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© 2018 Cemtek KVB-Enertec

Updating Your CEMSSeptember 11, 2018 – NetDAHS Edge Users Group

John DownsRegulatory Manager,CEMTEK KVB-Enertec


Agenda

• Open discussion on CEMS maintenance issues

• Determining when to repair or replace• Notifications• Certification Requirements• Post Certification actions


Maintenance Issues

• Analyzers drift at varying frequency• Site fails to follow analyzer O&M manual

properly• Incomplete QA program or QA program not

followed properly• Analyzer Age, difficulty finding spare parts• Other issues


Example Maintenance Issues

• CO2 analyzer continually fails daily calibrations– Analyze if exhaust stream has changed.

• Is fuel consistent?• Increased moisture?• Air clean up system maintained properly• Review maintenance records for analyzer



• Current customer request:– Claim that a major component of Flow analyzer

was replaced late Q2 – Failed Abbreviated Flow-to-Load– Stack flow at same load is increased by

approximately 24% over last RATA.– CO2 is consistent– What to do?



• Flow analyzer issue:– What component was changed?

• Analyzer is DP flow analyzer– Site changed from Coal/NG to only NG 2016.

• Passed post fuel change RATA, • Did not change re-range/span analyzer• Did not change K-factors at the time.


Repair or Replace?

• Routine Maintenance as defined in QA plan does not trigger recertification actions– Requires post maintenance Calibration

• Above examples trigger some testing– Conditional data validation calibration is required– Data is invalid from conditional calibration after

analyzer component replaced until completion of RATA.

– Failed Abbreviated Flow-to-Load– No Like-kind analyzer available to use


Notifications

• Federal rules:– Part 75 sources need notification when CEMS is

replaced• Update Monitoring plan – Electronic• Required notification 21 days prior to start of

testing– Initial Certification–Recertification

• Test Change Dates: 7 days prior


Notifications – Part 75 Cont.

• Retesting and Partial Recertification• Required notification 7 days prior to start of

testing–Exception: 2 days in cases of uncontrollable

failure of equipment• Test Date Change: 2 business days

–By Telephone or other means


Notifications – Part 75 Cont.

• New Unit Notification:– Including Newly affected unit, New Stack, or New

FGD:• Not later than 45 days Prior to Commercial Op• 45 days prior to New Stack or New FGD

exhausts to atmosphere– If Date changes: Not later than 7 days

following


Notifications – Part 60

• Notification of Physical or Operational Change– 60 days prior to change

• For emissions increases

• CEMS performance Testing– Not later that 30 days prior

• COMS - 30 days prior to start


Notifications – Part 63

• CMS Performance testing– 60 days prior to start of testing

• CMS Performance Testing results due 60-days after test completion


Notifications – State

• States vary, Check with your state• Minimum seen is 30 days• Max is 90 Days• A few have 30-day test result submission deadlines

– Most are 45 days– A few are 60 days

• Check with your state, Local, or regional Agency


Required Testing

40CFR75.20(b)“whenever the owner or operator makes a

replacement, modification, or change in the certified CEMS….

“…shall recertify the continuous emission monitoring system or continuous opacity

monitoring system …”

Presenter

Presentation Notes

According to § 75.20(b), "whenever the owner or operator makes a replacement, modification, or change in the certified continuous emission monitoring system or continuous opacity monitoring system that may significantly affect the ability of the system to accurately measure or record the SO2 or CO2 concentration, stack gas volumetric flow rate, NOx emission rate, percent moisture, or opacity, or to meet the requirements of § 75.21 or Appendix B to this part, the owner or operator shall recertify the continuous emission monitoring system or continuous opacity monitoring system according to the procedures in this paragraph."


Required Testing

• Initial Certification:– 7-Day Calibration Error or Drift– Cycle Time (Part 75) or Response Time

test (Part 60/63)– Linearity (Part 75 sources + a few states)– Relative Accuracy Test Audit– DAHS Verification – Data Substitution and

Formula Verification


Required Testing

• Initial Certification (cont., (As Applicable)):– Fuel Flowmeters (gas and/or oil meters)– Opacity (PS-1)– Hg CEMS – 3-Level System Integrity Check– HG STS – Sample Flowmeter, Pressure and

Temperature Sensor Calibrations– Other CEMS have some specific testing

requirements


Required Testing

• Recertification:– Part 75 follows requirements in 75.20(b) for

required testing– Part 75 Emissions Monitoring Policy Manual

• Great resource and guide for specific changes and required post change testing requirements


Policy Manual

• Question 12.10 lists numerous types of CEMS and components or parts, when replaced that trigger either Diagnostic or Recertification testing for:Dry-Extractive /Hot-Wet Extractive CEMS

Dilution-Extractive CEMS

In-Situ CEMS Stack Flow CEMS

Flue Gas Moisture Sensors Fuel Flowmeters

DAHS


Policy Manual

• Recertification testing is triggered when:• Replacement of the analyzer; • Change in location or orientation of the

sampling probe or site; and • Complete replacement of an existing

continuous emission monitoring system or continuous opacity monitoring system.


Policy Manual

• Recertification is also triggered when work triggers a RATA.– Changing from extractive CEMS to In-Situ or to

Dilution CEMS– Replace Critical Orifice in Dilution Probe with one

of different size– Change from in-stack to out of stack dilution

probe


Policy Manual

• Some changes on DAHS can trigger RATA: – Change or insert new temperature,

pressure or molecular weight correction algorithms in DAHS

– Change or insert mathematical algorithm in DAHS, for correcting measured NO Concentration to total NOx


Policy Manual – Diagnostic

• Diagnostic testing is defined as “ … any other tests that are necessary to ensure continued proper operation of the monitoring system (e.g., three-load flow RATAs following changes to flow monitor polynomial coefficients, linearity checks, calibration error tests, DAHS verifications, etc.) shall be performed as diagnostic tests, rather than as recertification

tests.“



• In addition, repairing or replacing specific parts of an analyzer trigger diagnostic testing.– Photomultiplier, Lamp, Pump rebuild, NO2

converter, etc. trigger:• Daily calibration• Abbreviated Linearity or• Abbreviated Cycle Time



• Diagnostic Testing for Flow Monitors– Replace or Repair Ultrasonic Transducer;

Differential Pressure probe; Thermal Probe or the interface:• Daily calibration• Abbreviated Flow-to-Load or• Leak Check


Part 60, 63, and state

• Neither Part 60 or Part 63 have defined items that trigger a recertification action.– Suggest that this be defined in QA plan– Consult with the Delegated Authority for

guidance– Follow Part 75 as guidance– Several States have adopted Part 75 like

guidance


Time-Frames for Testing

• Part 75 Policy references 75.20(b)(iv) for deadline to complete Recertification testing:

Test Deadline For CompletionLinearity 168 Consecutive Unit Operating Hours

Cycle-Time Test 168 Consecutive Unit Operating Hours

7-Day Drift Test 21 Consecutive Unit Operating Days

RATA 720 Consecutive Unit Operating Hours


Time-Frames for Testing

• No stated deadlines for:– Opacity– Fuel Flowmeters– Flue gas Moisture Sensor– DAHS


Abbreviated Testing

• All Abbreviated Testing Must be done after conditional data validation calibration.

• Abbreviated testing required completion within same time frames as full testing

• If Abbreviated test is failed, full testing is required after additional cal and data from work until this cal is Out of control.


Reporting

• All Recertification Testing is required to be reported

• Recertification Event Record Also Required• Most Diagnostic Testing not reported and

does not trigger Recertification Event record,– Some Exceptions to Recert Event reporting


Reporting

• Sources subject to Part 75 required to report summary test results via ECMPS and Hardcopy to Delegated Authority and regional EPA– ECMPS reports within 45 days of test

completion or 30th day after end of calendar quarter.


Reporting

• Sources subject to Part 63 required to report test results via Hardcopy to Delegated Authority and regional EPA– May also be required to submit data

electronically through the ERT and CEDRI– And possible via State specific reporting

platform (i.e. PADEP)


Thank YouJohn DownsRegulatory Manager CEMTEK KVB-Enertec405.360.1833 Office215.353.6125 [email protected]

mailto:[email protected]

http://www.cemteks.com/

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