EcoChem Analytics

1. EcoChem Analytics Experience with PADEP, CEM Phase I Approval Under Rev 7ARIPPA Technical SymposiumJuly 27, 2005Jim Carroll & Ron Baker

2. Presentation Overview • Project Scope • Hardware Description • Project Schedule • Application Experience • Interaction with the Department • Recommendations • CEM Supplier Perspective

3. CEM Project Scope • Install new stand alone CEMS enclosure • Install two (2) new EcoChem MC3 multi-component analyzer packages • NOx, SO2, CO, CO2, O2 • Two (2) new sample handling systems • Probes • Sample lines • Sample pumps

4. CEM Project Scope ( Cont’d) • New DAS by ESC for PA STEMS (Part 60) and NOx Budget (Part 75) reporting • Maintain use of existing stack flow monitors in new system • Maintain use of existing Opacity Monitor (near term)

5. New Enclosure

6. Heated Probe Assembly

7. Heated tubes (185°C PFA) • Sample gas from probe to analyzer • Spare Power for probe Heating element • Non-heated tubes (PFA-PTFE) • Calibration Gas (from calibration cylinder and solenoid valves to probe) • Isolation Air (isolation of probe from flue gas during calibration & temperature failures) • Blowback air (used for purging probe) Power for sample line heating and temperature sensors Insulation Heated Sample Line

8. Heated Pump

9. CEM Cabinets

10. CEM Cabinet Interior

11. Gas Range Interval CO 0-200 PPM, 0-3000 PPM SO2 0-150 PPM, 0 - 400 PPM 0-160 PPM NOx O2 0-25% CO2 0-20% H2O 0-30% MC3 Configuration

12. Touch Screen Display

13. Real-Time Strip Chart

14. Project Schedule • Prelim Meeting - August 2003 • New CEM Spec Issued – August 2004 • EcoChem Selected – Sept 2004 • PO issued/Order placed – Sept 2004 • Teleconference with PADEP – Sept 2004 • Phase I Submittal – Oct 2004 • Included a listing of project milestones (testing)

15. Project Schedule (Cont’d) • Phase II Submittal – Nov 2004 • FAT Testing – Jan 2005 • Installation/Commissioning – Feb 2005 • Phase I and II Status Request – Feb 22 • PADEP Response – Feb 24, 2005 • Proposed Certification – March 16, 2005 • New Schedule Proposed – March 17, 2005

16. Project Schedule (Cont’d) • Performance Testing – April 2005 • RATA Testing – April 13 & 14, 2005 • Phase I Approval – April 18, 2005 • Submittal of Performance Testing Data – May 2005 • Submittal of Part 75 Certification EDRs – May 2005 • EDR Certification Data – App’d in 10 days • Phase III Acknowledgement Letter – June 2, 2005 (Response by July 2, 2005) • Certification is currently pending

17. Application Experience • Opted to utilize the electronic Phase I forms • Theory: Electronic submittal may expedite the approval process (Not!) • Completed forms encompassed 41 pages • Forms were cumbersome to work with • Some requested data was not well defined • Requested more fluff than stuff

18. Application Experience (Cont’d) • Requested data aids in fulfilling the Department’s CEMS database • ID codes, Result Codes, Source Codes, Analyzer Codes & CEMS Codes are meaningless to the preparer • It’s difficult to keep them straight!

19. Application Experience (Cont’d) • Regurgitate many of the standards in the CSMM • Defining the Lowest Monitored Standard (LMS) • LMES now replaces the old “Span”

20. Interaction with Department • Phase I Pre-submittal teleconference is beneficial • Also beneficial to speak with Bob Vollaro of EPA to review Part 75 issues • There was little or no communication unless we initiated it • Phone call follow-ups were initiated starting in December

21. Interaction with Department (Cont’d) • Exchanged LMES calculations via FAX in January • They opted not to visit the plant during installation or testing • Communication via letter stimulated the best response • The Department is still working to understand all the nuances of Rev 7. • Their plates are FULL.

22. Recommendations • Schedule an informal pre-submittal conference • Build a lot of time into your schedule • 1 year from Phase I submittal to Certification • Submit your project schedule with the Phase I • Understand & be clear about your LMES calculations in your Phase I

23. Recommendations (Cont’d) • Keep your project on the radar screen after the Phase I is submitted • Submit your Phase II early • Correspond with the Dept in writing about project milestones • Make sure the Dept understands your Part 75 issues

24. CEM Supplier Perspective on PADEP Rev. 7 • Awaiting Responses Caused Project Delays • Phase I Submittal Approval took >4 months • Rev. 7 Phase I Electronic Version confusing • Reconciling NOx Budget, Part 60 and PADEP overlapping requirements inefficient • PADEP Going Thru Transition

25. Benefits of More Current CEM Beside Simply Meeting Regulations • Hot-wet system provides moisture concentrations – assists with auditing tube leaks • New sample system and automatic audits reduces manual oversight • Enhanced remote troubleshooting reduces frequency of lengthy E&I staff call-outs • Convenient format and data access useful management tool • Avoid total obsolescence

26. Operator Interface and Remote System Access • Presents data in larger color screen • Most functions 1-2 touch screen taps • Provides meaningful system history to do troubleshooting right at the CEM location (fewer trips back and forth to control room or office) • Can control the system remotely PC Anywhere Excel

27. A Contrast in Case Histories • Removed old system and installed new CEM in three days – during scheduled outage • No overlap with original CEM • RATA test within 10 days • No “Phase I” submittal – letter notification • No NOx Budget Issues Waste Coal Plant – Utah

28. EcoChem’s Suggestions for a “Win-Win” CEM Upgrade • Build in sufficient scheduling contingency - allow 9-12+ months depending upon scope • Allow appropriate overlap with existing CEM – You usually don’t have a choice! • Don’t forget training and spare parts inventory • Use experienced CEM integrator & DAS vendor • Pray for Rev 8 to be more efficient