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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New EnclosureNew Enclosure

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Heated Probe AssemblyHeated Probe Assembly

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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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Heated PumpHeated Pump

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CEM CabinetsCEM Cabinets

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CEM Cabinet InteriorCEM Cabinet Interior

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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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Touch Screen DisplayTouch Screen Display

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Real-Time Strip ChartReal-Time Strip Chart

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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