Past RMB Projects
The following sections provides a synopsis of some of RMB's past projects
The development and implementation of continuous emission monitoring system (CEMS) compliance programs is one of RMB’s principal service areas. RMB can provide clients with a turnkey CEMS procurement package or consulting services for individual facets of a procurement project. In addition to project oversight and regulatory assistance, project tasks typically include, but are not limited to:
- Develop monitoring strategy based on site-specific conditions and applicable regulatory requirements. This is an important element of the project since complete compliance often cuts across several Federal and state regulations.
- Develop a comprehensive bid specification for the CEM and DAHS and evaluate vendor proposals.
- Develop required Quality Assurance and Monitoring Plans.
- Conduct CEMS factory acceptance tests.
- Prepare test protocols, review certification test reports and prepare certification applications.
Each year RMB works with utilities to install new CEMS or upgrade existing equipment (hardware and/or software). Since most utility sources were required to install CEMS per Part 75 much of our work now deals with turbines, Appendix D&E DAHS installations and DAHS upgrades. RMB is also assisting industrial sources for complying with the upcoming NOx monitoring requirements. A summary of current and/or recent CEM procurement projects is presented below.
Example Project 1. RMB is currently providing consulting services to a large cogeneration facility for the development and implementation of a CEM program. Monitoring systems will be required for twelve units in order to comply with the requirements specified in 40 CFR Part 97, the "Federal NOx Budget Program" as well as 40 CFR Part 75. Project tasks include project oversight, site evaluation, the development of a comprehensive bid specification for twelve CEMS, evaluation of CEM vendor proposals, development of Monitoring Plans and Quality Assurance (QA) Plans, preparation of certification test protocol and certification applications.
Example Project 2. RMB recently completed projects for two mid-western utility companies for the procurement of Part 75 Appendix D and E DAHS and NOx CEMS. The DAHS is being used to comply with the requirements specified in Appendices D, E and G of Part 75, as well as specific permit reporting specifications. The projects encompassed 13 natural gas-fired combustion turbines and three boilers located at six electric generating stations. Both projects were aggressively scheduled to ensure unit operation during upcoming peak electrical demand periods. RMB was responsible for the development of detailed bid specifications for equipment procurement and evaluating vendor responses. Additional project support included preparing QA Plans, Monitoring Plans, certification notices and applications, site-specific test protocols, certification test reports, and other documents required by 40 CFR Part 75 and applicable state agencies.
Example Project 3. RMB is currently providing consulting services to a mid-western refinery for the procurement of CEMS to comply with the requirements of 40 CFR Part 97. The project includes an affected unit and a non-affected unit. The configuration of the units is unique and is not specifically addressed in Parts 97 and 75. RMB has worked with refinery personnel to develop a monitoring approach as well as a petition requesting EPA approval of an alternate method for determining volumetric flow from the non-affected unit. Additional project tasks include, but are not limited to, the development of CEM bid specification, evaluation of CEM vendor proposals, development of Monitoring Plans and QA Plans, preparation of certification test protocol and certification applications.
Example Project 4. RMB personnel provided overall project management and consulting services to a mid-western utility for the procurement, installation, start-up and certification of seven Part 75 CEMS. RMB prepared the bid specifications for equipment procurement and evaluated vendor proposals. Additionally, RMB personnel made recommendations on numerous specific aspects of the CEMS design and equipment installed, and provided oversight during all installation, start-up and certification activities. CEMS program support also included preparing QA plans, Monitoring Plans, certification notices and applications, certification test reports, and other documents required by 40 CFR Part 75.
Example Project 5. RMB personnel provided CEMS procurement consulting services for two natural gas pipeline companies. RMB personnel prepared comprehensive CEMS bid specifications in order to procure a CEMS for each company that would monitor NOx, CO, and total hydrocarbon (THC) emissions from reciprocating engines. Proposals were evaluated to determine if they met minimal acceptance criteria, and a detailed analysis of remaining proposals was performed to determine conformance with technical specifications. RMB personnel assisted in interfacing with the successful bidder to ensure contract conformance, including conducting a factory acceptance test of the CEMS and DAHS. RMB also reviewed and provided recommendations for revising vendor prepared QA Plans.
Example Project 6. Since 1997, RMB has provided general consulting services to a large northeastern refinery for complying with the requirements specified by the Ozone Transport Commission (OTC) NOx Budget Program, 40 CFR Part 75, as well as 40 CFR Part 97. During the course of the project, RMB services have included, but not been limited to:
- Developing a petition which was approved for monitoring coke flow in lieu of installing a volumetric flow monitor.
- Preparing Monitoring Plans for a variety of sources, including process heaters, combined-cycle turbines, and boilers.
- Developing CEM QA Plans for several sources.
- Preparing numerous source-specific test protocols.
- Providing a two-day training course to approximately 30 personnel that focused on the monitoring, QA/QC, reporting and recordkeeping requirements specified in 40 CFR Part 75 and the OTC NOx Budget Program.
Example Project 7. RMB is currently providing services to a northeastern refinery for the procurement of two CEMS to monitor emissions from two Polypropylene Thermal Oxidizers. The CEMS are being installed to comply with specific operating permit requirements. Each CEMS will include analyzers to monitor SO2, NOx, CO, VOCs, O2, volumetric flow, and moisture content. Data will be collected by a DAHS. At this juncture, RMB has developed a detailed bid specification and is evaluating the CEMS vendors’ proposals. Additional project tasks include the development of a detailed performance specification test protocol, attend factory acceptance tests, and prepare a QA Plan.
RMB’s staff continues to remain on the leading edge of current CEM technologies, including mercury and particulate matter CEMS. A brief summary of relevant projects is presented below.
EPRI’s Advanced QA/QC for CEMS Project
Since 1997, RMB has served as EPRI’s primary technical consultant for its "Advanced QA/QC for CEMS" project. One project objective is to develop alternative and/or additional Part 75 CEMS program activities that will reduce the cost of operating and maintaining CEMS. A second objective is to improve accuracy and reliability of the CEMS data. In 1999, EPRI published Optimizing CEMS Performance Through Advanced QA/QC Practices (Palo Alto, CA: TE-114127), written by RMB. This document also discussed the results of EPRI’s CABLE study which was designed to resolve observed differences between dilution CEMS measurements and extractive Reference Method analyzer measurements. In 2000, EPRI published the final project report, Advanced Quality Assurance and Quality Control Guidance for CEMS (Palo Alto, CA:1000312), written by RMB.
Revisions to EPRI's Continuous Emissions Monitoring Guidelines
In 2017, RMB completed a substantial revision to EPRI's Continuous Emissions Monitoring Guidelines (Palo Alto, CA: 1999. TR-111165.) to address significant changes to 40 CFR Part 75. EPA’s 40 CFR Part 75 requirements represented a major change in CEM regulations and resulted in a greatly expanded role of CEM technology in the electric utility industry. These new technology-forcing regulations necessitated extensive revisions to every section of EPRI's CEM guidelines manual. Under this contract, RMB staff worked closely with EPRI's CEMS Technical Advisory Committee and utility membership to produce a revised guidelines manual that clearly delineates EPA's complex Part 75 regulations, including rigid performance specifications and QA procedures, flow monitoring requirements, complex missing data procedures, and extensive recordkeeping and reporting requirements. As a related service to its member companies, EPRI continues to retain RMB staff to conduct CEMS-related training courses and workshops on CEMS technologies, CEMS program implementation, initial certification and relative accuracy test observation activities, and comprehensive QA/QC program development.
Particulate Matter CEM Systems Evaluation Project
RMB also directed EPRI’s second particulate matter (PM) CEMS evaluation project. Four PM CEMS have been installed at a mid-western coal-fired boiler. The boiler combusts coal from the Powder River Basin. The initial calibration testing was conducted in July 2000. Additional field testing will be performed in October to evaluate PM CEMS robustness and calibration stability.
In 1998, RMB also managed EPRI’s Compliance Assurance Monitoring (CAM) Field Demonstration Project. The CAM project was designed to evaluate two distinctly different approaches for formulating a CAM plan for particulate emissions for coal-fired utility boilers. During the project, four PM CEMS as well as three ESP computer models were evaluated over the course four months.
Mercury CEM Systems
RMB continues to serve as EPRI’s technical consultant for evaluating mercury CEMS. During EPA’s recent mercury Information Collection Request (ICR), RMB assisted EPRI in reviewing and analyzing the Part II coal data. RMB also assisted in identifying "outliers" and other potential data entry errors. With respect to the Part III stack sampling, RMB assisted EPRI in identifying and pre-qualifying testing contractors to conduct the required speciated mercury stack sampling as part of an EPRI tailored collaboration (TC) project. RMB observed and provided independent, third-party quality assurance (QA) audits for each of four testing contractors. RMB also assisted EPRI in analyzing all of the ICR data and in developing independent estimates of annual mercury emissions for all coal-fired power plants in the U.S.
Presently, verification of mercury CEMS is being conducted under EPA’s Environmental Technology Verification (ETV) Program. EPA instituted the ETV Program in 1997 to evaluate innovative technologies designed to prevent, control and clean up pollution. EPA established ETV to "substantially escalate" the introduction of environmental technologies to the marketplace. Mercury CEMS verification is being conducted under the Advanced Monitoring System (AMS) pilot, one of twelve ongoing pilots. RMB intends to follow closely mercury CEMS technology and associated mercury regulatory developments.
Each year, RMB prepares or revises numerous CEM QA/QC manuals for utility and industrial clients. In addition to the 40 CFR Part 75 requirements, the QA/QC Plans are often required to comply with other regulations, specific permit requirements and/or guidance documents. RMB has developed both "corporate-type" QA/QC Plans that focus on the regulatory requirements and reference other CEM procedures, as well as the more comprehensive QA/QC Plan that includes step-by-step procedures. The corporate-type QA/QC Plan format essentially instructs plant personnel on what has to be done without detailing how to do it. The positive aspect of this approach is the flexibility afforded each individual plant. However, EPA's requirements to maintain specific information and procedures cannot be avoided, and this "corporate document" approach places all responsibility on the plant personnel to maintain and update the document(s) which provide this additional information. This approach differs from a comprehensive QA/QC Plan which includes all required step-by-step procedures, typically presented as appendices to the QA/QC Manual.
RMB performs between five and ten CEMS program reviews and audits for utility clients each year. Because of our long history with, and exposure to many different clients’ CEMS programs, RMB brings a unique perspective to the review process. Our CEMS program reviews focus on regulatory compliance, however; our extensive background also allows for a complete review of the program process and implementation. In other words, we can evaluate the efficiency of your entire CEMS program, develop benchmarks to other utility programs and identify areas where efficiency improvements can be made. RMB personnel have the experience to dig beneath the typical "check sheet" questions used by other CEMS consultants to uncover both good and bad practices. Now that EPA has developed and is preparing to implement its CEMS audit program, it is more critical path than ever to conduct your own audit.
To date, monitor data availability has been the primary benchmark used by personnel to rate the effectiveness of a CEM program. Unfortunately, this rule of thumb overlooks the importance of CEMS accuracy. Experience shows that in many cases, sources are over-reporting emissions by 10% or more. This can be especially punitive for those sources involved in both SO2 and NOx trading programs. Although data availability continues to be important, data inaccuracy can result in real and potentially substantial monetary losses. RMB is working with several clients to improve CEMS performance and accuracy, reducing or eliminating CEMS biases.
RMB is currently providing consulting services to five utility clients for enhancing CEMS operation and accuracy. RMB’s five projects encompass 16 generating stations and approximately 28 CEMS. During these projects, RMB has or will conduct a detailed onsite evaluation of each CEMS. Typical CEMS problem areas include sample conditioning systems, sample pumps, and data biases associated with dilution ratio fluctuations. In addition to providing recommendations for improving CEMS equipment and maintenance procedures and facilitating the implementation of these procedures, RMB also provides training for personnel with CEM program responsibilities.
Just prior to the May, 2001 EPRI CEMS User Group Meeting in Charlotte, North Carolina, where RMB taught a course on CEMS Program Optimization. This course addressed enhanced operation and maintenance procedures, recommended equipment/design improvements, and important regulatory aspects associated with optimizing a Part 75 CEMS Program. Course discussions focused on ways to reduce CEMS program costs by (1) implementing an effective O&M strategy, (2) enhancing the performance of specific CEMS components, (3) improving CEMS accuracy and stability, and (4) minimizing regulatory complications.
RMB offers a wide variety of regulatory and CEM program related training programs. RMB invites the reader to review information concerning our training courses, including our semiannual CEMS Training Program at Training.
CEMS Users Training Program
Since 1996, RMB has presented a semi-annual CEMS Users Training Course in Raleigh, North Carolina. Topics include regulatory requirements and revisions, CEM technologies, CEM QA/QC, CEM program auditing, and Hg and PM CEMS. EPA representatives and CEM equipment vendors often join RMB staff members as instructors. In the past, the course has been attended by utility personnel from the United States and abroad, as well as federal and state agency representatives.
OTC Continuous Emission Monitoring Requirements
RMB recently developed and presented a course to a northeastern utility which focused on the monitoring requirements specified by the Ozone Transport Commission’s (OTC) NOx Budget Program. The course was presented to over thirty personnel during a two-day period. Topics included OTC requirements, Part 75 requirements, CEM QA/QC, as well as record-keeping and reporting requirements.
Many utilities have found that continuous emissions monitoring systems (CEMS) are generating consistently higher heat input and mass emission values than conventional methods. The discrepancy, prevalent across the industry, is causing utilities to report greater heat input and SO2/NOX/CO2 mass emissions, with significant implications. Positive bias in the CEMS measurements translates directly into over-reporting of allowances under the Acid Rain and CSAPR Programs, with millions of dollars of impact. In addition, many utility boilers have operating permits that contain heat input and mass emission limits and, in the past, compliance with these limits has been demonstrated with fuel analysis. However, some state agencies and EPA regional offices have begun using the CEMS data to evaluate compliance with the permit limits and have started applying pressure on utilities showing "excess" emissions and heat input. CEMS bias may also introduce technical, and possibly legal, concerns into the Title V permitting process.
Coupling RMB's experience in evaluating power plant performance and CEMS bias with our knowledge and understanding of the environmental regulations involved makes us uniquely qualified to assist our clients in evaluating the sources of CEMS bias. RMB has conducted a number of CEMS bias/heat rate tests for both utility and non-utility clients and conducted an EPRI-funded research project to identify the cause of the high heat input and mass emission measurements. Through the EPRI project we were able to identify and quantify various sources of error in the CEMS measurements. Although flow measurement was not the sole culprit in all cases, the EPRI study found it to be a significant contributor to the overall problem. In response to the EPRI study, EPA initiated a number of field tests to evaluate possible modifications to Method 2, which were promulgated in 1999 along with revisions to 40 CFR Part 75. Beyond the initial study, RMB has also been involved with supplemental research in conjunction with EPRI to investigate CEMS bias issues, such as a project that developed correction algorithms for dilution-based systems and an on-going project to identify CEMS design modifications that will reduce operation and maintenance (O&M) costs and/or improve CEMS accuracy.
RMB has helped a number of its clients to determine the most prudent and cost effective method to reduce costly CEMS measurement bias at their plants. While the best approach or combination of approaches can vary from site-to-site, RMB has brought together its knowledge, testing expertise, and careful data analysis skills to develop and evaluate potential options for eliminating or reducing measurement error such as:
- Potential analyzer maintenance recommendations
- Employing dilution correction algorithms
- Use of new volumetric stack flow reference methods techniques
- Flow straightening or conditioning options
- Alternative monitoring locations/testing and approaches
- Special QA/QC requirements and recommendations
This has allowed our clients to increase the accuracy of their CEMS measurements and let them realize substantial cost saving by reducing their total reported emissions.