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Lessons Learned from ARP, NOx Budget, and CAIR Monitoring/Reporting. Louis Nichols USEPA CEMUG Conference May 15, 2009. Check Fuel flowmeter QA Requirements.
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Lessons Learned from ARP, NOx Budget, and CAIR Monitoring/Reporting Louis Nichols USEPA CEMUG Conference May 15, 2009
Check Fuel flowmeter QA Requirements • The orifice, nozzle, and venturi fuel flowmeter QA in appendix D, section 2.1.6(c) does not include QA for coriolis, V-cone, or annubar fuel flowmeters. See AGA Report No. 3 • Perform the primary element inspection and transmitter/transducer accuracy test for orifice/venturi/nozzle plate fuel flowmeters in the same quarter in order to start baseline fuel flow-to- load data collection in appendix D, section 126.96.36.199(a) • Do not report transmitter/transducer accuracy tests for meters unless using the PEI, transmitter/transducer method of QA (orifice, nozzle and venturi only). For other meters report only the accuracy test and keep the results of the trasmitter/transducer test records on-site
Annual MPV, MPC, MEC, and Span Review • Check data at least once annually to see if MPV, MPC, MEC, and span are set according to the rule • See part 75, appendix A, sections 188.8.131.52, 184.108.40.206, 220.127.116.11, and 18.104.22.168 • Addition of pollution controls or fuel changes will change MPV, MPC, MEC and span
Calibration Gas Concentrations • Make sure that the calibration gas concentration that you enter into the DAHS agrees with the actual bottle concentration. • The DAHS will believe anything you enter into it
Separation of Loads • Make sure that prior to performing a multi-load flow RATA, you calculate a spread of 25% of load between high and mid loads and 25 % between mid and low loads. • This might be difficult for small units • Buy donuts for dispatchers and operators
Minute Data • Spot check minute data • Any changes in concentrations around blowback? • Might detect probe pluggage • Expect changes after adding pollution control devices. FGDs will change moisture and increase possibility of probe pluggage
Peruse Hourly Data • Check CO2 data (sanity check) • Check NOx and SO2 concentrations (Is these concentrations possible and is are they consistent with prior data?) • Can you justify any changes? • Are the daily calibrations consistent?
Check Annual QA/QC Data • Does this year’s RATA results look like last year’s RATA results (not just the RA)? • Is the flow–to-load ratio approximately the same? • Are the gas concentrations at the time of the RATA consistent with the sulfur content of the fuel? • Are the values corrected for moisture if necessary? • Is the NOx concentration consistent with previous RATAs? If not, is there a good reason? • Use a good testing firm, better testers are accredited
Part 60 vs. Part 75 • Do not Confuse part 60 monitoring with part 75 monitoring • One linearity check per operating quarter • no pass for quarter with RATA for part 75 • Three calibration gases are required • Do not correct NOx Concentration (ppmv) to 15% oxygen for combustion turbines
Ozone Season Reporting • Some large utilities now operate industrial sources • Different QA/QC schedule for ozone season reporters • See January 24, 2008 amendments to section 75.74
New Stacks and Controls • Use conditional data and timelines in “Part 75 Emission Monitoring Policy Manual” Questions 16.14, 16.15, and 16.16 to help avoid data loss when adding pollution controls or new stacks
Monitored Bypass Stacks • How can you QA/QC a monitor on a stack that is used at infrequent and unpredictable intervals? • Consider alternatives in sections 75.16(c)(3) and 75.17(d)(2)