Lars K. Gram. FORCE Technology. The Danish EPA's Reference Laboratory for Air Emission Monitoring.

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1 Lars K. Gram FORCE Technology The Danish EPA's Reference Laboratory for Air Emission Monitoring 1

2 Title: International regulation on emission monitoring Sub title: How to implement PEMS as an alternative to CEMS Compliance and quality control of PEMS and CEMS 2

3 Agenda FORCE Technology National Reference Laboratory PEMS and CEMS differences and similarities from a compliance point of view Legislation in Europe: environmental emission measurements and emission taxes Relevant standards (norms) and national legislation compliance and quality control of CEMS and PEMS Quality control of CEMS and PEMS differences and similarities How to deal with them in practice 3

4 About FORCE Technology FORCE Technology is one of the leading technology, consulting and service companies on the international market. We transform highly specialised engineering knowledge into practical and value-creating solutions for a broad spectrum of sectors and industries. 4

5 About FORCE Technology FORCE Technology is Independent, Unbiased Non-profit Development budget > MEUR 30 A GTS company As a GTS company, we are dedicated to develop and use technologies and new knowledge for the benefit of Danish companies and the Danish society as a whole. 5

6 Business Concept Industry and society System and management development Integrity management and maintenance optimisation Inspection, testing, verification and certification Design, product, process and production optimisation Training and mediation Process and automation Materials technology Testing technology Sensors and metrology Hydro- and aerodynamics Simulation technology Energy and environment Structural integrity 6

7 Business Areas Energy, Climate and Environment Environmental assessment and cooperate social responsibility Energy labelling Projecting of energy and environmental plants Energy and process optimisation Optimisation of flow bearing equipment & processes - i.e. pumps & compressors Combustion and gasification of biomass & waste Emission and immission measurements Air pollution Odour emissions 7

8 Public-Private Partnership in Air Quality Management A case study from Nepal Urban Environmental Management and Air Quality in Less Developed Countries DDRN Workshop 30 Nov 2007 Carlsberg Academy, Copenhagen Karsten Fuglsang FORCE Technology Suman Sharma, MOEST & Chiranjibi Gautam, AEPN, Nepal 8

9 National Reference Laboratory Air Emission Monitoring Since 1997 on contract from the Danish EPA Main objectives: Measuring methods Quality and quality control Legislation and complience Profficiency tests Information Hot line, help desk 9

10 National Reference Laboratory Air Emission Monitoring Legislation Measuring methods Quality assurance Accreditation Standardisation Environmental approvals Test house performance Etc. These are all interlinked! Ref-Lab ensures that legislation works Consultancy for EPA, testhouses and enterprises 10

11 PEMS and CEMS PEMS: Predictive Emission Monitoring System CEMS: Continous Emission Monitoring System = AMS: Automatic Measuring System (European standards) EN: European Norm (standard) ISO: International Standard Organisation EPA: Environmental Protection Agency 11

12 PEMS and CEMS PEMS: calculates (predicts) the emission based on measured parameters CEMS: measures the emission 12

13 PEMS and CEMS NO X - and CO-PEMS: Calculates concentration, flow and mass flow rate NO X - and CO-CEMS: meausures conc. Flow-CEMS : measures flow Flow-PEMS: calculates flow-rate from fuel-consumption O 2 -CEMS and fuel composition 13

14 PEMS and CEMS Legislation (environmental, trading or taxes) demands continous monitoring of e.g. the NO X -emission The monitoring is performed by the enterprise The supervision is performed by the authoraties Quality control (parallel measurements) is performed by a third party (accredited / certified / traceable) 14

15 Legislation in Europe The QAL-system Quality control of CEMS in general: Installation of CEMS (QAL1) Suitability of the CEMS-installation Calibration/validation by third party (QAL2): Within 6 month from installation Every 5 years Annual Surveillance Test (AST) Every year (except in QAL2-years) On-going inspection (QAL3) Zero and span check and control charts Lars K. Gram, FORCE Technology, Denmark 15

16 Legislation in Europe Regular quality control by third party is mandatory Drift, failures, incorrect calculations etc. are revealed with third party quality control Examples of errors, that can exist, without QC: Double O 2 correction Leaks (false air) Failure of periferal parameters (temp., pressure, H 2 O etc.) 16

17 Relevant standards (norms) EN part 1-4 and EN Quality Assurance Levels (QAL1, 2, 3 and AST) for gas conc. CEMS Is supplemented with EN : for particle conc. CEMS EN : for flow CEMS 17

18 Relevant standards (norms) EN CEN TC 264 WG33 Greenhouse gases Greenhouse gas (GHG) emissions in energyintensive industries Work on new European standard in progress: Guidelines for PEMS applicability execution and quality assurance Draft standard (working document) available Published: 2016? 18

19 Taxes or trading CEMS (or PEMS) or calculation requiered: SO 2 taxes NO X -taxes CO 2 -trading Fossil CO 2 percentage in waste incineration plants (biogenic CO 2 are free of taxes) 19

20 Environmental legislation CEMS (or PEMS) are requiered: Europe: Waste incineration plants Large combustion plants Industrial emissions > certain mass flow rate Similar legislation in many countries outside EU 20

21 USA: Special rules for PEMS USEPA PS 16 (PS=Performance Specification): 21

22 USEPA PS 16 tttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttt tttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttttt Link: 16.pdf Lars K. Gram, FORCE Technology, Denmark 22

23 USEPA PS 16 QAL procedures: Initial PEMS certification 27 parallel measurements in three emission levels Quarterly Relative Accuracy Audit (RAA) and Yearly Relative Accuracy Test Audit (RATA) 27 parallel measurements in three emission levels Third party test with a reference method Statistical test (10 % deviation accepted) Passed: reduced frequency Failed: Repair sensors or PEMS. New initial PEMS certification might be needed 23

24 United Kingdom Environment Agency (Oct. 2013): 4.12 Quality Assurance of PEMS Link: 24

25 France Guidance on how to apply the QAL-system (EN 14181) on PEMS Very detailed procedures on how to deal with issues from EN 14181, that are not possible or different with PEMS. 25

26 The Netherlands Senter Novem-InfoMil: Factasheet L40-7C AIR tttttttttttt tttttttttttt tttttttttttt Link: open Factasheet Quality assurance og automated measuring systems Lars K. Gram, FORCE Technology, Denmark 26

27 Permits PEMS! The Netherlands Has in 2005 set up factasheet L-40-7C Air on how to perform QAL1, 2, 3 and AST on PEMS The Netherlands has provided a convenor (chairman) for the new standard (QAL-system for PEMS) 27

28 Permits PEMS for NO X NO X taxes Denmark For biogenic/fossil percentage of CO 2 from waste incineration QA of PEMS shall follow the principles in EN (QAL-system) Guidance document on quality procedures for PEMS has been issued by the Danish EPA Link: (in Danish open MEL-16 and see app. B) 28

29 Europe EN and EN ISO Specifies an Automatic Measuring System, that can be calibrated Both CEMS and PEMS fulfills that requirement But QA procedures are different for PEMS EN lack these different QA-procedures Thus, new QA-procedures for PEMS are needed! EU realises that guidelines and standards for QA for PEMS are necessary = new standard 29

30 QA of PEMS in practice QAL1: installation Identify all relevant parameters for the PEMS Measurable and not measurable Calculate the total uncertainty of the PEMS = s Relevent uncertainty sources for PEMS: Uncertainty from measurable parameters (input data) Uncertainty from not applying non-measurable parameters Uncertainty of the model it-self Uncertainty due to deviating ambient air conditions (for gas turbines) 30

31 QA of PEMS in practice QAL1: installation 2*s uncertainty requirements from legislation: EU NO X, Gas-turbines: 40 mg NO X /m³(s,d) s*2 40 mg NO X /m³(s,d) 31

32 QA of PEMS in practice QAL2: calibration Every 5 years Functional test Functional test for input instruments 15 parallel measurements Variability test PEMS performance compared with uncertainty requirements from legislation Result: Calibration function Variability test (passed / failed) Failed: new QAL2 32

33 QA of PEMS in practice QAL2: calibration Calibration function: y = ax + b can be applied on top of the PEMS results or (even better) The parallel measurements can be applied in the PEMS, providing a calibrated PEMS 33

34 CEMS: QA of PEMS in practice QAL3: on-going quality control Weekly, monthly, ½-yearly, depending on the maintenance interval for the CEMS (type approval) Zero and span gas Control charts PEMS: Monthly Check and evaluation of secundary parameters: Temp., pressure, energy output etc. 34

35 QA of PEMS in practice AST: Annual Surveillance Test Every year (not in QAL2-years) Functional test Functional test for input instruments 5 parallel measurements Test of calibration function from QAL2 is still valid Variability test Result: Calibration function: valid / not valid Variability test: passed / failed Not valid or failed: new QAL2 35

36 Summary PEMS is permitted in many countries EU standard(norm) for QA of PEMS is on its way (2016?) QA-procedures for PEMS exists PEMS and CEMS should always be verified by a third party frequent parallel measurements The QA procedures for PEMS or CEMS are (allmost) identical A PEMS is a CEMS, that needs slightly different QA-procedures! Lars K. Gram, FORCE Technology, Denmark 36

37 Thank you for your attention Questions? 37