the system(s) are provisionally certified
The completed certification application is submitted within 45 days after completing all initial certification tests
Permitting 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 Notification
Certification Application Submitted (Electronic and Hardcopy)
Start of the Certification Test Period
Deadline for Certification Approval
Date of Provisional Certification
Certification Testing Deadline
All Certification Testing Completed
No later than 120 Days after receipt of completed Certification Application Package
First certification test performed
45 Days Prior to the first day of Initial Certification Testing
No later than 45 days after completion of Certification Testing
Monitoring
Deadline in SIP
(January 1, 2008 Annual NOx
May 1, Ozone Season NOx
January 1, 2009 SO2)

28. Required Certification Tests for NOx and SO2 Concentration Systems
7-day Calibration Error Test
Linearity Check
RATA
Bias Test
Cycle Time Test
DAHS Verification

29. Required Certification Tests for NOx-Diluent Systems
7-day Calibration Error Test performed on both the NOx Concentration and Diluent components
Linearity Check performed on both the NOx Concentration and Diluent components
RATA and Bias Test
Cycle Time Test performed on both the NOx Concentration and Diluent components; cycle time for the system is the highest of the components
DAHS Verification

30. Types of Electronic Reports
Initial Monitoring Plans
Certification Application
Quarterly Electronic Data Report*
Includes:
Most up-to-date version of the Monitoring Plan
Latest Certification and/or QA Tests information
* ECMPS is different