Our work together began in 1990, when amid tightening environmental regulations and a drive for innovation they sought improved methods to meet new requirements for more frequent and accurate emissions reporting.
Most solutions at this time were hardware based, bringing higher costs of ownership and carbon emissions, both at odds with the client’s strategic priorities. Dedicated to sustainable operations, the company needed a cost-effective, reliable emissions monitoring solution, to ensure regulatory compliance and align with their environmental commitments. Developing a comprehensive understanding of emissions over time is crucial for compliance and sustainability; scalable improvements require a solid foundation of data and traceability. We were engaged to implement and validate the efficacy of a software-based continuous monitoring solution to both address regulatory requirements and create this data foundation.
Our work resulted in 99% monitoring uptime and over 25 continuous years of passed Relative Accuracy Test Audits (RATAs), supporting not only regulatory and operational goals, but crucially the client’s brand promise of environmental stewardship.
We partnered with the Client to implement a Software Continuous Emission Monitoring System (Software CEM®)
Work began in 1999–2000, with all models operational by 2001. We conducted rigorous testing and validation to demonstrate the solution's effectiveness to both company leadership and regulatory bodies.
Our approach was highly optimized, focusing on sustainability and working within existing constraints:
Leveraged Existing Instruments — The Software CEM® used existing process data from field instruments (e.g., fuel flow, air temperatures) to feed into mathematical models that accurately calculate emissions.
Eliminated Physical Analyzers — By utilizing predictive emissions monitoring, the need for physical hardware analyzers and related infrastructure was removed.
Secured Ongoing Scalability and Flexibility — Created predictive models for each of the 31 furnaces, allowing for easy updates and adjustments as operational conditions changed.
Regulatory Compliance — Conducted rigorous testing and validation against certified hardware analyzers to ensure the software's accuracy met or exceeded regulatory standards.
When the company upgraded to low-NOx burners in 2004-2005 to reduce emissions further, the Software CEM® models were seamlessly updated to accommodate the new equipment. Subsequent burner replacements required no additional changes, demonstrating the robustness of the solution.
Traditional Hardware-based Continuous Emission Monitoring Systems (CEMS) come with significant capital and environmental costs:
- Significant Capital Expenditure — Purchasing and installing 31 physical analyzers, shelters, heated sample lines and calibration gases requires substantial investment.
- High Maintenance Costs — Continuous upkeep of hardware analyzers, including regular calibration, part replacements and specialized personnel, increases operational expenses.
- Operational and Regulatory Risk — Physical analyzers break down, especially in harsh industrial environments, leading to increased monitor downtime and potential non-compliance with regulations that mandate minimum uptime requirements.
- Increased Carbon Footprint — The operation of hardware analyzers and associated equipment consumes additional energy and resources, conflicting with the company's sustainability goals.
Our work enabled continuous emission monitoring while minimizing downtime, reducing costs and protecting brand reputation
Our solution delivered substantial cost savings by eliminating hardware expenses, while achieving industry-leading 99% uptime. By removing physical analyzers, we reduced both carbon footprint and maintenance needs. The adaptable, scalable system powers continuous compliance across remote locations, and has established new standards for emissions monitoring in the industry.
The groundbreaking approach drove industry-wide adoption of Software CEM®s and influenced the U.S. Environmental Protection Agency (EPA) to establish Performance Specification 16 (PS-16) in 2009. This federal standard validated predictive emissions monitoring systems, accelerating their adoption across industries and promoting sustainable practices and setting new benchmarks for environmental compliance globally.
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