Business Objective

ALG was approached by a SCAQMD RECLAIM facility, with a significant number of RECLAIM regulated NOx emissions sources (including 4 CEMS monitored systems, RECLAIM Large emission, process and exempt equipment) to suggest ways to ensure ongoing compliance. The facility had previously been issued notices of violation (NOV) as a result of RECLAIM violations.

Technical Approach

ALG staff developed a complete and comprehensive overhaul of the facility's RECLAIM recordkeeping, reporting and monitoring program to ensure improved with the District's RECLAIM program requirements.

SCAQMD RECLAIM requirements include an array of recordkeeping, monitoring and reporting requirements. To ensure ongoing compliance ALG staff first developed an innovative method for the facility to report emissions from existing process and exempt equipment. This novel calculation method significantly reduces the number of individual fuel meters relied on at the facility for the calculation of RECLAIM NOx emissions - this results in both increased transparency of facility emissions calculations and a reduction in the liability that is associated with the continued maintenance and monitoring of fuel meters.

ALG staff developed a suite of databases which allowed for easily executed, transparent and well-documented calculations of all facility monthly, quarterly, and annual RECLAIM emissions.

To ensure facility CEMs were calculating emissions and reporting emissions to the District consistent with the requirements of the RECLAIM regulation, ALG staff developed software methods to perform a thorough and ongoing analysis of CEMS data from the facility's RECLAIM Major sources. Through the use of software solutions, ALG was able to audit minute, 15 minute and hourly NOx calculations performed by the CEMS' Data Acquisition System as well as an assessment of every transmission receipts sent to the District's Web Access to the Emission Reporting System (WATERS). Based upon the results of these analyses ALG worked with the CEMS Data Acquisition System software vendor to correct CEMS calculations and reporting methodologies according to RECLAIM requirements.

Results

Following the development of this new RECLAIM recordkeeping and reporting program the facility has maintained ongoing compliance with District RECLAIM requirements.