Experience with PADEP, CEM Experience with PADEP, CEM
Phase I Approval Under Rev 7Phase I Approval Under Rev 7
ARIPPA Technical SymposiumARIPPA Technical Symposium
July 27, 2005July 27, 2005
Jim Carroll & Ron BakerJim Carroll & Ron Baker
EcoChem AnalyticsEcoChem Analytics
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Presentation OverviewPresentation Overview
• Project Scope• Hardware Description• Project Schedule• Application Experience• Interaction with the
Department• Recommendations• CEM Supplier
Perspective
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CEM Project ScopeCEM Project Scope
• Install new stand alone CEMS enclosure
• Install two (2) new EcoChem MC3 multi-component analyzer packages
– NOx, SO2, CO, CO2, O2
• Two (2) new sample handling systems– Probes– Sample lines– Sample pumps
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CEM Project Scope ( Cont’d)CEM Project Scope ( Cont’d)
• New DAS by ESC for PA STEMS (Part 60) and NOx Budget (Part 75) reporting
• Maintain use of existing stack flow monitors in new system
• Maintain use of existing Opacity Monitor (near term)
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Heated Sample LineHeated Sample Line
Non-heated tubes (PFA-PTFE)
1. Calibration Gas (from calibration cylinder and solenoid valves to probe)
2. Isolation Air (isolation of probe from flue gas during calibration & temperature failures)
3. Blowback air (used for purging probe)
Heated tubes (185°C PFA)1. Sample gas from probe to
analyzer2. Spare
Heating element
Insulation
Power for probe
Power for sample line heating and temperature sensors
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MC3 ConfigurationMC3 Configuration
Gas Range Interval
CO 0-200 PPM, 0-3000 PPM
SO2 0-150 PPM, 0 - 400 PPM
NOx 0-160 PPM
O2 0-25%
CO2 0-20%
H2O 0-30%
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Project ScheduleProject Schedule
• Prelim Meeting - August 2003• New CEM Spec Issued –
August 2004• EcoChem Selected – Sept 2004• PO issued/Order placed – Sept
2004• Teleconference with PADEP –
Sept 2004• Phase I Submittal – Oct 2004
– Included a listing of project milestones (testing)
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Project Schedule (Cont’d)Project Schedule (Cont’d)
• Phase II Submittal – Nov 2004• FAT Testing – Jan 2005• Installation/Commissioning –
Feb 2005• Phase I and II Status Request –
Feb 22• PADEP Response – Feb 24,
2005• Proposed Certification –
March 16, 2005• New Schedule Proposed –
March 17, 2005
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Project Schedule (Cont’d)Project Schedule (Cont’d)
• Performance Testing – April 2005• RATA Testing – April 13 & 14, 2005• Phase I Approval – April 18, 2005• Submittal of Performance Testing
Data – May 2005• Submittal of Part 75 Certification
EDRs – May 2005• EDR Certification Data – App’d in
10 days • Phase III Acknowledgement Letter
– June 2, 2005 (Response by July 2, 2005)
• Certification is currently pending
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Application ExperienceApplication Experience
• Opted to utilize the electronic Phase I forms
• Theory: Electronic submittal may expedite the approval process (Not!)
• Completed forms encompassed 41 pages
• Forms were cumbersome to work with
• Some requested data was not well defined
• Requested more fluff than stuff
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Application Experience Application Experience (Cont’d)(Cont’d)
• Requested data aids in fulfilling the Department’s CEMS database
• ID codes, Result Codes, Source Codes, Analyzer Codes & CEMS Codes are meaningless to the preparer
• It’s difficult to keep them straight!
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Application Experience Application Experience (Cont’d)(Cont’d)
• Regurgitate many of the standards in the CSMM
• Defining the Lowest Monitored Standard (LMS)
• LMES now replaces the old “Span”
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Interaction with DepartmentInteraction with Department
• Phase I Pre-submittal teleconference is beneficial
• Also beneficial to speak with Bob Vollaro of EPA to review Part 75 issues
• There was little or no communication unless we initiated it
• Phone call follow-ups were initiated starting in December
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Interaction with Department Interaction with Department (Cont’d)(Cont’d)
• Exchanged LMES calculations via FAX in January
• They opted not to visit the plant during installation or testing
• Communication via letter stimulated the best response
• The Department is still working to understand all the nuances of Rev 7.
• Their plates are FULL.
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RecommendationsRecommendations
• Schedule an informal pre-submittal conference
• Build a lot of time into your schedule– 1 year from Phase I submittal to
Certification• Submit your project schedule with
the Phase I• Understand & be clear about your
LMES calculations in your Phase I
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Recommendations (Cont’d)Recommendations (Cont’d)
• Keep your project on the radar screen after the Phase I is submitted
• Submit your Phase II early• Correspond with the Dept in
writing about project milestones• Make sure the Dept understands
your Part 75 issues
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CEM Supplier Perspective on CEM Supplier Perspective on PADEP Rev. 7 PADEP Rev. 7
• Awaiting Responses Caused Project Delays
• Phase I Submittal Approval took >4 months
• Rev. 7 Phase I Electronic Version confusing
• Reconciling NOx Budget, Part 60 and PADEP overlapping requirements inefficient
• PADEP Going Thru Transition
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Benefits of More Current CEMBenefits of More Current CEM Beside Simply Meeting Beside Simply Meeting
RegulationsRegulations• Hot-wet system provides
moisture concentrations – assists with auditing tube leaks
• New sample system and automatic audits reduces manual oversight
• Enhanced remote troubleshooting reduces frequency of lengthy E&I staff call-outs
• Convenient format and data access useful management tool
• Avoid total obsolescence
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Operator Interface and Operator Interface and Remote System AccessRemote System Access
• Presents data in larger color screen
• Most functions 1-2 touch screen taps
• Provides meaningful system history to do troubleshooting right at the CEM location (fewer trips back and forth to control room or office)
• Can control the system remotely
Excel PC Anywhere
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A Contrast in Case HistoriesA Contrast in Case Histories
• Removed old system and installed new CEM in three days – during scheduled outage
• No overlap with original CEM• RATA test within 10 days• No “Phase I” submittal
– letter notification• No NOx Budget Issues
Waste Coal Plant – Utah
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EcoChem’s Suggestions EcoChem’s Suggestions for a “Win-Win” CEM Upgradefor a “Win-Win” CEM Upgrade
• Build in sufficient scheduling contingency - allow 9-12+ months depending upon scope
• Allow appropriate overlap with existing CEM – You usually don’t have a choice!
• Don’t forget training and spare parts inventory
• Use experienced CEM integrator & DAS vendor
• Pray for Rev 8 to be more efficient