Presented by: Danny Hintzman Luminant Power Company. Fall User Group 2015

Transcription

1 Presented by: Danny Hintzman Luminant Power Company Fall User Group 2015

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3 A good overall tool for determining what is recertification and what is Diagnostic: Recertification, Diagnostic, and Maintenance charts Located in Section 12 of the Emissions Monitoring Policy Manual manual.pdf

4 From Part 75 Emissions Monitoring Policy Manual-2013

5 From Part 75 Emissions Monitoring Policy Manual-2013

6 From Part 75 Emissions Monitoring Policy Manual May 2013 (Continued)

7 Examples of changes which require recertification include: Replacement of the analyzer; Change in location or orientation of the sampling probe or site; Complete replacement of an existing continuous emission monitoring system or continuous opacity monitoring system; The owner or operator shall also recertify the continuous emission monitoring systems for a unit that has recommenced commercial operation following a period of long-term cold storage as defined in How do you know when an event is Recertification or Diagnostic???

8 Important Column for differentiating between Recertification and Diagnostic Events.

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13 More examples of RDM charts for other system types are in Section 12 of the Emissions Monitoring Policy Manual

14 Step 1. Notify State and EPA Regional Office of recertification event (IAW 75.61). 3 Types of Events: Full recertification at least 21 days prior to 1 st scheduled day of important testing; Emergency recertification within 2 business days after 1 st scheduled day of testing; Partial recertification at least 7 days prior to 1 st scheduled day of testing.

15 Step 2. Perform recertification events (as referenced in 75.20). Important to Note: A. End of Probationary Calibration Error test - begins valid quality assured data and recertification process. B. Linearity and/or Cycle Time test - within 168 consecutive unit operating hours after the Probationary Calibration test (if necessary). C. 7-Day Calibration Error test - within 21 consecutive unit operating days after the Probationary Calibration test. D. RATA - within 720 consecutive unit operating hours after the Probationary Calibration test.

16 See 40 CFR Part for more details on specific tests that are required for each type of monitoring system. Note: Failing or aborting due to a problem with CEMS during any recertification event, starts the recertification period over, i.e. - the CEMS must not repaired, re-linearized or reprogrammed (e.g., changing flow monitor polynomial coefficients, linearity constants, or K-factors).

17 Step 3. Make Monitoring Plan changes for Component/System/DAHS Replacements. Reference: 75.53(g)(1)(iii)(A) and (B) Whenever a new analyzer is brought into service at a monitoring location, it must be assigned a new unique component ID. If an existing analyzer is removed and is later returned to service at the same monitoring location, the original component ID should continue to be used.

18 System ID's do not need to be changed unless there is going to be overlap where the existing system will continue to be used to monitor and report data while a new system of monitoring components is being certified. For minor DAHS upgrades (such as vendor patches) it is not necessary to change any monitoring system or component IDs. For DAHS vendor or platform changes you must close out the old DAHS component by adding an End date and hour to the existing records linking the old DAHS component to each monitoring system and then create a new record for each system pointing to the new DAHS component.

19 1. For late Linearity, RATA, or Cycle Time test that is passed on first attempt: data shall be invalidated from the hour of expiration of the test period until the hour of completion of the late test being performed. 2. For late 7-Day calibration error test, whether or not passed on first attempt: data shall be invalidated from the hour of expiration of the test period until the hour of completion of the late test being performed.

20 3. For late Linearity, RATA, or Cycle Time test that is failed or aborted on first attempt due to monitor issues: data shall be invalidated from the hour of the Probationary Calibration test period until the hour of completion of the late test and any additional recertification or diagnostic tests that are required to be performed as a result of changes made to correct problems that caused the failure. 4. For late 7-Day calibration error test, whether or not passed on first attempt: data shall be invalidated from the hour of expiration of the test period until the hour of completion of the late test being performed.

21 1. Whenever a calibration error test is failed or missed during a recertification test period: No further recertification tests shall be performed until the calibration error test has been passed. A missed or failed daily calibration does not restart recertification period. If failed calibration while RATA or Linearity in progress, must restart RATA or linearity. A failed calibration restarts 7-Day, if in progress.

22 2. Multi-load flow RATA where one or more load levels have passed (retest failed levels if no corrections ar made to analyzer) 3. Trial gas injections and/or trial RATA runs are permissible during the recertification test period prior to commencing a linearity check or RATA. Acceptable limits are: Gas injections: within 5% or 5 ppm of target value For RATA: within + 10% or + 15 ppm or H 2 O or lb/mmbtu (All limits are + from average ref. method value)

23 End of Presentation