J. Ron Jernigan, P.E., DEE
RMB Consulting & Research, Inc.

Abstract

Since the promulgation of the Acid Rain Regulations required by the Clean Air Act Amendments of 1990, the electric utility industry has installed and certified over 1,500 new CEM systems according to the regulatory requirements of 40 CFR Part 75 (Part 75). During this period numerous sampling problems have been encountered. Also, during this period, emission sampling equipment technology and new monitor reliability has continued to advance. Less reliable, problematic, and high maintenance continuous emission monitoring (CEM) equipment is being identified by most utilities. Additionally, some utilities are trying to identify future replacement equipment or sampling technologies. Many utilities are currently evaluating replacement CEM equipment and other utilities are expected to consider replacement equipment soon. EPRI's "Continuous Emission Monitoring Guidelines 1999 Update" Document will provide the utility industry CEMS users beneficial information regarding operation and maintenance of existing CEMS, as well as, information on issues to consider when replacing CEMS equipment and software. This paper will discuss the status of the development of this document and will describe significant information found in the document.

Introduction

Over the past twenty-five years, the application of CEM technology has become one of the most critical and demanding environmental programs within the electric utility industry. Throughout this period, the utility industry has been repeatedly challenged with increasingly complex Part 75 continuous emission monitoring regulations that have become entangled among a host of other federal and state statutes. Confounding utility industry efforts to struggle with this constantly changing regulatory maze is the requirement to understand and apply the rapidly changing, highly sophisticated technology which the Part 75 regulations rely. Basically, the utility industry has been forced to deal with the rapid, interrelated, parallel evolution of complicated CEM regulations and monitoring technologies.

In the early 1980s, the Electric Power Research Institute (EPRI) recognized the need for direction regarding the regulatory requirements and available CEM technologies. Accordingly, EPRI began publishing a series of guidance documents for use by its member utilities. Each document in the series contains comprehensive technical, administrative, and regulatory information (current as of the date of publication) believed to be essential in developing and implementing successful and cost-effective CEM programs. This document, (1999 update) the sixth publication in EPRI's CEM guideline series, is intended to:

• Update EPRI’s existing 1993 CEM Guideline Document to reflect the current installations and practices resulting from the recent Acid Rain Regulations.
• To summarize the most recent final Part 75 CEM regulations.
• Incorporate the results of completed and on-going EPRI investigations of sampling and measurement problems encountered by utilities and information on successful resolution of these problems.
• Document the current state of new technology improvements and emerging technology with contributions from manufacturers of continuous emission analyzers and sampling equipment.

Contents Of 1999 CEM Guideline Document

The 1999 CEM Guideline Document will contain, but is not limited to, the following section topics. This paper will briefly discuss, on a section by section basis, the updated information to be added to the 1999 CEM Guideline Document. From this point on the two CEM Guideline documents will be referred to as; 1999 Document and 1993 Document.

DOCUMENT SECTION DESCRIPTION

1. Introduction

The Introduction section in the 1999 document will give a brief explanation of the information in the updated 1999 document.

2. Summary of Part 75 CEM Regulations

There have been numerous amendments to Part 75 CEM regulations since the publication of EPRI’s 1993 document. This section will summarize the major CEM regulations and discuss the CEM rule revisions contained in the April 1999 final amendments to Part 75 CEM regulations. Additionally, any CEM regulation identified as problematic to implement, or that appear ambiguous to the utility CEM users will be discussed and guidance will be given where applicable. The 1993 document’s Section 3. Comparison of Part 75 Requirements with Other Regulations will be omitted from the 1999 document and a table of applicable comparisons will be added to the end of Section 2.

3. Part 75 Appendix D & E Requirements

This will be a new section that will emphasis the major monitoring and QA/QC requirements for those units subject to Appendix D & E requirements under the Part 75 regulation. This section will include information on the most widely used fuel flow meter technologies and their specific calibration requirements. This section will include for the major fuel flow meter technologies, detailed guidance for fuel flow meter certification and periodic calibrations.

4. Administrative Considerations

Administrative Considerations was also Section 4 in the 1993 document. This section will be updated in the 1999 document with new issues such as procurement of replacement or new CEMS with emphasis on lessons learned since 1993. Also, discussed with be considerations for installation and certification with emphasis on information learned since 1993.

During the past two to three years, the utility industry in general appears to be placing emphasis on reducing the manpower and man-hours required for operation and maintenance of their Part 75 CEMS without sacrificing data quality and data availability. Accordingly, routine operation and maintenance will be discussed with emphasis on economical quality assurance and quality control (QA/QC) programs. The 1993 document’s Section 8. Continuous Emission Monitoring System Procurement Installation and Start Up, will be deleted from the 1999 document, however, relevant information on the management of CEMS procurement will be retained and added to the updated Section 4. Administrative Considerations.

5. Continuous Emission Monitoring Technologies

Continuous Emission Monitoring Technologies was also Section 5 in the 1993 document and will be updated extensively in the 1999 document. The advances in CEMs, flow monitoring, and data acquisition and handling systems will be discussed in much detail. Emphasis will be placed on the equipment predominately used by the electric utility industry. A statistical comparison of the different CEMS measuring techniques, gas emission and flow rate monitors used in the acid rain program will be provided.

This section will describe in detail and discuss the following:

• Sample Acquisition Techniques,
• Gaseous Monitoring Analytical Techniques,
• Flow Monitoring Analytical Techniques,
• Commercially Available Gas Emission and Flow Rate Monitors Used in the Acid Rain Program, and
• Data Acquisition and Handling Systems

Advances in CEM technologies and any emerging technologies that may benefit the electric utility CEM user will be discussed.

6. Data Reporting and Recordkeeping

This will be a new section that will discuss electronic data reporting (EDR) requirements and list on-site recordkeeping needs. Emphases will be placed on discussing the new requirements in EDR Version 2.1, which replaces Version 1.3 beginning on April 1, 2000.

7. Monitor Location and Application-Specific Considerations

Monitor Location and Application-Specific Considerations were Section 6 and 7, respectively, in the 1993 document and each section will be reviewed and rewritten to combine the two sections. Relevant information learned during the first six years of monitoring under the acid rain program will be added to this section. This section will be useful for selecting monitor locations for new CEMS and for evaluating the representatives of existing monitoring locations.

8. Operation and Maintenance

Operation and Maintenance was Section 9 in the 1993 document. It will be reviewed and rewritten to reflect current operation and maintenance requirements and provide information learned from several EPRI studies.

9. Quality Assurance Manual Development

Quality Assurance Manual Development was Section 10 in the 1993 document. It will be reviewed and rewritten to reflect current Part 75 quality assurance plan requirements. This section will also discuss the latest quality assurance requirements promulgated in the April 1999 final revisions to the Part 75 CEM rule.

10. NO_x Trading Programs

This will be a new section that will discuss the various NO_x trading programs such as; NO_x SIP Call, Ozone Transport Assessment Group (OTAG) and Ozone Transport Commission (OTC) NO_x Budget Program as they apply to the electric utility industry.

In Summary

The EPRI "Continuous Emission Monitoring Guidelines: 1999 Update" is designed to help current Part 75 CEM users operate and maintain a successful cost-effective CEM program. A successful CEM program depends on a sound understanding of current applicable CEM regulations and the basic and emerging technologies for measuring emissions levels. Additionally, this document will help utility CEM users to economically select, install, operate and maintain replacement and new CEM systems.