1. 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

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

3. 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
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RKI Engineering LLC

4. 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
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RKI Engineering LLC

5. 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
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RKI Engineering LLC

6. 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
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RKI Engineering LLC

7. 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
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RKI Engineering LLC

8. 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
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RKI Engineering LLC

9. 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
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RKI Engineering LLC

10. Emission Rate Calculations
NOx Lbs/Hr = *NOx (ppmvd)*Stack Flow (mscfh)
SOx Lbs/Hr = *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
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RKI Engineering LLC

11. 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
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RKI Engineering LLC

12. 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
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RKI Engineering LLC

13. 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)
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RKI Engineering LLC

14. 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
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RKI Engineering LLC

15. 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
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RKI Engineering LLC

16. 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
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RKI Engineering LLC

17. 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
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RKI Engineering LLC

18. Monthly/Quarterly RTU File Data
Reported NOx/SOx Lbs to two decimal precision per Fuel Type
Aggregate NOx/SOx Lbs to two decimal precision
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RKI Engineering LLC

19. 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 ( )
hh = Hour ( )
mm = Minutes ( )
ss = Seconds ( )
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RKI Engineering LLC

20. SCAQMD Waters Website http://www.aqmd.gov/waters RKI Engineering LLC
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RKI Engineering LLC

21. 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
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RKI Engineering LLC