United States Office of Air Quality EPA-340/1 -85-010
Environmental Protection Planning and Standards October 1985
Agency Research Triangle Park NC 27711
I PB87-232138
Stationary Source Compliance Guideline
EPA Technical Guidance
On The Review And
Use Of Coal
Sampling And
Analysis (CSA)
Data
REPRODUCED BY
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA 340/1-85-010
3. RECIPIENT'S
I. TITLE AND SUBTITLE
Technical Guidance on the Review and Use of
Coal Sampling and Analysis
5. REPORT DATE
October 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO,
Louis R. Paley
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Same as box; 12.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
US Environmental Protection Agency
Office of Air Quality Planning and Standards
Washington, DC 20460
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
The author can be contacted at Stationary Source Compliance Division
(EN-341):. Telephone: (202) 382-2884
16. ABSTRACT :
This document provides technical guidance to EPA's regional offices
and State and local control .agencies on the review and use of coal sampling
and analysis fCSA) data in monitorine the compliance status of Subpart D boilers
burning compliance coal and other large boilers which are not presently using
S02 Continuous Emission Monitoring Systems (GEMS) nor submitting S02 Excess
Emission Reports (EERs). The guidance is not applicable when the CSA method is
specified as the emission compliance, alternative emission compliance, or sulfur-
in-fuel compliance test method. The guideline describes specific forms and
calculation methods to convert the source's coal sampling and analysis data into
S02 EERs.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS |c. COSATI Field/Group
Coal-Fired Boilers
S02 Emissions
Coal Sampling
Compliance Monitoring
Excess Emissions
8. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report I
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS COITION i* OBSOLETE
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EPA-340/1-85-010
Technical Guidance On The Review
And Use Of Coal Sampling And
Analysis (CSA) Data
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460
October 1985
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DISCLAIMER
This report has been reviewed by the Office ot Air Quality
Planning and Standards, EPA, and approved tor publication.
Mention ot trade names or commercial products is not intended
to constitute endorsement or recommendation tor use. Copies ot
this report are available through the Library Services Office
(MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, NC 27711; or, tor a tee, from the National Technical
Services, 5285 Port Royal Rd., Sprinytield, VA 22161.
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TRANSMITTAL MEMORANDUM
FINAL GUIDANCE ON THE REVIEW AND USE OF
COAL SAMPLING AND ANALYSIS DATA
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I MTEI) ST \TKS KNMKOMIKNT \L PKOTKCTION
\V \Hll.\«;TO\, D.C. 20460
OCT 301986
OFFICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT: Final Technical Guidance on the Review and Use of
Coal Sampling and Analysis Data
FROM: Director
Stationary Source Compliance Division
Office ot Air Quality Planning and Standards
TO: Air Management Division Directors
Regions I, III, V, and IX
Air and Waste Management Division Director
Region II
Air, Pesticides, and Toxics Management Division Directors
Regions IV and VI
Air and Toxics Division Directors
Regions VII, VIII, and X
I. INTRODUCTION
This memorandum transmits two documents: (A) final
technical guidance on the acquisition, review and use of
coal sampling and analysis (CSA) data from large coal-fired
boilers where the monitoring data are used for targeting
agency follow-up actions; and (B) an example of the
calculations performed in accordance with item A. The
guidance is not applicable when the CSA method is specified
as the emission compliance, alternative emission compliance,
or sulfur-in-fuel compliance test method. Furthermore, this
guidance may be helpful to State and local agencies as well
as EPA's Regional Offices.
\J
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On April 5, 1985, and again on August 16, 1985, a
draft of this guidance was distributed to the Regional
Offices and interested Headquarters offices. Comments were
received from six Regional offices and two Headquarters
offices. In general, the comments were very supportive of
the drafts, and included a number of constructive suggestions
for improving the document.
II. SUMMARY AND CONCLUSIONS
The guidance presented in Attachment I supplements the
October 5, 1984 source targeting document entitled "Technical
Guidance on the Review and Use of Excess Emission Reports"
(hereafter called the 1984 EER Guidance) by addressing those
large coal-fired boilers which burn "compliance" coal but
which are not currently required to operate SO2 CEMS, nor
to report SO2 CEMS data. Taken together, the CSA and EER
guidance packages equip agencies to review and use effectively
quarterly SO2 emission data, whether derived from S02 CEMS
or CSA methodologies.
This guidance recommends that agencies periodically
request source submittal of limited quantities of CSA
information. Such information will generally be available
to the sources as a result of their routine business practices.
In the event such information is not currently available
at a source, the source's cost of acquiring it should not
be substantial.
Furthermore, the guidance strongly recommends that
agencies use and follow-up the CSA information in a manner
comparable to how it presently uses CEMS-derived excess
emission reports (EERs).
The guidance contained in Attachment I provides forms,
equations and examples of how to convert CSA data into SO2
EERs. Attachment II presents actual calculations, discussion
and action recommendations, based upon empirical CSA data,
and is consistent with Attachment I.
III. MAJOR COMMENTS
A. Timing of Issuing the Subject Technical Guidance
Most of the commenters recommended that SSCD issue the
subject guidance as soon as possible. One Regional commenter
questioned the decision to issue it now, given that the
Agency is contemplating possible revision of the current
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NSPS Subpart D rules. A different Regional Office, one
which is presently using a sophisticated enhancement of
the CSA procedure described herein, recommended that we
issue CSA guidance in two phases, the subject guidance now
and a more sophisticated version later.
SSCD concluded that it is appropriate to issue the
subject CSA guidance now, even though a possible CSA
alternative compliance method (Reference Method 19-A) is
contained in the current draft of the NSPS Subpart D revision,
Issuing this technical guidance now is appropriate because:
1) the subject document is relevant to many non-NSPS,
large coal-fired, non-FGD controlled boilers which
do not monitor and report SC>2 CEMS data;
2) the possible Subpart D revision is not expected
to become effective for at least one year;* and
3) implementation of this guidance is not expected
to create a measurable additional burden upon the
applicable sources.
Therefore, agencies will benefit from having a CSA review
method immediately available to them.
Furthermore, SSCD agrees that it may be appropriate
to develop and disseminate more sophisticated guidance on
CSA. Therefore, after the subject guidance is issued, and
experience with it has been gained, SSCD will evaluate the
technical feasibility and advisability of issuing new, more
sophisticated, CSA guidance or procedures. If a decision
is made to develop additional CSA guidance, your input
and assistance will be requested.
B. Quality of CSA Data
One commenter expressed concern about the logic of
expending agency resources to acquire and use what they
construed were "uncertain data" to target enforcement
activities when sources are, or will in the near future
(the Region presumed), be required to submit quality-assured
SO2 CEMS data.
*Note: If EPA promulgates a revision of Subpart D which
specifies various types of continuous monitoring
(including CSA) as compliance methods, this guidance
would cease to be applicable to the S02 emissions
from Subpart D sources.
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This guidance addresses sources which are not required
to obtain GEMS data, but currently do have CSA data of
sufficient quality to warrant their use in targeting enforce-
ment activities. Since this guidance does not address CEMS
data, SSCD deemed it appropriate to issue this guidance at
this time. It should also be recalled that while striving to
obtain readily available, high quality data, the quality
assurance requirements for data used in targeting do not have
to be quite as stringent as when the data are used directly
to enforce an emission regulation. Furthermore, experience
shows that agencies which take the following steps generally
receive CSA data which are fully suitable to target boilers:
0 make the purpose of the agency's CSA data
acquisition program known to the source;
0 request a corporate official's signature on
each CSA data submittal;
0 conduct agency inspections and/or reviews of the
source's CSA equipment; and
0 demonstrate to the source that the agency is
using its CSA data to target enforcement follow-up
actions.
C. Relationship of the Subject Guidance to CEMS/EER Guidance
In 1984, SSCD issued the document entitled "Technical
Guidance on the Review and Use of Excess Emission Reports."
That document addressed EERs derived from SC>2 CEMS. However,
it recognized the need to develop and issue supplemental
guidance to address those large coal-fired boilers which
currently are not required to use SC>2 CEMS. The guidance
contained in Attachment I is specifically intended to supple-
ment the 1984 EER Guidance. Taken together, the 1984 EER
Guidance and this document provide agencies with the procedures
to target all large coal-fired boilers based upon SO2~related
criteria.
The guidance provides specific forms and calculation
methods to convert the source's coal sampling and analysis
data into SO2 EERs. Once such EERs are derived, it states
that one should target and follow-up such data in a manner
generally consistent with the procedures included in the 1984
EER Guidance.
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D. Length and Complexity of the Guidance
Some of the commenters recommended that the final
guidance should be simplified and streamlined in size.
It became clear that this could be accomplished through
the following two changes to the draft:
1) simplifying the calculation and technical details
in accordance with the comments received; and
2) reorganizing and repackaging the guidance into
two separate attachments.
IV. RESPONSES TO SSCD'S SPECIFIC CSA QUESTIONS
A. Agencies Should Obtain CSA Data from All
"Compliance Coal" Subpart D Boilers
The commenters generally supported the idea that
agencies should periodically obtain CSA data from every
non-FGD-controlled (compliance coal) Subpart D boiler and
other large boilers which are not presently using SC>2 CEMS,
nor submitting SC>2 EERs.
Some Regional commenters stated that the preferred
mechanism for obtaining quarterly CSA data is to request it
by letter (e.g., §114), though other methods may be chosen
by an agency.
With respect to which CSA data to obtain each quarter,
the consensus was that, in general, it is important to obtain
the summarized results of "as-fired" or "as-bunkered" CSA
data derived from sampling the coal which is (or will be)
combusted during each twenty-four hour period. Twenty-four
hour CSA data are currently available from most modern
boilers, and this period is consistent with those contained
in the Agency's Proposed CSA Reference Method 19-A.
B. Agencies Should Take Into Account Data Uncertainties
Comments on this issue generally fell into four widely
different viewpoints. These included: (1) do not use data
which has an uncertain quality; (2) assume that the data
values are high; (3) assume that data values are low; and
(4) assume that the data are generally representative of the
real level. SSCD recognizes that in a normal situation, there
are likely to be as many causes for the CSA data to be high
as there are for them to be low. Therefore, solely for the
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purpose of targeting, if the source takes reasonable care in
its CSA program, twenty-four hour CSA data are assumed to
represent adequately the actual average (three to twenty-four
hour) SO2 emission potential of the coal combusted.
C. Preparation of CSA-derived EERs
The sentiment among the commenters was in favor of
requesting the sources to submit CSA-derived EERs to the
agencies on a quarterly basis, rather than having the agencies
prepare the EERs in-house from "raw" source-submitted, daily
data. The experience to date is that sources generally
respond in the affirmative when requested to convert their
CSA data into SC>2 excess emission reports. Furthermore,
if the agency chooses to prepare EERs, it would require
two submittals (or more) per quarter of data from the source.
First it would receive "raw CSA data." Second, for every
excess emission identified by the agency, the agency would
require source submittal of concomitant process data.
Therefore, the guidance strongly recommends that agencies
request source submittal of its EERs.
D. Negative Reaction to Using "As-Received" CSA Data
The consensus opinion on the subject of agency use of
as-received CSA data was opposed to generally accepting and
using such data. The primary reasons for this position are:
(1) there are usually no practical and simple ways
to predict which day's SO2 emissions a specific
coal sample and its concomitant results represent;
(2) allowing a source to rely upon its own as-fired
or as-bunkered CSA data (in lieu of SO2 GEMS) was
seen by some commenters as providing a sufficient
selection of alternatives to the source; and
(3) many sources' as-received CSA hardware and test
procedures do not meet the minimum acceptable
criteria specified in the guidance and by ASTM.
Therefore, the consensus was that it would be inappropriate
to "generally" accept as-received CSA data.
However, the commenters recognized that there might
be some instances where reliance on as-received data would
be appropriate. Therefore, the guidance accommodates, on a
case-by-case basis (e.g., the sampling is consistent with
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a twenty-four burn's "lot size," the emission rate is
calculated to be far below the allowable rate, the coal
is received from a single mine), agency evaluation of
as-received data. Further, the guidance specifies that
before accepting such data, the agency should be as confident
about the resulting SC>2 EER as it would have been if it had
relied upon either as-fired or as-bunkered data.
E. Targeting Criteria
The consensus of the commenters on this subject was
that agencies should use targeting criteria for CSA-derived
EERs which are comparable, if not slightly tighter, than
those it uses for CEMS-derived EER results. The fact that
a source uses a different SC>2 monitoring method should not
measurably affect the agency's criteria. Therefore, with
only the few modifications noted in Attachment I, the
criteria included in the 1984 EER Guidance are appropriate
when CSA data are used.
In summary, the comments received on the draft
guidance urged that final CSA guidance be issued as soon
as possible, incorporating relatively few major changes
to the draft. SSCD intends to continue to support the
program by issuing supplementary information and program
guidance as necessary.
Since this guidance supplements and is conceptually
and programmatically quite similar to the previous EER
guidance, the following are true of the CSA guidance:
0 it is issued as "technical guidance" rather
than as "program guidance" in that it supports,
but does not mandate, a review program;
0 it is equally as important as CEMS targeting
activities and, therefore, both should be
implemented concurrently;
0 there is a need for a limited period of source
submittal of CSA-derived EERs to both State and
Federal agencies, as in the case of the CEMS-derived
EER data; and
0 it is not applicable to any situation where CSA
data are specified as the compliance method.
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If your staff desires to distribute the attached
guidance to Regional, State or industry personnel, additional
copies may be requested from Louis Paley of this office.
Requests should be sent to him at US EPA, SSCD (EN-341),
401 M Street, S.W., Washington, D.C. 20460, or by telephone
at (202) 382-2835.
Edward E. Reich
Attachments I and II
cc: Jerry Emison, Director, OAQPS
Jack Farmer, Director, ESED
Darryl Tyler, Director, CPDD
Earl Salo, OGC
Michael Alushin, OECM
James Kilgroe, IERL
Daryl von Lehmden, EMSL/RTP
Kenneth Knapp, ESRL
Tom Gallagher, NEIC
Air Branch Chiefs, Regions I-X
Air Compliance Branch Chiefs, Region II, III, IV, V, VI, IX
Directors, Environmental Services Division, Regions I-X
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ATTACHMENTS
ATTACHMENT I - GUIDANCE ON THE REVIEW AND USE OF
COAL SAMPLING ANALYSIS (CSA) DATA
ATTACHMENT II - EXAMPLE OF AN AGENCY'S CONVERSION OF
CSA DATA INTO A SO2 EER AND ITS FOLLOW-UP
ACTIVITIES
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TABLE Ob' CONTENTS
ATTACHMENT I - GUIDANCE ON THE REVIEW AND
USE OF COAL SAMPLING AND ANALYSIS (CSA) DATA
Page No.
I. Summary 1
Figure 1 - Agency's Program for Reviewing and 2
Using CSA-Derived EERs
II. An Agency's CSA Data Requirements 3
A. Develop an Inventory of CSA Guidance-affected 4
Sources
8. Characterization of the CSA Program and Fuel 4
III. CSA Data Acquisition 6
A. Format and Detail of the Source's CSA 6
Program Characterization Data
B. Format and Detail of the Source's Quarterly 6
Summary Excess Emission Reports
IV. CSA Data Evaluation Procedures 7
A. Evaluation of the Source's CSA Program 7
Characterization Data
B. Evaluation of the Periodic Data - General • 7
Information
C. Specific Procedures for Converting Daily 8
CSA Data into SO2 Emission Rate Data
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Step 1: Evaluate and record the completeness 8
and the quality of the data
Step 2: Record the source's CSA monitoring 9
performance
Step 3: Convert the paired sulfur and heat content 10
results into daily SO2 emission rate data
Step 4: Verify and record the source-submitted 11
values of the daily SC>2 emission rates
V. Completion of an SO2 Excess Emission Report 12
Step 5: Evaluate and record the source's 12
CSA monitoring performance (data
quality and availability)
Step 6: Convert and record the daily SC>2 13
emission rate data into excess
emission data
Step 7: Complete the EER and recommend 14
follow-up
VI. Agency Review, Summarization and Entry of CSA-derived 15
EER Data
A. Phase 1 - Screening Assessment and Summarization 17
of the Data
Step 8: Assess and record the completeness and 17
general acceptability of the EER
Step 9: Summarize and record the CSA monitoring IB
and emission performance data
B. -Phase 2 - Verification of Phase 1 Results, 19
Targeting of Sources, and Data Entry
into the Subset of the CDS
Step 10: Supervisory verification and concurrence 19
with Phase 1 results
Step 11: Supervision of entry of summarized EER 19
data into the CEMS Subset of the CDS
1) Considerations to be made prior to 19
targeting sources
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2) Consideration of a potential sulfur 20
retention credit
Step 12: Selectively target and record outlier 21
sources for follow-up
Step 13: Revise, if appropriate, the source's 22
compliance status in the CDS
C. Phase 3 - Conduct Conventional Enforcement 22
Follow-up Activities
VII. Example Targeting Criteria and Recommended Agency 23
Follow-up Actions
A. General Comments on the Example Criteria 24
•
B. Example Criteria and Recommended Follow-up 26
Actions (CSA Data Acquisition Deficiencies)
C. Example Criteria ana Recommended Follow-up 28
Actions (SC-2 Emission Performance Problems)
D. Example Criteria and Recommended Follow-up Actions 30
(Administration Problems with EER/CSA Data Submittal)
VIII. Contacts tor Future Technical Assistance, Comments, 31
and Additional Copies of the Guidance
APPENDICES
Appendix 1 - Characteristics of a Source's CSA Program 32
Appendix 2 - Summary of an organization's Available CSA 35
Data and its Excess Emission Report
Appendix 3 - Agency Reviewer's Checklist for 43
Source-Submitted EERs
ATTACHMENT II - EXAMPLE OF AN AGENCY'S
CONVERSION OF CSA DATA INTO A SO? EER
AND ITS FOLLOW-UP ACTIVITIES
I. Initial Agency Evaluation of the Completeness 49
and the Quality of the Data
Step 0: Complete the boiler-specific information 49
contained in Example Data #1
Step 1: Evaluate the completeness and the 49
quality of the data
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II. Agency Requested Additional Data 50
III. Agency Evaluation of the Additional Data 50
Skip IV and V and Steps 2-7
VI. Agency Review, Summarization and Entry of CSA-derived 50
EER Data
A. Phase 1 - Screening Assessment and Summarization 50
of the Data
Step 8: Assess and record the completeness 50
and general acceptability of the EER
Step 9: Summarize and record the source's 51
CSA monitoring and emission performance
data
B. Phase 2 - Verification of Phase 1 Results, Selective 51
Targeting of Sources, and Data Entry into the
Subset of the CDS
Step 10: Supervisory verification and concurrence 51
with Phase 1 results
Step 11: Supervision of entry of summarized EER 51
data into the CEMS Subset of the CDS
Step 12: Selectively Target and record outlier 52
source's for follow-up
Step 13: Revise, if appropriate, the source's 52
compliance status in the CDS
EXAMPLE DATA SHEETS
Example Data #1 - Summary of an Organization's Available 53
CSA Data and its Excess Emission Report
Example Data #2 - Characteristics of a Boiler Operator's 62
CSA Program
Example Data #3 - Summary of a Boiler Operator's Most 65
Recent Quarter CSA Data and Its
Excess Emission Report
Example Data #4 - Agency Reviewer's Checklist for 73
Source-Submitted EERs
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ATTACHMENT I
TECHNICAL GUIDANCE ON THE REVIEW AND USE Ob
COAL SAMPLING AND ANALYSIS (CSA) DATA
Prepared by
Louis R. Paley
Technical Support Branch
Stationary Source Compliance Division
Oftice ot Air Quality Planning and Standards
U.S. Environmental Protection Agency
Washington, DC 20460
October 1985
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ATTACHMENT I
TECHNICAL GUIDANCE ON THE REVIEW AND USE
OF COAL SAMPLING AND ANALYSIS (CSA) DATA
I. Summary
The issuance of the October 1984 "Technical Guidance
on the Review and Use of Excess Emission Reports (hereafter
called the 1984 EER Guidance), as supplemented by this
document, provides tools for agencies to obtain, review, and
use EERs trom all large coal-fired boilers except those where
SO2 continuous emission monitoring systems (CEMS) or CSA are
the specified compliance methods. The primary objectives of
these guidance packages are to provide the tools and procedures:
(a) to document periodically the compliance status of those
sources; and (b) to bring large boilers into continuous
compliance with applicable SO2 emission limits.
In conjunction with the previous guidance, this document
presents step-by-step procedures, equations, and forms for
agencies to follow when targeting boilers based on SO2 data.
This guidance permits agencies to address those boilers which
were not previously addressed by the 1984 EER Guidance, and
addresses boilers which do not use a flue gas desulfurization
system, but instead rely upon "compliance coal" to achieve
the relevant SO2 emission limits.
The purpose of this guidance is to assist Regional
Offices (and State agencies where such responsibility has
been delegated) to proceed expeditiously and in a nationally-
consistent manner with the review, conversion of CSA data
into SO2 excess emission reports (EER's) and, when appropriate,
foliow-up of such results. As shown in Figure 1, use of
CSA-derived EERs should be similar to that of the CEMS-derived
ones.
This document recommends that agencies give priority
attention to reviewing and selectively following-up source-
submitted, CSA-derived EERs in order to obtain the greatest
degree of SO2 emission reduction from assuring compliance by
coal-fired boilers. It recommends that agencies use CSA data
which the boiler operator obtains as a result of fixed-frequency
sampling by a mechanical device, and which represent the
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CSA/EER PROGRAM START-UP
CONTINUING CSA/EER PROGRAM
START
V
DEVELOP
AFFECTED
INVENTORY
1
REQUIRE SOURCE
SUBMITTAL OF
CSA DATA
J
SOURCE SUBMITS
•*• CiA UAIA OH
EER (2)
SOURCE SUBMITS
m:. "BACKGROUND"
CSA INFORMATION
1
AGENCY REVIEW
AND USE
+
t.U
AGENCY
REVIEWS
SUMMARIZES
DATA
1
1
1
1
E.D E.O •«.-
AWAIT NEXT
QUARTER'S EER
M>
I
EER USED TO
TARGET AGENCY'S
FOLLOW-UP ACTIONS
(U
NOTES:
1. APPLICATION AND FOLLOW-UP
OF CSA-EER DATA IMPLEMENTED
CONSISTENT WITH 1984 EER GUIDANCE.
2. OPTIONAL AGENCY
'IN-HOUSE' DEVELOPMENT OF EER
FROM SOURCE SUBMITTED DAILY CSA DATA
3. ^E.D. ENTER DATA INTO
CDS/OR CEMS SUBSET OF CDS
FIGURE 1. AGENCY'S PROGRAM FOR REVIEWING AND USING CSA-DERIVED EERs.
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quantity of coal normally combusted Dy the boiler in a twenty-
four hour period. Agencies should rely primarily upon "as-fired
and "as-bunkered" CSA data.* However, if such data are not
readily available, the procedures recommend that the agency
determine whether it is prudent tor it to rely upon other
available-, but less-suitable CSA data (e.g., data representing
several days of coal combustion, "as-received" CSA results),
or to require source submittal of acceptable SC>2 data.
Agencies should request that their (CSA-guidance-affected)
sources summarize and report quarterly two types of information:
(a) the failure to acquire CSA data,- and (b) the occurrence of
SC>2 excess emissions. However, of course agencies have the
option to derive such reports in-house from source-submitted
"raw" (e.g., daily monitoring performance and daily fuel
analysis data) CSA results if they prefer.
Each quarter, summarized EER results should be used to
target those "outlier" boilers which exceeded the agency's
CSA monitoring performance and/or excess emission rate
criteria (e.g., a large total duration of missing or inade-
quate CSA data, a large total duration of excess SC>2 emission
periods).
The guidance indicates that the agency's criteria for
taking follow-up action based on EER data should strike a
balance between factors such as the agency's resource
availability, the best performance shown (or expected) by
the subject class of sources, and its priority for obtaining
compliance by such sources.
II. An Agency's CSA Data Requirements
Agencies require three types of information in order to
implement a CSA/EER "review and follow-up" program. First
in importance, though probably least responsible for obtaining
SC>2 emission reductions and compliance, is an inventory of
sources to which this guidance applies. The agency can
obtain this information quite simply as described below.
However, though a complete inventory is helpful, the agency
should implement its CSA/EER activities even before it completes
its inventory.
* "As-fired" and "as-bunkered" coal sampling are performed at
a location near or downstream of the specific boiler's short-
term coal storage area (bunkers, silos). In contrast,
"as-received" coal sampling is performed at a location
between the facility's coal receiving location and the
specific boiler's long-term storage area (e.g., coal
pile) .
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Each agency also needs specific hardware and methodological
information about each boiler's CSA program. Such information
will generally be necessary "background" data and support the
agency's use of quarterly CSA-derived EERs.
Last, but most importantly, are source-submitted quarterly
summaries of periods of missing CSA data and periods of SO2
excess emissions.
Each of these are discussed further in the following
paragraphs.
A. Develop an Inventory of CSA Guidance-affected
Sources
An inventory of CSA Guidance-affected boilers can be
developed simply by taking the following steps:
1) define the universe of coal-fired boilers from
which the agency desires to receive periodic SO2
emission rate/EERs; and
2) remove from the list those which are FGD-controlled
and which are (or should be) submitting periodic
CEMS-based information to the agency.
The remaining boilers should comprise the CSA Guidance-affected
inventory.
B. Characterization of the CSA Program and Fuel
As noted above, the two general types ot CSA data which
must be obtained from a source are:
(1) physical equipment and methodological ("source CSA
program") information; and
(2) parametric data representing the coal
combusted during each twenty-four hour
period.
Both types of CSA information should be readily available
from the boiler operator. As one can see in Appendix 1,
the background data are limited in quantity. Furthermore,
one would expect a boiler operator to acquire no more than
ninety sets of CSA "emission" data, and even fewer CSA moni-
toring performance data points per quarter (see Appendix 2).
Additional details on each of these types of (JSA data are
prov ided.
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1) General characterization of a source's CSA program
Agencies need certain background information (generally
unchanging) in order to properly characterize and use the
daily fuel data. This information includes where and how the
samples were taken and which analytical methods were used.
Appendix 1 presents an example list and format for recording
and organizing such information. It is expected that the
agency will acquire and enter this type of information into
the Subset of CDS only once.
2) Characterization of the fuel combusted daily
For each boiler, agencies should have CSA parametric
data which represent the coal burned during each twenty-four
hour period. One can be quite confident, statistically, in
the daily calculated SC>2 emission rates and the resulting
EERs, if one has results:
0 representing at least 85% of the boiler
operating days (BODs) during the quarter;*
0 from as-fired or as-bunkered coal sampling;
0 from sampling that was performed by a mechanical
device which met ASTM D-2234 Type I, Conditions
B and C and Systematic Spacing (evenly spaced
increments);
0 from analyses that were performed using methods
which conform to ASTM D-2013 for sample preparation,
D-3177 for sulfur analysis, D-3173 for moisture
analysis, and D-2015 for gross calorific value; and
0 that were reported to the nearest five hundreths
(0.05) of a Ib. SO2/106 Btu.
It is highly recommended that an agency accept, as an
alternative to SC>2 CEMS data, only CSA data which conforms
to the aforementioned list of key characteristics. If the
agency chooses to give further consideration to non-conforming
CSA data, it should require the source to demonstrate that
such data will provide the agency with a sufficient basis for
targeting. In these circumstances, the agency should take
account of items such as the source's proximity to the emission
limit and the requirements which it has imposed on other,
comparable sources.
A "boiler operating day" is used in this guidance to
mean a twenty-four hour period during which any coal
is combusted in the steam generating unit.
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III. CSA Data Acquisition
An agency must acquire sufficient CSA data before it
can effectively implement a CSA targeting program. Generally,
this will require only a one-time acquisition of the background
information from each of the boilers, in addition to a quarterly
acquisition of the source's EER as shown in Appendix 2.
The preferred, most resource-effective method for agencies
to obtain such data is by a letter. Use of a formal (§114)
or informal letter would be appropriate. However, if if the
agency prefers, it may obtain the information in alternative
ways such as during an on-site visit of the facility.
A. Format and Detail of the Source's CSA Program
Characterization Data
Background data can be acquired quite effectively by
requesting a source to complete a form like Appendix 1.
B. Format and Detail of the Source's Quarterly Summary
Excess Emission Reports
It is strongly recommended that an agency request each
of its affected sources to prepare and submit quarterly
summarized SC<2 excess emission reports. They should be able
to prepare such reports from normally available business
data. Alternatively, at the discretion of each agency, it
may request source submission of quarterly reports containing
daily data (e.g., the CSA data acquisition rate and sulfur
and heat contents of the coal), and the agency prepares each
EER in-house.
The primary advantages of requesting each source to
prepare and submit its own summary EER, rather than the agency
preparing them, are:
0 it will likely minimize the resource burden upon both
the source and the agency (e.g. , a single submittal of
information, versus possibly two or more per quarter,
should normally suffice);
0 it should increase the likelihood that each source
will obtain and use such results to take any necessary
corrective actions; and
0 it may increase the accuracy of the EERs.
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Agency experience in requesting EERs from sources has
been generally positive since such requests are not unduly
burdensome.
IV. CSA Data Evaluation Procedures
A. Evaluation of the Source's CSA Program
Characterization Data
The background information received by an agency should
be evaluated to help it determine whether the source meets
the agency's criteria for an acceptable CSA program (e.g.,
if it represents twenty-tour hours of combustion, sampling
is "as-bunkered"), and help establish the credibility of
the agency's targeting results.
B. Evaluation of the Periodic Data - General
Information
The evaluation procedures described in this Section
are conceptually similar to those presently used by industry
when converting GEMS data into SC>2 EERs. As noted previously,
preferably the source (but possibly the agency) performs the
calculations and evaluations to derive its quarterly SC>2 EER.
The CSA-derived EER is completed by taking the following
steps:
0 evaluate whether there are sufficient data to
derive an EER;
0 identify and record each boiler operating
day when insufficient CSA data were acquired,
or where CSA hardware or methodology was modified;
0 calculate the daily SO2 emission rates; and
0 compare each daily emission rate value with the
applicable emission limit to identify periods
when the emission rate exceeded the limit.
Note that no sulfur retention credit (SRC) should be
used at this stage ot data evaluation. The agency may subse-
quently choose to account for any sulfur retention during the
targeting phase of the analysis. See the discussion presented
on this topic in Section VI, B, 2 of this document. Therefore,
the reviewer should take steps to ensure that the source did
not use a SRC when converting its data to daily SC>2 emission
rates. ~
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C. Specific Procedures for Converting Daily CSA
Data into SO2 Emission Rate Data
This Section provides a step-by-step explanation of
how to convert daily CSA data from paired-analytical
results to emission rate data, and how to verify source-
submitted emission rate data.*
Step 1; Evaluate and record the completeness and the
quality of the data (as recorded on Items I
and II of Appendix 2).
Step 1A;
The reviewer should evaluate and record
whether the data currently available within
the organization are sufficient in terms of
completeness, timeliness, quality, and known
sulfur retention credit. Criteria which the
reviewer should use include:
(a) "sufficiently complete" meaning have
CSA data representing at least 85%
(unless otherwise stated in a regulation,
etc.) of the boiler operating days during
the quarter;
(b) "sufficient timeliness" meaning that the
data are representative of the quarter of
interest;
(c) "sufficient quality" meaning that the CSA
results are from an as-fired or an
as-bunkered CSA system; and
(d) it must be known whether the data included
a sulfur retention credit; and if it did,
how much.
The reviewer should use a form, comparable to the one included
as Appendix 2, to organize and record the available data.
If the available data are not sufficient to derive
the EER, then Item III, B, of Appendix 2 should be used to
summarize what additional information are required and what
mechanism should be used to help ensure the acquisition of
sufficient data. The reviewer should record the recommenda-
tion for follow-up, and sign and date the form at the top of
the cover page.
*Note: Attachment II contains an example of an actual
agency review of such data.
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Note: The reviewer should not attempt to evaluate
the data further, or to go on to Items III (C-H)
of Appendix 2 until the required additional
data are obtained.
Step IB;
The first reviewer's supervisor should check
the initial findings and recommendations, regardless
of whether or not additional data are required. If
additional data are not required, the reviewer should
skip to Step 2. If the reviewer's supervisor (or
other designated person) agrees that additional
data are required, he should sign and date the form
on the top of the cover page and in Item III, G.*
Step 1C:
If additional data are required, Appendices
1 and 2 should facilitate the acquisition and
organization of such additional data. Such data
should be obtained, evaluated for completeness
(repeating Steps 1A and IB), and then used as
described below to derive a SC>2 EER.
Step 2; Record the source's CSA monitoring performance.
Recommendation; The agency should require the source to
perform this Step.
Step 2A;
If there were any periods, during the subject
calendar quarter, when the CSA monitoring equipment
malfunctioned or was inoperable, or for other reasons
sufficient CSA data (e.g., 85% of the boiler operating
hours in a boiler operating day) were not acquired,
this fact should be noted in Item II, A of Appendix 2.
The total number of BODs thus affected during the
quarter should be recorded in Item II, A, 1.
Note: If available data are in terms of SC>2 emission
rates (e.g., Ib. SO2/106 Btu) , go directly to
Step #4 below:
* This guidance presumes that the size of the organization
and volume of CSA data being evaluated may warrant a two-
level review of the CSA data. If that is the case, imple-
ment Step IB.
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Step 3; Convert the paired sulfur and heat content
results into daily SC>2 emission rate data.
Recommendation; The agency should require the source to
perform this Step.
Step 3A;
If any of the available CSA data delineated
in Items I and II of Appendix 2, are incomplete
or inconsistent with this guidance (e.g., both
sulfur and heat content data must be on the same
basis), additional or revised information should
be obtained or the results recalculated, as
necessary, before the reviewer proceeds to
calculate the daily SO2 emission rates.
Step 3B;
Whether the results have been adjusted to
account tor a sulfur retention credit (SRC) must
be known. To the extent that there were any
adjustments (credits) of the data, such data should
be recalculated to remove the adjustments. One
can use the following equation to remove any sulfur
retention credit adjustment while converting tne
CSA data (%S and GCV) to SC«2 emission rate data.*
E = (2.0 x 104 (%S) x (100 + SRC)
( GCV ) 100
Where: E =,daily emission rate
(Ib. S02/106 Btu), to be
calculated within 0.05 Ib.
SO2/106 Btu.
S = unadjusted (for SRC) daily
average sulfur content in
coal (% by wt., dry basis).
GCV = daily average gross calorific
heat content of coal (Btu/lb.,
dry basis).
SRC = any unauthorized sulfur retention credit
accounted for in the sulfur or heat
content values (%).
* Equations such as the one given here are provided solely to
clarify and simplify use of this guidance. Other equations
may be developed and used by the reveiwer.
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- 11 -
Note: During such calculations no sulfur retention credit
is to be used when converting CSA data to daily SC>2
emission rates. See Section VII for a discussion
of whether any SRC should be granted during the
agency's targeting of specific boilers.
Step 3C;
One might record the daily emission rate
data in a column next to the %S and GCV as shown
in Item III, B of Appendix 2. When the results are
recorded, also record which organization performed
the calculations (e.g., agency reviewer or source
reviewer) in Item III, B, 3.
Note: If the available data are in terms of "paired
analytical results", skip Step #4 and go
directly to Step 5.
Step 4; Verify and record the source-submitted values
of the daily SC>2 emission rates.
The key points that should be checked when
the available CSA data are submitted in terms of
502 emission rates are: whether any sulfur
retention credit was used; and whether the
calculations were performed correctly. This can
be determined as follows.
Step 4A;
Check to see if a positive statement that
"no SRC" was incorporated in the SC>2 emission rate
data. One must determine what, if any, SRC was
used before continuing. If a sulfur-retention
credit was applied, use the following equation
to correct (increase) each daily data point to
"no SRC baseline" results.
E
Where: E
ESRC
SRC
x (100 + SRC)
100
daily emission rate, without
(Ib. S07/106 Btu) , to
SRC
be calculated
within 8.05 Ib. S02/106 Btu.
unauthorized, SRC-adjusted daily
emission rate.
sulfur retention credit (in %).
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- 12 -
Therefore, one should increase each available emission rate
value by the factor: (100 + SRC).
100
Step 4B;
If concurrent paired analytical and
emission rate data are available, randomly
select a few data sets to audit the source-
submitted SO2 results. This is done by
calculating a few daily SC>2 emission rate
values. If the audit results do not agree
with the available SC>2 data, check further to
determine the cause (e.g., SRC used, miscalcu-
lation) of the discrepancy. As necessary,
recalculate the entire quarter's emission
rate values.
V. Completion of an SO? Excess Emission Report
After completion of Step 3 or 4, as appropriate, the
data are at a stage generally comparable to the recorded
output of a SC>2 GEMS. As in the case of a CEMS-derived EER,
a CSA-derived EER must include two types of data. These are:
0 information on each instance that the boiler
operator failed to obtain suitable CSA data; and
0 information on each instance that the boiler
operator failed to keep the SO2 emissions below
the relevant emission limit.
Furthermore, as in the case of the CEMS-derived EER, after
the CSA-derived EER data are recorded, it is recommended that
one summarize the data further (e.g., total duration in the
quarter when CSA data were not available, or total duration
when the daily SC>2 emissions exceeded the emission limit).
A summary will facilitate the subsequent uses of the results
such as targeting, trend analysis, and performance comparisons
with other boilers. The following Steps should be taken when
preparing and summarizing EER data.
Step 5; Evaluate and record the source's CSA
monitoring performance (data quality and
availability).
Recommendation; The agency should require the source to
perform this Step.
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Step 5A:
Evaluate the adequacy of the source's CSA
data acquisition program based upon the equipment,
methodological, and data acquisition information
provided (by the sources) on forms such as those
in Appendix 1 and Item II, A of Appendix 2,
respectively.
Step 5B;
Record the results of the evaluation on
a form such as that given in Appendix 2, Items
III, A and E, 1.
Step 5C;
To the extent that the evaluation identifies
substantial deficiencies or problems with the data
(e.g., data availability is less than 85% of the
boiler operating days) additional data should be
acquired and/or corrective actions should be
initiated (see Section VII for a further discussion
of possible corrective actions). Item III, B of
Appendix 2 may be used to recommend what type of
data should be obtained and how the organization
should obtain it.
Step 6; Convert and record the daily SO2 emission rate
data into excess emission data.
Recommendation; The agency should require the source to submit
a summarized EER (e.g., like Appendix 2).
Step 6A;
Compare each daily emission rate value
(II, B, 4 of Appendix 2) with the relevant value
of the SC"2 emission limit in order to identify
each period of excess emissions. This can be done
quite simply by scanning through the list of reported
St>2 emission rate data. Each time the daily emission
rate exceeds the limit, by any amount, annotate the
list (in Item II, B, 4) and record (in Item III, E,
2 of Appendix 2) the following information:
0 date of the excursion;
0 magnitude of the emission rate;
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- 14 -
0 the reason for the excess; and
0 the corrective action reported.
Step 6B:
Count the number of reported periods of SC>2
excess emissions (nex) and record this total number
in Item III, E, 2, b of Appendix 2.
Step 6C;
Calculate the total duration (dex) of BODs
during which the boiler exceeded the SC<2 emission
limit by multiplying the number of excess emission
periods (nex) by twenty-four hours. Record the total
duration when the boiler exceeded the emission
limit (dex) in Item III, E, 2, c of Appendix 2.
Step 7; Complete the EER and recommend follow-up.
Recommendation: The agency should require the source
to submit a summarized EER (e.g., like
Appendix 2)
Step 7A;
Review the emission performance information
and determine whether it was generally adequate.
Record the answer in Item III, E, 3 of Appendix 2.
Step 7B;
Record the name, affiliation and telephone
number of the reviewer(s) in Item III, F.
Step 7C;
Determine if any organizational (agency,
industry) follow-up action should be performed.
Record this determination, and sign and date the
top of the cover page.
Step 7D;
(Industry only) certify the representativeness
of the EER data by completing Items III, H, (1) and
(2).
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- 15 -
In summary, an adequate CSA-derived EER should contain
the following major components:
0 general information about the boiler, coal sampling
and analysis equipment, methodology, and reporting
period;
0 CSA monitoring performance data;
0 daily CSA or SO2 emission data;
0 summary monitoring performance and excess emission
results;
0 recommendations tor any follow-up actions;
0 reviewer's signature(s); and
0 (if source submitted) source certification of the
data.
VI. Agency Review, Summarization and Entry of CSA-derived
EER Data*
Agency use of EERs to target "outlier" sources (compared
to other sources) is a most effective means of motivating
sources to achieve continuous compliance. Therefore, it is
highly recommended that agencies prioritize their resources
and program emphasis by requesting source submittal of
summarized CSA-derived EERs (again, even if the reports are
less than perfect).
If source personnel prepared the EER, the agency should
review it before summarizing and using the data. Whether
source or agency personnel prepared the CSA-derived EER,
agency personnel should summarize and enter that data into
the CEMS Subset of EPA's Compliance Data System (CDS).
The following comments and those contained in Attachment II
assume that the agency requires source submittal of the
CSA-derived EER within thirty days after the end of each
calendar quarter, and in a manner generally consistent
with Appendix 2.
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- 16 -
Assuming that source personnel derived and submitted the
EER (in a form comparable to Appendix 2) to the agency, the
agency reviewer should evaluate, summarize and record the
following information on a form such as illustrated in
Appendix 3:
0 administrative details
0 adequacy of the source's CSA data acquisition
and reporting performance; and
0 adequacy of the source's emission compliance
program.
Appendix 3 presents an example form (modelled after the one
included as Appendix A-l in the 1984 EER Guidance) which
should tacilitate agency review, summarization and preparation
for data entry.
In the event that agency personnel derived a source's
EER, use of Appendix 3 will facilitate the agency's input of
the quarterly EER data into the GEMS Subset of the CDS. At a
minimum, some of the data contained in Item III of Appendix 2
should be summarized prior to data entry into the Subset of
the CDS.
The recommended analysis and follow-up procedures are
presented in this document (as in the 1984 EER Guidance) as a
three-phase process as follows:
0 Phase 1 - initial review and summarization of EER
data;
0 Phase 2 - confirmation of Phase 1 results, targeting
of sources for follow-up, and data input to the CEMS
Subset of the CDS; and
0 Phase 3 - conventional enforcement follow-up evaluation
using CSA data and other emission and process data;
this phase may result in recommendations for additional
testing or compliance/enforcement actions.
All EERs must be subjected to Phase 1 and Phase 2
evaluations. Evaluations performed during these two phases
are unique to EERs derived from CSA and CEMS data.
Phase 3 of the EER review and follow-up process represents
a conventional agency follow-up to data which have identified
a possible violator.
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Experience has shown that each EER should be processed
"sequentially" as it is received, since the EERs usually
arrive at the agency individually and since they are usually
assigned to different case engineers. Also, it appears to
be most beneficial for the agency to enter the new compliance
data into its data base management system (e.g., CDS) at
major milestones during the three phases. The phases are
described in more detail below.
A) Phase 1 - Screening Assessment and Summarization
of the Data
During the Phase 1 evaluation, the reviewer is to perform
a preliminary evaluation of the data and (if not already done
by the source) to summarize the data into specific categories
for subsequent entry into the CEMS Subset of the CDS. A
few Regional Offices have found that this can be very effec-
tively done by para-professionals or technicians, and that
it takes on the average about an hour per EER. The following
paragraphs provide additional details about Phase 1 activities,
Step 8; Assess and record the completeness and general
acceptability of the EER.
Review the EER and complete Items 1 to 4 on the "EER
Reviewer's Checklist". This assessment should compare the
EER data with the following requirements. While each item
is required, it is important to remember that the key to
effective use of EERs is to concentrate on whether the source
acquired and reported an adequate quantity of CSA data, and
whether its emissions remained below the emission limit.
(a) The source should submit EERs as follows:
(1) Within 30 days after the end of each
calendar quarter, submit a written report
of: (a) any failure of the CSA monitor
system to acquire data during a BOD, and
any modification or major repair of the
CSA system; (b) excess emissions (as
defined in the applicable regulation).
(b) An EER is required every quarter, even if no
excess emissions were recorded or if the CSA
data acquisition system had no downtime, and
was not repaired or modified.
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(c) Each EER shall include:
(1) The date, start and ending times of each
instance when the CSA data acquisition
system was inoperative, and a description
of the nature, cause and corrective action
taken for each such period.
(2) The magnitude (including any conversion
factor(s) used), date, start and ending
times, nature, cause and corrective
action taken for each excess emission;
specific identification of each period
of excess; and the nature and cause
(if known) of the corrective actions
taken.
(3) The number of days in a quarter (or percent
of time) when the CSA data acquisition system
was operating at the same time the process was
operating.*
Step 9; Summarize and record the CSA monitoring
and emission performance data.
Before the EER data can be entered into the CEMS
Subset, and effectively used, the data must be summarized.
To the extent that the EER data are not summarized by
the sources in a manner consistent with the definitions
shown in Item 5 of Appendix 3, the agency reviewer must
summarize the data. The two key parameters which must be
summarized by "reason code" are:
(a) total number and duration of individual CSA
data acquisition system downtime incidents; and
(b) total number and duration of individual
exceedance periods.
Record the results in Item 5(a) and 5(b) of Appendix 3.
It is recognized that if the agency reviewer were to
summarize the EER data, it would be the most resource intensive
element of the Phase 1 analysis. However, summarization of
This item is only implicitly specified in §60.7
However, it is essential for agencies to know the quantity
of CSA data acquistion system downtime while the process
was operating in order to determine the adequacy of the
source's monitoring performance and the representability
of the excess emission data reported in the EER.
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- 19 -
the data is critical to the effective use of EERs. Therefore,
it is strongly recommended that the agency require its sources
to report their data in a summarized form.
B) Phase 2 - Verification of Phase 1 Results, Targeting
of Sources, and Data Entry into the Subset of the CDS
The Phase 2 EER activities should be performed by an
experienced compliance person. To date, agencies have largely
relied upon a professional who was familiar with reviewing
other compliance data. This part of the EER assessment is
more complex than Phase 1 in that it involves: 1) completion
of an internal audit and concurrence with the Phase 1 results;
2) supervision of EER data entry into the CEMS Subset of the
CDS; and 3) comparison of the EER data with agency targeting
criteria, and in some instances includes recommendations for
additional agency evaluation of source-related data. Current
experience indicates that Phase 2 activities can be completed
within about one hour. The' following paragraphs provide
additional details about Phase 2.
Step 10; Supervisory verification and concurrence
with Phase 1 results
The supervisor should review the results of the Phase 1
evaluation as recorded in Items 1 to 5 of Appendix 3.
Step 11; Supervision of entry of summarized EER data
into the CEMS Subset of the CDS.*
At least once per quarter, the supervisor should insure
that the summarized EER data, targeting results and follow-up
recommendations are entered appropriately and in a timely
fashion. The supervisor should also insure that the source
is notified about these results. This will help to promote
better emission control and monitoring of operations by the
source because they will be aware that the data are being
scrutinized and will not want their EERs to trigger agency
follow-up activity. Furthermore, providing the results
to the sources will improve the credibility of the agency's
CSA and EER processes.
Completion of these data entry activities should be
recorded in Item 6 of Appendix 3.
1) Considerations to be made prior to targeting
sources
*Procedures for CSA data entry will be subsequently furnished
by SSCD as part of the CDS program.
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- 20 -
In general, one should not expect a quantitative,
predictable relationship to exist between the CSA-derived
and CEMS-derived EERs, particularly on a short-term averaging
basis because of the impact of the following items:
(a) two vastly different measurement methods;
(b) two physically different streams (coal,
exhaust gas) are being measured; and
(c) the differences in sampling and data averaging
times between the two types of data.
Therefore, if one were to quantitatively compare the SO2
emission rates from two different boilers (one obtained by
CSA, and one by CEMS) and found the CEMS-monitored boiler had
a greater frequency of excess emission periods, one should
not necessarily conclude that only the CEMS-monitored boiler
should be targeted for agency follow-up. Because there isn't
a linear relationship between short and long-term emission
data, one cannot convert the results obtained by CSA to those
by CEMS simply by multiplying the total duration ot CSA-derived
excess emission periods by eight (e.g., eight discrete three
hour (CEMS) periods per twenty-four hour (CSA) day), or by
twenty-four (e.g., twenty-four rolling three hour periods per
twenty-four hour day).
Based upon limited data and experience, one should expect
that results based upon data acquired during a twenty-four
hour period will measurably "understate" the magnitude, as
compared to data acquired over a three-hour period. A prelimi-
nary estimate of this difference might be 1U-2U% (e.g.,
24-hour number is 1.0 versus a 3-hour number of 1.2).
Although one should not quantitatively compare the EER
results obtained from CEMS and CSA, one can meaningfully
compare the results from different boilers as long as they
were all monitored by the same method. Therefore, agencies
can use both types of data in parallel, yet separate evalua-
tions, to target sources for agency follow-up activities.
2) Consideration of a potential sulfur retention
credit (SRC)
As noted previously, the SO2 emission rate and EER data
calculations up to this point must not take account of the
potential quantity of sulfur "retained" in a non-oxidized
form (e.g., not converted to SC^). As a point of departure
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- 21 -
on this, the Agency has received data indicating (or claimed
to indicate) that the sulfur retention was 0-100%, however,
the most credible estimates range from about 1-30%, depending
upon many physical and chemical phenomina.
It is SSCD's opinion that the actual retention of sulfur
will usually not affect the agency's use of CSA-derived EERs.*
This opinion is based upon the following points: (1) bituminous
coal has negligible sulfur retention (£ 2.5%); (2) many boiler
operators intentionally operate so that their emissions will
be measurably (at least 10%) below the SC>2 emission limit;
and (3) although coal which has a high sodium content (e.g.,
low sulfur western coal) may have a sulfur retention rate of
2U-30%, usually the SO2 emissions from such low sulfur coal
are inherently well below the limit. Thus, sources burning
low sulfur coal which has a high sodium content will normally
be in compliance even without receiving any "credit" for
sulfur retention.
As a first approximation, it is believed that the impact
(lower values) of using twenty-four hour data to represent a
short-term emission standard is offset by the potential
impact of sulfur retention associated with the combustion of
most types of coal (except for the low sulfur/high sodium
coal mentioned above). Therefore, it is recommended that
agencies grant no SRC to a source unless the source, on a
case-by-case basis, quantitatively and empirically demonstrates
that measurable (»10%) sulfur retention actually occurs at
the boiler. Furthermore, to the extent that any SRC is
granted, it should be conditioned upon: (a) the source conduc-
ting annual tests to quantify the sulfur retention rate; and
(b) the source notifying the agency about any changes in coal
suppliers or coal characteristics which might affect the
magnitude of their sulfur retention.
Step 12; Selectively target and record outlier
sources for follow-up.
The basic concept behind agency EER review and targeting
procedures is to separate all CSA Guidance-affected boilers
into three groups: (a) those that clearly are above the
emission limit, and should receive the agency's priority
attention; (b) those that are clearly well below the limit,
and definitely do not warrant agency follow-up; and (c) those
which have emissions near the limit and which may warrant,
and may receive (depending on resource availability), agency
* Note that CEMS-derived EERs, by virtue of being based upon
SC>2 emission measurements, inherently "take into account"
any sulfur retention which may have occurred in the process
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- 22 -
attention. Thus when the agency completes its selective
targeting, it will have a reasonably quantitative basis for
focusing its resources upon those few sources which are most
out of compliance and have the potential for providing the
largest emission reduction.
The agency, by judiciously selecting its criteria, will
likely confirm (in Phase 1) that most of its boilers were in
compliance with the monitoring and emission limits. Therefore,
few of its boilers will be targeted. However, as a "quality
assurance" check on the agency's EER review procedures, and
to verify the data (to the extent that resources permit) the
agency should randomly target a few of those "apparently
complying boilers" for follow-up action.
Compare the Phase 2 results to the agency's targeting
criteria. See the sample list of criteria and follow-up
actions presented in Section VII. Also see Attachment II for
an example of an agency's review and use of some empirical data.
Record the targeting results and recommendations for
agency tollow-up in Item 7 and on the top of the cover sheet
of Appendix 3.
Step 13; Revise, if appropriate, the source's compliance
status in the CDS.
If a source has been targeted for follow-up action, the
source should take corrective actions and the agency should
subsequently reassess the source's performance and compliance
status. Traditionally in circumstances similar to those which
warranted the source being targeted, agencies have "flagged"
the source by recording its compliance status in CDS as being
in "non-compliance".* Once the reviewer confirms that the
correct source compliance status is stored in the CDS, he
completes Item 8 of Appendix 3.
C) Phase 3 - Conduct Conventional Enforcement
Follow-up Activities
Phase 3's conventional enforcement analysis and follow-up
actions should be performed on a more manageable, smaller
fraction of the sources. Such activities should be more
comprehensive and more sophisticated than the activities
performed on the larger quantity of sources reviewed in
Phases 1 and 2.
* Other flagging techniques may also be considered
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- 23 -
Once a specific source has been targeted as a possible
violator (during Phase 2), the agency should proceed as it
normally would whenever it has reason to believe that a
source may be out of compliance. As with any conventional
follow-up activity, Phase 3 may be performed in the office
or in the field. It may include activities such as comparison
of the EER results with other available data (e.g., malfunction
reports, inspection reports, and stack test results), and
compliance activities which result in the acquisition of new
data. Furthermore, the Phase 3 assessment may result in
initiation of an enforcement action. Therefore, it is
suggested that a professionally-trained person perform these
activities.
Phase 3 activities may also result in:
0 a determination that an "apparently complying"
source, based upon conventional surveillance/
compliance monitoring data, actually is in
violation of one or more regulations; or
0 a determination that "an apparently violating"
source, based upon the CSA-derived EER data,
is actually in compliance.
Regardless of the outcome, the agency's confidence in its
compliance data on that source will be measurably enhanced.
VII. Example Targeting Criteria and Recommended Agency
Follow-up Actions
The following example criteria (e.g., < 2% = no action;
> b% = definite follow-up action) and follow-up actions are
based on recent Regional Office experience, largely with
EERs from large boilers. They are intentionally non-specific
in order to provide a framework or "starting point" for each
agency to formulate its own criteria and recommended follow-up
actions which are specifically suited to its unique set of
circumstances. It is suggested that an agency consider,
among other parameters, the following items when developing
its criteria for targeting sources:
0 agency staff size and expertise, relative to
the size and complexity of its responsibilities;
0 availability of external resources (cooperating
agencies, contractor assistance);
-------
- 24 -
0 current level and quality of agency knowledge of
its source's emissions, control sytems, processes,
fuel alternatives, etc.;
0 compliance and malfunction history of its sources;
and
0 relative priority of the sources and the pollutants
addressed by the criteria.
When an agency is considering which targeting criteria
to utilize, it will be helpful to recognize that the criteria
define the level(s) at which the agency will take certain
actions. Therefore, it is logical to establish the criteria
at values which "balance" the previously-listed parameters.
For^example, if an agency decides to increase its priority
for bringing certain sources (or category of sources) into
continuous compliance, its currently available resources
could be "targeted" for such sources simply by tightening the
criteria tor initiating action against the priority sources
(e.g., reducing the quantity of excursions permitted by an
agency before it initiates some form of enforcement follow-up
action). Similarly, once source compliance with a regulation
reaches a desired level, an agency would find fewer sources
exceeding the criteria, thus permitting it to shift some of
its resources to other areas.
In summary, each agency should select one or more criteria
(e.g., 2%/5% criteria) for selectively initiating follow-up
actions. The criteria should be used as the "benchmark" to
which each EEK should be compared. In this manner, the
agency's CSA and continuous compliance programs will be
implemented uniformly and equitably. Furthermore, each
agency should review its criteria and follow-up plans at
least annually, and revise them as necessary.
A) General Comments on the Example Criteria
The following additional comments are relevant to
understanding and using the example "Criteria for Action"
and "Recommended Follow-up Actions" provided in the following
pages.
0 Of the three types of criteria provided (i.e.,
CSA Monitoring Performance, Emission Performance,
and Administrative Performance), "Emission Performance"
is clearly the most important. However, the urgency
and magnitude of follow-up to CSA Monitoring or
-------
- 25 -
Administrative Problems should be controlled by the
degree to which monitoring, EER or administrative
deficiencies themselves inhibit interpretation and
use of data relating to compliance with SC>2 emission
limits. For example, major gaps in data from a
problem source, or chronic monitoring deficiencies
would warrant the strongest enforcement response.
On the other hand, format problems presenting only a
minor inconvenience to the reviewer might only warrant
a low level follow-up action such as a phone call or
form letter.
0 Whenever a detailed review of exceedances occurs,
a concurrent review of the source's CSA monitoring
performance should also be completed. Check next
quarter (whether or not the threshold point is reached)
to determine whether similar problems reocurred, and
whether the source's previous corrective action was
acceptable.
0 Every EER submitted should receive the agency's
timely review, be summarized (if necessary), be
added to the agency's data base management system
and, if appropriate, followed-up by surveillance or
enforcement actions.
0 The example criteria provided are not intended to
suggest that an agency's criteria should or could
all be precisely definable (e.g., 2% missing CSA data).
The criteria provided are for illustrative purposes.
Furthermore, it should be noted that regardless of the
SC>2 monitoring method, and even though CEMS and CSA methods
may "appear" to give different results for the same emissions,
the actual SC>2 emission rate and total duration of SC>2
excursions will be the same. Therefore, agencies should use
similar criteria and range of follow-up actions for both CEMS
and CSA-derived EERs.
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- 26 -
B). Example Criteria and Recommended Follow-up Actions
(CSA Data Acquisition Deficiencies)
Criteria for Action*
Recommended Follow-Up Actions
Total duration of missing
or insufficient CSA data was
below the low threshold point.**
Regardless of results, the
source should at least be
notified that its CSA data
were reviewed. Perhaps a
telephone report would
suffice unless a major
problem was identified.
Total duration of missing or
insufficient CSA data exceeded
the "low" threshold point.
The specific reasons should
be examined and if it is
determined that such performance
is unacceptable, the source
should be directed to take
corrective action. The source
should be notified (by tele-
phone should suffice) that its
CSA data were reviewed and
of the findings.
Total duration of missing or
insufficient CSA data during
the quarter exceeded the
"high" threshold point.
Similar to above except:
send a written report, and
during the next regularly
scheduled on-site visit
conduct an inspection of
the CSA system, O&M records,
etc.
Excessive total duration of
missing data during the quarter;
or excess emissions reportedly
"caused by the monitoring
system".
Conduct an inspection and/or
require the source to submit
a report or come to a
conference to explain what
corrective action it is
taking.
- - Continued on next page - -
These have been placed in a "relatively" ascending order of
severity/importance.
it *
These examples assume that
an agency utilizes a dual level
criteria in order to divide the EERs into three categories,
as delineated on the "S(J2 emission
EERs into three ^
performance problems" pages
-------
- 27 -
B). Example Criteria and Recommended Follow-up Actions
(CSA Data Acquisition Deficiencies) - Continued
Criteria for Action
Recommended Follow-Up Actions
Chronic problems with
monitoring system or its
data (e.g., for at least
three quarters)
Proceed with more rigorous
follow-up actions (e.g.,
require source to demon-
strate why it should not
be required to install and
operate a SO2 CEMS; actually
require source to install
and operate a SC-2 CEMS).
The urgency and severity
of actions should be
controlled by the degree to
which missing data interfere
with effective surveillance.
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- 28 -
C). Example Criteria and Recommended Follow-up Actions
(SC>2 Emission Performance Problems)
Criteria for Action*
Recommended Follow-Up Actions
Total duration of excursions
were below the low threshold
point.**
Conduct a random "quality
assurance" review of some EERs
each quarter.
In the first quarter after
the source's total duration
of excursions exceeded the
criteria, the emissions were
below the low threshold point.
Check next quarter to determine
whether or not similar problems
have reocurred.
Total duration of the
source's excursions in the
quarter exceeded the "low"
threshold point (two percent
of the total source operating
and monitored time, and certain
other factors, have been used
successfully by Region V for
their power plants).
Total duration was less
than the agency's "low"
threshold point, but there
is a significant increase
in the number or duration
of exceedances in this
quarter.
Detailed examination
of the EER disclosed unaccep-
table types of exceedances
or reasons for exceedances.
(a), (b), (c). Initiate the
lowest level of agency action
(e.g. , a more thorough analysis
of the EER and/or other data
by an engineer). This may rest
in the source receiving a warni
(by telephone or letter) about
its emission rate performance.
- - Continued on next page - -
These were placed in a "relatively" ascending order of
severity/importance.
These examples assume that agencies utilize a dual (e.g.,
low and high thresholds) criteria in order to divide the
EERs into three categories (e.g., those which won't be;
those which may be; and those which the agency definitely
will follow-up). Furthermore, "totalling the duration"
of a source's excursions during a quarter is the preferred
method for using EER data to target sources; the total
duration referred to here may be obtained from Item #5(b)
of Appendix 3. Agencies may choose to use criteria in
other ways.
-------
- 29 -
C). Example Criteria and Recommended Follow-up Actions
(SO2 Emission Performance Problems) - Continued
Criteria for Action
Recommended Follow-Up Actions
Total duration of the
source's excursions in the
quarter exceeded the "high"
threshold point (five percent
of the total source operating
and monitored time and certain
other factors, have been used
successfully by Region V for
their power plants).
Total duration is less than
the "high" threshold point, but
there has been a significant
increase in the number or dura-
tion of exceedances.
(a),(b) Initiate a moderate
level of agency action (e.g.,
a more thorough analysis of
the EER and other compliance
information by the compliance
staff). This may result in
additional surveillance
activity or a conference with
the source. An immediate
inquiry into specific excee-
dances should be conducted.
Reocurrence of the same or
similar problems from prior
reporting periods.
Proceed with more rigorous
follow-up action. The
precise nature of the follow-up
should depend on the severity
ot excess emissions and other
relevant targeting factors
(e.g., size, compliance history]
-------
- 30 -
D). Example Criteria and Recommended Follow-Up Actions
(Administrative Problems With EER/CSA Data Submittal)
Criteria for Action*
Recommended Follow-Up Actions
Present EER/CSA data
report contained one or
more reporting deficien-
cies.**
In every case, call or send
a written critique of the
submittal relative to the
agency's reporting require-
ments. Require corrective
action by next quarter.
EER/CSA data report
not received by 45
days after quarter
e nded.
In every case, call or write
the source requiring EER/CSA
data report submittal
within 15 days.
EER/CSA data report
contained the same or
similar deficiencies
for a second quarter.
Make a telephone follow-up,
confirmed by letter, stating
deficiencies and requiring
corrective action in the
next quarterly report.
Chronic (e.g., at least
three quarters) problem
with EER/CSA data reports
Proceed with more rigorous
follow-up than the previous
category (depending in part
on the degree these problems
impede agency's ability
to conduct source surveillance)
These have been placed
of severity/ import ance
in a "relatively" ascending order
* *
As noted previously, it is highly recommended that the
agency request that its sources submit a ( CSA-derived)
EER. However, the agency may choose to limit its
request for data to quarterly reporting of "raw" CSA data.
-------
- 31 -
VI11. Contacts for Future Technical Assistance, Comments ,
and Additional Copies of the Guidance
As agencies implement their GEMS and CSA-derived EER
targeting programs, EPA anticipates that there may be a
continuing need to respond to technical questions, and to
receive comments and suggestions. Additional copies of
the guidance may also be needed.
Please direct these technical questions and requests
to Louis Paley at (202) 382-2835; or for CDS-related items,
please contact Howard Wright at (202) 382-2831. The address
for both Mr. Paley and Mr. Wright is:
U.S. Environmental Protection Agency
Stationary Source Compliance Division (EN-341)
401 M Street, S.W.
Washington, D.C. 20460
-------
- 32 -
APPENDIX 1
CHARACTERISTICS OF A BOILER OPERATOR'S CSA PROGRAM
Company/Plant/Boiler: ^
Name of Contact:
Title: Phone Number
ttt (All data are to be reported on a "boiler-specific" basis)ttt
A. SAMPLING SYSTEM DESCRIPTION (Check Appropriate Description)
1) Coal Sample Location (see diagram, attached)
As loaded at mine
As received by facility
As bunkered by facility
As tired by facility
Other (describe in Comments #1) . .
2) Coal Composite Sampling Period
During loading of coal shipment . .
During unloading of coal shipment .
During bunkering
During coal firing
Other (describe in Comments #2) . .
t •
3) Coal Composite Sample Size (tons)
Fixed lot size (define size)*
Quantity delivered per shipment
Quantity bunkered daily ....
Quantity burned daily
Other (describe in Comments #3)
4) Number of Increment Samples per Composite
Sample (specify)
5) ASTM Sampling Designation (type, condition,
and spacing according to ASTM D-2234)
Other (describe in Comments #4)
* Lot is detined as the average quantity of coal combusted in
a 24-hour period
-------
- 33 -
Appendix 1 (2 of 3)
B. SAMPLE PREPARATION AND ANALYSIS PROCEDURE DESCRIPTION
1) Does "Sample Preparation" Method Conform to ASTM D-2013?
yes no (describe method used in Comments #5)
2) Does "Moisture" Analytical Method Conform to ASTM D-3173?
yes no (describe method used in Comments 16)
3) Does "Sulfur" Analytical Method Conform to ASTM D-3177?
yes no (describe method used in Comments |7)
4) Does "GCV" Analytical Method Conform to ASTM D-2015?
yes no (describe method used in Comments #8)
C. COMMENTS (Describe)
•
1) Other Sample Location
2) Other Compositing Sampling Period
3) Other Compositing Sample Size
4) Other ASTM Sampling Designation
5) Method Used in Sample Preparation Procedures
6) Method Used in Moisture Analysis
7) Method Used in Sulfur Analysis
8) Method Used in GCV Analysis
D. Source Certification: To the best of my knowledge, the
information included herein are accurate and true repre-
sentations of the subject plant's coal sampling and analysis
program.
Name/Title/Date
-------
COAL SAMPLING POINT LOCATION DIAGRAM
OM MINE-
MINE STORAGE
AND PROCESSING
COAL BUNKER
(SILO)
TO BUNKERS ONLY
FACILITY
BOUNDARY
BOILER
AS-MINED
TRANSPORT
TRANSPORT
AS-LOADED
TO STORAGE
OR BUNKERS
AS-RECEIVED
PULVERIZER
AS-
BUNKERED
AS-FIRED
-------
- 35 -
APPENDIX 2
SUMMARY OF AN ORGANIZATION'S
AVAILABLE CSA DATA AND ITS
EXCESS EMISSION REPORT
Reviewer's Signatures/Dates
first
supervisor
Recommend Follow-up Action?
yes, no (see
Item III, B for details)
Company
Facility
Boiler No.
ttt Review the available data and complete by checking or filling-in
the appropriate answer for each item, ttt
I. RECORD OF AN ORGANIZATION'S GENERAL CSA DATA
A. Measurement/Reporting Period?
B. Applicable SO2 emission limit (identify the regulation
and the allowable rate)?
C. Duration of regulation's averaging/compliance testing
period (in hours or days)?
D. Has an agency previously required the source to perform
CSA or CEMS monitoring? yes, no, unknown.
E. Is this data believed to be relevant to the period of
interest? yes, no, unknown.
F. Is the duration of time represented by each set of CSA
results given? yes, no (specify the duration
here)
G. Number of boiler operating days (BODs) during the
reporting period?
Number of BODs for which there are available CSA
data?
General quality of CSA program? agency-approved,
consistent with ASTM, other, unknown
Form of available CSA results? paired analytical
(%S, GCV) , SO2 rate (lb./10^~~Btu) , both
* Unless otherwise defined by the relevant regulation, a "boiler
operating day" is a fixed twenty-four hour period during which
some coal is combusted in the steam generating unit.
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- 36 -
Appendix 2 (2 of 8)
II. DETAILS OF THE ORGANIZATION'S EER DATA
A. CSA Data Acquisition Performance:
Problem Occurred
Start-hour/date
End-hour/date
Reason
Corrective Actions Taken
1) Total number of BOD's when CSA data were
reported as not available
B. Daily CSA/SO2 Emissions Data
1) Do the CSA data represent the coal combusted
in each twenty-four hours? yes, no,
unknown, other time frame (specify)
2) During which hours was the coal sampling per-
formed each day? a.m. to p.m.
3) Which organization calculated the daily SO2
emission rates shown in the next table?
source, agency
-------
- 37 -
Appendix 2 (3 of 8)
4) Daily CSA/SO2 data:
Sampling
Period
(date)
Sulfur
Content
(%S by
Weight,
dry
basis)
Higher
Heating
Values
(GCV, Btu,
dry basis)
Omission
Rate (lb/
106 Btu)*
Sampling
Period
(date)
Sultur
Content
(%S by
Weight,
dry
basis)
Higher
Heating
Values
(GCV, Btu,
dry basis)
Emission
Rate (lb/
106 Btu)*
No sulfur retention credit is to be used when converting CSA data to SC>2
emission rates.
-------
- 38 -
Appendix 2 (4 of a)
III. RESULTS OF AN ORGANIZATION'S CSA DATA EVALUATION AND EER
A. Are available data believed to be of sufficient
quantity, quality and timeliness to warrant
calculation of a SO2 EER? yes, no
B. If available data are not sufficient to warrant
preparation of an EER,
1) shall additional data/information be acquired?
yes, no. If yes:
a) list the types of additional data which
should be acquired:
*b) recommend which mechanism should be used
to acquire additional data/information:
(if source) search files further,
revise CSA protocol or record-keeping
for subsequent data acquisition, other
(specify) ;
(if agency) field acquisition by agency,
agency enforcement action (e.g., §114,
compliance test), other (specify)
C. Type of coal combusted and sulfur retention credit
(SRC) used.
1) What type of coal was combusted during the
quarter? bituminous, subbituminous,
anthracite, lignite, unknown
2) What SRC value was used in deriving the EER? %**
a) Should the SO2 emission rate values be
recalculated to eliminate the SRC effect
(e.g., SRC > O used)? yes, no,
unknown (the SRC values used must be
determined; "unknown" is unacceptable here)
* This is a "composite" example form which could be used to
tailor one or more forms for either an agency or industry
review.
** There should be a positive statement on what, if any
SRC value was used in deriving the EER. No SRC should
be incorporated in the calculations.
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- 39 -
Appendix 2 (b of 8)
D. Have EER results been completed? yes, no.
1) Who completed them? source, agency
ttt NOTE:. OTHER THAN ITEMS III, F, G and H (Reviewer informa-
tion), DO NOT COMPLETE THE REMAINING ITEMS IF THERE
ARE INSUFFICIENT DATA ttt
E. Summarize the EER results below.
1) Was the performance of the CSA monitoring and
reporting generally adequate? yes, no,
unknown (because agency criteria are unknown
to the source reviewer)
a) Using the following equation and previous
data for missing data and BODs, what total
quantity of CSA data were not available?
% of BODs
Qex = missing data (Item II, A, 1) x 100
quantity of BODs (Item I, G)
b) If the monitoring performance was not
adequate, summarize the reason(s) below:
sub-par sampling method used
sub-par analytical technique used
rate of data acquisition was outside
the agency's (high, low) threshold
value of % of BODs*
sub-par corrective actions were taken
inadequate reporting was made
2) Summarize the reported periods of excess
emissions below:
(a) The allowable SO2-.emission limit is?
Ib. SO2/106 Btu heat input
* If the agency uses dual threshold values, note which one
was violated
-------
- 40 -
Appendix 2 (6 of 8)
2) Continued
Date of
Excess SC>2
Emissions
Total
Magnitude
of Reported
Excess
Emissions
(Ib. S02/
106 Btu)*
Reason for Excess and Corrective Actions
(b) How many times did the daily emission rate
data (above) exceed the allowable emission
level (nex)?
(c) The total duration (dex) of BODs
during which the boiler exceeded the
emission limit was (from table above)
days.
No SRC value should be incorporated in these results
-------
- 41 -
Appendix 2 (7 ot" 8)
(d) Using the following equation, the total
duration (Dex) , in percent of BODs, during
which the boiler exceeded the SC>2 emission
limit was __ _ % of BODs.
Dex
BODs
3) Was the emission performance generally adequate?
_ yes, _ no, _ unknown (because agency
criteria are unknown). If no, specify the
reason below:
a) _ total duration of excursions was above
the agency's (high, low) _
threshold value(s) of _ % of BODs*
•
b) _ inadequate, unknown, or no corrective
action taken
F. Reviewer's name, affiliation and telephone number:
G. Final Recommendations and Signatures:
1) (if source) On the cover page, record if any
source follow-up action should be implemented.
2) (if agency) Depending upon the agency's criteria,
on the cover page record whether or not agency
follow-up action should be implemented.
3) (either) On the cover page, the reviewer and
reviewer's supervisor should date and sign
their names.
* If the agency uses multiple threshold (e.g., 2 & 5%) values,
note which one was violated.
-------
- 42 -
Appendix 2 (8 of 8)
H. (if source) Certification of Information
If the source submitted the EER, a source
representative should sign and date the following
i terns:
1) Data were acquired in a manner fully
conforming with the following method(s):
2) To the besj: of my knowledge, the data and
results included herein are accurate and
true representations of the subject boiler's
SC>2 emissions.
Name / Title / Date
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- 43 -
Recommended Follow-up
Action? yes, no
(see Item 7 for details)
APPENDIX 3
AGENCY REVIEWER'S CHECKLIST FOR SOURCE-SUBMITTED EERs
(to be completed only if a source derived the EER)
Phase 1 Review*
Phase 2 Review/Subset Data Entry
Phase 3 Review/CDS Action Entry
1. Company
Plant/Unit
2. Source Preparer
Names
Dates
Names
Dates
Names
Dates
Quarter Year
Name
Telephone Number
3. Timeliness
(a) Date Postmarked
(b) Days Late
(if more than 30 days after
quarter)
4. Completeness (a separate EER and review/summarization
form (Appendix 2) should be prepared for each boiler)
a. Were the following CSA Monitor-
ing Performance Data Adequate?
(1) Date and Time Identifying
Specitic Periods During Which
CSA Was Inoperative
(2) Nature of CSA System Repairs,
Adjustments, Modifications
(3) Affirmative Statement of No
Period of Downtime, Repair
or Adjustment (including
CSA modifications)
No
Problem
Problem (Describe)
"Phase 1 Review" and other similar phrases relate to the terminology
used in the October 5, 1984 EER Guidance and/or as supplemented by
the Technical Guidance on the Use of Coal Sampling and Analysis
Data to Derive and Follow-Up SO2 Excess Emission Reports.
-------
- 44 -
Appendix 3 (2 of 6)
b. Were
the Following Excess
Emission Data Adequate?
(1)
(2)
(3)
(4)
(5)
(6)
Data Reported in Units
of Applicable Standards
Date of Commencement
Date of Completion
Magnitude
Definite statement of the
Quantity of Sulfur Reten-
tion Credit which Was
Used in the Reported
Emission Values.
Affirmative Statement of
No Excess Emissions
No
Problem
Problem (Describe)
c. How many boiler operating days were there during the Quarter?* _
A revision of reporting requirements to require a summarization
of data, categorization of excess emissions and CSA problems
according to new uniform categories, and reporting of source
operating time is now under consideration by EPA. Although
it may not be specifically required, boiler operating days
has been included in this sample form because it is necessary
to allow for data analysis. A "boiler operating day" is
defined as a fixed twenty-four hour period during which some
coal is combusted in the steam generating unit.
-------
5.
- 45 -
Data Summary for CSA-derived EERs*
(a) CSA Monitoring Performance:
Appendix 3 (3 of 6)
Causes of CSA Monitoring
Unavailability
CSA Equipment Malfunctions
Non-CSA Equipment Malfunc-
tions (e.g., data recorder
etc. )
Calibration/QA
Other Known Causes
Unknown Causes
Number of
Incidents
BODs w/o
CSA Data
Percent of BODs
Without Data
%
%
%
%
%
(1) The total percent of BODs which do not have
sufficient CSA data is: % of BODs.+
(2) Agency criteria for CSA monitoring performance
are: % BODs without data.
(3) Based on the source's CSA monitoring performance
this quarter, is some type of agency follow-up
warranted? yes, no, maybe
Proposed definitions for these categories appear in the
October 5, 1984 "Technical Guidance in Agency Review of
Excess Emission Reports and Follow-up Actions," Appendix 3.
Assume all reported CSA downtime occurs during periods
of boiler operation unless explicitly stated otherwise.
-------
- 46 -
Appendix 3 (4 of 6)
(b) SC>2 Emission Performance (Data Reported as Daily
Periods Unless otherwise Noted):
Causes of Excess Emissions
Fuel Supply Problems
Fuel Blending/Mixing
Problems
Other Known Causes
Unknown Causes
Number of
Incidents
BODs with
Excess
Emissions
% of BODs
w/Excess
Emissions
%
%
%
%
6.
(1) The total percent of BODs during which
the boiler's emissions exceeded the SO2
limit is: % of BODs.
(2) Agency criteria for frequency of excursions
are: % of BODs with excursions.
(3) Based on the source's emission performance
this quarter, is agency follow-up warranted?
no, yes, maybe
Were the summarized EER data input to the CEMS Subset of
CDS? yes, no.
-------
- 47 -
Appendix 3 (5 of 6)
7. Recommendations for Follow-up Activity Based on Detailed
Review of EER and Other Compliance Information (Indicate
recommended agency action with check(s) and/or appropriate
letter(s) and comments below.)
Follow-up Actions
No Action
Target Source for
Detailed EER Review
Next Quarter
Contact State
Defer to State
Contact Source
a. Telephone source
b. Meet with source
c. Request additional
information
d. Request additional
reporting
e. Request corrective
action
f. Request additional
testing
g. Request alternate
monitoring
h. Request specific
Oi»M/QA procedures
i. Other (Specify)
CSA Monitor-
ing Problems
S02 Emission
Problems
Timeli-
ness
Complete-
ness
Continued
-------
- 48 -
Appendix 3 (6 of 6)
7. (continued)
Follow-up Actions
Targeting for Addi-
tional Surveillance
a. Inspection
b. Audit of CSA
c. Compliance Test
d. Other (Specify)
Take Enforcement
Action
a. Warning Letter
b. § 113 FOV/NOV
c. § 113 Compliance
Order
d. § 120 Notice of
Noncompliance
e. Initiate Civil
Action
f. Other (Specify)
CSA Monitor-
ing Problems
SO2 Emission
Problems
T imeli-
ness
Complete-
ness
Comments/Overall Recommendation: (also check "yes" in action block
on page 1 if action is recommended here)
8. Were the Agency's Revised Compliance Status and Follow-up
Action Coded and Entered in CDS? (Also sign the third
line, page 1 of the Checklist) yes, no, no change
required because .
(a) CDS data element "SCMS" was changed from
to
-------
ATTACHMENT II
EXAMPLE Of AN AGENCY'S CONVERSION OF CSA DATA
INTO A SO2 EER AND ITS FOLLOW-UP ACTIVITILS
Prepared by
Louis R. Paley
Technical Support Branch
Stationary Source Compliance Division
Otfice ot Air Quality Planning ana Standards
U.S. Environmental Protection Agency
Washington, DC 20460
October 1985
-------
- 49 -
ATTACHMENT II
EXAMPLE OF AN AGENCY'S CONVERSION OF CSA DATA
INTO A SO2 EER AND ITS FOLLOW-UP ACTIVITIES
In an effort to clarify the guidance further and to
assist in the preparation of a CSA-derived EER, a specific
example of an agency's review of actual CSA data is provided
in the following paragraphs and example data sheets.
I. Initial Agency Evaluation of the Completeness and
the Quality of the Data*
This activity was performed in Phase 1, of the agency's
EER review and follow-up program, and was done by a para-
professional .
Step 0; Complete the boiler-specific information
contained in Example Data #1.
Items I, II, and HI (A-D) of the "Example Data #1"
represented the data which the agency had at the outset of
the process. The agency had previously developed a "CSA
Guidance-affected Inventory."**
Step 1; Evaluate the completeness and the quality
of the data
Step lA:
The reviewer evaluated the data available
within the organization and determined if they were
sufficient in terms of: completeness (e.g., M35%
of the BODs); timeliness (from the calendar quarter
of interest); quality (data from an as-fired or
as-bunkered CSA system); and known sulfur retention
credit (SRC).
* The paragraph and Step numbers in this attachment coincide
(except tor Step 0) with those used in Attachment I.
** Such an inventory can be simply derived by defining which
coal-fired boilers the agency desires to receive periodic
SO2 emission rate/EERs from, and subtracting trom those
the boilers which operate FGDs and/or submit (of should
submit) CEMS-based data to the agency
-------
- 50 -
In this manner the reviewer evaluated the available
data relative to the specific boiler of interest. The results
of the review were recorded in Items III (A-D) of Example Data
#1, and he signed and dated the form in the signature blocks
on pages 1 and 10.
As one can see in Example Data #1, the agency's reviewer
found insufficient information to warrant development of an
EER.
II. Agency Requested Additional Data
The agency sent a §114 letter (enclosing forms similar
to those given as Appendix 1 and 2 of Attachment I) to the
boiler operator. It required source submittal, within 30
days after receipt of the request, of: (a) currently-available
CSA data and information for the most recent quarter; and
(b) source completion of a summary EER. A copy of the source's
response to that letter is presented as Example Data #2 and #3.
III. Agency Evaluation of the Additional Data
Because the agency requested, and the source provided,
the background data and EER, the reviewer did not have to
review anything but Example Data #2 and #3. Therefore,
Sections IV and V and Steps 2-7 of Attachment I were skipped.
VI. Agency Review, Summarization and Entry of CSA-derived
EER Data
A. Phase 1 - Screening Assessment and Summarization
of the Data
Step 8; Assess and record the completeness and
general acceptability of the EER.
The reviewer evaluated the EER and completed Items 1 to 4
on the "EER Reviewer's Checklist" (Example Data #4).
While many items were required, he remembered that the
key to effective use of EERs is to concentrate on
whether the source acquired and reported an adequate quantity
of CSA data, and whether its emissions remained below the
emission limit.
-------
- 51 -
Step 9; Summarize and record the source's CSA
monitoring and emission performance data.
Before the EER data were entered into the GEMS Subset
and used, the data were summarized consistent with Item 5
of Example Data f4. The two parameters which the reviewer
summarized were:
(a) total number and duration of individual CSA
data acquisition system downtime incidents; and
(b) total number and duration of individual exceedance
periods.
The results of the summarization were recorded in Items 5(a)
and 5(b) of Example Data #4. The agency's criteria for
taking follow-up actions (Item 5, (a), (2) and 5, (b), (2)
respectively), and the reviewer's determination of whether
such follow-up was warranted (Items 5, (a), (3) and 5, (b),
(3), respectively) were recorded.
B. Phase 2 - Verification of Phase 1 Results, Selective
Targeting of Sources, and Data Entry into the Subset
of the CDS
The Phase 2 EER activities were performed by an
experienced compliance person.
Step 10; Supervisory verification and concurrence
with Phase 1 results
The supervisor reviewed the results of the Phase 1
evaluation which were recorded in Items 1 to 5 of Example
Data #4.
Step 11: Supervision of entry of summarized EER data
into the CEMS Subset of the CDS.*
At least once per quarter, the supervisor insured
that the summarized EER data, targeting results and follow-up
recommendations were entered appropriately and in a timely
fashion. The supervisor also insured that the source was
notitied about these results. Completion of these entry
activities were recorded in Item 6 of Example Data #4.
Procedures for CSA data entry will be subsequently furnished
by SSCD as part of the CDS program.
-------
- 52 -
Step 12; Selectively target and record outlier
sources for tollow-up
The reviewer took account of the following items prior
to targeting the source:
a) impact of the differences in methodology and
averaging periods;
b) potential sulfur retention credit; and
c) previous compliance history.
The reviewer used the information provided in Section VI of
Attachment I to help address the first two points. He concluded
that the potential impacts of these points approximately
offset each other. Furthermore, he reassessed his initial
recommendation for agency follow-up (recorded in Item 5, (a),
(3) and 5, (b), (3)) because he took account of the source's
compliance history.
The reviewer's final recommendations for follow-up
actions were recorded in Item 7 ot Example Date #4. The
facts that the source had a good compliance record and
that this was the first quarter that the agency noted the
problems, resulted in a final recommendation that the agency
take somewhat less vigorous enforcement actions than he
preliminarily had recommended.*
Step 13: Revise, if appropriate, the source's compliance
status in the CDS.
The fact that the reviewer targeted the source should
cause the source to take some corrective actions.
The reviewer "flagged" the targeted sources by recording its
status in CDS as being in "non-compliance".** Once the reviewer
confirmed that the appropriate compliance status for the source
was stored in CDS, he completed Item 8 in Example Data #4.
* Had the source's problems (noted in the subject quarter)
been chronic ones, or if the source had a poor compliance
history, the reviewer would likely have recommended case
development and referral for litigation (based on (at
least) the source's continuing violation of the §6U.ll(d)
requirement to operate and maintain the process in a
manner which minimized air pollution).
** Other "flagging" methods may also be suitable.
-------
- 53 -
EXAMPLE DATA #1
SUMMARY OF AN ORGANIZATION'S
AVAILABLE CSA DATA AND ITS
EXCESS EMISSION REPORT
Reviewer's Signatures/Dates:
first
N/A
supervisor
Recommend Follow-up Action?
x yes, no (see Item
III, B for details)
Midwest Electric Co., Frequent Excursions Plant, Unit tl
Company / Facility / Boiler No.
ttt Review the available data and complete by checking or filling-in
the appropriate answer for each item, ttt
I. RECORD OF AN ORGANIZATION'S GENERAL CSA DATA
A. Measurement/Reporting Period? January 1 - March 31, 1983
B. Applicable SO2 emission limit (identify the regulation
and the allowable rate)? NSPS, Subpart D (1.201b/106 Btu)
C. Duration of regulation's averaging/compliance testing
period (in hours or days)? Reference Method 6 (a few hours)
D. Has an agency previously required the source to perform
CSA or GEMS monitoring? yes, x no, unknown.
E. Is this data believed to be relevant to the period of
interest? x yes, no, unknown.
F. Is the duration of time represented by each set of CSA
results given? yes, x no (specify the duration
here)
G. Number of boiler operating days (BODs) during the
reporting period? unknown *
* Unless otherwise defined by the relevant regulation, a "boiler
operating dav" is a fixed twenty-four hour period during which
some coal is combusted in the steam generating unit.
-------
- 54 -
H.
Example Data #1 (2 of 9)
Quantity of BODs for which there are available CSA
data? 11
II
I. General quality of CSA program? agency-approved,
consistent with ASTM , other, x unknown
J. Form of available CSA results? x paired analytical
(%S, GCV) , SO2 rate (lb./10G Btu) , both
DETAILS OF THE ORGANIZATION'S EER DATA
A. CSA Data Acquisition Performance:
Problem Occurred
Start-hour/date
8:00 a.m.
1/8/83
11:00 a.m.
3/29
End-hour/date
11:00 p.m.
1/8
4:30 p.m.
3/29
Reason
jammed
primary
cutting
arm
calibration
tests
Corrective Actions Taken
clean out, reset arm
and timing mechanism
general recalibration and
bias testing
1) Total number of BOD's when CSA data were
reported as not available = 2
-------
- 55 -
Example Data #1 (3 of 9)
B. Daily CSA/SO2 Emissions Data
1) Do the CSA data represent the coal combusted
in each twenty-four hours? x yes, no,
unknown, other time frame (specify)
2) During which hours was the coal sampling per-
formed each day? N/A a.m. to p.m.
3) Which organization calculated the daily SO2
emission rates shown in the next table?
N/A source, agency
-------
- 56 -
Example Data #1 (4 of 9)
4) Daily CSVS02 data:
Sampling
Period
(date)
1/1/83
1/2
1/3
1/4
1/5
1/6
1/7
1/8
1/9
1/10
3/29
3/30
3/31
Sulfur
Content
(%S by
Weight,
dry
basis)
0.61
0.67
0.57
0.68
0.93
0.64
0.69
*
0.87
0.83
*
0.73
0.82
Higher
Heating
Values
(GCV, Btu,
dry basis)
11,901
12,337
11,820
12,219
12,169
12,480
12,013
*
12,205
12,110
*
11,678
12,030
Omission
Rate (lb/
106 Btu)**
Sampling
Period
(date)
Sulfur
Content
(%S by
Weight,
dry
basis)
Higher
Heating
Values
(GCV, Btu,
dry basis)
Emission
Rate (lb/
106 Btu)**
1
No data available tor this day
No sulfur retention credit is to be used when converting CSA data to SO2
emission rates.
-------
- 57 -
Example Data #1 (5 of 9)
III. RESULTS OF AN ORGANIZATION'S CSA DATA EVALUATION AND EER
A. Are available data believed to be of sufficient
quantity, quality and timeliness to warrant
calculation of a SC>2 EER? yes, x no
B. If available data are not sufficient to warrant
preparation of an EER,
1) shall additional data/information be acquired?
x yes, no. If yes:
a) list the types of additional data which
should be acquired: CSA results for at
least 85% of the BODs in the most recent
quarter
'b) recommend which mechanism should be used
to acquire additional data/information:
(if source) N/A search files further,
revise CSA protocol or record-keeping
for subsequent data acquisition, other
(specify) ;
(if agency) field acquisition by agency
x agency enforcement action (e.g., §114,
compliance test), other (specify)
C. Type of coal combusted and sulfur retention credit
(SRC) used.
1) What type of coal was combusted during the
quarter? bituminous, subbituminous,
anthracite, lignite, x unknown
2) What SRC value was used in deriving the EER? N/A%
a) Should the SC>2 emission rate values be
recalculated to eliminate the SRC effect
(e.g., SRC > 0 used)? yes, no,
x unknown (the SRC values used must be
determined; "unknown" is unacceptable here)
D. Have EER results been completed? yes, x no.
1) Who completed them? source, agency
* There should be a positive statement on what, if any SRC
value was used in deriving the EER. No SRC should be
incorporated in the calculation.
-------
- 58 -
Example Data #1 (6 of 9)
ttt NOTE: OTHER THAN ITEMS III, F, G and H (Reviewer informa-
tion), DO NOT COMPLETE THE REMAINING ITEMS IF THERE
ARE INSUFFICIENT DATA ttt
E. Summarize the EER results below.
1) Was the performance of the CSA monitoring and
reporting generally adequate? yes, no,
unknown (because agency criteria are unknown)
a) Using the following equation and previous
data for missing data and BODs, what total
quantity (as a percent of BODs) of CSA data
were not available? % of BODs
Qex = missing data (Item II, A, 1) x 100
quantity of BODs (Item I ,G)
b) If the monitoring performance was not
adequate, summarize the reason(s) below:
sub-par sampling method used
sub-par analytical technique used
rate of missing data was above the
agency's (high, low) threshold
value of % of BODs**
sub-par corrective actions were taken
inadequate reporting was made
** If tne agency uses dual threshold values, note which
one was violated.
-------
- 59 -
Example Data #1 (7 of 9
2) Summarize the reported periods of excess
emissions below:
(a) The allowable SC>2,emission limit is?
lb. SO-,/10 Btu heat input
Date of
Excess SO2
Emissions
Total
Magnitude
of Reported
Excess
Emissions
(lb. S02/
106 Btu)*
Reason for Excess and Corrective Actions
(b) How many times did the daily emission rate
data (above) exceed the allowable emission
level (nex)?
* No SRC value should be incorporated in these results
-------
- 60 -
Example Data #1 (8 of 9,
(c) The total duration (dex) of BODs during
which the boiler exceeded the SO2 emission
limit was (from previous table) _ days.
(d) Using the following equation, the total
duration (Dex), in percent of BODs, during
which the boiler exceeded the SC>2 emission
limit was _ % of BODs.
D = dgv x 100
ex
BODs
3) Was the emission performance generally adequate?
_ yes, _ no, _ unknown (because agency
criteria are unknown). If no, specify reasons
below:
a) _ total duration of excursions was above
the agency's (high, low) _
threshold value(s) of _ % of BODs*
b) _ inadequate, unknown, or no corrective
action taken
Reviewer's name, affiliation and telephone number:
Louis Roberts, EPA (202) 382-4000
G. Final Recommendations and Signatures:
1) (if source) On the cover page record if any
source follow-up action should be implemented.
2) (if agency) Depending upon the agency's criteria,
on the cover page record whether or not agency
follow-up action should be implemented.
3) (either) On the cover page the reviewer and
reviewer's supervisor should date and sign
tneir names.
* Note both threshold value(s), and which one was violated,
if the agency uses multiple threshold (e.g., 2 & 5%) values.
-------
- 61 -
Example Data #1 (9 of 9)
(if source) Certification of Information
If the source submitted the EER, a source
representative should sign and date the following
i terns:
1) Data were acquired in a manner fully
conforming with the following method(s):
N/A
N/A .
2) To the best of my knowledge, the data and
results included herein are accurate and
true representations of the subject boiler's
SC>2 emissions.
N/A
Name / Title / Date
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- 62 -
EXAMPLE DATA #2
CHARACTERISTICS OF A BOILER OPERATOR'S CSA PROGRAM
Company/Plant/Boiler: Midwest Electric Co., Frequent Excursions
Plant, Unit »1
Name of Contact: John Smythe
Title: Plant Superintendent Phone Number (817) 279-5534
ttt (All data are to be reported on a "boiler-specific" basis)ttt
A. SAMPLING SYSTEM DESCRIPTION (Check Appropriate Description)
1) Coal Sample Location (see diagram, attached)
As loaded at mine
As received by facility
As bunkered by facility x_
As fired by facility
Other (describe in Comments fl)
2) Coal Composite Sampling Period
During loading of coal shipment
During unloading of coal shipment .... x_
During bunkering
During coal firing
Other (describe in Comments #2)
3) Coal Composite Sample Size (tons)
Fixed lot size (define size)*
Quantity delivered per shipment
Quantity bunkered daily
Quantity burned daily 4000 (avg . )
Other (describe in Comments #3)
4) Number of Increment Samples per Composite
Sample (specify) 35
5) ASTM Sampling Designation (type, condition,
and spacing according to ASTM D-2234)
I,B, x_
I,C,1
Other (describe in Comments #4)
* Lot is defined as the average quantity of coal combusted in
a 24-hour period
-------
- 63 -
Example Data #2 (2 of 3)
B. SAMPLE PREPARATION AND ANALYSIS PROCEDURE DESCRIPTION
1) Does "Sample Preparation" Method Conform to ASTM D-2013?
yes x no (describe method used in Comments #5)
2) Does "Moisture" Analytical Method Conform to ASTM D-3173?
yes x no (describe method used in Comments #6)
3) Does "Sulfur" Analytical Method Conform to ASTM D-3177?
yes x no (describe method used in Comments 17)
4) Does "GCV" Analytical Method Conform to ASTM D-2015?
yes x no (describe method used in Comments 18)
C. COMMENTS (Describe)
1) Other Sample Location N/A
2) Other Compositing Sampling Period N/A
3) Other Composited Sample Size N/A
4) Other ASTM Sampling Designation N/A
5) Method Used in Sample Preparation Procedures N/A
6) Method Used in Moisture Analysis N/A
7) Method Used in Sulfur Analysis N/A
8) Method Used in GCV Analysis N/A
D. Source Certification: To the best of my knowledge, the
information included herein are accurate and true repre-
sentations of the subject plant's coal sampling and analysis
program.
John Smythe, Plant Superintendent 7/6/83
Name / Title / Date
-------
COAL SAMPLING POINT LOCATION DIAGRAM
FROM MINE-
MINE STORAGE
AND PROCESSING
COAL
TO BUNKERS ONLY
FACILITY
BOUNDARY
BUNKER
(SILO)
BOILER
T
AS-MINED
TRANSPORT
TRANSPORT
AS-LOADED
TO STORAGE
OR BUNKERS
AS-RECEIVED
PULVERIZER
AS-
BUNKERED
AS-FIRED
-------
- 65 -
EXAMPLE DATA #3
SUMMARY OF A BOILER OPERATOR'S
MOST RECENT QUARTER CSA DATA
AND ITS EXCESS EMISSION REPORT
Midwest Electric Co., Frequent Excursions Plant, Unit tl
Company / Facility / Boiler No.
ttt Review the available data and complete by checking or filling-in
the appropriate answer for each item, ttt
I. RECORD OF AN ORGANIZATION'S GENERAL CSA DATA
A. Measurement/Reporting Period? April.1, 1983 - June 30, 1983
B. Applicable S02 emission limit (identify the regulation
and the allowable rate)? NSPS, Subpart D (1.201b/106 Btu)
C. Duration of regulation's averaging/compliance testing
period (in hours or days)? Reference Method 6 (a few hours)
D. Has an agency previously required the source to perform
CSA or CEMS monitoring? x yes, no, unknown.
E. Is this data believed to be relevant to the period of
interest? x yes, no, unknown.
F. Is the duration of time represented by each set of CSA
results given? x yes, no, (specify the duration
here) 24 hours
G. Number of boiler operating days (BODs) during the
reporting period? 5J *
H. Number ot BODs for which there are available CSA
data? 54
I. General quality of CSA program? agency-approved,
x consistent with ASTM, other, unknown
J. Form of available CSA results? paired analytical
(%S, GCV), SO2 rate (lb./10G Btu), x both
* Unless otherwise defined by the relevant regulation, a "boiler
operating day" is a fixed twenty-four hour period during which
some coal is combusted in the steam generating unit.
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- 66 -
Example Data #3 (2 of 8
II. DETAILS OF THE ORGANIZATION'S EER DATA
A. CSA Data Acquisition Performance:
Problem Occurred
Start-hour/date
8:00 a.m.
4/14/83
10:00 a.m.
6/6
5:00 a.m.
6/13
End-hour/date
11:00 p.m.
4/14
9:00 p.m.
6/6
8 :00 p.m.
6/13
Reason
cutter arm
jammed
riffles jam-
med and
broken
device
mechanism
jammed and
broken
Corrective Actions Taken
clean out, reset arm
and timing mechanism
replace and reset timing
replace belt and reset
timing
1) Total number of BOD's when CSA data were
reported as not available 3
B. Daily CSA/SO2 Emissions Data
1) Do the CSA data represent the coal combusted
in each twenty-four hours? x yes, no,
unknown, other time frame (specify)
2) During which hours was the coal sampling
performed each day? 8;00 a.m. to 3:00 p.m.
3) Which organization calculated the daily SO2
emission rates shown in the next table?
x source, agency
-------
- 67 -
Example Data #3 (3 of 8)
4) Daily CSA/SO2 data:
Sampling
Period
(date)
4/1/83
4/2
4>3
4/4
4/5
+4/6
4/7
+4/8
4/9
4/10
+4/11
4/12
4/13
4/14
+4/15
4/16
4/17
4/18
4/19
4/20
4/21
4/22
4/23
4/24
+4/25
+4/26
4/27
4/28
4/29
4/30
5/1-6/4
6/4
6/5
6/6
+6/7
6/8
6/9
6/10
6/11
6/12
6/13
6/14
6/15
6/16
6/17
Sulfur
Content
(%S by
Weight,
dry
basis)
0.60
0.65
0.70
0.56
0.66
0.93
0.66
0.73
0.62
0.67
0.76
0.57
0.62
*
0.80
0.58
0.56
0.60
0.55
0.67
0.63
0.58
0.53
0.70
0.76
0.78
0.58
0.56
0.62
0.64
Higher
Heating
Values
(GCV, Btu,
dry basis)
11,901
12,337
12,037
11,820
12,219
12,167
12,692
11,939
12,480
12,013
11,995
12,105
12,462
*
12,110
12,050
11,950
11,958
11,980
12,050
12,400
12,301
12,052
12,080
12,120
11,985
12,080
12,050
12,008
11,985
Emission
Rate (lb/
106 Btu)**
0.999
1.059
1.166
0.940
1.085
1.491
1.044
1.225
1.000
1.120
1.268
0.934
1.001
1.320
0.971
0.946
1.011
0.928
1.117
1.022
0.951
0.890
1.162
1.255
1.302
0.969
0.939
1.039
1.074
Annual Outage
0.66
0.72
*
0.81
0.71
0.70
0.62
0.60
0.64
*
0.70
0.72
0.67
0.68
11,989
12,080
*
12,068
12,045
12,045
12,003
11,895
11,933
*
12,115
12,005
12,201
12,500
1.106
1.195
*
1.341
1.182
1.166
1.040
1.016
1.079
*
1.16
1.198
1.103
1.092
Sampling
Period
(date)
6/18
6/19
6/20
6/21
6/22
6/23
6/24
6/25
6/26
6/27
6/28
6/29
6/30
Sulfur
Content
(%S by
Weight,
dry
basis)
0.70
0.72
0.67
0.56
0.57
0.66
0.60
0.65
0.70
0.71
0.66
0.57
0.60
Higher
Heating
Values
(GCV, Btu,
dry basis)
12,075
12,123
12,129
12,089
12,355
12,280
12,305
12,308
11,998
12,015
12,025
12,283
12,291
Emission
Rate (lb/
106 Btu)**
1.163
1.190
1.109
0.936
0.931
0.984
1.078
1.061
1.153
1.185
1.103
0.937
0.984
* Data not available for this HOD due to CSA monitoring problems
+ BODs during which emissions exceeded the allowable, based on analysis
performed in Item III, E, 2, (b).
** No sulfur retention credit was used when converting CSA data to SC>2
emission rates.
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- 68 -
Example Data #3 (4 of 8)
III. RESULTS OF THE BOILER OPERATOR'S CSA DATA
EVALUATION AND EER
A. Are available data believed to be of sufficient
quantity, quality and timeliness to warrant
calculation of a S02 EER? x yes, no
B. If available data are not sufficient to warrant
preparation of an EER,
1) shall additional data/information be acquired?
yes, x no. If yes:
a) list the types of additional data which
should be acquired: N/A
b) recommend which mechanism should be used
to acquire additional data/information:
(if source) N/A search files further,
revise CSA protocol or record-keeping
for subsequent data acquisition, other
(specify) •
(if agency) N/A field acquisition by agency,
agency enforcement action (e.g., §114,
compliance test), other (specify)
C. Type of coal combusted and sulfur retention credit
(SRC) used.
1) What type of coal was combusted during the
quarter? x bituminous, subbituminous,
anthracite, lignite, unknown
2) What SRC value was used in deriving the EER? 0 %*
a) Should the SC>2 emission rate values be
recalculated to eliminate the SRC effect
(e.g., SRC > 0 used)? yes, x no,
unknown (the SRC values used must be
determined; "unknown" is unacceptable here)
D. Have EER results been completed? x yes, no.
1) Who completed them? x source, ayency
There should be a positive statement on what, if any SRC
value was used in deriving the EER. Mo SRC should be
incorporated in the calculation.
-------
- 69 -
Example Data #3 (5 of 8)
ttt NOTE: OTHER THAN ITEMS III, F, G and H (Reviewer informa-
tion), DO NOT COMPLETE THE REMAINING ITEMS IF THERE
ARE INSUFFICIENT DATA ttt
E. Summarize the EER results below.
1) Was the performance of the CSA monitoring and
reporting generally adequate? _ yes, _ no,
x unknown (because agency criteria are unknown)
a) Using the following equation and the previous
data for missing data and BODs , what total
quantity of CSA data, were not available?
5.3 % of BODs
* Qex = missing data (Item II, A, 1) x 100
quantity of BODs (Item I,G)
b) If the monitoring performance was not
adequate, summarize the reason(s) below:
_ sub-par sampling method used
_ sub-par analytical technique used
_ rate of missing data was above the
agency's (high, low) threshold
value of % of
sub-par corrective actions were taken
inadequate reporting was made
** It the agency uses dual threshold values, note which
one was violated.
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- 70 -
Example Data #3 (6 of 8)
2) Summarize the reported periods of excess
emissions below:
(a) The allowable SO2 emission limit is?
1.20 Ib. SO2/106 Btu heat input
Date of
Excess SC-2
Emissions
4/6
4/8
4/11
4/15
4/25
4/26
Total
Magnitude
of Reported
Excess
Emissions
(Ib. SO2/
106 Btu)*
1.491
1.225
1.268
1.320
1.225
1.302
Annual Outage 5/1-6/4
6/7
1.341
Reason for Excess and
coal blender broken -
coal blender jammed -
coal blender jammed -
coal blender broken -
sulfur content above
lower sulfur coal
sulfur content above
lower sulfur coal
Corrective Actions
fixed blender
readjust blender
readjust blender
fixed blender
spec. - blend with
spec. - blend with
N/A
coal blender jammed,
readjust blender
(b) How many times did the daily emission rate
data (above) exceed the allowable emission
limit (nex)? 7
(c) Total duration (dex) of BODs during which
the boiler exceeded the S02 emission limit
(from table above) was 7 days.
No SRC value was incorporated in these results.
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- 71 -
Example Data #3 (7 of 8)
(d) Using the following equation, the total
duration (Dex), in percent of BODs, during
which the boiler exceeded the SC>2 emission
limit was 12.2 % of BODs.
Dex « lex x 10°
BODs
3) Was the emission performance generally adequate?
yes, no, x unknown (because agency
criteria are unknown). If no, specify reasons
below:
a) total duration of excursions was above
the agency's (high, low)
threshold value(s) of % of BODs*
b) inadequate, unknown, or no corrective
action taken
Reviewer's name, affiliation and telephone number:
Robert Johns, Midwest Electric Co. (404) 872-2534
G. Final Recommendations and Signatures:
1) (if source) On the cover page record if any
source follow-up action should be implemented.
2) (if agency) Depending upon the agency's criteria,
on the cover page record whether or not agency
follow-up action should be implemented.
3) (either) On the cover page the reviewer and
reviewer's supervisor should data and sign
their names.
* Note both threshold value(s), and which one was violated,
if the agency uses multiple threshold (e.g., 2 & 5%) values.
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- 72 -
Example Data #3 (8 of 8)
H. (if source) Certification of Information
If the source submitted the EER, a source
representative should sign and date the following
i terns:
1) Data were acquired in a manner fully
conforming with the (specify) following
method(s) :
ASTM methods as noted above
2) To the best of my knowledge, the data and
results included herein are accurate and
true representations of the subject boiler's
SO2 emissions.
John Smythe, Plant Superintendent, 7/6/83
Name / Title / Date
-------
- 73 -
Recommended Follow-up
Action? x yes, no
(see Item 7 for details)
EXAMPLE DATA 14
AGENCY REVIEWER'S CHECKLIST FOR SOURCE-SUBMITTED EERs
(to be completed only if a source derived the EER)
Phase 1 Review*
Louis Roberts
Names
Phase 2 Review/Subset Data Entry Louis Roberts
Names
Phase 3 Review/CDS Action Entry
Louis Roberts
1. Company
Plant/Unit
2. Source Preparer
3. Timeliness
Names
Midwest Electric Company
Quarter
Frequent Excursions Plant, Unit tl
7/25/83
Dates
7/27/83
Dates
7/27/83
Dates
2nd 1983
Year
Robert Johns
Name
(404) 872-2534
Telephone Number
(a) Date Postmarked 7/7/83
(b) Days Late N/A
(if more than 30 days after
quarter)
Completeness (a separate EER and review/summarization
form (Appendix 2) should be prepared for each boiler)
a.
Were the following CSA Monitor-
ing Performance Data Adequate?
(1) Date and Time Identifying
Specific Periods During Which
CSA Was Inoperative
(2) Nature of CSA System Repairs,
Adjustments, Modifications
(3) Affirmative Statement of No
Period of Downtime, Repair
or Adjustment (including
CSA modifications)
No
Problem
Problem (Describe)
* "Phase 1 Review" and other similar phrases relate to the terminology
used in the October 5, 1984 EER Guidance and/or as supplemented by
the Technical Guidance on the Use of Coal Sampling and Analysis
Data to Derive and Follow-Up SO2 Excess Emission Reports.
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- 74 -
Example Data #4 (2 of 6)
b. Were
the Following Excess
Emission Data Adequate?
(1)
(2)
(3)
(4)
(5)
(6)
Data Reported in Units
of Applicable Standards
Date of Commencement
Date of Completion
Magnitude
Definite statement on the
Quantity of Sulfur Reten-
tion Credit which Was
Used in the Reported
Emission Values.
Affirmative Statement of
No Excess Emissions
No
Problem
X
X
X
X
X
X
Problem (Describe)
c. How many boiler operating days were there during the Quarter?* __5
A revision of reporting requirements to require a summarization
of data, categorization of excess emissions and CSA problems
according to new uniform categories, and reporting of source
operating time is now under consideration by EPA. Although
it may not be specifically required, boiler operating days
has been included in this sample form because it is necessary
to allow for data analysis. A "boiler operating day" is
defined as a fixed twenty-four hour period during which some
coal is combusted in the steam generating unit.
-------
5.
- 75 -
Data Summary for CSA-derived EERs*
(a) CSA Monitoring Performance:
Example Data #4 (3 of 6)
Causes of CSA Monitoring
Unavailability
CSA Equipment Malfunctions
Non-CSA Equipment Malfunc-
tions (e.g., data recorder
etc. )
Calibration/OA
Other Known Causes
Unknown Causes
Number of
Incidents
3
r
BODs w/o
CSA Data
3
Percent of BODs
Missing Data
5.3 %
%
%
%
%
(1) The total percent of BODs which do not have
sufficient CSA data is: 5.3 % of BODs."1"
(2) Agency criteria for CSA monitoring performance
are: <5 % of BODs without data.
(3) Based on the source's CSA monitoring performance
this quarter, is some type of agency follow-up
warranted? x yes, no, maybe
* Proposed definitions for these categories appear in the
October 5, 1984 "Technical Guidance in Agency Review of
Excess Emission Reports and Follow-up Actions," Appendix 3
+ Assume all reported CSA downtime occurs during periods
of boiler operation unless explicitly stated otherwise.
-------
- 76 -
Example Data #4 (4 of 6)
(b) SC>2 Emission Performance (Data Reported as Daily
Periods Unless otherwise Noted):
Causes of Excess Emissions
Fuel Supply Problems
fuel Blending/Mixing
Problems
Other Known Problems
Unknown Causes
Number of
Incidents
2
5
BODs with
Excess
Emissions
2
5
% of BODs
w/Excess
Emissions
3.5 %
8.8 %
%
%
6.
(1) The total percent of BODs during which
the boiler's emissions exceeded the SO2
limit is: 12.3 % of BODs.
(2) Agency criteria for frequency of excursions
are: <5 % of BODs with excursions.
(3) Based on the source's emission performance
this quarter, is agency follow-up warranted?
no, x yes, maybe
Were the summarized EER data input to the CEMS Subset of
CDS? x yes, no.
-------
- 77 -
Example Data #4 (5 of 6)
7. Recommendations for Follow-up Activity Based on Detailed
Review of EER and Other Compliance Information (Indicate
recommended agency action with check(s) and/or appropriate
letter(s) and comments below.)
Follow-up Actions
No Action
Target Source for
Detailed EER Review
Next Quarter
Contact State
Defer to State
Contact Source
a. Telephone source
b. Meet with source
c. Request additional
information
d. Request additional
reporting
e. Request corrective
action
f. Request additional
testing
g. Request alternate
monitoring
h. Request specific
O&M/QA procedures
i. Other (Specify)
CSA Monitor-
ing Problems
S02 Emission
Problems
Timeli-
ness
X
Complete-
ness
X
Continued
-------
- 78 -
Example Data #4 (6 of 6)
7. (continued)
Follow-ujj Actions
Targeting for Addi-
tional Surveillance
a. Inspection
b. Audit of CSA
c. Compliance test
d. Other (Specify)
Take Enforcement
Action
a. Warning Letter
b. § 113 FOV/NOV
c. § 113 Compliance
Order
d. § 120 Notice of
Noncompliance
e. Initiative civil
action
f. Other (Specify)
CbA Monitor-
ing Problems
X
SO2 Emission
Problems
X
T imeli-
ness
Comple te-
ness
Comments/Overall Recommendation: (also check "yes" in action block
on page 1 if action is recommended here) At a minimum, make a FOV
and offer the boiler's owner or operator an opportunity to partici-
pate in a §113 conference.
8. Were the Agency's Revised Compliance Status and Follow-up
Action Coded and Entered in CDS? (Also sign the third
line, page 1 of the Checklist) x yes, no, no change
required because .
(a) CDS data element "SCMS" was changed from
3 to 1 .
-------
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