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U.S. EPA Compliance Background
The U.S.EPA requires that each and every analyzer installed as a CEMS ("continuous
emissions monitoring system" for compliance monitoring and reporting) must be tested
following installation [Certification Test] to verify compliance with the applicable
Federal Standards and Regulations, which includes, but is not limited to 40 CFR Part 60,
Appendix B [Instrument Performance Specifications]; 40 CFR Part 60, Appendix F [Quality
Assurance Procedures]; and/or 40 CFR Part 75 [Continuous Emission Monitoring], the
"Acid Rain" rules. In addition, performance specs require that the
equipments zero and span drift must be checked daily to verify that it continues to
operate within specifications.
Explanation
The EPA does not issue a "blanket" approval of an analyzer Model type for
continuous flue gas emissions monitoring; but rather, each and every installation must be
individually tested, on site, in the specific application and environment, to verify
compliance, and the installation must be retested annually, for its lifetime, to verify
continued compliance.
Initial CEMS Certification Test: Generally the plant will
arrange for the test, and will coordinate with a similar set of tests on the combustion
source as well as the control hardware (but sometimes the plant will also contract the
CEMS testing with the CEMS supplier). An independent third-party testing company will
bring their equipment to the site and will perform a series of EPA reference tests on the
flue gas emissions, for a minimum of 9 tests (for instrument certification). The average
of these tests is compared with the average a report for the plant to submit to the
regional EPA office. Examples of such test reports are available upon request.
Approval
The resulting EPA approval is an approval to the plant that they can operate their
facility, as long as the tested CEMS continues to operate properly [within specifications,
i.e. daily drifts; % data collection (under Part 75); quarterly relative accuracy {RA}
checks (under Part 60 App F); etc]. If the equipment does not meet the specs, it must be
repaired, retested, and pass; or it must be replaced with another system that does pass.
Approved Installations Equipped with AIM Analyzers
There are many approved installations equipped with AIM analyzers, both the in-situ as well as the extractive Model
.... and probably more importantly, no installations where AIM has failed the test
and been replaced with another analyzer. AIM EPA Compliance installations have included municipal waste incinerators, hazardous waste incinerators, hospital waste
incinerators, fluidized bed boilers and incinerators, industrial boilers and utility
boilers; measuring Opacity, O2, CO, CO2, NOx, NO, NO2, SO2, THC, HCI, and H2O, with
Data Acquisition & Reporting.
Daily Drift Checks
40 CFR Part 60, Appendix B requires each CEMS zero and span drift be checked daily.
Both negative and positive drifts must be measurable. Zero is the instrument response with
no sample, and span is typically 90% of range (with the range set at 150 to 250% of the
emission limit). If out of spec, appropriate action must be taken [refer to AIM Field QC
Program Manual, rear of the O&M Manual]. All AIM systems offer the ability for
automatic calibration check and data logging. [One of the benefits of the in-situ Model
E-6000 is that the accepted EPA daily drift checks do not require the use of calibration
gases
a significant operating cost reduction. The system always includes an internal
zero mirror and reference span filters which automatically sequence into the beam at a
preprogrammed interval for the daily drift check. (EPA requires this check every 24 hours.
Other agencies might require more frequent check; and some local agencies require the use
of gases, either daily or monthly.)]
The drift is computed by the system controller, as the
difference between the measured value and the initial value. This drift data is stored in
memory, and can be accessed through the operator interface, and summarized in the optional
DAS report.
NOTE In the US, the local agencies are allowed to required
more stringent requirements than the EPA requirements, if they desire. In several regions,
including So. California, as well as New England, New York, Now Jersey, and Pennsylvania
the daily zero and span drift checks must be performed with cylinder gases. In this case,
for the in-site systems, the optional internal audit cell [used for the quarterly relative
accuracy audits] is used for the daily calibration checks also (see CGA below).
The extractive system [Model 5000, 7100, 7200, FTIR, etc]
analyzers are calibrated in the classical way, either manually or automatically under the
PC control. The calibration gas is inserted at the sample probe be opening a solenoid
valve. The cal gas rather than sample flows through the system and through the sample
cell.
Quarterly Relative Accuracy Checks [Cylinder Gas Audits,
CGAs]: Reference standard [EPA Protocol] cylinder gases (typically located outdoors at
ground level) flow through the in-situ internal audit cell and/or the extractive sample
cell, for the quarterly cylinder gas audits. Mixed/blended gases can be used to reduce the
calibration cycle time.
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