Ongoing Quality Assurance for NOx and SO2 CEMS

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Ongoing Quality Assurance for NOx and SO2 CEMS

• Matthew Boze
• US EPA, Clean Air Markets Division (CAMD)
• March 2007

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Focus

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

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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

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Quality Assurance Tests for CEM Systems

• Daily Calibration Error Test
• Linearity Check
• Relative Accuracy Test Audit (RATA)
• Bias Test
• Also, for initial and recertifications only
• 7-day Calibration Error Test
• Cycle Time Tests

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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

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Daily Data ValidationApp B, 2.1.4

• NOX and SO2 monitors
• CE lt 5.0 of span, or
• R A lt 5.0 ppm if span lt 50 ppm, or
• R A lt 10.0 ppm if span gt50 lt 200 ppm
• Diluent monitors (CO2 O2)
• R A lt 1.0 CO2 or O2
• Flow monitor
• CE lt 6.0 of span, and
• Interference check must pass

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Quarterly QA App B, 2.2

• Required each QA operating quarter (gt 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)

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Data Validation App B, 2.2.3

• NOX and SO2 monitors
• LE lt 5.0 of reference value, or
• R A lt 5.0 ppm if span lt 200 ppm, or
• Diluent monitors (CO2 O2)
• LE lt 5.0 of reference value, or
• R A lt 0.5 CO2 or O2

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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 (annual reporters
  only).
• 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

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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
• RATAs are performed on a system basis
• NOX and NOX emission rate RATAs are to be
  performed at normal load

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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
• gt 85 of the unit operating hours at a single
  load
• Must submit a RT 695 (Single-load Flow RATA claim)

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Data Validation App B, 2.3.2

• Each RA lt 10.0 to pass (lt 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

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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
• Annual reporters only
• 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

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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

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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.

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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!

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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

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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 lt336 hours in the last ozone
  season
• In-season
• Linearity required each QA operating Quarter
• No grace periods allowed!

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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 lt336 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.

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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)

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Quality Assurance for Ozone Season Only
Reporters(Proposed Revised Regulation)

• 75.74(c)

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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

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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.

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Pre-Season RATAs

• RATA from previous ozone season will no longer be
  accepted
• RATAs 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.

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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

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Recertification Events
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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
• Re-linearization of a stack flow monitor
• No compliance deadline, however data is not
  considered to be valid until all recertification
  test are completed (Use substitute data)

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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)

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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

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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

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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

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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/
  emissions/process-recertification.html
• Copy EPA Region and State with
  hardcopy submittal

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Recertification Application Submittal (ECMPS
Process)

• Submit QA tests and a certification application
  record using the ECMPS client tool

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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

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The End

• Questions?