1. RECLAIM Monitoring, 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 Large 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 MMBTU/hr
I.C. Engine bhp
Gas Turbine 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 QA/QC Plan
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)
Paper report signed and mailed to SCAQMD
Annual
Signed certification mailed to SCAQMD
Reconciliation of actual usage by RTC allocation

13. Report Schedule Daily Monthly Quarterly Certification
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
Use any computer with a modem
Hyperterminal
Send a text file with a strict format
Check format with test number
( )
Submit valid data
( )

15. Confirm Electronic Reporting
Web Access to Electronic Reporting System (WATERS)
Data Acceptance Check
Transmission check
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 Large sources Process units
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. Peter Moore Yorke Engineering, LLC
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