Presentation by President of CMC Solutions to PNWIS & AWMA (Pacific Northwest International Section of the Air & Waste Management Association) CMC Solutions was retained to perform a demonstration of a statistical hybrid predictive emissions monitoring system (PEMS) under 40 CFR Part 75, Subpart E. The PEMS was deployed in September of 2010 for stack gas flow and pollutant emissions. The demonstration confirmed that the PEMS passes all the statistical tests for the 720 hour demonstration period. Summary Statistical hybrid PEMS have been successful in meeting the requirements of the U.S. emission trading program PEMS achieve very high accuracy levels PEMS demonstrate superior reliability PEMS are certified as an alternative to CEMS PEMS are a cost effective alternative to a CEMS

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PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Presented by:
Brian Swanson, President
CMC Solutions, L.L.C.
Replacing a Stack Gas Flow Hardware
Device with PEMS
1

2. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Introduction
 CMC Solutions was retained to perform a
demonstration of a statistical hybrid predictive
emissions monitoring system (PEMS) under 40 CFR
Part 75, Subpart E.
 The PEMS was deployed in September of 2010 for
stack gas flow and pollutant emissions.
 The demonstration confirmed that the PEMS passes
all the statistical tests for the 720 hour demonstration
period.

3. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS Technology
 Early models included first principle theoretical
models by OEMs.
 Commercial PEMS available on the market include
first principles and empirical models.
 Empirical models such as neural network and
statistical hybrid have passed EPA requirements.
 Hundreds of PEMS are used in the U.S. today for
compliance monitoring under EPA rules.

4. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Performance Testing Methods
 40 CFR Part 75, Subpart E demonstration – 720 hours
of PEMS vs. CEMS data, 24 hours each additional fuel
 PS-16 Relative Accuracy Test Audit (RATA)
 27 runs (9 at each of three loads)
 Relative Accuracy FLOW PEMS was 2 percent
 F Test
 Correlation
 Data Availability

5. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PS-16 RATA Testing
 27 Run RATA Testing

6. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS QA
 Sensor validation – model envelope excursions for
empirical models
 Sensor quality assurance and PEMS QA programming
 Periodic Audits (RAA)
 Annual recertification (RATA) tests
 Model updates and tuning of empirical models

7. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS QA Programming
 QA Plan developed around input parameters
INPUT DESCRIPTION UNITS MIN MAX
Input24* Unit Load Set Point MW 2.34 99.92
Input56* Total Gas kscfh 0.60 1003.96
Input4 Boiler Feed-water flow kpph 0.00 748.10
Input22 Unit Megawatts MW 0.00 101.92
Input23 Unit Megawatt Demand MW 0.00 100.09
Input34 1st Stage Pressure psi 0.00 1371.40
Input37 Hot Reheat Steam Pressure psi 0.00 442.30
Input45 TopWind-box Pressure inwc 1.20 37.60
Input46 MIDWind-box Pressure inwc 1.30 27.12
Input47 BTMWind-box Pressure inwc 0.10 29.60
Input60 Auxiliary Steam Pressure DMD % 0.00 100.00
Input74 Steam Flow kpph 1.30 684.70
TABLE II - MODEL ENVELOPE

8. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Results
 The raw minute data output from the CEMS data
acquisition system was quality assured. The PEMS
was deployed in the September of 2010 for stack gas
flow and pollutant emissions.
 An X-Y plot of the PEMS values against the CEMS
values is presented. Also included in the report is a
graph of the percentage differences between the
CEMS and PEMS for each hour record.

9. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Performance Evaluation
 Statistical Hybrid PEMS met requirements.

10. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Performance Evaluation
 Stack Gas Flow PEMS vs. CEMS XY Plot
0
50
100
150
200
250
300
350
400
450
500
0 50 100 150 200 250 300 350 400 450 500
StackFlow-CEMSkM3/hr
Stack Flow-PEMS kM3/hr

11. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Performance Evaluation
 Stack Flow Rate PEMS vs. CEMS X-Y PLOT.
-250
-200
-150
-100
-50
0
50
100
150
200
250
1 51 101 151 201 251 301 351 401 451 501 551 601 651 701
PercentageDifferenceCEMSvsPEMS
Hours

12. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Performance Evaluation
 Statistical Hybrid PEMS met requirements.
Test Value EPA Limit High/Low Limit Pass/Fail
FTest
0.845
<
0.88 High Limit Pass
Correlation
0.899
>
0.8 Low Limit Pass
Data Availability
0.97
>
0.9 Low Limit Pass
TABLE I – 720 HOUR STATISTICAL ANALYSIS

13. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Conclusion
 CMC Solutions PEMS was capable of meeting the most
stringent requirements for monitoring stack gas flow
on gas and oil fired boilers.
 The PEMS was reliable and accurate.
 The demonstration confirmed that the PEMS was
accurate under both base-load and startup conditions
along with transitional load periods.

14. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Introduction
14
 Federal regulations require continuous
monitoring of NOx , CO, SO2, O2 and/or CO2 from
industrial processes in the United States
 A statistical hybrid PEMS has been employed at a
number of compliance sites in the United States
 Brief History of CEMS/PEMS development
 PEMS have been used for compliance since the 70’s
 Advantages of PEMS
 PEMS are less Costly
 PEMS are easier to maintain

15. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
CEMS Components / Maintenance
 Sample Probe
 Umbilical
 Analyzers
 Gases
 Pumps
 Filters
 Controllers
 Computer
 Air Source
 Spare Parts

16. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Why consider PEMS?
 SmartCEM® is a proven and patented product
 Guaranteed to meet U.S. EPA regulations
 Supported by a network of professionals
 Virtually no maintenance or operational costs
 PEMS model can be updated by owner
 In addition, SmartCEM® can be setup quickly
 The model is developed and retrained onsite
 Replaces your existing CEMS
 No spare parts, analyzer repairs, emergency service

17. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS History and Use in Compliance
Monitoring for 40 CFR Regulations
17

18. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS Design and History
PEMS are not new, they evolved …
 Introduced in the 1970s
 Parametric and First Principles initially
 First PEMS were NSPS (40 CFR Part 60)
 OEM models, GE, Solar, others (~ 500 worldwide)
 Empirical Methods introduced in the 1980s
 PEMS on the market today are theoretical First
Principles (Parametric) and Empirical (Neural
Network, and Statistical Hybrid Methods)

19. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
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 and 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 (SO2, NH3, CO or VOC
PEMS optional measurements)

20. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
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

21. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS Classifications
21
 Parametric Systems
 Predictive Systems
Theoretical
 “First principle” method
Empirical
 Neural network
 Statistical hybrid

22. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Parametric Systems
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23. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Features of Parametric Systems
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 Simple formulaic approach
 Accuracy is very limited
 No flexibility – if signal is lost, no prediction is available
 Do NOT predict excess emissions
 Are NOT certified as an alternative to CEMS
 Acceptable for peaking units with less than 10% operating
time in a given year

24. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Theoretical Predictive Systems
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25. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Features of Theoretical PEMS
25
 Complex formulaic approach
 Accuracy is maintained when unit is operated as it was in
the factory or under similar ambient conditions
 No flexibility – if critical signals are lost, prediction is lost
 Can only be verified against limited factory test data
 Can be certified as an alternative to CEMS
 Many implementations have been removed due to failure
to meet ongoing quality assurance tests or respond to unit
changes that are not reflected in the formula
 Expensive to maintain and requires specialized staff

26. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Empirical Neural Network Predictive
Systems
26

27. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Features of Neural Network PEMS
27
 Complex neural network approach
 Requires extensive up front testing with specialized staff
onsite in an iterative process
 Accuracy is maintained when unit is operated as it was in
the initial setup or under similar ambient conditions
 Can be certified as an alternative to CEMS
 Some implementations have been removed due to
expense and support required to pass QA audits
 Expensive to maintain and requires specialized staff

28. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Empirical Statistical Hybrid Model
28

29. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Features of the Statistical Hybrid
29
 Robust Model that is accurate across the full load of the
unit including all normal operating conditions and during
transitional states such as startup and shutdown
 Equivalent accuracy as a CEMS with superior reliability
 Flexibility to be implemented using existing
instrumentation
 Can certify as an alternative to CEMS
 Systems in operation around the world today on gas
turbines both in the U.S. and in the E.U.
 Virtually no maintenance – no specialized staff required
and can be maintained by operators or other staff onsite

30. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Statistical Hybrid Advantages
30
 Requires no specialized staff to maintain
 Model can be developed without a great deal of
knowledge of the underlying process or chemistry
 Highly reliable with options for data recovery
 Minimize or eliminate monitor downtime
 Can generate predictions with a variety of inputs
 Can generate predictions with inputs that fail
 Can be retrained by non-specialized staff

31. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Features of the Statistical Hybrid
31
 Can be assessed using quality control procedures defined
to meet the requirements of U.S. EPA
 Can be developed and retrained by non-technical onsite
staff or consultants using third party test data during
normal operations
 Can be tested against EPA reference methods and has been
demonstrated at multiple sites on various gas turbine
classes to meet 40 CFR Part 75, Subpart E

32. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Example Applications
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33. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Applications
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 Gas and liquid fuel fired turbines
 Gas and liquid fired boilers
 Gas fired ethanol plant boilers
 Petroleum refinery processes
 Other continuous systems

34. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Gas and Liquid Fired Turbines
34
 Applied to turbines from 60kW to 180 MW
 Fuels included natural gas, deisel, and fuel oil
 Equipped with a variety of control technologies
including dry low NOx, steam and water injection,
SoloNox, and post combustion SCR
 Turbines were from a variety of manufacturers

35. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
NOx PEMS Time Plot
35

36. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
NOx PEMS XY Plot
36

37. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Gas and Liquid Fired Boilers
37
 Applied to boilers from 100 mmBTU to 750 mmBTU
 Fuels included natural gas, blast furnace gas, coke
oven gas, refinery gas, and fuel oil
 Equipped with a variety of control technologies
 Boilers were from a variety of manufacturers
 PEMS developed with existing instrumentation and
input parameters readily available from distributed
control system

38. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Oil Fired Boiler O2/NOx Time Plot
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39. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Oil Fired Boiler CO/CO2 Time Plot
39

40. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA Test Results
Relative Accuracy Test Audit (RATA) was conducted to certify
the results
40

41. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA Test Procedures
41
 Uses U.S. EPA reference methods (RM)
 The RM was compared to the PEMS predicted
emissions
 The process was tested under three operating loads
 3 or 4 test runs conducted at each load with a
duration of 21 minutes each

42. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA Conducted on 3 Processes
42
 Ethanol plant boiler rated at 100 mmBTU/hr located in
Western Iowa
 170 MW combined cycle turbine at a power plant in
Detroit, Michigan
 750 mmBTU/hr boiler firing pipeline natural gas and
blast furnace gas

43. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA at Ethanol Plant
43
0
0.01
0.02
0.03
0.04
0.05
0.06
0.07
0.08
0.09
0.1
1 2 3 4 5 6 7 8 9 10 11 12
Test Run
NOxlb/mmbtu
RM
PEMS

44. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA on Power Plant Turbine
44
0.027
0.028
0.029
0.030
0.031
0.032
0.033
0.034
1 2 3 4 5 6 7 8 9
Test Run
NOxlbs/mmbtu
RM
PEMS

45. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
RATA at Power Plant Boiler
45
0.000
0.020
0.040
0.060
0.080
0.100
0.120
0.140
0.160
1 2 3 4 5 6 7 8 9
Test Run
SO2lb/mmbtu
RM
PEMS

46. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS Quality Assurance
46
 Instrumentation was subjected to annual QA
 QA follows 40 CFR Part 75, Appendix B
 QA manual is prepared and placed next to PEMS
server for documenting all QC activity
 System maintenance, database maintenance, and data
backup procedures are instituted
 All PEMS QC procedures and audits are documented
in QA manual

47. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Summary
47
 Statistical hybrid PEMS have been successful in
meeting the requirements of the U.S. emission trading
program
 PEMS achieve very high accuracy levels
 PEMS demonstrate superior reliability
 PEMS are certified as an alternative to CEMS
 PEMS are a cost-effective alternative to a CEMS

48. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
PEMS vs. CEMS XY Plot
48

49. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Concluding Remarks
49
 Advanced empirical PEMS have been used
successfully in the U. S. for 40 CFR Compliance
 PEMS achieve very high accuracy levels
 PEMS demonstrate superior reliability
 PEMS can be certified as an alternative to CEMS
 Some PEMS require no specialized support making
them ideal for offshore and remote applications
 A robust statistical hybrid model is a cost-effective
solution for continuous monitoring applications

50. PNWIS & AWMA 52nd Annual Conference | Portland, Oregon The Nines Hotel | November 7 through 9, 2012
Questions?
CEMS? , or … PEMS!
Which would you prefer, if you had a choice -