Are You Really Ready for a RATA? August 5, 2015 CIBO Portland Maine Bob Davis Project Director TRC Environmental

Transcription

1 Are You Really Ready for a RATA? August 5, 2015 CIBO Portland Maine Bob Davis Project Director TRC Environmental

2 So What is a RATA? R Relative A Accuracy T Test A Audit It compares data from a facility Continuous Emissions Monitor (CEM) system to independent Reference Method data. The test is comprised of 9 valid test runs ~ 21 min. each. Up to 12 runs are allowable and 3 can be discarded. 2

3 The Test Methods are in appendix B, of 40 CFR part 60 Performance specifications define the agreement requirements of the results of the tests. RATAs have taken place for more than 20 years. Independent Source Test Performing CFR 40 part 60 test methods Continuous Emissions Monitoring System 3

4 So do you just hope that everything goes well? It is better to prepare! 4

5 What happens when you are not prepared, and have unchecked errors that could lead to Problems? 1. People can get hurt! 2. You might not get compliant results from your source test! 3. You might have to spend a lot of extra money for delays and problems! 5

6 What is required for a compliant RATA? Things that are absolutely necessary are: 1. A safe place to work. 2. A plant CEM system that is working properly. 3. A CEMS maintenance staff and plant operations staff that are ready for the test. 4. An informed regulatory agency that is prepared for the test. 5. A source testing company that is competent to test. 6

7 What are the consequences of poor preparations? If the facility is not safe people will get hurt and the job is delayed or cancelled! When the plant operational personnel, CEMS staff, regulatory agency or source testers are not prepared : -The results of the test could be compromised -There will be costly delays -The plant can be held up from operations 7

8 What are the necessary preparations for an effective stationary source test? Safety: Before the test: - All platforms have been checked for safety, and they are ready for testing. - The evacuation routes are clearly defined for everyone. - All safety presentations about the plant and specific hazards have been reviewed. - All personal protective equipment is proper, and available for use. 8

9 What are the errors that contribute to poor test results? The CEM System: Hope it doesn t look like this! The Sample Probe: - What does it look like? - Did you change the filter? - Can you change the filter? - The filter is required to carry a representative sample to the sample lines? Picture courtesy of Universal Ametek 9

10 Are you getting the representative sample? Poor sample = Error in measurement! Probe Tube Filters Probe Tube Options Probe Tip Demister - use after a wet scrubber Entrained moisture produces - raining in stack Heated Probe Tubes used if there is a dew point issue at the point of measurement the transition from stack to flange must be heated. Pictures courtesy of Universal Ametek 10

11 It is probably best to clean or replace the filter before the test. -If you cannot, get a contractor to do it. Can be cleaned in an Ultrasonic bath Gas flow path from inside - out Probe Tip Filters Photos courtesy of Universal Ametek 11

12 Check if the probe can be cleared remotely? Check the blow back to clear out the sample probe during testing. It will have to be heated to insure that the sample will have no moisture that can be carried though the sample lines. Picture courtesy of Unversal Ametek 12

13 Sample Lines can have problems! 1/3 Make sure that there is no moisture that can degrade the sample: Picture courtesy of Universal Ametek The temperature must be maintained at: o o 250 F or 365 F if using FTIR* *Method 321 > > 13

14 Maintain the seals on the end of the sample lines for cracks and wear. 2/3 -This is done to avoid moisture intrusion (check them). Picture courtesy of Ametek Photo courtesy of Universal Ametek

15 Sample Line problems 3/3 -Assure that there is adequate flow in the sample line. -Perform a sampling transport system leak check to verify as well. Picture courtesy of Universal Ametek 15

16 Data Logger errors -Make sure you are reporting in a consistent manner - Verify that the source tester has synchronized the reference method handling and the Data Handling and Acquisition System (DHAS) with the plant s DHAS. 16

17 Analyzer Errors 1/2 - Check to make sure there is adequate NO conversion. - If the NO x converter is not at > 95% it will be very difficult to pass. x Picture courtesy of Thermo Fisher 17

18 Analyzer Errors -Don t ignore the obvious! 2/2 - Do not ignore warning lights. - Check for the internal and external pump lights also. - Call the vendors if you cannot resolve the problem. 18

19 Gas cylinder potential issues - Are you using a vendor that has the PGVP qualifications (required number) if the test is for a 40 CFR part 75? - Make certain the gases used are appropriate for the analytical systems, and the linearity reference methods. - Are the cylinder gas certifications within the allowable (unexpired) time frame? - Are the zero gases accurate, can you test them on your analyzer and then source tester s? 19

20 Plant Operational Issues - Fuel 1/4 - Make sure you have enough fuel or raw material (i.e.. biomass) inventory to sustain the test maintaining at the proper load. 20

21 Plant Operational Issues - Unannounced, Automatic, or unplanned events -If the chiller comes on or power changes (surges) during test. - Did you inform the source testers when the automatic events (calibration, etc.) occur? -Has the plant been advised to notify the test crews of any operational changes before they occur? 2/4 21

22 Plant Operational Issues Operations issues with power for the source testers and trailers 3/4 - Do you have enough power for the upper (on the stack) and lower level of testing (trailer)? - Make efforts to have the power cords in place so that they will not be disconnected from the source tester s equipment or trailer. 22

23 -Plant Operational Issues cont.. Don t over look the obvious! 4/4 - Loosen the ports for easy removal before the test. - Make sure the ports are clean and free of debris. 23

24 Regulatory Agency Issues - Has the test protocol been submitted in accordance with the proper time frame for the regulatory requirements? - Be aware that the state my have another notification letter which is required within a limited time before the test. 24

25 Source Tester Issues 1/2 - Do the source testers have the proper ASTM D7036 qualifications and a Qualified Individual present (if it is a 40 CFR Part 75 test)? - Does the company have the appropriate credentials to run the test? - If they have a lab trailer does it have controls for maintaining a consistent temperature? 25

26 Source Tester Issues 2/2 - How is the electronic data backed up (hard drive)? - Are the proper number of test runs for the proper duration being run? Has the plant operations been informed of the schedule? - Have the source testers arranged for operational data to support the source test? - Will the results be known at the end of the test (pass / fail)? 26

27 Communications is Key to Success -Make sure everyone knows: - The scope of the test program - The schedule of the test program - Their responsibility in the test program - Their communications procedures during the test program -These things will alleviate most significant problems! 27

28 What happens when the unexpected occurs? 1. Have a contingency plan to manage issues with the resources you have. Document it so you will know how to deal with it if it happens again. 2. Don t panic work with your competent source tester and fix the problem. 28

29 Potential errors and issues are always there that can contribute to uncertainty of test results. In Summary: -Understand where the potential issues are. -Have your contingency plans ready for the unexpected. - Communicate effectively 29

30 Questions? Bob Davis P: E: 30