Ongoing NOx Budget Program Compliance: Electric Utility Industry Lessons Learned

摘要

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