New Jersey CEMS Quality Assurance Requirements for Non-Operating Quarters

On May 21, 2019, the New Jersey Department of Environmental Protection (NJDEP) Emission Measurement Section (EMS) issued clarifications to Technical Manual #1005 (TM1005). These clarifications were sent out via email through the EMS Listserv and are intended to provide clarification to the quality assurance (QA) requirements for continuous emissions monitoring systems (CEMS) during non-operational quarters. The archived message is available for review on NJDEP’s website.

TM1005 includes NJDEP guidelines for monitoring (i.e., continuous and periodic) and annual combustion adjustments. Section VI(I) of TM1005 requires that CEMS, required by permit to demonstrate compliance with allowable emissions, be quality assured in accordance with 40 CFR Part 60, Appendix F. Further, 40 CFR Part 60, Appendix F, Procedure 1 (Procedure 1) requires that either a quarterly cylinder gas audit (CGA) or relative accuracy test audit (RATA) be completed in each quarter that the source operates. §5.1.4 of Procedure 1 then goes on to state that a CGA or RATA is not required in a quarter where the source does not operate, with the caveat that if a RATA is required during the non-operational quarter it is then due in the quarter which the source recommences operation. Note that while Section VI(I) of TM1005 also allows a CGA to be conducted in lieu of a linearity test when a required linearity test is not performed due to the Part 75 grace period. That situation is not addressed by this article because the Part 75 grace period only comes into play in quarters where some operation took place.

It is the opinion of NJDEP EMS that the QA exemptions were not intended for continued periods of non-operation. The purpose of the May 21, 2019 email is to provide affected facilities with clarification regarding QA requirements during instances of multiple successive non-operational quarters when there is a break in quarterly QA activities. The following scenarios are presented to identify, and simplify, what QA activities are required relative to the source’s operational status.

1. First Non-Operational Quarter: In accordance with Procedure 1, if a CGA or RATA is required in the first quarter of non-operation, the facility may opt to skip the required quarterly test.
2. Second Consecutive Non-Operational Quarter: If a CGA was required in the first non-operational quarter, a CGA must be completed in this quarter regardless of the operational status of the source. If a RATA is required in the second consecutive non-operational quarter, the facility must perform a CGA while the source is not operating. A common term used to denote a CGA performed while the source in not operating is an off-line CGA. This term will be used for the remainder of the article to identify this QA scenarios.
3. Subsequent Non-Operational Quarters: Facilities have the option to discontinue quarterly QA tests if a source will be non-operational for an extended period of time (i.e., exceeding two consecutive non-operational quarters). However, in certain situations it makes sense to continue with the quarterly QA testing regardless of the operational status of the source. If a facility opts to continue quarterly QA, then an off-line CGA test is required in each non-operational quarter. It is important to note that the following caveats also apply when it comes to extended periods of non-operation.
   • If the facility chooses to discontinue quarterly QA for two or more consecutive quarters, a Performance Specification Test (PST), performed in accordance with the procedures outlined in either Option 1 or Option 2 of Appendix E of TM1005, will be required the quarter in which the source resumes operation.
   • If the unit is non-operational for five or more consecutive quarters, and one of those quarters includes a quarter without QA, it is considered a recertification event and a PST must be performed the quarter in which the source resumes operation.
   • If the facility chooses to continue quarterly QA during non-operating quarters, it can be done by performing an off-line CGA in each quarter including the quarter in which the RATA was due. However, if the facility goes six or more quarters without performing a RATA, a PST is required to be completed the quarter in which the source resumes operation.
4. Source Resumes Operation: If a CGA is due the quarter in which the source resumes operation, the CGA is required upon startup. If a RATA is due when the source resumes operation, the facility must follow the procedures detailed in Option 1 of Appendix E to TM1005. When following Option 1 for this purpose, substitute RATA for PST and exclude references to 7-day drift assessments. Alternatively, the facility may also choose to conduct a full PST as described in Option 2 of Appendix E to TM1005.

Now that we have discussed the required quarterly QA tests based on the length of the non-operational period, it is important to address data validation in relation to the performance of these tests. TM1005 requires valid data reporting upon start-up, unless the facility has a Start-up Operating Scenario that allows for something different. So, what does this mean to you? It means that a source required to perform a CGA, either as a standalone test, or as part of a PST performed in accordance with Option 1 of Appendix E to TM1005, must report downtime for operational periods from the time the source resumes operation to the completion of the CGA. For facilities electing to perform a full PST in accordance with Option 2 of Appendix E to TM1005, data is considered invalid from the time the source resumes operation until the completion of the calibration drift check on day 1 of the 7-day calibration drift period. It is important to note that if a PST is required (following either Option 1 or Option 2) the above information assumes that the RATA is passed. If the RATA is not passed, then the data from the time that the source resumed operation until the completion of a successful RATA will be considered invalid and is required to be reported as downtime.

This article focuses on the quarterly quality assurance requirements, and the associated data validation, during extended periods of unit non-operation. However, it is also important to mention that affected facilities should update their CEMS Quality Assurance Plan (QA Plan) to reflect the NJDEP update. If you have questions about the content of this article or would like assistance with updating your QA Plan, please feel free to contact me. I can be reached at 610.422.1164 or at jmillard@all4inc.com.