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