Environmental Compliance – Moving Beyond Spreadsheets
Streamlined Part 60 and other CEMS Based Compliance
Enforcement of environmental regulations in process facilities with emissions sources is becoming increasingly prevalent. Compliance is often based on data gathered from continuous emissions monitoring systems, or CEMS. Penalties and fines associated with violations have made accurate monitoring, calculating, and reporting emissions a strong economic factor in the operation of these facilities. Minimizing the occurrence of inaccurate data and avoiding late data reports is necessary to reduce the costs associated with maintaining compliance.
The Spreadsheet Solution
Currently, many facilities bring CEMS data into spreadsheets to perform most of the required calculations for compliance. Data in these spreadsheets usually needs to be manually scrubbed to account for anomalies due to monitoring or operating issues that may render data invalid.
There are many disadvantages inherent to the spreadsheet solution:
- It requires a large amount of work devoted to performing data processing and arithmetic.
- The calculations are obscured behind complex spreadsheet equations that are typically only known to a small number of people. This makes it difficult to transfer responsibility for these actions and there is a steep learning curve to overcome.
- Results may not be repeatable due to the large amount of manual effort involved in the calculations. There is not much traceability or transparency.
- The results are not easily shared within the organization or with regulatory agencies since they only exist in flat files that have to be passed around. This reduces data integrity and creates issues with versioning.
Exele’s PI-DAS system addresses all of these issues and provides an automated and reliable environmental compliance solution. Most implementations of PI-DAS are based on OSIsoft PI as the data historian although other historians have been utilized.
- Raw process data is read and stored in the archive where it is then analyzed and processed with rules based validation and aggregation procedures that comply with regulatory requirements.
- Intermediate and final calculation results are stored back into the data archive allowing the same data set to be shared, trended, and reported using a set of standard and easy to use tools without jeopardizing the integrity of the calculation equations or results.
- Detailed tracing is produced so each calculation can be analyzed to see how each result was computed.
- Results are formatted for transmission to the appropriate parties.
All of these actions are scheduled to happen automatically. Calculations are rerun for a number of days to account for changing parameters affecting data substitution and invalidation.
Real-time Compliance Calculations
Each facility generally has slightly different equipment setups or data recording methods that may result in unique data signatures. Minor adjustments to processing algorithms to account for this are handled by adjustable parameters in the PI-DAS system.
Compliance calculations involve data substitution and other procedures that require a full day of data to be accurate. Because of this, accurate calculation results cannot be generated until after the day is over. A source may be operating in a manner that will violate limits but it will not be known until the compliance calculations are run and the limit has already been exceeded. To help avoid this, PI-DAS runs real time calculations to provide up to the minute emissions values. These calculations do not perform every aspect required for reporting purposes, but they provide an early indication of what the results will be when the full calculation is run. This can alert operators that a source has been in calibration for too long or that operation level should be adjusted to avoid permit violations. These data are also used for RATA and CGA testing.
PI-DAS handles reporting requirements for 40CFR Part 60, MACT, SCAQMD RECLAIM, Title V, SCAQMD R1110.2, R1118 (Flaring), Greenhouse Gases (GHG), and others. PI-DAS has been developed with a core set of features and a flexible architecture so it can easily be configured to support requirements unique to any locality.