The Differences Between Part 60, and 75 Regulations

Transcription

1 ESC SPRING USERS GROUP The Differences Between Part 60, and 75 Regulations Taking energy to heart.

2 Applicability 2 Part 60 regulations mostly apply to Limit monitoring Subparts D, Da, and Db Often required when states apply CEM monitored limits For example PSD limits for CO. Part 75 applies to most EGUs over 25 Mw (Cap and Trade) Some Harmonization for above stated rules Total Harmonization for Part 60 subpart GG and KKKK

3 Required CEM QA/QC 3 Part 60 Daily Calibration Drift 7-day drift test Cylinder Gas Audits (CGAs) RATAs Response Time Test CO monitors with emission standard < 200 ppm Part 75 Daily Calibration Error 7-day Calibration Error Linearity RATA Cycle Time Tests

4 Daily Calibration Checks 4 Part 60 CD criteria located in PS 2-4A Complete every 24 hours OOC if NOx/SO2 (PS-2) 5%for 5 days 10% for 1 day CO2/O2 (PS-3) 1% for 5 days 2% for 1 day CO (PS 4/4A) 10% for 5 days 20% for 1 day Part 75 CD Criteria in Appendix B Complete every 26 hours 8 hour start up grace period OCC if SO2/NOx 5% R-A 5 ppm (span< 50) R-A 10ppm (span<200) CO2/O2 1% absolute difference Part 75 does not include CO May use Mid or High gas for daily cal.

5 7 Day Drift Test 5 Part 60 7-day Drift Test Measures daily Calibration drift at 24 hour intervals during 7 consecutive operating days NOx/SO2 2.5% of span O2 0.5% absolute difference CO 5% of span & pass 6 out of 7 days Applies to all units and Spans Part 75 7-day Calibration Error Same as Part 60 Exempts peaking units and spans less than 50 ppm

6 Linearity/CGA 6 Part 60 Cylinder Gas Audits (CGAs) Must be performed 3 out of 4 Calendar quarters NOx/SO2/CO Use gases at 20 to 30% and 50 to 60% of span O2 gas at 4-6% and 8-12% CO2 gas at 5-8% and 10-14% Error must not be > 15% of reference value (or not be > 5 ppm) Unit does not have to be operating Part 75 Linearity Performed every operating quarter and at least once per year Use gases at 20-30%, 50-60% and % Error must be > 5% or 5 ppm (0.5% for CO2 and O2) Spans 30 ppm and under are exempt Unit must be operating

7 Response/Cycle Time 7 Part 60 Response Time Test CO monitors with emission standard < 200 ppm Shoot zero gas, then shoot span gas Repeat 3 times Response time must be < 1.5 minutes Upscale and downscale Part 75 Cycle Time Tests Same as part 60 except response time must not exceed 15 min. If using mid gas for day cal you still need a high bottle to complete. For the Alt. system response check Mid Bottle is ok.

8 RATAs 8 A RATA consists of 9 or more sets of concurrent reference method (RM) and CEMS measurements Must be conducted for SO 2 and CO 2 /O 2 monitors, NO X + CO 2 (or O 2 ) CEM systems, and flow monitors Gas RATA (SO 2, NO x, diluent) = Single (Normal) Load NO x normally in conjunction with diluent (lb/mmbtu basis) Both Part 60 and 75 require a Stratification test before conducting RATA

9 Stratification 9 Perform stratification test prior to RATA 40 CFR Part 75, Appendix A, Section Or at least have the historical stratification data Perform 12-point traverse at normal, steady load Determine points via RM 1 Minimum of 2 minutes per traverse point Option to perform abbreviated stratification test -- 3-point traverse at 16.7, 50.0, 83.3% of stack diameter, or 6-point traverse along stack diameter via RM 1

10 Stratification Long/Default measurement line (Option A) 3 points at 16.7, 50.0, and 83.3% of stack diameter Exempt from performing stratification test Short measurement line (Option B) 3 points at 0.4, 1.2, and 2.0 meters from stack wall Must initially pass stratification test Each traverse point differs by no more than 10.0% from the 12- point average, or Each traverse point differs by no more than + 5 ppm or + 0.5% absolute from the 12-point average Single point measurement line (Option C) 1 point located at least 1.0 meter from stack wall Cannot use abbreviated stratification test Must pass more stringent stratification test prior to each RATA Each traverse point differs by no more than 5.0% from the 12-point average, or Each traverse point differs by no more than + 3 ppm or + 0.3% absolute from the 12-point average 10

11 Stratification 11 For Part 75 RATAs -- When long/default measurement line is not used on sources with wet scrubbers (or suspected stratified sources), must perform stratification test prior to each RATA Must initially perform 12-point stratification test and every time for single point sampling Can perform abbreviated stratification test for subsequent RATAs For Part 60 RATAs -- Basically limited to Options A and B Can petition to use alternative traverse points, provided that a representative sample can be obtained (e.g., single point RATAs) Single point RATAs not permitted (unless petition granted) Abbreviated stratification checks not permitted For CEMS installed downstream of a wet scrubber, must use long measurement line

12 RATAs 12 Part 60 Operate unit at > 50% load Performed at least once every 4 calendar quarters RATAs (NO x /SO 2 ) Results must not be > 20% RA Results must not be > 10% emission standard if RA emissions are less than 50% of the emission standard (aka permit limit) RATAs (O 2 /CO 2 ) Must not be > 20% RA, or Must be within + 1.0% absolute difference RATAs (CO) RA results must not be > 10% when the RM value is used to calculate the RA RA results must not be > 5% when the applicable emission standard is used to calculate the RA RM and CEMS within 5 ppm

13 RATAs 13 Method used to determine normal load Prepare historical load frequency distribution Identify 2 most frequently used load levels Designate the most frequently used load level as the normal load level Other load level may be designated as a second normal load level Reports Part 75 Operating Load Analysis

14 RATAs 14 Qualify for Semi-Annual Testing (Every 2 operating QRTs) SO 2 > 250 ppm: 10.0% RA < 250 ppm: 10.0% RA or within ±15 ppm when RA > 10.0% NO X /CO 2 (or O 2 ) > lb/mmbtu: 10.0% RA < lb/mmbtu: 10.0% RA or ±0.020 lb/mmbtu when RA >10.0% Diluent Either 10% RA Or within ±1.0% absolute Qualify for Annual Testing (Every 4 operating QRTs) SO 2 > 250 ppm: 7.5% RA < 250 ppm: 7.5% RA or within ± 12 ppm when RA > 7.5% NO X /CO 2 (or O 2 ) > lb/mmbtu: 7.5% RA < lb/mmbtu: 7.5% RA or ±0.015 lb/mmbtu when RA > 7.5% Diluent Either 7.5% RA Or within ±0.7% absolute

15 RATAs 15 Must be calculated for SO 2 monitor, NO X /CO 2 (or O 2 ) system, and flow monitor Highest a BAF can be is Definition: When the mean of the differences between CEMS and reference method values is positive and greater than the 95% confidence coefficient In layman s terms, most often means if the tester s RM value is greater than the facility CEMS value If the bias test is failed: Take corrective action and repeat the RATA Use non-routine pre-test adjustments and/or trial runs Part 75, Appendix B, Section 2.1.3(c) Adjust subsequent CEMS data using a bias adjustment factor (BAF)

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