### SOUTH COAST

### AIR QUALITYMANAGEMENT DISTRICT

Staff Report for Proposed Amended Rule 218

## - Continuous Emission Monitoring and Proposed Rule 218.1 

## - ContinuousEmission Monitoring Performance Specifications

Deputy Executive Officer Science & 

### Technology Advancement Chung Liu, D.Env.



### Asst. Deputy Executive Officer Science & 

### Technology Advancement Melvin D. Zeldin



### Manager Monitoring & 

### Source Testing Engineering JohnHiguchi



### Supervising Engineer Monitoring & 

### Source TestingEngineering SteveMarinoff

Author: Rarniro Gonzalez, Jr. Senior Air QualityEngineer Monitoring & SourceTesting Engineering

Date: April 9, 1999

### SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT GOVERNING BOARD

Chairman: WILLIAMA. BURKE, Ed.D. Speaker ofthe Assembly Appointee

Vice Chairman: NORMA J. GLOVER Cities Representative,Orange County

Members:

MICHAELD. ANTONOVICH Los Angeles County Representative

HAL BERNSON Cities Representative, Los Angeles CountyIWesternRegion



### . CYNTHIAP. COAD Orange County Representative

BEATRICEJ.S.LAPIST0-KIRTLEY Cities Representative, Los Angeles CountyiEasternRegion

MEEHAE LEE SenateRules Committee Appointee

RONALD 0.LOVERIDGE Cities ~epresentative, Riverside County

JON D. MIKELS San Bernardino County Representative

LEONARD PAULITZ Cities Representative, San BernardinoCounty

S. ROY WILSON, Ed.D. Riverside County Representative

VACANT Governor's Appointee

Executive Officer

BARRY R. WALLERSTEM, D.Env.

### TABLE OFCONTENTS



### I. EXECUTIVE SUMMARY


### I1 BACKGROUND



## m. SUMMARY OF PROPOSED

### AMENDMENTS TORULE 218



### IV. SUMMARYOFPROPOSEDRULE 

### 218.1

V. 

### IMPACTS

VI. COMMENTS



### VII. ATTACHMENTS

Attachment 

### A

# - Summary ofPublic Comments

Attachment B 

### -List ofPublic Comment Letters Received

Attachment C 

## - Socioeconomic Assessment Report

VIII. APPENDICES Appendix

### A

## -Technical Guidance Documents Appendix B

## - Guidelines to Rule

### 218 CEMSQuality Assurance and Quality Control Plan Appendix C

## - Sample CEMSQAIQC Plan

## - I. EXECUTIVE SUMMARY

The South Coast Air Quality Management District (AQMD) has various rules, regulations and permit conditions that require the installation and use of continuous emission monitoring systems (CEMS) as 

### a means to determine source compliance. One of these is Rule 218

## - StackMonitoring (R2

### 18) which provides administrative guidelines and technical specificationsfor the approval of stack monitoring systems that are required for specified sources of oxides of nitrogen (Nod, sulfur dioxide (SO,), carbon dioxide (CO,) and carbon monoxide (CO). Currently,this rule covers twenty-four (24) existing certified CEMS and thirty-five 

### (35) CEMS that are in the process of obtaining final approval by AQMD. The practical applicability of CEMS technology for regulatory compliance is increasingly being recognized by AQMD as

### well as 

### by other regulatory agenciesin the federal, state and local levels.
Staff proposes to divide the administrative and technical provisions of the current Rule 218 into two separate rules, Proposed Amended Rule 218 

### - Continuous Emission Monitoring (PAR218) and Proposed Rule 21 8.1 1

## - Continuous Emission Monitoring Performance Specifications (PR218.1). PAR2 1 8 defines the applicability and specifies the administrativerequirements for continuous emission monitoring including the application and approvalprocess for CEMS, the option to choose alternative performance specifications, compliance dates, and record retention and reporting. PR218.1 specifies CEMS certification, performance specifications, and technical requiremehts for CEMS operation and maintenance. PAR218 and PR218.1 will apply to all sources for which CEMS are required in AQMD regulations or permit conditions, except as stated below. Examples where PAR2 18 and PR218.1 apply are CEMS that are required under Rule 1 110.2 

# - Emissions from Gaseous- and Liquid-Fueled Internal Combustion Engines, Rule 11 34

## - Emissions of Oxides ofNitrogen from Stationary Gas Turbines, Rule 1 135

## - Emissions of Oxides of Nitrogen from Electric Power Generating Systems, and Rule 1146 

### - Emissions of Oxides of Nitrogen from Industrial Institutional, CommercialBoilers, Steam Generatorsand Process Heaters.
Proposed amended Rule 218 will delete obsolete language, clarify administrative requirements, and delete the CEMS performance specifications in the rule. Proposed Rule 218.1 will revise and identify these CEMS performance specifications to meet AQMD requirements for approval. Both PAR21 8 and

### PR218.1 would not apply to CEMS under Regulation 

### XX 

### - Regional Clean Air Incentives Market (RECLAIM), Regulation 

### XX 

### - New Source Performance Standards (NSPS), Regulation 

### X 

## - National Emission Standards for Hazardous Air Pollutants (NESHAP), and Regulation 

### XXI 

### - Acid 

### Rain Permit Program (Acid 

### Rain).

At the direction of the Stationary Source Committee, staff requested EPA Region 

### XX to review the proposed amendments to Rule 218 and newly proposed Rule 218.1, with respect to conformity with Title 

### V. The specific issues were theinclusion of the absolute de minirnus values for Relative Accuracy 

### (RA) performance specifications and alternative quality assurancerequirements,and their impact on stringency relative to federal requirements under 40CFR60, Appendices 

### B and F.

EPA Region 

### IX expressed concern over how emission limits in the lower ranges would be enforced and originally agreed to the use of a de-minimus absolute performance specification provided that the AQMD commit to developing written guidelines on how enforcement would be handled where low emission limits are an issue. However, upon concurring with the efficacy of addressing measurements at

or near the lower limits of current technology, the availability and accuracy of low concentration of calibration gases, and the degree of precision of the reference methods at low concentrations, EPA subsequentlyeliminated the written guideline requirement and approved the use of PR218.1 absolute de minimus relative accuracy specifications.

Staff has reviewed PAR218 and PR218.1and has determinedthat the proposals are exempt fiom the requirements of California Environmental Quality Act (CEQA). Staff has concluded with certainty that the proposals will not have a significant adverseimpact on the environment and has prepared a Notice of Exemption (NOE) pursuant to state CEQA Guidelines Section 15061(b)(3) 

### - Review for Exemption (AQMD Guidelines Section 5.1) and Section 15308 

### - Actions by the Regulatory Agencies for Protection of the Environment (AQMD Guidelines Section 19.12) The NOE will be filed with the local county clerks inirnediately following the adoption of the PAR2 18 and PR218.1. Staff has prepared an assessment of the socioeconomic and cost impacts that are associated with PAR2 18 and PR218.1, and this isprovided in 

### Attachment C.11. 

### BACKGROUND The AQMD Governing Board adopted Rule 218 

## - Stack Monitoring, on January 9, 1976 which requires continuous stack emissionmonitoring ofNO,, SO,, CO, andlor CO discharged fiom sources such as power plants, refineries, sulfuric acid plants and nitric acid plants. The rule has been amended four times to provide procedural clarity and facilitate enforcement. The most recent amendments to Rule 

### 218 were adopted in August 7, 1981. These amendmentswere purely administrativeinnature and did not affect any increase or decreasein contaminantemissions.

Since the last amendments, the development and progress in source specific rules, the recent adoption of RECLAIM and the advancement in continuous emissions monitoring technology have made most of Rule 218 administrative provisions and many of the technical requirements obsolete and outdated. Proper CEMS installation, testing and certification, subsequent operation and maintenance, advances in calibration gas integrity, and the computerization of data acquisition, recording and reporting are just some of the issues that warrant delineation of requirements to provide CEMS with better operational and output reliability. Also, through the implementation CEMS quality assurance and quality control programs (QNQC), the CEMS is adequately managed to produce good quality assured data and achievehigh system availability.
AQMD staff, recognizing the deficiency or inapplicability of several R218 provisions, is proposing amendments that will provide specific administrative and technical guidelines to provide clarity for review, certification, approval and operation of CEMS. In essence, the proposals identify the requirements, intent and standards in CEMS certification and performance by providing well-defined specifications and guidelines to eliminate ambiguity in both the technical and administrative provisions of the rule. The deficiencies in guidelines have led to varying rule interpretationsby the regulated industry 

### with staff implementation of Rule 218 CEMS requirements. The proposed administrative requirements and performance specifications are more consistent with current CEMS standards contained in otherregulations with similarrequirements.

### Public comments and clarifying questionswere raised at the initial public workshop

on March 25, 1998. A consultation meeting on June 11, 1998 followed to provide feedback to key contacts and interested parties regarding staff responses to the public comments. A second public workshop was held on August 26, 1998 to discuss the revisions and changes to the proposals following the consultation meeting. Another cosultation meeting was held on April 2, 1999 to discuss and receive comments on the changes made in response to EPA Region 

### M co'mments and recommendations. Attachment A to this staff report lists and summarizes the public comments and staffresponses.

111. 

### SLMMARY OFPROPOSEDAMENDED RULE 218 

### The basic intent of amending Rule 218 is to clarify and revise both the administrative and technical provisions. PAR21 8 contains administrative provisions and PR218.1 contains the performance specifications and technical requirements. Some provisions of Rule 218 

### have been deleted or revised, as appropriate. PAR218 include the foIlowing major sections: Definitions, Applicability and Requirements, Application qnd Approval for New or Modified 

### CEMS and SCEMS, Requirements for existing CEMS and SCEMS, Quality AssuranceIQuality Control Plan, Retention of Records, Reporting, and Posting of Written -4pproval.

A. Rule Title 

### - Continuous Emission Monitoring The proposal amends the rule title from "Stack Monitoring" to "Continuous Emission Monitoring". The proposed titIe is more appropriate with the applicability of the provisions of PAR218 and more consistent with other regulations of similar requirements and intent. The requirementsfor monitoring of emissions to enforce source compliance with emission standards are no longer limited to the monitoring of contaminant concentration in the stack. As in the case of Rule 43

### 1.l, sulhcontent of gaseous fuels are measured before burning.

B. 

### Definitions All the definitions in Rule 218have eitherbeen deleted or revised while several new terms have been defined. All terms related to the performance

### specifications and technical requirements have been deleted and incorporated in PR218.1. The new defmed terms include: certified CEMS, continuous monitoring, CEMS, data acquisition system (DAS), Laboratory Approval Program (LAP), modification requiringrecertification, quality assurance/quality control (QAIQC) plan, semi-continuous emission monitoring (SCEMS), and working day. The definition for CEMS has been expanded to include the total combined equipment required for the continuous determination of contaminant and diluent emissions, mass emission, fuel flow and/or stack gas flow rates as applicable. CEMS consists of three major subsystems: sampling interface, analyzer and DAS.

A major component of the proposed amendment is the definition for "continuous monitoring". Continuous monitoring is defined as a minimum of

one measurement taken and recorded each minute and where 15 or 60 minute averages may be required. Semi-continuous emission monitoring is a monitoring technique in which a minimum of one measurement is taken and recorded every 15 minutes. One measurement may be of concentration, mass



# -- emission rate, stack gas flow rate and/or fuel flow rate. As further discussed ( 

### below, an application for SCEMS may be submitted in lieu of CEMS. It is important to note in the duration ofthis report that, unless otherwise stipulated, the requirements, specifications and standards for CEMS shall al'so apply to SCEMS.

C. Applicability PAR2 18 applies to all CEMS that are required or specified in AQMD rules and regulations including permit conditions. Examples are CEMS that are required under Rule 11 10.1 

## - Emissions fiom Stationary Combustion Engines, Rule 1 110.2 

### - Emissions fiom Gaseous- and Liquid-Fueled Internal Combustion Engines, Rule 1134 

## - Emissions of Oxides of Nitrogen from Stationary Gas Turbines, Rule 1135 

## - Emissions of Oxides of Nitrogen from Electric Power Generating Systems, and Rule 1146 

## - Emissions of Oxides of Nitrogen from Industrial Institutional, Commercial Boilers, Steam Generators and Process Heaters.

PAR218 does not apply to CEMS under RECLAIM, NSPS, NESHAP, Acid Rain, and permit conditions where the CEMS is mainly to monitor theperformance of the equipment (basic or control) being served 

### and not to determine compliance with any applicable limit or standard. The rule does not apply to CEMS where alternative performance specifications are stipulated.

It is not the intent of PAR218 to expand its applicability to include any equipment which are not currently covered by the Rule 218, nor to mandate additional monitoring devices other 

### than those required by a rule or 

### a permit condition. Similarly, the rule does not apply to systems where .only a flow meter or a continuous oxygen analyzer (not a contaminant analyzer) is required by a permit under which contaminant emissions are calculated fiom emission factors or test data. PAR21 8 will not supercedethe permit conditionto require a contaminant analyzer.

D. CEMS Application and Approval for CEMS and SCEMS PAR218 requires the owner or operator of any CEMS subject to the rule to submit an "Application for new CEMS or CEMS Modifications". 

### An initial approval from the Executive Officer is required before the installation of the

new CEMS or performing any modificationto an existing CEMS, as applicable. The Executive Officerwill notify the applicant within 60 calendar days (for new CEMS) or 30 calendar days (for modified CEMS) from the receipt of the application that is deemed complete. Should the Executive Officer require additional information to complete the application, a new 30-day period from the receipt of any resubmittal or additional information requested shall begin. 

## - During this period, the Executive Officer will notify the applicant regarding the completeness of the application.

Upon submission of an "Application for new or Modified CEMS", the owner or operator is provided an option to choose the set of performance specifications and requirements for the technical review, approval, certification, and operational requirements the new or modified CEMS will be subject to. The applicant may choose either the standards and specifications that are provided according to the provisions of PR 218.1 

### - Continuous Emission Monitoring Performance Specifications, or, according to the applicable provisions of the Code of Federal Regulations, Title 40 

### - "Protection of Environment",Part 60 

### - "Standards of Performance for New Stationary Sources" (40CFR60),Appendix 

### B 

## - "Performance Specifications" (Appendix 

### B) and the requirements of

### 40CFR60, Appendix F 

### - "Quality Assurance Procedures" (Appendix F). Table 1 of this report provides a comparison of the administrative and technical requirements ofthe currentRule 

### 218,PR218.1and 40CFR60 Appendices 

### B and F. The table also compares the stringencyofeachrule against PR2 18.1.
Notwithstanding these requirements, any alternative test methods for 40CFR60, Appendices 

### B and 

### F will be .those that are listed 

### in PR218.1, Table 1 

## - Reference Methods.

The standards, requirements and performance specifications of PR218.1 or 40CFR60 Appendices 

### B and F, 

### as applicable, will be referred to as "New Standards" for the duration of this report. "New CEMS or SCEMS" includes those CEMS 

### with applications that were submitted to the Executive Officer on or after May 14, 1999. "Modified CEMS or SCEMS" include all CEMS or SCEMS, after certification and approval, is subjected to modifications requiring recertifications. Modification requiring recertification is further discussed below.

The CEMS owner or operator is required to notify the District at least 14 days before the scheduled certificationtests. Thetest report 

### must be submitted to the Executive Officer no later than 45 days upon completion of the tests. Only those testing laboratories or fms that are approved under the AQMD Laboratory Approval Program (LAP) are authorized to perform CEMS certification and other performance tests. LAP is a program administered by AQMD that grants test method-specific approvals to private testing laboratories

or hs to perform tests to determine source compliancewith AQMD rules and regulations. The certification tests are to be performed no later than 90 days after the CEMS installation. If the equipment being served by the CEMS is not operating at the end of the 90-day period, the certification tests must be performedno later than 60 days fromthe start-up ofthe equipment.

After certification and final approval, any CEMS that is subjected to a modification requiring recertification will require approval from the Executive Officer. Modification requiring a recertification is any change to the basic equipment, control equipment, contaminant concentration, interfering substances, or CEMS, that has a potential for adversely affecting the ability ofthe CEMS to provide accurate, precise and timely data representative of the emissions for which the CEMS isrequired. Examples ofmodification requiring

arecertification are as follows: a) Modification ofbasic equipmentor basic process that results in theneed to change a CEMS range. b) Modification of basic equipment orbasic process that results in a change in the gas matrix that could interfere

### with the detection and quantification ofthe species of interest. c) Replacement of a complete monitor.

The Executive Officer will review and approve modifications made to the CEMS and, depending on the assessment, may require all or a portion of the performance tests to be conducted. The Executive Officer will assess how the modification to the CEMS will affect its intesty to generate quality assured data. Any modifications following the AQMD Technical Guidance Document #ROO2 

### - Quality Assurance Requirements for CEMS Modification (see Appendix A) will not require recertification. This guidance document provides specifics regarding the changes or modifications to CEMS technology, equipment, parts, design, model, etc., and the corresponding required tests to assess the CEMS ability to generate good, quality assured data. It also includes both identical (such as same model, temperature setting, operation and maintenance requirements) and non-identical replacements. This document is the prevailing reference for CEMS modification at this time. Staff anticipates that, as CEMS technologies progress, revisions to this document are inevitable such that the most recent version of the guidance document will be the prevailing reference at that time.

An application for a semi-continuous emission monitoring system (SCEMS) may be submitted in-lieu of an application for CEMS. An owner may submit an applicationfor SCEMS if: a) the averaging time for the applicable limit(s) for which the CEMS is required is 24 hours or greater; or, b) ifthe owner or operator ofthe equipment for which the CEMS is required, demonstrates that no CEMS technology is commercially available for the applicable contaminant and the applicable limits.Ifthe conditions in (a) andlor (b) above do not apply, the owner or operator may still chooseto submit an application for SCEMS subjectto the following: a) the owner or operator demonstrates that the concentration andlor emissions required to be monitored would 

### be equivalent to those monitored by a CEMS for the applicableaveraging period; b) the SCEMS is capable to take and record a 

### minimum of one measurement of the pararneter(s) of interest every fifteen minutes with data points 

### as equally spaced aspractical; c) the owner or operator provides in the QAIQC plan the method of calculation to be used in determining the 15 minute averages for complianceto the applicablelimit(s); d) the owner of operator accepts the condition that ifthe allowable limit(s) is exceeded using fewer than 100% valid data points, the AQMD will use any relevant operational or process data to verify the calculated exceedance; e) if a time-shared CEMS is proposed, it must meet the standards for timeshared CEMS in accordance with PR218.1.

E. Requirements for Existing CEMS and SCEMS Existing CEMS and SCEMS include previously certified CEMS and SCEMS, and also those for which applications for initial approval were submitted to the Executive Officer before May 14, 1999. Existing CEMS and SCEMS will continue to be subject to the performance specification standards of the current R218, now incorporated in PR218.1 sections (c) & (d), 

### as referenced in PAR218. The standards to which existing CEMS and SCEMS are subject to will be referred to 

### as "Old Standards" for the duration of this report. And, 

### as mentioned in an earlier section of this report, all requirements for CEMS will also applyto SCEMS, unless otherwise stated.

The proposals require that existing CEMS must comply with the "New Standards" no later than May 14, 2006, which is seven years from the adoption of the proposed amended rule. The proposals provide several means for the CEMS to meet or waive the requirementsby the compliance date. The owner or operator may choose to replace, unreliable existing CEMS with a new system, or modify the existing CEMS, to meet the "New Standards". The owner or operator of a CEMS that meets the "New Standards" without requiring amodification may submit a certification, signed by an authorized representative of the source, to that effect. Another option is to submit an application for a waiver. These options are further discussed below.

Upon recommendation from the U.S. Environmental Protection Agency (EPA), the proposal includes a requirement for existing CEMS to have a written CEMS Quality Assurance Plan on record and implemented on or before May 14,2000. The plan must be available to the Executive Officer for inspection upon request.

When a modification requiring a recertification is made to an existing CEMS before the compliance date, an "Application for Modified CEMS" must be submitted with the corresponding fee as required in Rule 301 at least one year before the compliance date. This will allow sufficient time for staff to review the application, address changes or request for additional information, as appropriate. The application will be evaluated and approved based on the "New Standards" (e.g., 40CFR60 App. 

### B & F or PR218.1 performance specifications

as opted by the applicant). The AQMD will consider each existing CEMS modification on a case-by-case basis and may require all or only a portion ofthe performancetests to be conducted.
For existing CEMS that meets the "New Standards" without modification requiring recertification, the owner or operator must submit a certification to that effect, signed by an authorized representative ofthe facility, one year before the date on which the existing CEMS must comply with the "New Standards". When a modification(s) is made 

### in accordance with AQMD's Technical Guidance Document #R002, recertification is not required. However,the owner must submit to the Executive Officer a "Notification of Pre-Approved Modification" and a report ofresults ofthe prescribed quality assurance checks, in-lieu of an "Application for CEMS Modification".

For existing CEMS that provides proven good quality, consistent data that is
commensurate with the original performance specificationsinchding other data quality factors, the owner may elect to submit an application for waiver to the compliance date requirements every three years after May 14, 2006. In this regard, AQMD will consider the following data quality factors to evaluate CEMS performance:a) Relativeaccuracy b) Calibration error c) Calibration

### drift d) Zero 

### drift e) Valid datareturn percentage 

### f) Availability or up-time percentage 

### g) Breakdown frequency and duration,and 

### h) Excursions beyond quality control limits.

This waiver provision of the PAR2 18 will not apply to existing CEMS that are made to comply with the "New Standards" as a result of CEMS modification requiring recertification, rule implementation or compliance with a permit condition.



### F. Existing Time-Shared CEMS PAR21 8 allows existingtime-shared CEMS to comply with the "Old Standards" indefinitely until a modification requiring a recertification occurs. Modificationsmay be necessary as a result of a new monitoring range for one or more ofthe sources served by the CEMS, or, a source specific rule is amended

or the operating permit is modified such that the continuous monitoring requirement must be satisfied. If a modification occurs, then it will be required to meet the "New Standards". 

### In order that time-shared CEMS will satis6 the definition of continuous monitoring, a new CEMS or a replacement of 

### aportion of the CEMS (i.e., analyzer) may be required in most situations. Otherwise, a SCEMSrequirement may apply. Each situationwill be evaluated on a case-bycase basis.



### G. Quality AssuranceIQuality Control (QNQC)Plan QNQCprograms will ensure the reliability of the data generated by the CEMS to meet regulatory requirements. The current Rule 218 does not implicitly provide for CEMS QNQC. Basically, QNQC programs are not new requirements. The AQMD, in implementing CEMS, has put the responsibility on the source for CEM performance and has recommended a minimum QNQC program to achieve the specified levels of performance. Some source specific rules (e.g., Rule 1 110.2, Rule 1 134, and Rule 1135) speci6 that CEMS must

### comply with the QA requirements of 40CFR60 Appendix 

### F. Owners or operators of new or modified CEMS electing the performance specifications of 40CFR60, the quality assurance requirements of Appendix F will apply. If the owner or operator of the CEMS elects the performance specifications of PR218.1, PAR218 will require CEMS owners or operators of new or modified CEMSto submit a QNQCPlan within 90 days after the CEMS installation (or modification) and no later than 30 days before the certification test. The QNQC Plan will be reviewed for approval according to the "Guidelines for Rule 218 CEMS Quality Assurance/Quality Control Plan" (see appendix 

### B), before a CEMS certification is granted. After approval, any changes or revisions to the QNQC shall be submitted to and approved by the Executive Officer before implementation.

CEMS owners or operatorsmay be able to expand and develop existing CEMS QNQC (i.e., RECLAIM) to include the requirements of PR218.1, or, may develop their specific alternative quality assurance practices to assure data of equivalent or better quality. These alternative QNQC procedures must be


# - submitted with the facility CEMS QNQC procedures and are subject to the ( 

### approval ofthe Executive Officer.



### H. Reporting Requirementsfor Existing,New or Modified CEMS and SCEMS CEMS owners or operators are required to submit a CEMS semiannd- report within 

### 30 days ofthe end ofthe six-month period being reported. The report is a summary of the concentration or emission rate data, as applicable, as 

### well as other pertinent information as specified by the Executive Officer. 

### It is also required that the report shall be maintained on-site to be made available to the Executive Officer upon request, in a retrievable and readable form. Should an applicable rule or permit condition require or specify data reporting and frequency other than that of PAR218, the requirements ofthe applicable rule or permit condition shallprevail regardless of stringency. If the applicable rule or permit condition does not specify reporting requirements, the reporting provisions in PAR218 will apply.

I. CEMS Failure or Shutdown Reporting for Existing, New or Modified CEMS and SCEMS

### The proposals require the owner or operator to report to the AQMD any exeedance fiom the regulated concentrationandlor mass emission rate limits, or any system failure or shutdown,which exceeds24 hours, within 24 hours or the next working day. An 

### interim variance must be filed according to AQMD Regulation 

### V if CEMS shutdown or failure exceeds the 96-hour-period waiver. Next working day is defined as any Monday throughFriday excluding holidays. The definition fits practically those facilities, operating on a 24-hour-7-day-aweek schedule, that experience a CEMS failure or limit exeedance during weekend operations.

Staff has also incorporated in PAR218 Section 

### (f)(3)(B) 

## - Reports of CEMS Failure and Shutdown, a referenceto Rule 

### 518.2 

## - Federal Alternative Operating Conditions to provide for Regulation 

### XXX facilities to obtain ~e&n~ Board approval of alternative operating condition in the event of CEMS failures in

excess of 96hours.



### J. Notice ofApproval As an alternative to the current requirement of affixing the District written notice of CEMS approval (or a legible facsimile)on the equipment, the proposal allows the notice to be placed within 26 feet (AQMD Rule 206) from the equipment as 

### long 

### as it is visible, legible and safely accessible. Should either requirement becomes impractical, the notice may be placed on a location approved by the Executive Officer.IV. 

### SUMMARY OF PROPOSED RULE 218.1

PR218.1 provides for the performance specification standards for new, modified and existing CEMS that are under the requirements of 

### PAR.218. The standards for existing CEMS, which are deleted fiom the current 

### R218 and incorporated in 

### PR218.1; are basically unchanged with minor revisions for technical clax$3cation. To provide technical clarity and applicability, the definitions for the following have been deleted fiom 

### R218 definitions,revised and incorporated in 

### PR218.1 : CEMS, analyzer, data recorder, sampling interface, calibration drift (CD), calibration error (CE), certified gas mixture, confidence coefficient (CC), full span range (FSR), relative accuracy 

### (RA), relative accuracy audit 

### (RAA), relative accuracy test audit (RATA) and zero drift (ZD).Furthermore,

### R218.1 provides additional definitions of

new terms as follows: CEMS availability percentage, continuous monitoring, operational period, quality assurancelquality control plan (QNQC), modification requiring recertification, and linearity error. The proposal also includes each equation(s) necessary to calculate for CEMS performance that corresponds to each standard specification.



### PAR21

### 8.1 also provides for the standards for certification, operational requirements and performance specifications fornew, modified and existing CEMS, including the requirements for time-sharing operations. The "Old Standards" are deleted fiom Rule 

### 21 8 and incorporated in 

### PR218.1 without revisions to specifications. Therefore, 

### PR218.1 provides different sets of performance specifications and technical requirements: standards that apply to new or modified CEMS, which is referredto 

### as the "New Standards", and those that apply to existing CEMS which is referredto as the "Old Standards".

A. Standards forNew or Modified CEMS Standards that apply to new or modified CEMS, referred to as "New Standards" include specifications and requirements for installation and sample location, certification tests, relative accuracy tests and the performance specifications for the subsequent operation and maintenance of the installed CEMS after AQMD certification. A CEMS meeting these standards is considered capable of providing quality assured data for compliancepurposes.a) Pre-Certification Testing Standards Before any certification tests are performed, the CEMS must conform to the requirements for sampling probe location, reference samplingports, full span range (FSR), strip chart recorder,Data Acquisition System (DAS) and operational period. The basic criteria for sampling location is at a point where the measurements of the parameters of interest are made which are representative of the stack emissions of the source. The location of the CEMS sampling probe and the reference sampling ports are determined according to Method 

### 1.1 where the two probes do not interfere with each other when in use. However, there is no guaranteethat at these locations, the flue gas concentrations are not stratified such that the absence of stratification must be verified, as discussed below.
1) Sample Location The overall representativeness of the sample to the emissions of the

source is as dependent on the sampling location as it is to the accuracy of the CEMS subsystems. The monitoring sampling probe must be located where a samplemay be obtained which is representative of the source emissions. The monitoring system sampling probe tip and the reference method sampling port locations must be determined according to District Method 1.1. Each probe shall not interfere with the other when in use. Other locations may be chosen subject to a written approval of the Executive Officer. If an alternate location is chosen which does not conform with District Method 1.1, the absence of flow disturbance must be demonstrated using the District method 

### in the source Test Manual, Chapter X, Section 1.4 

### - "Alternative Site Selection Method", or 40 CFR, Part 60, Appendix A, Method 1, Section 

### 2.5 

### - "Alternative Measurement Site Selection Procedure", and, the absence of stratification must be demonstrated using the District method in the source Test Manual, Chapter X, Section 

### I3 

### - "Determination of Gaseous Constituent Stratification". 

### PR218.1 21S.l(b)(;)(C)(ii) also provides alternatives to sampling site selection where testing demonstrates the presence of stratification. The alternatives are subject to the approval of the Executive Officer. The overall goal is to select a sampling site that will obtain a sample which isrepresentative of the source emissions.Full Span Range PAR218.1 provides that the FSR is set such that all data points fall within 10 to 95 percent of the span range for the measurement to be valid. Furthermore, the FSR for contaminantmonitors must be able to

measure between 150 to 200 percent of the allowed concentration limit, or at a value approved by the Executive Officer. At this range, exeedance to the applicable limits may be quantified. For normally low contaminant concentration, a dual-span-range may be required if the owner or operator needs to quantify, at low-concentration range, the emissions for Emission Fee Billing (EFB) and reporting. Otherwise, concentrations (or other parameters of interest) may be reported at the 10% of the span range. Alternate FSR may be approved by the Executive Officer provided that the CEMS owner or operator could demonstrate, through historical data and operational or process stability, that the proposed FSR will not be exceeded. Alternate FSR may not be lower than 120% of the allowed concentration limit.
Additionally, PR218.1 stipulatesthe following DAS requirements: a) DAS must maintain all the required data as stipulated in Rule 2 18, Section (e) as follows: CEMS generated data, calculations of emissions and all parameters used in the calculations, start-up and shutdown information, calibration and adjustments made, and CEMS repair and maintenanceinformation. b) CEMS data acquisition of monitored parameters must be at least once per minute. c) SCEMS data acquisition of monitored parameters must be at least once every fifteen minutes. d) The acquisition rate of monitored parameters must be set at a constant rate such that the time span between data points are equally spaced aspractical. e) All valid points will be used for determining compliance with applicable standards.f) 

### The DAS sample acquisitionrate during certification must be the

same as DAS sample acquisitionrate during the normal operating mode ofthe CEMS or SCEMS.

3) 

### OperationalPeriod The operational period is a minimum of 168 hours of continuous CEMS operation without unscheduled maintenance, repair or adjustments before any certification test is conducted. During this period, the source andthe CEMS must be operating.

b) Certification Testing Certificationisthe 

### final approval of a CEMS demonstrating its acceptability to conform to all the technical requirementsfor operation. To be a certified CEMS, a CEMS must meet all the specifications and pass a series of certification tests, such as the 24-hour CE test, linearity error (LE), and RATA.



### 1) 

### 24-Hour CE The 24-hour CE test is comprised of a series of eight (8) tests during a seven-day period performed once each day with as close to 24-hour interval as practicable. During this seven-day period test, the CE specificationsmay not be exceededon any ofthe tests.

2-Hour CE and Analyzer Enclosure Diurnal temperature variations may. affect the analyzer performance should it exceed the manufacturer specificationsfor temperature 

### drift. PR218.1 requires that analyzers be contained in an environmentally controlled enclosure, supplied with an alarm device to alert the operator for any corrective action if the analyzer exceeds recommended temperature specifications. However, the CEMS owner may waive the above requirement if he demonstratesto the Executive Officer that the analyzer is located in 

### a geographical area where the seasonal temperatures do not exceed the analyzer temperature specifications, and where the averaged monthly diurnal temperature variation is less than 30 

### degrees

### F for all months the year.If the above enclosure requirement is not met, the operator may perform the 2-Hr CE test in lieu of meeting the requirement, The 2- hour CE test is a series of thirteen (13) tests over a 24-hour period performed once every two (2) hours. The CE must be less than or equal to 2.5% ofthe FSR for all analyzers and 3.0 % of FSR for flow monitors when an electronic calibrationis applicable.


### 3) Relative Accuracy Test Audit RATA is the relative accuracy statistical test that is performed during certification testing to determine CEMS accuracy in generating data within specified limits, that can be compared with the reference methods or other applicable standards data. RATA is performed for raw pollutant concentrations (for corrected concentrations, if applicable), emission rates, diluent concentrations, stack flow monitors, and/or fuel flow monitors, as applicable. RATA consists of nine sets (minimum) of 

### RM tests to determine the degree of accuracy between the CEMS generate data as compared to the value generated by the reference method 

### (RM). RATA may include data from concentrations and flow monitors to perform calculation in terms of units of applicable standards. A minimum of 

### 9 sets of tests will be used for RATA calculations. If more than 

### 9 sets oftests are collected,

no data may be rejected without a valid reason and all data collected must be submittedand reported to the Executive Officer. Appendix A includes AQMD's Technical Guidance Document #002 

## - Relative Accuracy Test Audit Outliers. Theprocedure in this documentmay be used if the tester elects to discard any RATA test data after the minimmnumber oftests (nine) have been performed. This document may be revised in the future, in which case, the most recent version of the guidance document will be the prevailing reference at that time. Any documentsrevisionswill go through a public review process.

PR218.1 (b)(2)(C) provides for the RATA specifications for pollutants, dilluents, flow and emission rates.' It also provides for alternative specifications for low pollutant and diluent concentrations, low flowrates,and low emission rates.c) Other test requirements during RATA PAR218 requires specific tests during certification and other relative accuracy tests. These tests must be satisfied within 14 days or during all relative accuracy tests and are as follows:

Response Time The response time specification for CO CEMS, ifthere is no technical limitation, is no more than 1.5 minutes. Otherwise, it will be the same


### as all other CEMS and flow monitors-which is not to exceed 5 minutes. Response is determined by injecting calibration 

### gas (at a value between 50 and 90% of FSR) at the probe of the CEMS. The average time interval between injecting a known concentration and reaching 95% of the concentration value must be no more than 

### 5 minutes.

Stratification,CyclonicFlow & Interference The absence of stratification, cyclonic flow and sampling, analytical and flow interference must all be verified. Cyclonic flow check is specifically required for emission rate measurements. Cyclonic flow and stratification tests must be performed according to AQMD method 

### in the Source Test Manual, Chapter 

### X: Non- Standard Methods and Techniques at one load ifthe equipment servedby the CEMS operates within 20% load range at least 80% of the time or at two loads if it operates at 50% load range for at least 80% of the time, or, at three loads it operates outsidethe above criteria.
Testing under cyclonic flow profiles and stratified concentrationsmay require additional preparation, relocation of sampling ports or process modificationto obtain a representativevelocity/flow and concentration data, 

### as applicable. PR218.1 Section (b)(2)(C) also provides other alternativesif the testing proves that stratificationexists.

Previous tests or historical data that will support the absence of cyclonic flow, stratification or interference may be submitted for approval by the Executive Officer to satisfy the requirements for periodic relative accuracy tests.

### 3) Linearity Error Linearity Error (LE) will be required for all certification tests and RATA's. LE is performed by introducing a known gas concentration at the low (10 to 30%), middle (40 to 60%) and high ranges (75 

### to 95%) of concentration. The CEMS is challenged with the calibration gas three times at each range. The same gas may not be used twice in succession. The specification for LE tests is less than or equal to 5.0 %

### ofthe calibration gas concentration.



### B. Quality Assurance/Quality ControlRequirements The above test procedures and performance specifications have been established to certify CEMS (as 

### installed) as capable of generating data that are of adequate quality and representative of the stack emissions. However, certification does not assure the long-term operation ofthe CEMS in such a manner as to provide the same level of data quality ascertified. Continued adequate data quality relies on the QNQC program that is developed for the CEMS. A well-thought out and implemented QNQC program will result in CEMS good quality data. AQMD has prepared a Technical Guidance Document for Rule 218 CEMS QNQC Plan, and is provided 

### in Appendix 

### B. PAR21

### 8.1 provides at a minimum the following requirements and specifications for a continuing CEMS operations.

a) Daily 24-hour CE tests to be performed as close to 24-hour intervals as practicable at the low (0 to 20%) and high (80 to 100%) ranges of concentration. CE's greater that 2.5% but less than 5.0% will be addressed by QNQCplan remediation. The CEMS is considered out-of-controlwhen CE's exceeds 5.0%of FSR until brought downto specifications.

b) System bias tests are required once a year during relative accuracy tests audits or at a time of replacement of specific parts of CEMS as specified in the technical guidance document for modifications. The CEMS bias must not exceed 5.0% of FSR for contaminant analyzers. The criteria for excessive drift, such as 

### the control limits on cumulative drift, and appropriate diagnostic techniques mustbe included in the QAQC programto identify sources of analyzerdrift and system bias when QC limit infractions

### occur. Since sample system bias can be a cause of drift aside from many other possibilities, CEMS operators are allowed to choose the appropriate diagnostic techniques to prevent and resolve sampling bias problems.

c) RATA must be performed annually and be completed by the end of the calendar quarter in which the CEMSwas originally certified.
d) A quarterly Cylinder Gas Audit (CGA) must be performed for three of the four calendar quarters, with no more 

### than three quarters in succession. The CGA must be performed according to the requirements of 40 CFR, Part 60, Appendix F, Section 5.1.2.

e) The CEMS availability may not be lower than 95%, otherwise, the Executive Officer may require a recertification of the CEMS. The 95% CEMS availability percentage does not include periods of calibration, maintenance, repair, or audit,up to amaximum of 40 hours per month. This in essence is in the 90% data availability requirement when these exclusions are considered. The basic concern is more for the accumulation of many short term CEMS "unexplainable"outagesthat add up to a large number at the end of the year. Staff will take into account mitigating factors (appropriately documented) that contribute to CEMS downtime such as a broken part that cannotbe replaced immediately.

The CEMS QNQC Plan directs the facility in establishing the implementation of procedures for QC activities. These procedures incorporated into a 

### written document, the QA manual, provide at a 

### minimum, the CEMS system description, detailed operation checks (daily checks, observations, adjustments), routine periodic and preventive maintenance, audit procedures and standard operating procedures. The QNQCrequirements are discussed extensively in the "Guidelines for Rule 218 CEMS Quality Assurance and Quality Control Plan". This guidance document is subject to revisions as often as necessary, to reflect the CEMS state-of-the-science, particularly in the operation and maintenance affecting quality control and quality assurance activities. The most recent revisions to this document will serve as the prevailing technical guidance for QNQC for Rule 218 CEMS. Any future changes to this guidance document will go through a public review process.V. 

### IMPACTS
A. Environmental Impacts

Staff has reviewed PAR218 and PR2 18.1 and has determined that they are exempt fiom the requirements of California Environmental Quality Act (CEQA). Staff has conducted with certainty that the proposals will not have a significant adverse impact on the environment. Therefore, staff has prepared a Notice of Exemption WOE) pursuant to state CEQA Guidelines Section 15061(b)(3) 

## - Review for Exemption (AQMD Guidelines Section 5.1) and Section 15308 

## - Actions by the Regulatory Agencies for Protection of the Environment (AQMD Guidelines Section 19.12). The NOE will be filed with the local county clerks immediately following the adoption of the PAR218 and PR218.1.
B. Cost Impacts
The AQMD staff has prepared a SocioeconomicAssessment Report to address the potential cost impacts associated with PAR2 18 and PR218.1. The report is in Attachment C.

C. AQMD Impacts
No significant additional resources will be required to implement PAR21 8 and PR218.1. The clarification and delineation of the CEMS specifications and requirements will allow staff to evaluate, review and approve CEMS more efficiently and consistently.



### VI. COMMENTS

A. CaliforniaAir Resources Board (ARB) Comments In consultation with ARB regarding the proposed relative accuracy specifications as provided in PR21 8.1, ARB 

### recognized that the proposed

### standards may in many cases be more restrictive than the federal standards addressed and supported by 40CFR60, Appendix 

### B. The District's approach "seem reasonable provided the de minimus differential concentration standards

are asrestrictive as the concentrationswhich would be found by converting the percentages given in 40CFR60 Appendix 

### B to differential concentration based

on values of the federal standards for a comparablefacility."



### B. U.S. EnvironmentalAgency (EPA) Comments AQMD staff consulted with EPA and requested the review of PAR218 and PR218.1, particularly on the equivalency of the requirements of PR218.1 to 40CFR60 requirements for Title V purposes and federal enforceability. EPA accepted the proposed de minimus specifications of PR21 8.1. EPA considered that at medium to high emission limits, PR218.11s relative accuracy criteria are equivalent to, or more stringent than, the federal standards. At low concentrations, however, where the de minimus criteria apply (e.g., at less than 5 ppm NOX limits), PR21 8.1's relative accuracy de minimus specifications become less stringent than the federal limits. EPA recognized that the intent of the de minimus criteria is to compensate for the limitations of current technology in obtaining a meaningfid relative accuracy at low emission levels including the availability and accuracy of low concentrationprotocol calibration gases.

Additional comments and recommendationsfromEPA are summarized as follows: a) Add languageto the fullspanrange provisions ofPR218.1 onhowto handle spikes and specifLacceptable conditions that would allowalternate full spanrange to be approvedby the Executive Officer. b) ClarifLin PR218.1 the hierarchy that will be used to evaluate and approve alternate sampling locations. c) ClarifLin PR218.1the hierarchy that will be used to evaluate and approve alternative certification methods for low concentrationgases such as 

### 10 ppm NOx or CO. d) UnIess there is a technical limitation,incIudethe 1.5 minutes response time for CO monitors per 40CFR60,AppendixA, Performance Spec4A.

### e) Provide in PAR2 18to require existing CEMS to have the written QAQC Plan availableand implementation within one year fiom adoption ofthe rule. f) 

### Provide a fiveyear record retentionperiod rather than the two year period to make record retention consistentwith the statute of limitations. g) Provide a quarterly cylindergas auditrequirement as part of the QAQC similar to 40CFR60, Appendix

### F.

EPA Regions 

### IX and district 

### staff discussed the above issues extensively. District staffhas revisedthe proposed languageto incorporate changesasagreed upon with EPA Region 

### IX. Table 2 is a summary of EPA comments and recommendationsand the corresponding staffresponses.

C. Public Comments Staff received public comments and inputs during and after the public workshops held on March 25, 1998 and August 26, 1998. Consultation meetings were also held on June 11, 1998 and April 2, 1999. Staff provided responses and actions to the comments received, and incorporated suggestions,

as appropriate. A summarized tabulation of verbal and written comments and staff responses and actions is in AttachmentA. A list ofpublic comment letters received is in Attachment 

### B and copies of the written comments are on file and availableupon request.



### VII. ATTACHMENTS Attachment A

## - Summary of Public Comments Attachment 

### B 

### - List ofPublic Comment LettersReceived Attachment C 

### - SocioeconomicAssessment Report



### VIII. APPENDICES Appendix A 

### - Technical GuidanceDocuments Appendix 

### B 

### - Guidelinesto Rule 2 18CEMS QualityAssurance and Quality Control Plan Appendix C 

### - Sample CEMS QNQCPlanTable 1

### - Comparison of REQUIREMENTS & PERFORMANCE SPECIFICATIONS 

### Rule 218 vs. Proposed 

### Rule 2181218.1 

### vs. 

### 40CFR60,App. 

### B & 

### P 

# II ADMINISTMTIVE REQUIREMENTS

A CEMSApplication Required before installation; initial approval = Required before installation; initial by Exec. Off~cer approval by Exec. Officer Standards, Tests
orParameters

A 

### I Certification Test 

### I 

### - Proposed Rule 2 181218.1 (New orModified CEMS)

Upon completion ofinstallation Current Rule 2 18 (Existing CEMS)


# I I Within 90days of installation S2** s1*+

A Test Notification None specified 

### + A QNQCPlan None provided 

### + 40CFR60, Appendices B & F (Non- Acid Rain)

FailureIShutdown Duration Exceeds 60consecutiveminutes for Reoortine 14davsbefore tests Written plan submitted 45days afler CEMS installation and 30daysbefore certification test, for approval Morethan 24 hours in duration

A Failure/Sl~utdow~i Reporting Wilhin 96hours 

### + Within 24 hoursorthe next working day A FailureIShutdown Waiver Not to exceed 96hours, extended through = Not to exceed 96hours, extended through Hearing Board variance HearingBoard variance A Exeedance Reporting Within 96hours + Within 24 lioursor the next working day A Data Summary Reporting Monthly 

### - Quarterly A Records Retention 2 years = 2 years A Posting of Written Approval Affix on equipmentor other approved = Affix on equipment, orwithin 26 feet, or location other approved location In a form of written notification and plan for review & initial approval by Exec. Officer (Administrator) Within 60 days after the maximum production rate but no later than 180 days from start-up. 30daysbefore test Written QC procedures maintained in the facility, not required to be submitted for approval.. Every incident



### + Included in quarterly sumnlary report + None specified

None specified 

# 1) PRE

### -CERTIFICATION REQUIREMENTS

-Table 1 page i 

### - A A

A Operational Period CEMSLocation

Sampling Location - - 

### +

= 2 168hours lnstalled where measurements are representative of stack emissions or can be adjusted toberepresentative Accessible location where the concentration oremission rate 1 168hours Installed where measurements are representative of stack emissions

Located where measurements are representative of stack emissions -

=

= 1 168hours Installed where measurements are representative ofstack emissions
Locations shall be determined per SCAQMDMethod 1.1

## 'i- -> 

# -

1 

### B i Table 1

### - Comparison of REQUIREMENTS & PERFORMANCE SPECIFICATIONS 

### Rule 218 vs. Proposed Rule 2181218.1 vs. 40CFR60,App. 

### B & 

### F

or Parameters (Existing GEMS)

measurements aredirectly representative
orcanbe corrected so astobe representative ofthe total emissions or at a location. Suggested measurement location is greater than I meter from stack orduct wall, or, centrally located over thecentroidal area ofthe stack or duct. 1.25 to 2 times of the average emission contaminant monitors. percent of the span range. FSR between for uncontrolled emissions 150and 200 %oftheconcentration limit. 1.5 times of standard limit for controlled emissions

00% of the c 1.25 to 2 times of the average emrsslori contaminantmonitors. for uncontrolled emissions 150and 200 %oftheconcentration limit. 1.5 times of standard limit for controlled emissions

normal concentration range
Multiple

### - span range may be required

concentrations can be can be measured for diluent monitors. diluent monitors, with maximum setting at 25.0% 0, and a minimum setting of

Revised: 04/07/99 KG -Table I page 2 -i' Table 1

### - Comparison of REQUIREMENTS & PERFORMANCE SPECIFICATIONS 

### Rule 218 vs. Proposed Rule 2181218.1 vs. 40CFR60, App. 

### B & 

### F

or Parameters (ExistingCEMS) (New orModified CEMS) (NOD- Acid Rain) 

# II CERTIFICATION TEST REQUIREMENTS

Verification ofnon-existence Verification of non-existence Verification ofnon-existence Verification ofnon-existence Stratification
'$' Stratification
's' Cvclonic Flow 's3 None specified None specified None specified None soecified Verification of non-existence Verification ofnon-existence Verification of~OII-existence Interference

## ' Verification ofnon-existence ResponseTime Response Time Response Time Response Time I 10minutes 5 5 minutes None specified None specified None specified 5 1.5 min. to achieve 95% of stable value I 10minutes 5 10minutes I 10 minutes < 5 minutes I 5minutes I 1.5 minutes or 5 5 minutes if technical limitations exists 

### < 5% ofthe cal. gas value Calibration Error (CE) 5 5%ofthe cal. gas value < 5%ofthe cal. gas value
Calibration Error (CE) I 5%ofthe cal. gas value

I 20% of the mean value of the RM or 10% of the allowed concentration, whichever is greater < 5%of the cal. gas value 5 5% of the cal. gas value

< 20% of the mean value of the .RM concentrations, or, the de-minimus concentration of 1.0 ppm NOx, whichever is greater < 20% ofthe mean value ofthe RM concentratio~~s, or,I0 % of applicable standard, whichever is greater 520%ofthe mean value ofthe Rh4 concentrations, or, I0 % of applicable stkdard, whichever is greater 

### < 15%of applicable standard if standard is bet. 0.20-0.30 Ib per MMBTU,
or, 

### < 20% of applicable standard if standard is
<0.20 Ib per MMBTU. I10%ofthe mean value ofthe RM concentrations, or, 5 %of applicable standard, whichever is Relative Accuracy

20% of the mean value of the Rh4 concentrations or, the de-minimus concentration of 2.0 ppm S02, whichever is greater lielative Accuracy I 20% of the mean value of the Rh4 or 10% of the allowed concentration, whichever is greater

. 5 20% of the mean value of the RM concentrations or, the de-minimus concentration of 2.0 ppm CO, whichever is ereater Relative Accuracy 5 20% of the mean value of the RM or 10% of the allowed concentration, whichever is greater

Revised:04/07/99 RG -Table 1 page 3 

### -t Table 1

### - Comparison of REQUIREMENTS & PERFORMANCESPECIFICATIONS 

### Rule 218 vs. Proposed Rule2181218.1 vs. 40CFR60, App. 

### B & 

### F



## I greater 5 20% of the mean value of the RM ,or Relative Accuracy 'Code*

10% of the allowed concentration, whichever is greater orParanleters (ExistingCEMS) (New orModified CEMS) (Non- Acid Rain) 

# I

I S2**

concentrations or, the de-minimus concentration of 4.0 ppm Total Reduced Sulfur (TRS), whichever is ' ' 40CFR60, Appendices B & P

10% of the applicable standard, whichever is greater -.. Propwed Rule 218/218.1 Standards,Tests.

greater. 5 10%ofthe mean value of the RM for diluent concentrations, or 1.O% O,, - - 5 20% of the mean value of the Rh4 for diluent concentrations, or 1.O% 0,;
or C 0, whichever is greater None; included in RA for Inass emission rate (CERMS) Current Rule 2 18

Relative Accuracy Sl**

None specified
whichever is greater 5 15% ofthe mean value of the RM for flow monitors, or the equivalent flow rate based on 2.0 fps stack gas velocity, whichever is greater Relative Accuracy None provided

I 20% of the mean value of the RM

concentrations, or.10 % of applicable standard, whichever is greater None provided 

### + 5 20% ofthe mean value of the RM for mass emission rates, or the equivalent mass emission rate based
on 2.0 fps stack gasvelocity, whichever is greater 5 2.5 % ofthe FSR, or, analyzer environmental enclosure 5 2.5 % of the FSR, or, analyzer Relative Accuracy



### + 

# ( none specified 2-hour Zero Drift (ZD) 5 2% ofthe FSR for contaminant monitors - 

# I

+ 

# I none specified 2-hour Zero Drift (ZD) 5 0.4% CO, or 0, 

## I - environmental enclosure <2% ofthe FSR for contaminant monitors 5 2.5 % of theFSR, - - -52.5 % of the FSR
5 0.5% CO, or 0, <2.5 % of the FSR, - - -52.5 % of the FSR
5 2% ofthe FSIC for contaminant mo~iitors - 5 2.5 % of tlie FSR, or, analyzer 

### + none specified environmental enclosure 5 0.4% CO, or 0, <2.5 % of the FSR, or, analyzer 

### + none specified 24-hour ZD 2-liour Calibratio~i Dri (CD) (or CE)5 2-hour CI))( or CE) environmental enclosure 5 2.5% ofthe FSR - - r2.5 % oftheFSR - 52,5 % oltheFSR

### - 5 2.5% of the FSR - - 5 2.5 % ofthe FSR - 5 2.5 % of the FSR

### - 5 0.5% CO, or 0, 5 2.5 % ofthe FSR - 5 0.5% CO, or 0, - 24-liour CD (or CE)

### ' 24-hour CD ( or CE)5 24-hour CD f or CE)' 24-hour CD ( orCE)' 24-hour CD (or CE) 5 2.5% ofthe FSR 

## I - 5 2.5 % ofthe FSR 

### I 

### + 

## I - 5 5.0 %ofFSR, 6 of 7 test None provided 

### + <3.0 %oftheFSR for flow monitors 

## 1 - -< 3.0 % of 1.25 times the average - 

# I I Revised: 04/07/99RG 

### -Table 1 page 4 -

### - Table 1 page 5 - 7-, 

### i Table 1

### - Co~nparison of REQUIREMENTS& PEWORhANCE SPECIFICATIONS 

### Rule 218 vs. Proposed Rule 2181218.1 vs. 40CFR60, App. B & 

### F

%ode* Standards, Tests
orParameters

I:

N 

### vsp*,

- ~ Current Rule2 18 '" (ExistingCEMS) A 40CFR60, Appendices B &F (Non- Acid Rain)

F-factors

NOx Conversion Efficiency

MINIMUM QUALITY ASSUMNCE/CONTROL REQUIREMENTS S1**

- -


### + Proposed Rule 2181218.1

te 7 -,(New orModified CEMS) '
potential absolute value for that measurement. Fd factors listed in 40CFR60, App. A, Method 19, Table 19-1 None provided None provided

None provided

Once every four calendar quarters Daily CDcheck Conducted in 3 of4 calendar quarters, but no more than three quarters in succession


### ------

EPA Protocol Gases

EPA Protocol Gases

EPA Protocol Gases

EPA Protocol Gases

Revised: 04/07/99RG =

- -

=

+

=

=

=

, = A
A A

A

P

D

P

C
, 

### +

+ Fd factors listed in 40CFR60, App. A, Method 19, Table 19-1 According to Method 100.1.-

RATA CD (or CE) Cylinder GasAudit (CGA)

SystemBias

Calibration Gas

Calibration Gas

ZeroGas

Zero Gas None provided Daily CDchecks None specified

None specified

5 2.0% of stated value,

I 0.2% of stated value, ambient air ' maybe used for oxygen monitors if span is
>21 % 02.

< 1 ppm of contaminant for contaminant monitors

< 10ppm CO for COmonitors +

= +

+

=

=

=



# - Performed annually Daily CE check Conducted in 3 of 4 calendar quarters, but no more than three quarters in succession f 5.0 percent of the FSR performed every 7 days or every 3months6 According to EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards, EPA-600/R93/22 According to EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards. Instrument air may be used if filteredprocessed and included in QNQCPlan. According to EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards
< 1.0 % of FSR of contaminant monitors Instrument air may be used if filteredprocessed and included in the QNQCPlan. According to EPA Traceability Protocol

## t Table 1 

### - Comparison of REQUIREMENTS & PERFORMANCE SPECIFICATIONS 

### Rule 218 vs. Proposed 

### Rule 2181218.1 vs. 40CFR60, App. 

### B & 

### F

Standards, Tests

Every 6 months by NBS procedures 

# --

I ! i for Assay and Certification of Gaseous Calibration Standards. Instrument air may be used if filteredprocessed and included in QNQCPlan

. According to EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards.



### * Code: A

### - applies to all CEMS C

### - applies to COCEMS D

### - applies to diluent CEMS According to EPA Traceability Protocol for Assay and Certification of Gaseous calibration Standards. 

## I Current Rule218

F

### - applies to flow monitors P- applies to pollutant CEMS N - applies to NOx CEMS S

### - applies to SO2 CEMS M

### - applies to mass emissions T - applies to TSR CEMS or Parameters Proposed Rule2181218.1 ' * St**



### * * SI - Stringency comparison of PR2 18.1 to current Rule 2 18 (e., 

### "+ " in S1 means PR2 18.1 is more stringent than current Rule 2 18) S2

### - Stringency comparison of PR218.1 to 40CFR60, Appendices B & F (i.e., "+" in S2 means PR218.1 is more stringent than 40CFR60)

,I_ ,,

- denotes equally stringent "

### + " denotes more stringent " - " denotes less stringent EPA Protocol Gases

EPA Protocol Gases (ExistingCEMS) S2**

The CEMS and the RM sampling probes shall not interfere with each other. If not applicable, other locations may be chosen with approval of the Executive Officer following specificprovisions. The stratification and cyclonic flowtests are performed according to the method in the Source Test Manual Chapter X: Non-Standard Methods and Techniquestested asfollows: at one (1) load ifthe equipment operates within a 20% load range for at least 80%of the time; at two (2)loads if the equipment operates within a 50% load range for at least 80%of the time; or at three loads if the equipment operates other than the two above criteria. Docu~nentation ofprevioustests or historical data may satisfy the stratification, cyclonic flow and interference requirements. Linearity Error (LE) test at low and high range of concentration. The CD for the current Rule 218 is the same term and isused in the samecontext as that for the CE in PR2 18.1that applies to new or modified CEMS. May be tested once every quarter with a documented procedure in QAiQC to assure and record that no cumulative adjustments > 5.0 %. If the cumulative adjustments exceed 5 %, a system bias check shall be performed within 24 hours. Recertification periods of certified gas mixtures shall be in accordance with EPA Traceability Protocol, Procedure GI or EPA Procedure G2, if EPA Procedure GI is not available. If EPA protocols donot apply, the gas manufacturer may submit arecertification protocol for approval. ' 40CFRb0, Appendices B &F

-Table 1 page 6 - (New orModified CE;MS) ' s (Non- Acid Rain) 

# I

### Table 2


### SUMMARY OF EPA COMMENTS & 

### RECOMMENDATIONS

EPA CO~IMENTS / RECOMMENDATIONS

## I PRQPOSED RULE LANGUAGE REVISED PROPOSED RULELANGUAGE I) Relative Accuracy: Because of current technical limitations in obtaining meaningful relative accuracy (RA) at low concentration levels, EPA does not object to PR218.l'~ use of an absolute de-minimus value subject to the following condition:

3) Record Retention: Provide a five-year record retention requirement rather than atwo-year period.
4) Cylinder GasAudit (CGA) The rule is silent on CGA; strongly recomniendsthat CGA be required. PR218.1 (b)(2)(C)

### - Relative Accuracy The CEMS shall meet the followingRA performance specifications: Less than or equal to 20.0 percent of the
mean value of .the reference method for pollutant concentrations, or the de-minimus concentration as follows, whichever is greater: Pollutant De-minimus Concentration NOx 1.0ppm 

## so2 2.0 ppm CO 2.0 ppm Reduced Sulfur Compounds 4.0 ppm (QAQCrequired within threeyears after adoption) PAR218(D)(l)(E)

### - The owner or operator of existing CEMS shall submitto the Executive Officer for approval, a Quality Assurance/ Quality Control (QNQC)Plan no later than May 14,2002.

PAR218(e)(l) 

### - The records



## ......... , shall be maintained by the CEMS owner oroperator for a minimum period of two years or as specified by the applicable rule or regulation



### .. . . .

## ..

## .. None required

. Nochange in proposed rule language;

(revised to one year after adoption) PAR218(D)(l)(E)

### - The owner or operator of existing CEMS shall develop and implement a writtell Quality Assurance/ Quality Control (QAIQC)Plan no later than May 14, 2000. The written QA/QC Plan shall be kept on record and available for inspection upon request by the Executive Officer.

No revisions made on the proposed language to be consistent with recent federal rulemaking activities (February 12, 1999) pertaining to 40CFR59, 60 & 61 on recordkeeping and reporting. PR218.l(b)(4)(D) 

### - Cylinder Gas Audit (CGA) A CGA shall be performed every calendar auarterbut in nomore than three auartersin

! Table 2 - page 2

## I 'Table 2


### SUMMARY OF EPA COMMENTS & RECOMMENDATIONS

1 5) Response Time: Unless there is atechnical limitation, includethe shorter responsetime of 1.5 minutes for CO CEMS,per40CFR60, App. B, I'erformance Spec4A

6) Full SpanRange (FSR) : Add languageto therule on how to handle spikes, indicating that ifa value falls outside the acceptable range,it shall be invalid but must be reported.

7) Full SpanRange (FSR): Specify acceptable conditionswhich would warrant alternateFSR which is outsideofthe FSR specification. PAR218.1(b)(3)(A)

### - ResponseTime The response time for all analyzersand flowmonitors, as applicable, shallnot exceed 5minutes.

PR218.1(b)(l)(C)(i)

### - Full Span Range The FSR for mass emission rate, air contaminant, diluent and flow analyzers shall be set such that all data points are within I0to 95 percentof therange.

PR2 18.1 (b)(l)(C)(ii)

### - Full Span Range For air contaminant monitors, the FSR shall be set between 150 and 200 percent of the concentration limit as specified in the applicablerule or permitcondition. Table2 - page 3 succession. The CGA shall be conducted according to the provisions of 40 CFR 60, Appendix F. The audit gases shall be according to the certification requirements ofRule218.1. PAR218,l(b)(3)(A)

### - ResponseTime The responsetime for CO analyzersshall not exceed 1.5 minutes except wherethere is a technical limitation,in which case the response time shallbe 5 minutes. The response time for all other analyzersand flowmonitors, as applicable,shall not exceed 5minutes. PR2 18.1(b)(l)(C)(ii)

### - Full Span Range The FSR for mass emission rate, air contaminant, diluent and flow analyzers shall be set such that all data points are within 10to 95 percent of the range. Pm 18.l(b)(l)(C)(vi) 

### - Should any data points fall above 95 percent of FSR, the value shallbe invalid for quantificationand the CEMS shall be considered unavailable for the purposes of determining CEMS availability percentage. All excursions above 95 percent of FSR and the duration of these excursions shall be reported in the CEMS summary report as prescribed under Rule 218(f).

For air contaminant monitors,the FSR shall be set between 150 and 200 percent of the concentration limit as specified in the

### Table 2


### SUMMARYOF EPA COMMENTS & 

### RECOMMENDATIONS

-A CO~IMENTS / RECOL~MENDATIONS ORIGINAL PROPOSED RULE LANGUAGE REVISED PROPOSED RULE LANGUAGE 

## I

provide hierarchy that will be used to evaluate and approve alternate certificationand recertificatiom methods for calibratio~i gases. - PR218.l(d)(l) 

### - CalibrationGas (A) Calibration gas mixtures shall be certified in accordance with the EPA Traceability Protocol for Assay and Certification of Gaseous Calibration Standards. Alternative certification methods for low concentration calibration gases, such as 10 ppm NOx or CO, may be submitted to the Executive Officer for approval. (B) Recertification periods ofcertified gas mixtures shall be in accordancewith 

### EPA TraceabilityProtocol, Procedure 

### G1
or EPA Procedure G2, ifEPA Procedure G1 is unavailable. IfEPA protocols are not applicable, the gas manufacturermay submit an alternative recertification protocol for District approval. Ally FSR may be set at a value other than that specified, but no lower than 120 percent, provided that the CEMS owner or operator demonstrates to the satisfaction of the Executive Officer that the FSR will not be exceeded. Such demonstrations may include, but not limited to, historical emissions data, historical process information, and historical operational information. A written approval from the Executive Officer shall be obtained before the FSR may be modified outside of the 150 to 200 percent of the concentration limit.
PR218.1(d)(l) - Calibration Gas (A) Calibration gas mixtures, asdefined in Rule2 1 8.1 (a)@), shall be manufactured, analyzed and certified in accorda~ice with the "EPA Traceability Protocol for Assay and Certification of Gaseous Calibration 

### Standards9'-EPA-6001R9711 21, September 1997 Revision (EPA Protocol). The certification period and recertification requirements, as applicable, shall be accordingto the EPA Protocol. (B) For gas calibration standards not explicitly covered by the EPA I'rotocol, the CEMS owner or operator shall submit the gas manufacturer's alternative certification protocol for the specific compound ordompounds.

(i) The procedures of the EPA Protocol shall be used for gas calibration
Table 2

### - page 4tecnnical aara also proviaea oy me manufacturer. This alternative shall be subject to the approval of Executive Officer. (ii) If there is no existing National Institute of Standards and Technology (NIST) standard for the measured parameter, the gas manufacturer may submit an alternative reference standard and the supporting technical data that define the stability, accuracy, and precision of the alternative reference standard. This alternative shall be subject to the approval of Executive Officer. (iii) The CEMS owner or operator may submit 

### an alternative protocol to the EPA.Protocol, provided that the CEMS
owner or operator demonstrates through supporting technical data that the procedures therein are not applicable to the constituent in the calibration gas standard being certified. This alternative shall be subject to the approval of Executive Officer.

Table2 - page 5

### SUMMARY OF' 

### EPA COMMENTS & 

### RECOMMENDATIONS

9) Alternate Sampling Locations: provide hierarchythat will be used to evaluateand approve alternate sampling I locations. 

# I

PR218.l(b)(l)(B)- SamplingLocation The monitoring system sampling probe tip and the reference method sampling port locations shall be determined according to District Method 1.1. The monitoring sampling probe shall be located where a sample may be obtained which is representative of the source emissions. Each probe shall not interfere with the other when in use. Other locations may be chosen subject to a written approval of the Executive Officer. PR218.l(b)(l)(B) 

### - SamplingLocation The monitoring system sampling probe tip and the reference method sampling port locations shall be determined according to District Method 1.1. The monitoring sampling probe shall be located where a sample may be obtained which is representative of the source emissions. Each probe shall not interfere with the other when in use. Other locations may be chosen subject to a written approval of the Executive Officer. If an alternate location is chosen which does not conform with District Method 1.1, the absence of flow disturbance shall be demonstrated using the District method in the source Test Manual, Chapter X, Section 1.4 

### - "Alternative Site Selection Method", or 40 CFR, Part 60, Appendix A, Method 1, Section 2.5 

### - "Alternative Measurement Site Selection Procedure", and, the absence of stratification shall be demonstrated using the District method in the source Test Manual, Chapter X, Section 13 

## - "Determination of Gaseous Constituent Stratification". Alternatives to sampling site selection in the presence of stratification are presented in Rule 218.1(b)(3)(C)(ii). REVISED PROPOSED RULE LANGUAGE EPA COMMENTS 1RECOMMENDATIONS

Table2

### - page 6 ORIGINAL PROPOSED RULE LANGUAGE