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RECLAIMRECLAIMMonitoring, Recordkeeping and Monitoring, Recordkeeping and
Reporting (MRR)Reporting (MRR)
Peter MoorePeter MooreYorke Engineering, LLCYorke Engineering, LLC
OutlineOutline
The language of RECLAIMThe language of RECLAIM What are you monitoring?What are you monitoring?
– Continuous Emissions Monitoring (CEMS)Continuous Emissions Monitoring (CEMS)
What records do you keep?What records do you keep? ReportingReporting
– ScheduleSchedule
Language of RECLAIMLanguage of RECLAIM
REREgional gional CLCLean ean AAir ir IIncentives ncentives MMarketarket Cycle 1/Cycle 2Cycle 1/Cycle 2
– Cycle 1 compliance year is from Jan – DecCycle 1 compliance year is from Jan – Dec– Cycle 2 compliance year is from Jul – JunCycle 2 compliance year is from Jul – Jun
ZonesZones– CoastalCoastal– InlandInland
RECLAIM Trading Credits (RTC)RECLAIM Trading Credits (RTC)– Four “flavors”: combinations of Cycles 1/2 and Four “flavors”: combinations of Cycles 1/2 and
Inland/CoastalInland/Coastal
Language of RECLAIMLanguage of RECLAIM
Major SourceMajor Source– Boiler >40 MMBTU/hrBoiler >40 MMBTU/hr– I.C. Engine >1000 bhp operated > 2190 hr/yearI.C. Engine >1000 bhp operated > 2190 hr/year– Gas Turbine >2.9 MWGas Turbine >2.9 MW– Any NOx source or process unit that uses a CEMSAny NOx source or process unit that uses a CEMS
Large SourceLarge Source– Boiler 10 - 40 MMBTU/hrBoiler 10 - 40 MMBTU/hr– I.C. Engine 200 -1000 bhpI.C. Engine 200 -1000 bhp– Gas Turbine 0.2 - 2.9 MWGas Turbine 0.2 - 2.9 MW
Language of RECLAIMLanguage of RECLAIM
Process UnitProcess Unit– Pretty much everything else that is not major, Pretty much everything else that is not major,
large, and is subject to permit requirementslarge, and is subject to permit requirements
Continuous Emissions Monitoring System Continuous Emissions Monitoring System (CEMS)(CEMS)– SensorsSensors– Data Acquisition System (DAS)Data Acquisition System (DAS)
Relative Accuracy Test Audit (RATA)Relative Accuracy Test Audit (RATA)
What Are You Monitoring?What Are You Monitoring?
NOx (SOx) emissionsNOx (SOx) emissions Related parameters (for example…)Related parameters (for example…)
– Natural gas flow or meter readingsNatural gas flow or meter readings– Engine timersEngine timers– Power generatedPower generated– Ammonia injection rates for SCR systemsAmmonia injection rates for SCR systems
Anything that documents compliance with Anything that documents compliance with permit conditions or rulespermit conditions or rules
Continuous Emissions Monitoring Continuous Emissions Monitoring System (CEMS)System (CEMS)
Required only for major sourcesRequired only for major sources Continuously measures:Continuously measures:
– NOx concentrationNOx concentration– Oxygen (OOxygen (O22) concentration) concentration– Stack gas volumetric flow rateStack gas volumetric flow rate
Either measure directly; orEither measure directly; or Calculate using fuel flow rateCalculate using fuel flow rate
– Other variablesOther variables Strip chart recorder in parallelStrip chart recorder in parallel
CEMS CalibrationCEMS Calibration
Must be calibrated dailyMust be calibrated daily– Unsuccessful calibration results in missing dataUnsuccessful calibration results in missing data
Calibration records must be keptCalibration records must be kept Calibration gases must be certifiedCalibration gases must be certified Annual certification of entire measurement Annual certification of entire measurement
system by RATA testsystem by RATA test
CEMSCEMS
Permit applications are required forPermit applications are required for– Initial certificationInitial certification– ModificationModification
QA/QC PlanQA/QC Plan– Required for certificationRequired for certification– Follow it!Follow it!
CEMS – Missing DataCEMS – Missing Data
Each 1-hour reading must be based on four valid Each 1-hour reading must be based on four valid 15-minute readings15-minute readings– One missing 15-min data point means the whole hour is One missing 15-min data point means the whole hour is
missingmissing– Except for calibration & maintenance times when as few Except for calibration & maintenance times when as few
as two 15-min points are acceptableas two 15-min points are acceptable
How do you know you have missing data?How do you know you have missing data?– Look at the data for obvious gaps and inconsistenciesLook at the data for obvious gaps and inconsistencies
CEMS – Missing DataCEMS – Missing Data
Fill in missing data using missing data proceduresFill in missing data using missing data procedures– Calculate percent availabilityCalculate percent availability
This can be >100%!This can be >100%!
– For >95% availability and short gaps, use 1N ProcedureFor >95% availability and short gaps, use 1N Procedure– For <95% availability or longer gaps, use highest hourly For <95% availability or longer gaps, use highest hourly
NOx rate for last 30 days, or 365 daysNOx rate for last 30 days, or 365 days– For <90% availability, use highest hourly NOx rate since For <90% availability, use highest hourly NOx rate since
equipment was commissioned! equipment was commissioned!
NOx Emission ReportsNOx Emission Reports
Daily (Major Sources)Daily (Major Sources)– Electronic report via CEMS/DAS and modemElectronic report via CEMS/DAS and modem
Monthly (Major & Large Sources)Monthly (Major & Large Sources)– Electronic report via modemElectronic report via modem
Quarterly (All sources)Quarterly (All sources)– Electronic report via modemElectronic report via modem– Paper report signed and mailed to SCAQMDPaper report signed and mailed to SCAQMD
AnnualAnnual– Signed certification mailed to SCAQMDSigned certification mailed to SCAQMD– Reconciliation of actual usage by RTC allocationReconciliation of actual usage by RTC allocation
Report ScheduleReport Schedule
DailyDaily– By 5:00 PM the next dayBy 5:00 PM the next day
MonthlyMonthly– 15 days after end of the month15 days after end of the month
Quarterly CertificationQuarterly Certification– 30 days after end of the quarter30 days after end of the quarter
Annual Permit Emissions Program (APEP)Annual Permit Emissions Program (APEP)– 60 days after end of the compliance year60 days after end of the compliance year
Electronic ReportingElectronic Reporting
Use SCAQMD website to reportUse SCAQMD website to report– ERS Web ReportingERS Web Reporting– http://http://www.aqmd.govwww.aqmd.gov/waters//waters/
Use any computer with a modemUse any computer with a modem– HyperterminalHyperterminal– Send a text file with a Send a text file with a strict formatstrict format
Check format with test numberCheck format with test number– (909-396-3947)(909-396-3947)
Submit valid dataSubmit valid data– (877-727-1117)(877-727-1117)
Confirm Electronic ReportingConfirm Electronic Reporting Web Access to Electronic Reporting System Web Access to Electronic Reporting System
(WATERS)(WATERS)– Data Acceptance CheckData Acceptance Check– www.aqmd.gov/waters/waters.htmlwww.aqmd.gov/waters/waters.html
Transmission checkTransmission check– www.aqmd.gov/waters/erslogin.aspwww.aqmd.gov/waters/erslogin.asp– Type in facility ID and passwordType in facility ID and password
Note that if the report was late, it will NOT Note that if the report was late, it will NOT show up in WATERS, but will show up in show up in WATERS, but will show up in Transmission CheckTransmission Check
Source Test ReportsSource Test Reports
MajorMajor– CEMS RATA testing every 6 or 12 monthsCEMS RATA testing every 6 or 12 months
Large sourcesLarge sources– Every three years for NOxEvery three years for NOx– Annual source test for CO (boilers)Annual source test for CO (boilers)
Process unitsProcess units– Every five years to verify concentration limitsEvery five years to verify concentration limits
Breakdown ReportingBreakdown Reporting
You are required to report breakdownsYou are required to report breakdowns(Rule 2004(i))(Rule 2004(i))
Call the SCAQMD within one hour of breakdown Call the SCAQMD within one hour of breakdown or within one hour of when you should have or within one hour of when you should have reasonably known! (800-CUT-SMOG)reasonably known! (800-CUT-SMOG)– Write down the report number and operator Write down the report number and operator
name/numbername/number Submit report to SCAQMD 7 days after correction Submit report to SCAQMD 7 days after correction
but no later than 30 days from initial date of but no later than 30 days from initial date of breakdownbreakdown
Dealing with Audits,Dealing with Audits,Notices to Comply (NTC)Notices to Comply (NTC)Notices of Violation (NOV)Notices of Violation (NOV)
Peter MoorePeter Moore
Yorke Engineering, LLCYorke Engineering, LLC
Dealing with Audits, NTCs, NOVsDealing with Audits, NTCs, NOVs
PreparationPreparation When the Inspector ComesWhen the Inspector Comes Dealing with Notices to ComplyDealing with Notices to Comply Dealing with Notices of ViolationDealing with Notices of Violation
Preparation: Self-AuditsPreparation: Self-Audits
Conduct systematic self-audits to identify Conduct systematic self-audits to identify potential problemspotential problems– Go through each permit requirementGo through each permit requirement– Go through each rule requirementGo through each rule requirement– Document your findingsDocument your findings– Make corrections!Make corrections!
Preparation: Get OrganizedPreparation: Get Organized
Have a copy of your current permit in a 3 ring binderHave a copy of your current permit in a 3 ring binder Keep all current Keep all current and previousand previous permits organized in permits organized in
filesfiles Create a facility map showing equipment locationsCreate a facility map showing equipment locations Keep organized files of submitted reports Keep organized files of submitted reports Organize your recordsOrganize your records
– Electronic and hardcopyElectronic and hardcopy
Preparation: Organize RecordsPreparation: Organize Records
RECLAIM reportsRECLAIM reports– APEP, QCER, Monthly, Daily (CEMS)APEP, QCER, Monthly, Daily (CEMS)
Annual Emission ReportsAnnual Emission Reports Natural gas billsNatural gas bills Tune-up records for boilersTune-up records for boilers Maintenance recordsMaintenance records Source test reportsSource test reports
Preparation: Organize RecordsPreparation: Organize Records
CEMS recordsCEMS records– Calibration recordsCalibration records– Electronic transmissionsElectronic transmissions– Calculation of CEMS missing data; What days, Calculation of CEMS missing data; What days,
how you calculatedhow you calculated– Maintenance recordsMaintenance records– Calibration gas certificatesCalibration gas certificates
When the Inspector ComesWhen the Inspector Comes
Inspectors do have a legal basis Inspectors do have a legal basis to inspect equipment and recordsto inspect equipment and records
Treat the inspector with respect Treat the inspector with respect and understanding for their joband understanding for their job
Provide documents quicklyProvide documents quickly Make copies of any requested Make copies of any requested
recordsrecords
Dealing with Notices to ComplyDealing with Notices to Comply
Understand the problemUnderstand the problem Understand the specific rule or regulatory Understand the specific rule or regulatory
requirementrequirement Follow deadlines providedFollow deadlines provided Fix the problem and document complianceFix the problem and document compliance Get help if you need!Get help if you need!
Dealing With Notices of ViolationDealing With Notices of Violation
Understand the problemUnderstand the problem Understand the specific rule or regulatory Understand the specific rule or regulatory
requirementrequirement Follow deadlines providedFollow deadlines provided You may have to shut down equipment to avoid You may have to shut down equipment to avoid
further violations or increased finesfurther violations or increased fines Apply for a variance if you need to continue Apply for a variance if you need to continue
operatingoperating Get professional help (i.e. an attorney)Get professional help (i.e. an attorney)
Resources for HelpResources for Help
Talk to your Account Executive (AE)Talk to your Account Executive (AE)– For permitting assistanceFor permitting assistance– For equipment informationFor equipment information– For incentive programsFor incentive programs
Call The Gas Company’s Air Quality Call The Gas Company’s Air Quality AnswerLine with any combustion related air AnswerLine with any combustion related air quality question!quality question!
–800-GAS-2000 or800-GAS-2000 or–562-803-7428562-803-7428
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