Ed Wentling Environmental Regulatory Specialist, B&W, KVB- Enertec Products September 23, 2015

Transcription

1 Ed Wentling Environmental Regulatory Specialist, B&W, KVB- Enertec Products September 23, 2015

2 Introduction What is a DAHS? Electronic Reporting Quality Assurance of Data Summary & Question

3 A data acquisition and handling system (DAHS) captures all data from the continuous emissions monitoring systems (CEMS), performs calculations to convert it into the units of measure required by a standard, generates reports in a format that is suitable and/or required by regulation, and retains the data for retrieval and inspection. In addition to emissions data, the DAHS also captures unit operating data such as volume of production, fuels consumed, control equipment performance, and unit efficiency. DAHS are required to perform certain functions automatically (e.g. applying missing data substitution routines) as well as serve as a mechanism for manual entry of data.

4 Typically comprised of two critical components: Programmable Logic Controller (PLC) or Data Logger A software application typically based on a Windows platform Unix and Linux based systems

5 What is a CEMS/DAHS? What is Emission Monitoring? Emissions Source Sample Extracted Data Flow CEMS Hardware Main Components Include: Stack Sample Probe Analyzers Flow meters Conditioning Equipment Programmable Logic Controller DAHS Software Emission Monitoring System Design Technology Software Technology Data Acquisition and Handling System (DAHS) Data Flow Data Recorded, Processed and EPA Report Generated Plant Monitoring Emissions for Site Performance Site Emission Report Electronically Delivered to Plant Manager

6 Serves as intermediary between software application and CEMS/COMS analyzers Capture instantaneous data from analyzers Initiate calibrations, activate solenoids, probe purge Sends/receives data to plant distributed control system (DCS) From: Load, fuel usage, process on/off To: Emissions, CEMS alarms, Data Valid/Invalid

7 Typically resides on a server class Windows-based PC Performs calculations to convert raw data in units of measure required by the standard Applies missing data substitution routines required by the regulation Generates reports for operational analysis and regulatory requirements Stores all historical data in a format suitable for inspection

8 Typically, DAHS vendors provide software that meets the Part 75 recordkeeping requirements. 1 The Part 75 program is administered by the Clean Air Markets Division (CAMD) A clearly written rule that details what is required from sources with various resources available to assist them with complying with the rule Policy Manual, Emission Collection and Monitoring Plan System (ECMPS), detailed reporting instructions 1 USEPA Plain English Guide to the Part 75

9 A compilation of questions that have been posed to the EPA over the years covering a myriad of issues, for example: How to calculate hourly averages when the emissions are in excess of analyzer s range Detailed explanation of how the 8-hour grace period applies for daily calibrations Guidance on what follow-up QA tests are required following a maintenance event

10 ECMPS is the mechanism for sources to submit EDRs to the EPA checks the reported data with regards to format, calculations, and completeness Reporting Instructions for each of the three types of EDRs submitted via ECMPS Monitoring Plan CEMS systems and components, formulas, default values Quality Assurance Data Linearity, RATAs, Flow to Load Emissions Monitored and Derived Hourly Emissions Data

11 PADEP has also provided industry with resources for how to comply with their program Continuous Source Monitoring Manual Revision 8 (CSMM Rev 8) Performance specifications, Certification requirements, Reporting Instructions

12 Data Validation Clarification Document provides clear examples of to how calculate hourly averages using various scenarios Continuous Emission Monitoring Data Processing System (CEMDPS) PADEP s reporting application for submitting monitoring plan, certification, and emissions data

13 Both EPA and PADEP require a DAHS and Formula Verification as a part of a CEMS certification to ensure calculations are accurate DAHS Verification Used to validate the DAHS is applying the appropriate missing data substitution algorithms Formula Verification Minute to Hour Averages, Hourly Averages used to calculate Derived Hourly Averages

14 O2 (%) XYZ Co. Unit CT01 Load (MW) vs O2% Load (MW)

15 Vendors are faced with the challenge of developing a core product offering compliant with a multitude of regulations affecting sources throughout the world Not every state defines how they determine a valid averaging period Without clearly defined guidelines you are exposing yourself to interpretation Provide regulator with example calculations in writing and get concurrence

16 At the end of the day it is your company s name on the bottom line Make sure your DAHS is configured properly according to permit Ask your vendor to show their work and check it Document the data flow from measurement through to the 30-day average.

17 Have a formal process for documenting changes to your DAHS May impact monitoring and/or QA plans and prompt a DAHS/CEMS recertification event Discuss changes with your vendor and have sign off on both sides on what is expected Clearly define who in your company can request changes

18 The size of today s hard-drives essentially eliminates space limitations with regards to storage Data retention is now primarily driven by regulatory recordkeeping requirements 40 CFR Part 75 requires data be made available in a format suitable for inspection for at least three years from the date of record (75.57(a)) PADEP requires data to retained for five years (CSMM Rev. 8, Section I.A.4) Internal recordkeeping requirements must meet the most stringent regulation but often go above and beyond

19 Require a backup of configuration as part of your change management process Consider a local backup (e.g. external hard-drive) and a remote backup in case of catastrophic failure Consider RAID configuration with extra HDs for quick recovery of a failure Exercise your Backup and Recovery Plan at least annually

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21 Edward C. Wentling Senior Environmental Regulatory Specialist KVB Enertec Products The Babcock & Wilcox Company 2849 Sterling Drive / Hatfield, PA Phone: (215) / Cell: (267) ecwentling@babcock.com Web: