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US EPA RATA Testing

Friday, December 16, 2016   By: john [1794] 2 Stars
Looking for requirements in regards to RATA,RACT and emissions testing.Are they required annually or more often?

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Wednesday, December 21, 2016   By: Ross Burns [390] 5 Stars
RATA is an abbreviation for relative accuracy test audit. In 1963 the clean air act in the United States became law and CO2 was not included because it is essential for lifes existence and common sense prevailed. In 1970 the enforcement arm of the clean air act was established. This enforcement arm is called the US EPA. In the past two decades the US EPA has been in an authoritarian cycle causing great hardship socially and economically to suit the whims of their supporting hegemony. We will be seeing the end of this authoritarian cycle is the fourth turning -generational changes- in the saeculum cycle in America that will ends very soon for the social tide of big government will contract again.

First, we are all for common sense efficiency and pollution control but without the lunacy.

This test audit is essentially an audit of existing field instruments that are part of a facilities CEMS or continuous emission monitoring system as well as non-CEMS emissions tests. Now its reasonable to expect instruments to be calibrated however RATAs enforcers dont see it that way. This is a costly regulation in the billions of dollars annually, and should you be a power station that dispatches, more wildly now, electricity on demand because of the diminishing of baseload power stations, which also includes forced closures of smaller stations less than 250MW by EPA because they are coal burners, and due to the unpredictable generators of electricity by wind or solar, then its even harder since great deal of planning has to be put in place to steady the load for many hours or days so the audit can be done and it cannot be at dispatch-able power.

So the burden of the audit is on the owner of the boilers and the EPA accepts the reported audit. This is a pattern of behavior resulting from an authoritarian regulator. Had the taxpayer been funding EPA employees with test equipment to satisfy their RATA then the taxpayers would simply say no to their budget to fund it.

Also, as a result of RATA the tester who performs the test audit needs to meet the qualifications of ASTM-D-7036.

The RATA is simply a statistical approach with additional sampling to show your existing instrumentation is not lying or you are not cheating. Ugh!

So there are basically two groupings of industries that the EPA passed regulations on her own known as Part 75 and Part 60. Part 75 are related to power stations and part 60 to everyone else whose a larger emitter.

Part 75 encompasses SO2, NOx, heat input, moisture, opacity or particulate matter, CO2 and Mercury. The frequency of the test audit for part 75 power stations or electricity producers is every six months. Now if your plant has been behaving well and everybodys been a good boy you can bump the test frequency with permission of the EPA to annually. Basically to step up to annual test audits you need to reduce your missions by 25% from your semi annual targets.

Part 75 requires you to operate your boiler during the test audit in three ranges based on consistency of load such as the most common load, then the second most common load in the past year. The EPA also deemed that instruments that measure flow will be measured at a low flow rate, a midpoint flow rate, and a high flow rate.

Ross

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