Ongoing NOx Budget Program Compliance: Electric Utility Industry Lessons Learned, 2004 Paper Summit, Spring Technical & International Environmental Conference, (including Papermakers; Process Control, Electrical & Information; Product & Product Quality)

This paper presents valuable lessons learned by the electric utility industry in their efforts to comply with the 40 CFR Part 75 and NOx Budget Program continuous emission monitoring (CEM) requirements. For other sources following similar regulatory paths, this paper provides important observations and recommendations to assist with the implementation of allowance trading program CEM requirements (e.g., Part 75 or NOx Budget Program). These observations and recommendations are based on extensive experience with Part 75 CEM programs at utilities and NOx Budget programs at a wide variety of other industrial sources. The paper summarizes typical CEM program problems associated with quality control and quality assurance (QA/QC) tests, fuel flowmeter QA tests, diagnostic and recertification test requirements, and manpower resources. The paper also addresses routine recordkeeping and reporting issues that can jeopardize regulatory compliance. Lastly, the paper provides recommendations and guidance for resolving these issues.