CSMM 8 Implementation - Lesson Learned Standards


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  • When developing this presentation there was a lot of “little things” or “lessons learned” that I wanted to include.Of course, these “lessons learned” were all over the place giving me that overwhelming feeling of “where do I go from here?”In an attempt to bring it all together, I organized the presentation in the following format;Background – First take a step back.Implementation Process – Description of the transition to Revision 8 “Where most of you are now”.Lesson Learned – During the discussion of the implementation process, I will highlight some of the “lessoned learned”.
  • Revision 8 applies to source in PA that most comply with 25 Pa. Code § 139.102(3)If you are requirement to used a Continuous Monitoring System (CMS) to demonstrate compliance with a permit condition, most likely this applies to you.Major Changes from earlier versions Revision 6 or 7 (or some may consider “what was accomplished”) by Revision 8.It streamlined Data Validation Requirements with Part 75 (and even Part 60 in most cases) – Meaning that except for CO, temperature, and opacity a valid hour is defined as 1 valid reading in each 15 minute hourly quadrant while the unit is operating.No more 75% minutes in the hour validation for PA.CO, temperature, and opacity hourly validation is based on 75% of the hourly segments corresponding to the minimum cycle time. For example, minimum cycle time for CO is 5 min or 12 segments in an hour. The hourly validation for CO would be 75% of 12 segment or 9 valid readings per hour.The reporting format change. All of you left EPA’s text based electronic data reports (EDR) behind when you transitioned to ECMPS and the .xml format. Revision 8 fills your EDR void. Revision 8 files are flat txt files that include record types. One file per facility that has all of your facility data.No more separate txt files per analyzer. QA activities that are more similar to Part 75. No more Rev 6/7 QA activities based on a October 10, 1979 Proposed Rule.
  • To transition to Revision 8 each facility must go through an implementation process.Show of hands:How many of are affected by Revision 8?How many of you have completed the Revision 8 process and are currently uploading quarterly data via CEMDPS?So most of you are in the Revision 8 Transition process.The process includes various activities such as:Getting access the Continuous Emission Monitoring System Data Processing System (CEMDPS)Conducting the Migration Error CheckCompleting Certification ActivitiesImplementing new QA/QC ActivitiesWithin each of these steps in the process, there are other tasks to be completed.
  • This also includes ongoing certification testing and quarterly reports. No more 3.5 inch floppies.
  • Migration Error CheckIs a review of the information PADEP has in the Legacy System. It is what they thing they know about your facility. Broken into two (2) part theStandards or a summary of the Emission Standards in which compliance is demonstrated using CMS.Tracking or the information about each monitoring system.This is the information that PADEP will expect to represent or facility. We have had to comment/correct on every single facility we reviewed.
  • These comments include:Streamlining of multiple standards – Making sure that all applicable standards have been streamlined in your permit if you are only demonstrating compliance with one standard.For example, Subpart Da has a SO2 standard so does the State or maybe a part of your permit. These emission standard be streamlined.
  • This can get tricking since many standards are in different units or averaging periods For example lb/MMBtu or ppm or even tons/year.You have to know what you are demonstrate compliance with?
  • Most of this information is straight forward. The Lowest Monitored Emission Standard Equivalent (LMESE) is were we see the most confusion.
  • The LMESE is used only for the calculation of daily drift tolerances.And is based on the ppm equivalents of an emission standards.For Part 75 and Part 60 the dominator is SPAN rather than LMESE. This will result in different daily drift tolerances depending on the regulation.
  • First get the CEMDPS review the default LMESE is ½ the full scale.One range using a LMESE and another using 2.5 % of the range.You can petition for the use of a LMESE that corresponds to the drift tolerances of other regulations.These are called Alternative or Streamlined LMESE.
  • Whatever the number is in the LMESE that is what the daily drift should be calculated.
  • One of the biggest things noticed during this process is the realization that the Revision 8 transition extends from the Environmental Department to the E&I Departments.One aspect of this process was the need for refresher training regarding the regulatory requirements for quality assuring CEMS. The E&I guys need to know why they are doing what there doing to properly quality assure the data.
  • I know that this was only highlights of the Revision 8 Transition, there is a lot more that could be shared. So if there is any questions we have a few minutes.
  • CSMM 8 Implementation - Lesson Learned Standards

    1. 1. CSMM 8 Implementation -Lesson Learned Standards Eric Swisher All4 Inc. ARIPPA 2010 Technical Symposium Harrisburg, PA August 25, 2010
    2. 2. Overview  Background  Implementation Process  Lesson Learned2
    3. 3. Background  Continuous Source Monitoring Manual (CSMM) Revision 8  Data Validation Requirements  Reporting Format  QA Activities3
    4. 4. Implementation Process  CEMDPS Access  Migration Error Check  Certification Activities  QA/QC Activities4
    5. 5. CEMDPS Access  Continuous Emission Monitoring System Data Processing System (CEMDPS) • GreenPort • Web-based portal in which all CEMS related information will be submitted.  Phase I (Monitoring Plan)  Phase II Testing  Phase III Certification5
    6. 6. Migration Error Check  Standards • Facility Emission Standards  Tracking • Analyzer Information6
    7. 7. Standards  Streamlining • “This condition also assures compliance with….”  25 Pa. Code §123.22(c)(4) [SO2]  25 Pa. Code §123.41 [Opacity]  40 CFR Part 60, Subpart Da7
    8. 8. Standards  Values  Averaging Periods8
    9. 9. Tracking  Tracking • Analyzer Type • Measurement Basis (units, wet/dry) • Manufacturer • Model No. • Full Scale Range • LMESE9
    10. 10. LMESE  Lowest Monitored Emission Standard Equivalent (LMESE ) • Lowest emission standard (i.e., lb/hr, lb/MMBtu, etc.) in terms of the analyzer output (i.e., ppm) • Used to determine daily zero/upscale calibration drift CE = | R - A | /LMESE x 10010
    11. 11. LMESE  LMESE [PADEP Default = (FS) ÷ 2]  No LMESE for: • Opacity (Abs. Difference) • CO2 (Abs. Difference) • O2 (Abs. Difference) • VFR (most cases 2.5% range) • Dual Range Analyzers?11
    12. 12. Alternative LMESE  VFR (FS Range = 150,000 scfm) • No flow standard • Maintenance Limit = ≤ 3,750 scfm (2.5% * 150,000 scfm) • OOC = ≤ 7,500 scfm (5.0% * 150,000 scfm) • Alternative LMESE = 62,500 scfm (3,750 scfm ÷ 6.0%)12
    13. 13. Example CEMDPS Information As Received Parameter Units MAN MN FS LMESE Flow scfm Teledyne 150 150,000 75,000 Corrected Parameter Units MAN MN FS LMESE Flow scfm Teledyne 150 150,000 62,50013
    14. 14. Streamlined Alternative LMESE  NOX (LMESE = 120 ppm) • Maintenance Limit = ≤ 6 ppm (5.0% * 120 ppm) • OOC = ≤ 12 ppm (10.0% * 120 ppm)14
    15. 15. Streamlined Alternative LMESE  NOX (Part 75 Span = 260 ppm) • Maintenance Limit = ≤ 6.5 ppm (2.5% * 260 ppm) • OOC = ≤ 13 ppm (5.0% * 260 ppm) • Streamlined LMESE = 130 ppm (6.5 ppm ÷ 5.0%)15
    16. 16. Example CEMDPS Information As Received Parameter Units MAN MN FS LMESE NOX ppm TECO 43C 300 150 Part 75 Petitioned Parameter Units MAN MN FS LMESE NOX ppm TECO 43C 300 13016
    17. 17. Certification Activities  7-Day Drift  DAHS Verification  Sample Reports  QA/QC Plan17
    18. 18. 7-Day Drift  Evaluates the accuracy and stability of CMS calibrations over an extended period of unit operation  Revision 6 CEMS  Uses the LMESE drift tolerances18
    19. 19. DAHS Verification  Certifies that the DAHS is functioning correctly • Normal Operating Hours • Process Down Hours • Partial Operating Hours • Invalid Data Hours • Missing Data Hours19
    20. 20. Sample Reports  Submittal of sample data via CEMDPS to ensure proper data format20
    21. 21. QA/QC Activities  Daily Calibrations  Calibration Error Tests vs. Linearity Tests  Maintenance Activities  Flow Monitor Leak Checks21
    22. 22. Other Lessons Learned  Refresher Training22
    23. 23. Questions? eswisher@all4inc.com (610) 933-5246, extension 17 All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x17 www.all4inc.com23