Advanced Process Control Chats: Software Continuous Emissions Monitoring
A Conversation with Our Team of Experts
We recently discussed how organizations continue to face stringent environmental regulations. Many organizations have encountered problems with aging and obsolete systems, regulatory paperwork burdens, and pressures to reduce costs and increase profitability. The prior article discussed Software Continuous Emissions Monitoring (Software CEM®) and what organizations must consider when choosing the hardware or software path.
Thank you for the great response to the piece! We wanted to address some follow-up questions we have received from one of our co-authors, Keith Smith. Keith is a senior project engineer at Kalypso: A Rockwell Automation business and part of the technical team and product leadership for the Software CEM, commonly referred to as Predictive Emission Monitoring Systems (PEMS), product line.
What is done to get regulatory approval?
Because the US EPA regulates Software CEM, if you are required to monitor emissions under 40 CFR 60,61, or 63, you may follow 40 CFR 60 Performance Specification 16. This regulation states that Software CEM is allowed for these units; therefore, you don’t have to ask for special permission to use a Software CEM. You need to follow Performance Specification 16 and demonstrate that this criteria was followed. If you are under 40 CFR 75, follow the rules outlined in Subpart E for an ACEMS (Alternative CEMS). If you are in an EU country, follow the regulations outlined in Technical Specification 17198.
How do the regulators view the Software CEM/PEMS?
Many regulators have not heard of Software CEM/PEMS, so their initial reaction is somewhat skeptical. Once you point them to the regulations, how long they have been in place, and Rockwell's multi-decade successful track record of PEMS implementations, they begin to understand. Inform them that SoftwareCEM/PEMS has been approved for over 25 years by the US EPA in multiple states and regulators around the globe.
What are some customer opportunities you see on the horizon?
The opportunities on the horizon are remote locations, such as the Asia Pacific region, the Middle East, and anywhere where getting technicians and equipment is difficult and expensive. In these locations, hardware emission monitors are even more costly than in the usual urban factory, causing the Software CEM ROI to be much faster.
Are there benefits to leveraging what is learned with Software CEM in other areas?
When testing the combustion unit for a Software CEM, we discover much about the unit's operations and can consult with the customer on ways to improve efficiency and operations and reduce emissions. We also delve into the permit and operating procedures and constraints and improve operator instructions.
As several locations, we delved further into their operations, more than just a particular combustion unit. We found opportunities for machine learning and discovered opportunities for Model Predictive Control (MPC) that improved operations and made demonstrable production improvements.
Can you talk more about how Software CEM supports regulatory compliance? Is it approved by the US Environmental Protection Agency (EPA) or other international authorities?
The Software CEM/PEMS is approved under two US-EPA regulations Title 40 Code of Federal Regulations Part 60 Performance Specification 16 (40 CFR 60 PS-16) and it is allowed for units under 40 CFR 60, 61 and 63. For electricity producers, 40 CFR 75 Subpart E calls PEMS "ACEMS" or Alternative CEMS.
For customers in the European Union, a PEMS is regulated under Technical Specification 17198 (EU_TS17198_PEMS).
We've had successful applications in these markets for over 25 years before these regulations were promulgated. Since then, we have helped draft and refine these regulations.
Do you know which asset types of Software CEM work well? Have you seen any limitations in these applications?
The Software CEM models depend on the inputs (flows, temperatures, damper position, etc.) and must predict the output (NOx, O2, CO, SOx, etc.). We utilize the same sensors that the combustion unit owner/operator uses to safely and efficiently operate their equipment. By leveraging these existing sensors, we save money and assure accuracy. We know they will be maintained for operational purposes.
That said, we have found that most solid fuel sources, such as coal, vary too much in the makeup of nitrogen, water, and sulfur to meet the accuracy requirements required by the US-EPA. We have found excellent accuracy for liquid and gas-powered units like oil or gas-fired boilers, oil or gas turbines, and oil or gas heaters.
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