When it comes to managing DAS and CEMS systems, there are some common challenges that arise. Compliance Managers must have access to the most current and thorough emissions data to ensure regulations are being met. Here are five common DAS and CEMS operations concerns and accompanying solutions:
1. Multiple Regulations
Combustion units are typically subject to multiple air regulatory programs. More often than not, different rules require different validations, averaging, calculations and/or reporting. Steps you can take to address this problem include fully understanding your company’s compliance obligations (NSPS, NESHAPS, Title V), determining if “harmonization” is permitted among the various programs, and checking DAS documentation and the QA/QC Plan to make sure you’re in compliance with all necessary validation and ongoing QA tests.
2. Equipment Range and Scaling
When CEMS measurements are “pegged” at the full-scale range of the analyzer it can not only be frustrating but also a compliance issue. Additionally, it may be problematic when systems are unable to measure and record negative readings. Beyond researching and understanding your compliance obligations, you can review your DAS programming. Correct any hardware or software limitations that have been preventing recording when required. You may find it’s time to upgrade your DAS.
3. Fuel Flowmeter
There are several challenges that can afflict proper fuel flowmeter operations. One issue could be your initial certification documents are missing, incomplete, or don’t meet Part 75 requirements. Another common issue is default or inaccurate constants preloaded into the flow computer or DCS. You may even discover that the measurement and/or scaling of signals to your DAS are incorrect. Resolutions to these challenges include holding the EPC accountable and tracking down the necessary information, coordinating with engineering to verify calculations and programming, and performing a reality check on data.
4. Late or Incomplete QA Test
Missed or incomplete testing can result in excessive downtime. Excessive downtimes can be very expensive for sources in trading programs such as ARP, SIP, CSAPR, and RGGI. One way to combat these challenges is to be proactive with tracking QA test deadlines – don’t wait for ECMPS to tell you. Having a thorough understanding of what qualifies for an extension and/or grace period can help ensure you’re conducting and submitting information on time.
5. CO2 Control Chart Inquiry
No one wants to receive an email from their Regional EMB Analyst that articulates you have had a sample line leak and potentially under-reporting emissions. It’s equally discouraging to fail the EPA’s CO2 control chart check, especially for sources in an emission trading program. Combat these challenges by running the data before the EPA even sees it to make sure it’s properly aligned. Study the test to have a more robust understanding of it and be communicative with your technicians. Be ready to state your case!
If you’ve been in an industry with emissions regulations for a few years, you know that mistakes turn into lessons learned. Keep track of past mistakes and how you came to address them for future reference and the training of new employees. Having a comprehensive understanding of your systems, regulations updates, equipment updates, and requirements is a surefire way to manage your DAS and CEMS. Need help learning and practicing best management tactics? Discover how VIM’s COMPAS team can support you.
