Standard Operating Procedure (SOP) for Compliance Monitoring ...

SOP for Compliance Monitoring Using CEMSs
provides examples on how to calculate values during instrument malfunction or calibration. For
calibrations lasting 30 minutes or less, the average values for the remainder of that hour can simply be
used (there is no need to calculate averages 4 hours before and 4 hours after).
If emissions standards for combustion sources are in the form of an exhaust stack concentration, they
typically include the oxygen (O 2 ) level for which the measurements should be reported. This prevents
compliance with the standard from being achieved simply by adding more excess air to the process or
allowing ambient air in-leakage into the exhaust duct. Annex 4 describes how pollutant concentration
measurements are adjusted to conform to O 2 levels specified in the standard.
Quarterly Reporting
Presently, electrical generating units report quarterly to EAD. It is recommended that other industries
that are similarly large sources of air pollution (e.g., primary aluminium smelters, large cement kilns,
electric arc furnaces) also report quarterly. Quarterly reports that are to be submitted to EAD should
include the following information:
• Facility information
• Monitoring Plan, which includes information and drawings with regards to monitor
specifications
• Maps showing the plant location, monitoring locations, and potential receptor locations
• Hourly and cumulative emissions data, including an emissions inventory with total pollutants
reported in tonnes
• Hourly unit operating information (e.g., load, heat input rate, operating time, flow rate), if
being monitored by the CEMS
• Results of required certification, recertification, and QA tests (e.g., daily calibrations,
RATAs)
• Certification statements from a designated representative (or an alternate representative),
attesting to the completeness and accuracy of the data
• Excess Emission Report (EER), including a summary of the EER.
Excess Emission Reports
There are uses for CEMS data beyond permit provisions. EERs track the events when monitored
emissions exceed the emissions standards. EERs can be used for several purposes. First, EERs can
indicate if the source is using good operating and maintenance practices on its process and control
equipment to minimise emissions. Second, EERs can provide EAD with data on upset conditions or
trend data, indicating a degradation of control equipment performance. Lastly, EERs can provide a
continuous record on the source’s ability to comply with standards. This information can be used as a
screening tool in inspections to target problems. EERs should include the following information:
• Total operating time of each source during the reporting period
• Documentation of excess emissions, including the following:
− Date of each exceedance of the applicable standard
− Start and end times of each exceedance of the applicable standard
• Magnitude of each exceedance of the applicable limit (exceedances in the units of the
standard and averaging period shall be reported)
• Nature or cause of each exceedance of the applicable standard and averaging period,
including occurrence due to startups, shutdowns, and malfunctions
• Corrective actions or preventive measures of each exceedance of the applicable standard
• Any mathematical factors used to convert emissions to units of the applicable standard
• Documentation of the CEMS’s performance, including the following:
− Date when monitoring system was inoperative (daily zero and span checks are exempt)
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