NOx Emissions Monitoring

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					   General Monitoring
Requirements and Options
    EPA Region 4 Workshop
       March 15, 2007
        Louis Nichols
      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
     Monitoring Regulations

   40 CFR Part 72.2
    – Basic Definitions referred to throughout Part 75
   40 CFR Part 75 - Continuous Emissions
    –   Monitoring Provisions
    –   Operation and Maintenance Requirements
    –   Missing Data Substitution Procedures
    –   Record Keeping and Reporting Requirements
     Monitoring Regulations

   40 CFR Part 75 - Appendices
    – App A, Specifications and Test Procedures
    – App B, Quality Assurance and Quality Control
    – App F, Conversion Procedures (equations)
    Monitoring Requirements

   SO2 Mass Emissions (lb/hr)

   Heat Input (mmBtu/hr)

 NOx   Mass Emissions (lb/hr) – Subpart H
    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
     – 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
Monitoring Options for Determining
      NOx Mass Emissions

 NOx   Concentration (ppm) & Stack Flow Rate (scfh)

    Emission Rate (lb/mmBtu) & Heat Input Rate
 NOx
SO2 Mass Monitoring Options

 SO2 Mass
  – SO2 and Stack flow monitor, or
  – Part 75, Appendix D (for gas or oil fired
    peaking units)
  – LME Method §75.19
NOx Emission Rate Monitoring Options

    NOx Emission Rate
      – NOx-Diluent CEMS, or
      – Part 75, Appendix E (for gas or oil fired peaking units)
      – LME Default NOx Emission Rate
         NOx-Diluent CEMS

   Two components
     – NOx Concentration Analyzer &
     – CO2 or O2 Concentration Analyzer as the Diluent

   Part 75, Appendix F, §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
        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
         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
        Part 75, Appendix E

   For units that make a change in capacity factor may qualify
     – Collecting three calendar years of data following the
        change to meet the historical capacity factor
        specification, or
     – Collecting 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
         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
        Part 75, Appendix E

   The average NOx emission rate (lb/mmBtu) is determined
     – 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
             Method 7E for NOx

             Method 3A for the diluent
           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 0.001 lb/mmBtu using heat input values
       rounded to the nearest 0.1 mmBtu/hr
                                                         NOx Correlation Curve Segments

                                                                                              Segment 4
                                                                      Segment 3
                                                                                                                 Level 4
                                             Level 1
NOx Emission Rate (lb/mmBtu)

                               0.200                      Segment 2                        Operating
                                                                                           Level 3

                                           Segment 1

                                                                           Level 2


                                       0          200      400             600              800           1000      1200     1400
                                                                        Heat Input Rate (mmBtu/hr)
Heat Input Rate Monitoring Options

   Heat Input Rate
     – 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
     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
       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
        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
        Part 75, Appendix D
   Fuel Flowmeters Certified by Design
     – Orifice Plate
     – Nozzle
     – Venturi

   Fuel Flowmeters Certified by Accuracy testing
     – Coriolis
     – Annubars
     – Vortex
     – Turbine meters
     – Others
        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)
LME Monitoring Option

 Low Mass Emissions Units
            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
     – DAHS Verification
    – 7-day Calibration Error
    – Cycle Time
    – Linearity
    – RATA & Bias Test
         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
                Initial Certification Timeline
Monitoring                                                                              Certification
  Plan &                                                                                 Application
Certification          Start of the                                                      Submitted         Deadline for
                                                   Date of            Certification
    Test               Certification             Provisional            Testing        (Electronic and     Certification
Notification           Test Period               Certification         Deadline          Hardcopy)          Approval

                                         Certification                                                No later than 120
45 Days Prior to    certification test
                                         Testing                                       No later than Days after receipt
 the first day of   performed            Completed                                     45 days after   of completed
      Initial                                            Monitoring                    completion of   Certification
  Certification                                                                         Certification   Application
     Testing                                             Deadline in SIP                  Testing         Package
                                                         (January 1, 2008 Annual NOx
                                                         May 1, 2008 Ozone Season NOx
                                                         January 1, 2009 SO2)
      Required Certification Tests
for NOx and SO2 Concentration Systems

 7-day Calibration Error Test
 Linearity Check
 Bias Test
 Cycle Time Test
 DAHS Verification
 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
  Types of Electronic Reports

 InitialMonitoring Plans
 Certification Application
 Quarterly Electronic Data Report*
  – Includes:
     »Most up-to-date version of the
       Monitoring Plan
     »Latest Certification and/or QA Tests
     * ECMPS is different

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