Advanced Emission Monitoring for Compliance in the U.S.
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1 Advanced Emission Monitoring for Compliance in the U.S. A Cost-effective Advanced Monitoring Solution - Deployment of Predictive Emissions Monitoring System (PEMS) as a Compliance Solution for Gas Turbine and Boiler Applications in the United States Provided by: Thomas Eisenmann Brian Swanson - CMC Slide 1
2 Presentation Outline Part 1 Part 1: Brief historical perspective of Compliance PEMS (U.S. EPA 40 CFR Part 60 and Part 75) Part 2: Selection criteria for PEMS use Part 3: Examples of PEMS model development using a CMC Statistical Hybrid PEMS Part 4: PEMS cost analysis and ongoing quality assurance Slide 2
3 Objectives Introduce Predictive Emissions Monitoring Technology and PEMS Solutions for Compliance Discuss the differences between PEMS and CEMS or parametric approaches to compliance monitoring Discuss the costs and ongoing quality assurance requirements for PEMS Slide 3
4 Why consider PEMS? A PEMS is a software based solution interfaced with the process control system. PEMS utilize inputs from the combustion or pollution control process to determine the regulated emission rates without gas analyzers. SmartCEM is a proven and patented PEMS Has met specifications under U.S. EPA regulations Minimal maintenance & operational costs PEMS are cost effective & can be setup quickly Model is developed and retrained onsite Replaces an existing CEMS in some cases Achieves very high data availability Slide 4
5 CEMS Components / Maintenance Sample Probe Umbilical Analyzers Gases Pumps Filters Controllers Computer Air Source Spare Parts Slide 5
6 CEMS Emissio ns SO2 NOx CO CO2 O2 NH3 Probe PLC NOx CO SO2 CO2 O2 NH3 Emissions Data Source I/O DCS Calibration Gases DAS Fuel Flow Emissions Reports Alarms etc. Fuels: Natural Gas, B FG, Oil(s) Coke Oven Gas, etc. Slide 6
7 PEMS PEMS Data collection Emissions & Process PEMS/DAS SO2 NOx CO CO2 O2 NH3 I/O DCS Inputs (read only) Fuel Flow Emissions Reports Alarms etc. Source Fuels: Natural Gas, B FG, Oil(s) Coke Oven Gas, etc. Slide 7
8 PEMS Design Considerations PEMS are allowed as alternatives to CEMS Evolution in PEMS methodology and improved results (theoretical then empirical) The required elements of a PEMS proven under the most stringent U.S. regulations (40 CFR 75) are empirical models that can be retrained Empirical neural network and statistical hybrid PEMS models have been certified by C.A.M.D. Slide 8
9 PEMS Design and History PEMS are not new, they evolved Introduced in the 1970s Parametric and First Principles initially First PEMS were formulaic approaches OEM models, GE, Solar, others Empirical Methods introduced in the 1980s and established in 2001 under U.S. EPA regulations PEMS on the market today include First Principles, Neural Network, and Statistical Hybrid Methods Slide 9
10 Regulatory Selection Criteria Monitoring Primary Pollutants (NOx, SOx, CO) PEMS may be used as an alternative to CEMS for all gas or oil fired boilers, ethanol plants, for gas fired heaters and simple or combined cycle turbines Parametric, PEMS, or CEMS approaches can be used for all smaller units (< 100 mmbtu) CEMS must be used on some units that fire solid fuels such as municipal waste (> 250 mmbtu) Local agencies may require monitoring of specific pollutants in non attainment (CO or HC) Slide 10
11 PEMS Regulatory Selection Matrix 40 CFR Part 75 Yes, as 40 CFR Part 75, Subpart E P1, P2, and Subpart H alternate Electrical Generating Units 40 CFR Part 60 Yes 40 CFR Part 60, Appendix B, PS 16 Subpart Da, Db, Dc Boilers (All Fuels) 40 CFR Part 60 Yes 40 CFR Part 60, Appendix B, PS 16 Subpart GG or KKKK Turbines (Gas and Oil Fired) Clean Air Interstate Rules Yes, as 40 CFR Part 75, Subpart E CAIR alternate All Affected Units (All Types) Maximum Achievable Technology Yes, as 40 CFR Part 60, Appendix B, PS 16 MACT alternate Boilers (All Fuels) Continuous Assurance Monitoring Yes All Affected Units (All Fuels) CAM Voluntary Superior Monitoring Yes All Affected Units (All Fuels) VSM Slide 11
12 PEMS Outside the U.S. Asia Countries in Asia with regulations following U.S. EPA look for PEMS implementation as a method of choice for compliance monitoring. Examples are Malaysia, Philippines, Singapore, Korea, and others. China Emerging large market due to the vast number of manufacturing and energy facilities and the large number of suitable power and industrial plants. CMC is actively seeking partners in the China market. Middle East Strong activity has developed in the United Arab Emirates, Saudi Arabia, and other GCC countries who look to U.S. EPA regulations as guidance. Many plants do not consider the use of CEMS as a practical option and have opted for PEMS wherever possible. Europe Some countries use PEMS in lieu of CEMS like the Netherlands and Ireland. The larger U.S. countries including Germany, France, Italy, and Spain are developing PEMS applications. PEMS already used for small sources (< 50 MW GT applications). Slide 12
13 Parametric System Design Up to 3 inputs with correlation to emissions Performance will not be the same as CEMS Perform Initial Baseline Testing One set of three runs (one hour each) at three or four normal operating loads with process data and emissions data (time correlated). Perform Annual Testing Periodic (annual) testing to validate the emission levels at each load point. Slide 13
14 Parametric System Results Slide 14
15 Theoretical First Principles Design Few inputs with strong correlation to emissions can be used and a formulaic model is developed Validate against site specific test data Collect process and emission data for a period of several hours under several load points Certification and Performance Testing Periodic testing as required Failure of key inputs leads to monitor downtime Long term performance is impacted when critical sensors fail, drift, or the process changes Slide 15
16 Empirical System Design Many inputs with correlation to emissions can be used and performance can be the same as a CEMS with similar or slightly more quality assurance Collect Historical Training Dataset Collect process and emission data for a period of 7 to 30 days under normal operating conditions through full load with varying ambient range Certification and Performance Testing Periodic (annual or quarterly) testing to validate the emission levels at each load point Slide 16
17 Empirical System Results Slide 17
18 Empirical System Results (NOx O2) Slide 18
19 Empirical System Results (CO CO2) Slide 19
20 PEMS Cogeneration Facility Slide 20
21 PEMS Adaptability (Example) EPA Demonstration Virginia Dominion Power and Kissimmee Utilities Authority Initial model developed using 16 inputs and certified using a month of test data for large frame combined cycle turbine with steam injection for NOx controls (170 MW capacity unit) Subpart E demonstration completed in 2002 Slide 21
22 XY Plot Base Load Unit EPA Demonstration 1st Simple Model (with 680 hours of data) Slide 22
23 XY Plot Base Load Unit Updated EPA Demonstration 1st Simple Model (with 1400 hours of data) Slide 23
24 PEMS Flexibility (Example) Dearborn Industrial Generation DCS providing the inputs for the combined cycle units did not have valve position inputs available in 1 st model Model developed using a different 19 inputs and 200 hours (9 days) of test data including NO x, CO, and O 2 content Subpart E demonstration completed in 2004 Slide 24
25 XY Plot (16 inputs hardwired) XY Plot Peaking Unit (DIG Simple Cycle Turbine 1 st Model with 16 inputs) Slide 25
26 XY Plot (74 input via OPC) XY Plot Base load Unit (DIG Combined Cycle Turbine 1 st Model with 22 inputs) Slide 26
27 Configuration and Retraining Dearborn Industrial Generation 750 mmbtu Gas Fired (NG and BFG) Boilers Three large pipeline natural gas and blast furnace gas fired boilers with existing CEMS. U.S. EPA Part 75 NOx Trading, and Part 60 CO and SO2 Subpart E demonstration completed in 2004 Slide 27
28 Gas Fired Boiler Initial Model XY and Time Plot Baseload Boiler (750 mmbtu 1 st Model with 720 Hours Slide 28
29 Gas Fired Boiler Auto Tuned XY and Time Plot Baseload Boiler (750 mmbtu 1 st Model with Autotuning) Slide 29
30 Gas Fired Boiler Enhanced XY and Time Plot Baseload Boiler (750 mmbtu 1 st Model with 120 Hours Added after autotuning) Slide 30
31 Model Portability NRG Houston Texas 60 MW Gas Turbine combined cycle with HRSG Eight natural gas fired turbines with existing PEMS. U.S. EPA Part 75 NOx Trading, and Part 60 compliance replacement for neural network 2007 Subpart E demonstration and EPA approval 2008 Slide 31
32 PEMS Subpart E Time Plot Time Plot Simple Cycle Turbine (GE Frame 5 PSM retrofit peaking unit) Slide 32
33 PEMS Subpart E XY Plot XY Simple Cycle Turbine 1 (GE Frame 5 PSM retrofit peaking unit) Slide 33
34 PEMS Subpart E XY Plot XY Simple Cycle Turbine 2 (GE Frame 5 PSM retrofit peaking unit) Slide 34
35 PEMS Subpart E XY Plot XY Simple Cycle Turbine 3 (GE Frame 5 PSM retrofit peaking unit) Slide 35
36 PEMS Periodic Quality Control Zero and Span checks: Daily Direct gas measurement: Quarterly Relative Accuracy Test Audit: Annually Input failure detection system: Before RATA Bias Check: After RATA Statistical Analysis: After retraining of Model Input failure alarms: After retraining or RATA Slide 36
37 PEMS Initial RATA Test (Boiler Oil) SO2 lb/mmbtu RM PEMS Test Run Slide 37
38 PEMS Model Envelope INPUT DESCRIPTION MIN MAX Input1 B2 PID CONTROL VARIABLE AIR FLOW Input2 B2 PID AIR FLOW Input3 B2 PID CONTROL SET POINT AIR FLOW Input4 B2 PID CONTROL VARIABLE BOILER MASTER Input7 B2 PID CONTROL VARIABLE DRUM LEVEL Input10 B2 PID CONTROL VARIABLE FEEDWATER FLOW Input11 B2 PID FEEDWATER FLOW Input12 B2 PID CONTROL SET POINT FEEDWATER FLOW Input13 B2 PID CONTROL VARIABLE GAS FLOW Input15 B2 PID CONTROL SET POINT GAS FLOW Input16 B2 PID CONTROL VARIABLE EXCESS AIR Input17 B2 PID EXCESS AIR LEVEL Input18 B2 PID CONTROL SET POINT EXCESS AIR Input19 B2 Air Flow Input21 B2 Feedwater Flow Input23* B2 Gas Flow Input27* B2 Steam Flow Input29 B2 Conductivity Analyzer Input31 B2 Feedwater Temp Econ Outlet Input32 B2 Flue Gas Temp Econ Outlet Slide 38
39 PEMS Quality Assurance Plan INPUT DESCRIPTION PERIOD QC ACTIVITY Input1 B1 PID CONTROL VARIABLE AIR FLOW Annual Output Checked Input2 B1 PID AIR FLOW Annual Output Checked Input3 B1 PID CONTROL SET POINT AIR FLOW Annual Output Checked Input4 B1 PID CONTROL VARIABLE BOILER MASTER Annual Output Checked Input7 B1 PID CONTROL VARIABLE DRUM LEVEL Annual Output Checked Input10 B1 PID CONTROL VARIABLE FEEDWATER FLOW Annual Output Checked Input11 B1 PID FEEDWATER FLOW Annual Output Checked Input12 B1 PID CONTROL SET POINT FEEDWATER FLOW Annual Output Checked Input13 B1 PID CONTROL VARIABLE GAS FLOW Annual Output Checked Input15 B1 PID CONTROL SET POINT GAS FLOW Annual Output Checked Input16 B1 PID CONTROL VARIABLE EXCESS AIR Annual Output Checked Input17 B1 PID EXCESS AIR LEVEL Annual Output Checked Input18 B1 PID CONTROL SET POINT EXCESS AIR Annual Output Checked Input19 B1 Air Flow Annual Calibration Check Input21 B1 Feedwater Flow Annual Calibration Check Input23* B1 Gas Flow Annual Calibration Check Input27* B1 Steam Flow Annual Calibration Check Input29 B1 Conductivity Analyzer Quarterly Calibration Input31 B1 Feedwater Temp Econ Outlet Annual Calibration Check Slide 39
40 PEMS O&M and QA Cost Summary CEMS vs. PEMS Quality Assurance Costs about the same or sometimes more PEMS vs. CEMS Initial Capital Costs About ¼ to ½ of CEMS PEMS vs. CEMS Operational Costs About 1/10 of CEMS Slide 40
41 PEMS vs. CEMS Operational Costs Initial Cost (2 sources) 3 Gases (CO, NOx, O2) Base System PEMS w/ hardware / CEM installed PEMS Cost Vs CEMS Cost $166K Vs $255K Annual Cost of Operation $30k Vs $67k Annual Maintenance Costs $12k Vs $54K Totals (1 year) Totals (5 year) Annual Savings $208,000 Vs $375,000 $376,000 Vs $859,000 $79,000 Slide 41
42 Why Choose PEMS? No spare parts No calibration gases Lower capital cost than CEMS Can be as accurate as a CEMS Greater uptime than CEMS Quicker implementation than CEMS An environmental product with a return on investment Slide 42
43 Industries Currently Served Utility and Industrial Combustion Turbines Ethanol Plants University Steam Plants / Cogeneration Governmental and Municipal Utilities Industrial Boilers (gas and oil fired) Petroleum Refineries Steel Plants Slide 43
44 Questions? Thomas Eisenmann Brian G. Swanson, President Slide 44
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