Impacts of U.S. EPA Region 6 Guidance on CMS Downtime and Data Calculations
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The document summarizes guidance from the U.S. EPA Region 6 on calculating hourly averages from continuous emissions monitoring systems (CMS) data and reporting CMS downtime. The EPA guidance clarifies that using the average of 4 quarter-hour periods to calculate an hourly average is improper, and the average should instead use all valid 1-minute data points from the full hour. The guidance also changes the method for determining reportable CMS downtime, defining it as any period where valid data is not collected for more than 40% of the hour. The impacts of this new guidance include changes to compliance determination, enforcement procedures, data acquisition and handling system vendors, and reporting procedures.
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Impacts of U.S. EPA Region 6 Guidance on CMS Downtime and Data Calculations
- 1. www.all4inc.com Impacts of U.S. EPA Region 6 Guidance on CMS Downtime and Data Calculations Eric Swisher | eswisher@all4inc.com | 610-422-1117
- 2. 2 Your environmental compliance is clearly our business. Typical CMS Diagram Sample Conditioning SystemProbe Assembly Data Acquisition & Handling System Analyzers Sample Pump Calibration Gases Sample Line Instrument Air
- 3. 3 Your environmental compliance is clearly our business. CMS Sampling Frequency ❑ 40 CFR §60.13 (e) – …all continuous monitoring systems shall be in continuous operation and shall meet minimum frequency of operation requirements as follows: [40 CFR §60.13 (e)(1)&(2)] ❑ 40 CFR §60.13 (e)(2) - All continuous monitoring systems shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period.
- 4. 4 Your environmental compliance is clearly our business. ❑ 40 CFR §60.7 (b) – …Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. CMS Downtime
- 5. 5 Your environmental compliance is clearly our business. Compliance Demonstration Build Base Average Excluded from Compliance Demonstration Reportable CMS Downtime Measured CMS Data Validation Compliance Demonstration Calculation Unable to Demonstrate Compliance in Terms of the Emission Standard Express in Terms of the Emission Standard Good Bad Hourly Average CMS Bad Good Compliance Average Validation Good Bad
- 6. 6 Your environmental compliance is clearly our business. 1-hour Block Average Validation ❑ Full Operating Hour [§60.13(h)(2)(i)] ❑ Partial Operating Hour [§60.13(h)(2)(ii)] ❑ Maintenance or Quality Assurance Hour [§60.13(h)(2)(iii)]
- 7. 7 Your environmental compliance is clearly our business. 1 23 4 0 15 30 45 1-hour Block Average Validation ❑ …1-hour averages shall be computed as follows…for a full operating hour (any clock hour with 60 minutes of unit operation), at least four valid data points are required to calculate the hourly average, i.e., one data point in each of the 15- minute quadrants of the hour. [§60.13(h)(1) & (h)(2)(i)]
- 8. 8 Your environmental compliance is clearly our business. U.S. EPA Region 6 Guidance ❑ April 18, 2017 – ODEQ requested clarification from U.S. EPA Region 6 on: 1. Reporting of CMS Downtime 2. Calculation of an Hourly Average ❑ June 26, 2017 – U.S. EPA Region 6 responded to ODEQ (in coordination with OECA & OAQPS)
- 9. 9 Your environmental compliance is clearly our business. The unit operated the entire hour, and there was no required maintenance or quality assurance activity conducted in this hour. Hourly Validation Example Minute Value 0 2 1 2 2 3 3 2 4 3 5 2 6 PURGE 7 PURGE 8 PURGE 9 PURGE 10 3 11 4 12 3 13 3 14 3 Minute Value 15 4 16 PURGE 17 PURGE 18 PURGE 19 PURGE 20 4 21 25 22 35 23 30 24 25 25 5 26 PURGE 27 PURGE 28 PURGE 29 PURGE Minute Value 30 2 31 3 32 4 33 2 34 3 35 3 36 PURGE 37 PURGE 38 PURGE 39 PURGE 40 3 41 2 42 3 43 2 44 2 Minute Value 45 4 46 PURGE 47 PURGE 48 PURGE 49 PURGE 50 4 51 3 52 3 53 4 54 4 55 3 56 PURGE 57 PURGE 58 PURGE 59 PURGE 1 2 3 4 Average 2.73 Valid 12 Invalid 4 Quadrant Valid Average 18.29 Valid 7 Invalid 8 Quadrant Valid Average 3.57 Valid 7 Invalid 8 Quadrant Valid 1 23 4 0 15 30 45 Average 2.64 Valid 12 Invalid 4 Quadrant Valid
- 10. 10 Your environmental compliance is clearly our business. Current: ❑ Can a compliance average be calculated? ❑ Reportable CMS Downtime? U.S. EPA Region 6 Guidance: ❑ Can a compliance average be calculated? ❑ Reportable CMS Downtime? Hourly Validation Example YES 0 Hours or 0 % YES 24 Minutes or 40 % 1 23 4 0 15 30 45
- 11. 11 Your environmental compliance is clearly our business. Compliance Demonstration Build Base Average Excluded from Compliance Demonstration Reportable CMS Downtime Measured CMS Data Validation Compliance Demonstration Calculation Unable to Demonstrate Compliance in Terms of the Emission Standard Express in Terms of the Emission Standard Good Bad Hourly Average CEMS Bad Good Compliance Average Validation Good Bad
- 12. 12 Your environmental compliance is clearly our business. U.S. EPA Region 6 Guidance ❑ April 18, 2017 – ODEQ requested clarification from U.S. EPA Region 6 on: 1. Reporting of CMS Downtime 2. Calculation of an Hourly Average ❑ June 26, 2017 – U.S. EPA Region 6 responded to ODEQ (in coordination with OECA & OAQPS)
- 13. 13 Your environmental compliance is clearly our business. ODEQ Request – Hourly Averages ❑ Hourly average based on: • 4, 15-minute quadrant averages collected during a clock hour OR • 60, 1-minute averages collected during a clock hour ❑ U.S. EPA Region 6 Response ❑ Using the quadrant average “appears to be improper data reduction”
- 14. 14 Your environmental compliance is clearly our business. The unit operated the entire hour, and there was no required maintenance or quality assurance activity conducted in this hour. Hourly Validation Example Minute Value 0 2 1 2 2 3 3 2 4 3 5 2 6 PURGE 7 PURGE 8 PURGE 9 PURGE 10 3 11 4 12 3 13 3 14 3 Minute Value 15 4 16 PURGE 17 PURGE 18 PURGE 19 PURGE 20 4 21 25 22 35 23 30 24 25 25 5 26 PURGE 27 PURGE 28 PURGE 29 PURGE Minute Value 30 2 31 3 32 4 33 2 34 3 35 3 36 PURGE 37 PURGE 38 PURGE 39 PURGE 40 3 41 2 42 3 43 2 44 2 Minute Value 45 4 46 PURGE 47 PURGE 48 PURGE 49 PURGE 50 4 51 3 52 3 53 4 54 4 55 3 56 PURGE 57 PURGE 58 PURGE 59 PURGE 1 2 3 4 Average 2.73 Valid 12 Invalid 4 Quadrant Valid Average 18.29 Valid 7 Invalid 8 Quadrant Valid Average 3.57 Valid 7 Invalid 8 Quadrant Valid 1 23 4 0 15 30 45 Average 2.64 Valid 12 Invalid 4 Quadrant Valid Methodology Average 4, 15-min Quadrant 6.81 All valid minutes 5.89
- 15. 15 Your environmental compliance is clearly our business. Additional Impacts ❑ Compliance ❑ Enforcement ❑ DAHS Vendors ❑ Reporting Procedures
- 16. 16 Your environmental compliance is clearly our business. Questions? Eric Swisher Technical Manager (610) 422-1117 eswisher@all4inc.com