United States Environmental Protection Agency Air and Radiation (ANR-445) 400/1-91/036 December 1991 oEFA Continuous Emission Monitoring Proposed Acid Rain Rule The U.S. Environmental Protection Agency (EPA) has proposed four rules containing the core acid rain requirements: the Permits Rule (40 CFR Part 72), the Allowances Rule (40 CFR Part 73), the Continuous Emission Monitoring Rule (40 CFR Part 75), and the Excess Emissions Rule (40 CFR Part 77). EPA will also propose additional rules at a future date. These rules will include requirements for facilities that elect to opt in to the Acid Rain Program (40 CFR Part 74) and for the nitrogen oxide (NOX) control program (40 CFR Part 76). This fact sheet summarizes the key components of the proposed Continuous Emission Monitoring Rule (40 CFR Part 75). T Tnder Title IV of the Clean Air Act l^J Amendments of 1990, Congress authorized the U.S. Environmental Protection Agency (EPA) to establish the Acid Rain Program. The overall goal of this program is to significant- ly reduce sulfur dioxide (§02) and nitrogen oxide (NOX) emissions, the precursors of acid rain. To achieve this goal at the lowest cost, the Sgram will employ both traditional ^2 emissions in a cost-effective manner. (One allowance is an authorization to emit 1 ton of SO2 during or after a specified calendar year; a utility may ouy, sell, or hold allowances as part of its compliance strategy.) Complete and accurate emissions data are key to implement- ing this market-based approach. Printed on Recycled Paper. ------- Table 1 . CEM Monitor Components Required for Proposed Acid Ra Monitoring requirement (units required) SOz (Ibs/hr) NO, (Ibs/mmBtu)1 Opacity (%) CO2 (Ibs/hr)2 n Monitoring Regulations Required CEM Monitoring Component SOz Yes NO* Yes Flow Yes Yes Opacity Yes Diluent Gas Yes Yes Data Handling Yes Yes Yes Yes 1Heat input in mm/Btu/hr is also required. Alternative methods may be used to monitor CO?. An essential feature of smoothly operating markets is a method for certifying the existence of the com- modity being traded. The CEM data will, in effect, supply the "gold standard" to back up the paper cur- rency of emissions allowances. The CEM requirements, therefore, will instill confidence in the market- based approach by certifying the ex- istence and value of the trading commodity (the allowance). CEM will also be instrumental in ensuring that the mandated reduc- tions of SO2 and NOx are achieved. While traditional emissions limita- tion programs have required facilities to meet specific emissions rate limitations, the Acid Rain Program requires an accounting of the total emissions from regulated units during each year. Compliance for each unit is then determined through a direct comparison of SO2 emissions totals reported by CEM and allowances held for the unit. What Are the Proposed Monitoring Requirements? T Tnder the proposed rule, the LJ owner or operator of a unit regu- lated under Phase I or Phase II (or a unit that opts in to the program) and any new unit must install a CEM sys- tem on the unit unless otherwise specified in the regulation. A CEM system includes: • An SO2 pollutant concentration monitor. • A NOx pollutant concentration monitor. • A volumetric flow monitor. • An opacity monitor. • A diluent gas monitor. • A data acquisition and handling system (computer-based) for recording and performing cal- culations with the data. Table 1 summarizes the CEM monitors required by the proposed rule. In all cases, a data acquisition and handling system must be used to collect and report the data. To monitor SO2 emissions using a CEM system, a facility must use both an SQz pollutant concentration monitor and a volumetric flow monitor to measure the emissions in pounds per hour (the units needed to determine compliance). If the SQz monitor measures on a dry basis and the flow monitor measures on a wet basis, the owner or operator must determine the hourly moisture content of the flue gases and correct the measured flow rate for moisture using procedures specified in the rule. To measure NOX emissions, both an NOx pollutant concentration monitor and a diluent gas monitor are required to calculate an emissions rate in pounds per million British thermal units (Ibs/mmBtu). Opacity monitoring, which involves a percentage calculation, requires only an opacity monitor. (Under the proposed rule, units firing 90 percent or more natural gas with oil as the backup fuel are ex- empted from the opacity monitoring requirements.) The proposed rule does not re- quire a utility to use a CEM system to measure CQz. If a utility chooses to use a CEM system, however, a COa diluent monitor plus a flow monitor may be used to compute emissions in pounds per hour. If a CEM system is installed in such a way that any portion of the flue gases from an affected unit can bypass the monitoring system, a separate CEM system is required on the bypass flue gas stream. All CEM systems must be in con- tinuous operation and must be able to sample, analyze, and record data at least every 15 minutes. All emis- sions and flow data will be reduced to 1-hour averages. The proposed rule specifies procedures for convert- ing the hourly emissions data into the appropriate units (pounds per hour for SO? and pounds per million Btus for NOx). How Will Emissions Be Calculated for Periods of Missing Data? Four or more data points are needed to compile valid 1-houd averages for emissions flow data, ex" cept during calibration, main- tenance, repair, or other required quality assurance activity periods, where two or more data points may comprise a valid hour. Failure of the system to acquire the data points would result in the loss of data for the entire hour. The proposed rule con- tains procedures for "filling in" data when no valid hour or hours of data have been recorded by the SO2 monitor, the flow monitor, and the NOX CEM system consisting of the NOx monitor and the diluent gas monitor. The proposed rule uses a conservative approach to substitut- ing for missing data. The proposed procedures are summarized in Table 2. What Are the Requirements for Units Using a Phase I Qualifying Technology? The proposed rule specifies addi- tional monitoring requirement! for units that are implementing an optional compliance method specified under the Permits Rule that allows a unit to use a Phase I ------- qualifying technology (a system that achieves a 90-percent reduction in SC>2 emissions). Each such unit must be equipped with pollutant and diluent gas monitors to measure SOa ^missions at the inlet to the control device, in addition to the monitors required for measuring SC>2 emis- sions discharged to the atmosphere. What Are the Requirements for Multiple Units with a Common Stack? If two or more units share a common stack, the proposed rule allows the owner or operator to com- bine SO2 allowances according to the procedures outlined in the Allowance System Rule and install one monitoring system. If a Phase I and Phase II unit share a common stack, the owner or operator must either (1) install a separate CEM sys- tem in each duct leading to the stack; (2) declare the Phase II unit as a sub- stitute unit in accordance with the requirements of the Permits Rule; or (3) obtain the Administrator's ap- proval to differentiate between the ynits parametricly. F If a regulated unit and a nonregulated unit share a common stack, the owner or operator must either (1) install a separate CEM sys- tem in each duct leading to the stack; (2) declare the nonregulated unit as an opt-in unit under me Opt-in Rule; or (3) obtain the Administrator's ap- proval to differentiate the units parametricly. What Tests Are Required for Performance Certification? HPhe proposed rule requires the fol- JL lowing performance certification tests for CEM systems: • Calibration error tests for each pollutant concentration monitor, diluent gas monitor, and flow monitor capable of daily calibration tests. • An electronic stability test for each flow monitor not capable of daily calibration tests. • A relative accuracy test for each SC»2 pollutant concentration monitor, flow monitor, and the NOx CEM system. (Units with SC>2 concentrations of 250 parts per million or less, gas velocities of 10 feet per second or less, or NOx emissions rates of 0.5 Ibs/mmBtu or less are not re- quired to meet the relative ac- curacy requirement for the SO2 monitor, the flow monitor, or the NOx monitoring system, respec- tively, but must meet an alterna- tive requirement specified in the rule.) • A bias test for each SO2 pol- lutant concentration monitor, flow monitor, and the NOx CEM systems. • A cycle response test for SQz pol- lutant concentration monitors and NOx CEM sytems. • For differential pressure flow monitors, an orientation sen- sitivity test, and for ultrasonic and differential pressure flow monitors, an interference test, and calibration error tests whenever possible. • For continuous opacity monitoring systems, perfor- mance verification tests for calibration error, response time, zero drift, and calibration drift. These tests must be conducted according to the requirements of 40 CFR Part 60, Appendix B ("Performance Specification 1— Standards of Performance for New Stationary Sources"). What Are the Certification Requirements for CEMS? T Tnder the proposed rule, the EPA IteJ Administrator must certify the CEM system (CEMS) before it can be used in the Acid Rain Program. To Table 2. Summary of CEM Substitution Criteria for Estimating Values for Missing Data Periods . Annual availability (%) of monitor or system1 Greater than or equal to 95% Less than 95% but greater than or equal to 90% Less than 90% Number of hours missing (N) N 5 24 hours N > 24 hours N S 6 hours N > 6 and £ 24 hours N > 24 hours N > 0 hours Value substituted for each missing hour Average of the hour before missing period and the hour recorded after missing period 90th percentJIe value recorded in previous 30 days of service or the before/after value, whichever is greater Average of the hour recorded before missing period and the hci«r recorded after missing period 90th percentile value recorded in previous 30 days of service or the before/after value, whichever is greater 90th percentile value recorded in previous 365 days of service or the before/after value, whichever is greater. 90th percentile value recorded in previous 365 days of service or the before/after value, whichever is greater. 1SO2 and flow monitors are Individually evaluated for missing data. For NOx monitoring, the monitor system (NOx polllutant concentration monitor and diluent gas monitor) are considered In combination. NOx and flow monitoring data Is correlated to unit gross operating load before selecting the percentile values. SOz data are correlated to fuel sulfur content before selecting the pVcentlle value. ------- obtain certification, the owner or operator of a unit must submit a request to the EPA Administrator. The request must include the follow- ing information: • Unit identification. • Stack inside diameter at monitor location and stack height. • Description of CEMS and con- tinuous opacity monitoring sys- tem (COMS) installed. • Results and date of each perfor- mance verification test for cer- tification. • Supporting documentation to substantiate the test results. • Calculations to verify that the data acquisition and handling system properly calculates and converts the recorded emissions data into units of the standard. EPA will issue a notice approving or disapproving the request for cer- tification within 120 days. If the proposed system is disapproved, the owner or operator must revise the equipment, procedures, or methods as necessary and resubmit a request for certification. What Quality Assurance/ Quality Control Procedures Are Required? The proposed rule requires the owner or operator to develop and implement a written quality as- surance/quality control plan for each system. This plan must be sub- mitted as part of the utility's acid rain permit application. The quality con- trol plan must include complete, step-by-step procedures and opera- tions for calibration checks, calibration adjustments, preventive maintenance, audits, and record- keeping and reporting. The proposed rule specifies procedures for assessment of calibration error, relative accuracy, and bias. The quality assurance plan must in- clude relative accuracy test audits, calibration error tests, and bias tests. What Alternative Monitoring Systems Are Allowed? he owner or operator of an af- fected unit may apply to the T EPA Administrator for approval of an alternative monitoring system to determine hourly emissions data for SO2, NOx, and/or volumetric flow. An alternative system must provide the same or better precision, reliability, accessibility, and timeliness as a certified CEM system. The owner or operator must submit certain information and data to demonstrate that the alternative system meets these criteria. The proposed rule includes an exception for units fired 90 percent or more by natural gas because emissions from the 525 units in this category emitted only about 7,600 tons of SO2 in 1985. These units may use in-line oil flow meters and oil sampling and analysis to es- timate tons of SQz emitted. Units burning greater than 10 percent oil may also use this approved, ex- cepted method, although they must sample the oil hourly using flow- proportional or continuous drip methods. This exception is based on a combination of factors: (1) the relative ease of obtaining oil samples; (2) the fact that oil is much more homogeneous in sulfur con- tent than coal; and (3) the approved oil sampling and analysis methods produce SO2 emission estimates consistently higher than actual CEM data. What Are the Recordkeeping, Reporting, and Notification Requirements? The CEM rule proposes requirements for notification, recordkeeping, and reporting for the Acid Rain Program. The require- ments include: • Submission of monitoring plans as part of the compliance plan and permit required under the Permits Rule. • Written notifications of monitor certification tests. • Daily recording of hourly emis- sions data and other informa- tion. • Maintaining records of emis- sions, flow data, and other in- formation. • Initial and quarterly reports of quality assurance and quality control tests for the CEM system. • Reports of recorded emissions, flow, unit operating status, and monitoring performance data. The proposed rule also requires the owner or operator to electronicaa ly report the required information on a quarterly basis as an ASCII flat file via either an IBM-compatible per- sonal computer floppy diskette or a modem. EPA will use the information to determine compliance with the emissions reductions mandated by the Clean Air Act. What Are the Deadlines for Compliance? The proposed rule applies to ex- isting units regulated under Phase I or Phase II of the Acid Rain Program, and to each new utility unit when it begins its operation. (A "new unit" is a defined as a unit that begins commercial operation on or after November 15, 1990.) Equipment required by the proposed rule must be installed, certified, and operational by November 15, 1993, for Phase I af- fected units, and by January 1,1995, for any Phase II units. A unit that formally commits to retiremei^ before December 31, 1994, will flQ exempt from the requirements of the proposed rule. For More Information more information, write to: U.S. EPA Office of Air and Radiation Acid Rain Division (ANR-445) Washington, DC 20460 If you would like to receive other fact sheets in this series, call the Acid Rain Hotline at (617) 641-5377 or the EPA Public Information Center (PIC) at 202-260-2080. Fact sheets are available on the fol- lowing subjects: • Allowance System • Environmental Benefits • Excess Emissions • Permits • Proposed Acid Rain Rules ------- |