US EPA Roundtable Research Triangle Park. By: Richard A. Hovan Sr., QEP Date: December 05, 2016

Transcription

1 US EPA Roundtable Research Triangle Park By: Richard A. Hovan Sr., QEP Date: December 05, 2016

2 SPECIFICATIONS AND TEST PROCEDURES FOR PREDICTIVE EMISSION MONITORING SYSTEMS IN STATIONARY SOURCES Major Sources most effected by PS-16 Stationary Gas Turbines Industrial, Commercial, Institutional Steam Generating Units Performance Specification 16 will neither apply to existing PEMS nor those covered under Subpart E of 40 CFR part 75. Part 75 is the Acid Rain Market trading program monitoring requirements Subpart E is the monitoring criteria for Alternative Monitoring Systems

3 Harmonization of Part 75; Subpart-E Part 75 is the Acid Rain Market trading program monitoring requirements Subpart E is the monitoring criteria for Alternative Monitoring Systems (AMS) Currently (until 3/15) required that all AMS applications perform monthly CGAs or equivalent tests to provide acceptable system validation of accuracy March 2015 ruling by CAMD specific to PEMS PEMS are to be able to provide validation testing for Part 75 applications according to PS-16 standards This was approved for a facility in Arkansas with 7 Combined Cycle GTs

4 Initial Relative Accuracy Test Audit (RATA) Third Party Testing Company Quarterly Relative Accuracy Audit (RA) Portable Analyzer Test Yearly Relative Accuracy Test Audit (RATA) Third Party Testing Company

5 Initial Relative Accuracy Test Audit (RATA) Measurand >100ppm = 10% RA Measurand 10ppm 100ppm = 20% Measurand < 10ppm = +/- 2ppm Quarterly Relative Accuracy Audit (RAA) Measurand >100ppm = 10% RA Measurand 10ppm 100ppm = 20% Measurand < 10ppm = +/- 2ppm Yearly Relative Accuracy Test Audit (RATA) Measurand >100ppm = 10% RA Measurand 10ppm 100ppm = 20% Measurand < 10ppm = +/- 2ppm

6 PS-16 has been written for NO X and O 2 only PEMS has evolved and now does SO 2 CO 2 CO H X C Y (specific) and THC States have been imposing standard Part 60 analyzer accuracies on tester analyzers and PEMS for emissions other than NO X

7 States have been imposing standard Part 60 analyzer accuracies on tester analyzers and PEMS for emissions other than NO X CO is the issue and needs harmonization A little History Late 90s to early 2000s tests where run by CARB on low level CO sample-line absorption ~1ppm absorption and random off-gas occurred Final results was Low level testing limitations CO for 5ppm and less; the analyzer only has to be +1ppm

8 States have been imposing standard Part 60 analyzer accuracies on tester analyzers and PEMS for emissions other than NO X CO is the issue and needs harmonization Final results was Low level testing limitations CO for 5ppm and less; the analyzer only has to be +1ppm PEMS required to meet 20% for all gases (NO X to follow PS-16) If CO is 2ppm then PEMS CO would have to meet an RATA of 0.4ppm Certifying with a tester instrument that only has to meet a +1ppm on a 2ppm reading Doable but difficult PS-16 must be changed to include all primary pollutants for the same test accuracies

9 8.3 Statistical Tests for PEMS that are Used for Continual Compliance. In addition to the RA determination, evaluate the paired RA and PEMS data using the following statistical tests Bias Test. From the RA data taken at the mid-level, determine if a bias exists between the RM and PEMS. (Use the equations in PS-16,Section ) F-test. Perform a separate F-test for the RA paired data from each operating level to determine if the RM and PEMS variances differ by more than might be expected from chance. (Use the equations in PS-16, Section ) Correlation Analysis. Perform a correlation analysis using the RA paired data from all operating levels combined to determine how well the RM and PEMS correlate. (Use the equations in PS-16, Section The correlation is waived if the process cannot be varied to produce a concentration change sufficient for a successful correlation Correlation Analysis. Calculate the correlation coefficient either manually (as per PS-16 Eq.16-8) or by computing all of the paired data points from all operating levels. The PEMS correlation must be 0.8% or greater to be acceptable If Auto-correlation is determined during initial certification test then the correlation analysis is permanently waived Auto-correlated according to 40CFR 75.41(b)(2) procedures If signal-to-noise ratio of the data is less than 4.

10 Initial RATA Once at initial system certification Quarterly RAA 3 consecutive Quarterly Audits (1 st year) If 1 st year RAAs and Yearly RATA pass then RAAs can be reduced to 6 month intervals. Yearly RATA Yearly at the completion of the 4 th Quarter

11 RM Tests for Excess Emission PEMS. For PEMS used for excess emission reporting, conduct at least 3, 21 minute runs of RM tests at the following key parameter operating levels: Low Load (minimum - 50%) Mid Load (50% - 80%) High Load (80% - 100%) RM Tests for Continual Compliance PEMS. For PEMS used to determine compliance, conduct at least 9, 21 minute runs of RM tests at the following key parameter operating levels: Low Load (minimum - 50%) Mid Load (50% - 80%) High Load (80% - 100%)

12 RM for Quarterly RA 3, 21 minute runs with portable analyzer Each run at 3 equidistant traverse points across measurement point Each traverse point averaged for 7 minutes Simultaneously record PEMS data and calculate RAA

13 RM Tests for Excess Emission PEMS. For PEMS used for excess emission reporting, conduct at least 3, 21 minute runs of RM tests at the following key parameter operating levels: Normal Operating Load RM Tests for Continual Compliance PEMS. For PEMS used to determine compliance, conduct at least 9, 21 minute runs of RM tests at the following key parameter operating levels: Normal Operating Load

14 PS-16RM Tests for Excess Emission PEMS For PEMS used for excess emission reporting, conduct at least 3, 21 minute runs of RM tests at the following key parameter operating levels: Normal Operating Load RM Tests for Continual Compliance PEMS. For PEMS used to determine compliance, conduct at least 9, 21 minute runs of RM tests at the following key parameter operating levels: Normal Operating Load