Pennsylvania announces actions to combat climate change News in late April sent a clear message that Pennsylvania is serious about climate change. Governor Tom Wolf announced plans to become the 24th state to join the U.S. Climate Alliance. The Alliance supports clean energy development and the Paris Agreement goal of reducing 2005 level greenhouse gas (GHG) emissions 26-28 percent by 2025. The Governor’s announcement also included the release of the 2018 Climate Action Plan. Some history The Pennsylvania Climate Change Act of 2008 requires the Department of Environmental Protection to develop annual GHG inventories, maintain a Climate Change Advisory Committee, have a voluntary GHG emissions registry, and provide an updated Climate Change Action Plan every three years. The Governor previously issued Executive Order 2019-01 (covered in an earlier blog). This order set ambitious goals to achieve a 26 percent reduction of greenhouse gas emissions by 2025 and an 80 percent reduction by 2050, from 2005 levels. Highlights of the Plan The plan identifies over 100 actions within 19 strategies to reduce GHG emissions. Energy conservation and efficiency, sustainable transportation, and clean electricity generation are the low hanging fruit. The following chart shows the modeling results of 15 related actions considered the most impactful. If these actions are started now, the plan predicts that they will result in a 21 percent decrease in 2025 and a 36 percent decrease in 2050. As this falls short of the goals specified in the Executive Order, additional actions will be necessary. The Plan recognizes the importance of maintaining current nuclear generation levels. Pennsylvania’s five nuclear plants account for 93% of Pennsylvania’s carbon-free electric generation -- far above wind, solar and hydro. But policy is needed to value these zero-emission sources of baseload electricity. Two of these plants, Three Mile Island and Beaver Valley, are not currently competitive in the wholesale market. Without subsidies, these plants are expected to close in 2019 and 2021. As one would expect, this is generating heated debate within the Legislature. Potential costs to electric ratepayers to support Pennsylvania’s nuclear plants could be $500 million a year (See analysis by the Kleinman Center for Energy Policy ). The Path Forward We have a long way to go to meet the 2050 goals. The current Plan gives a good description of the scale of this challenge. The Plan itself provides only a starting point to reach the 2025 goals. It recognizes that additional actions are needed by not just government, but by individuals, businesses, and communities. The choice of actions will involve compromises between effectiveness, economic feasibility, and impacts to our standard of living. Future three-year updates of the plan will undoubtedly include technology advancements and new Federal regulations that shape the course of action. It will be interesting to see how much things change by the time the 2021 Action Plan is released.
On February 14, 2019, the EPA unveiled the Agency's first-ever comprehensive nation-wide Action Plan for Per- and Polyfluoroalkyl Substances (PFAS). According to the current EPA Acting Administrator Andrew Wheeler at a news conference in Philadelphia, this is the first time the agency has engaged all of its program offices to deal with an emerging chemical of concern. The plan provides a long list of steps the EPA plans to take over the next several years as it addresses protection of public health from PFAS. As reported in our blog, The “Forever Chemicals” are Back in the House, earlier this month, PFAS are synthetic chemicals that are found widely in the environment, especially drinking water and soil. There is broad consensus among scientists that these chemicals represent an environmental threat. Exposure to them may lead to adverse health effects. Studies have linked PFAS to a wide range of diseases, including cancer and birth defects. However, questions remain over the mechanisms in which these chemicals cause these health effects and at what levels in the environment do they represent a threat. Which PFAS Chemicals Are Being Regulated? Much of EPA's Action Plan deals with answering these questions and creating a better and more widely communicated understanding of the problem. The Plan contains little in the way of concrete regulatory steps. However, the EPA says it has already initiated the process of listing two specific and prevalent PFAS chemicals – PFOA and PFOS – as hazardous substances under the Superfund law (CERCLA), and Mr. Wheeler stated in the news conference that the Agency is committed to move forward with the Maximum Contaminant Level (MCL) process outlined in the Safe Drinking Water Act for these two chemicals. Increased Monitoring Although much of the Action Plan focuses on the drinking water impacts of PFAS, it does address other media as well. Over the coming years, the Plan indicates the EPA’s intention to expand monitoring and regulatory efforts to other matrices including air: Ambient, Stack emissions, and off-gases. To this end, the Agency plans to develop and validate methods for stack emissions measurements sometime in 2020. One can anticipate that the starting point for these efforts would be the current coupling of traditional methods for measuring air emissions of semi-volatile organic compounds (e.g., SW-846 Method 0010) with the newest drinking water method for PFAS (Research Method 537.1). However, the Plan indicated that measurement of Total Organic Fluorine may also be considered as a surrogate measurement for PFAS. Learn more about CleanAir's many services related to air measurements.
The Cooling Technology Institute (CTI) has recently announced the release of ATC-105DS, a new test code for air cooled fluid coolers, more commonly referred to as dry coolers. This newly published dry cooling supplement is an addendum to the ATC-105 Acceptance Test Code for Wet Cooling Towers. The supplement for dry cooling specifies the measurement of inlet dry-bulb temperature for the dry cooler under test as opposed to inlet wet-bulb temperature, which is required for evaporative (wet) towers. Since dry fluid coolers frequently use a solution of glycol as the process fluid, the supplement also provides a method for correcting for the thermodynamic properties of the process fluid. Like an evaporative cooling tower, the dry cooler is tested as a unit, inclusive of the fan. In contrast with ASME PTC-30, airflow rate measurements are not required, which makes it practical to test multiple fan units. The major parameters required for the test method specified by the dry supplement are: Process fluid flow Process fluid inlet temperature Process fluid outlet temperature Process fluid composition Inlet dry bulb temperature Fan motor power The number and placement of dry bulb temperature sensors are based on the air inlet cross sectional area in the same manner as wet bulb temperature sensors are configured for a wet cooling tower. The CTI Press Release from last September includes a link that allows you to purchase the new supplement as well as other CTI standards, codes, and guidelines. As one of the CTI licensed test agents for cooling towers, CleanAir has decades of experience in testing cooling towers, closed circuit cooling towers, and air-cooled condensers. This experience allows CleanAir to plan and conduct acceptance tests of all types of heat rejection equipment, including dry fluid coolers, with the high accuracy required by the test codes, while minimizing costs.
Danny Landry is a pioneering entrepreneur in the field of drone (or UAV) use for industrial inspection and air quality monitoring. In this episode of Hot Air, I talk with Danny about various UAV applications in air quality monitoring, optical gas imaging, confined space inspections, 3-D plant modeling, and related topics. I met Danny when he worked with us on an innovative project using a drone as one end of an open path monitoring system to measure stack emissions. Danny did an amazing job implementing the aerial logistics of our vision for using this innovative technology developed by CleanAir. The video below shows some scenes from that project. There is music so be prepared... In addition to the open path project, Danny and I discuss the use of UAVs for confined space entry monitoring and inspection, using sophisticated photogrammetric software to develop 3-D models of plants, and other aspects of UAV use for monitoring and inspection. Check out some photos of Danny and his drones below. Also links to two videos on 3-D plant modeling and aerial photography. You can reach Danny at email@example.com or visit the website at www.pitinc.com. Listen and subscribe to Hot Air on iTunes, Google Play, Spotify, or anywhere you get your podcasts. Search for "Hot Air" or use one of the links below. Listen on the web: http://cleanair.libsyn.com Listen on iTunes: https://itunes.apple.com/us/podcast/hot-air-by-clean-air/id1413894085?mt=2 Listen on Spotify: https://open.spotify.com/show/24gUGGOvpygt3ayjAJtdbU?si=sbKPuLaVQFayMGPG50sEEQ Listen on Google Play: https://play.google.com/music/listen#/ps/Ivy2hniljmxncjhtj72jblrgcua Listen on Stitcher: https://www.stitcher.com/podcast/scott-evans/hot-air-by-clean-air?refid=stpr Video Links: 3-D Plant Modeling Aerial photography Discussing Strategy for Open Path Monitoring Project 3-D Plant Model Rendered from Drone Photographs Confined Space Entry Drone Preparing for Inspection Thermal Imaging Drone in Flight with Retroreflector Confined Space Inspection Photo Discussing Confined Space Inspection Flight Plan Ground Control
Infrared cameras are typically perceived as tools for hydrocarbon detection. However, with the proper equipment, they can be used for a variety of chemical detection projects. CleanAir helped a whipped cream manufacturer who experienced significant releases of nitrous oxide (N2O) in their production process. The leaks created a hazardous work environment and frequent production shutdowns. They employed a manually intensive leak detection method using a soapy mixture to identify the source of the leak. Benefits Of FLIR Cameras CleanAir supplied an Optical Gas Imaging (OGI) solution using a FLIR camera with interchangeable band-pass filters. As opposed to the manual soap approach. Unlike the well-known FLIR GasFind cameras that have fixed filters for specific compounds. The FLIR SC8313 camera can be fitted with filters for a wide range of compounds – both hydrocarbon and non-hydrocarbon. This camera provides rapid frame-rate and high definition images. Thus, enabling low detection limits for small leak detection. Drawbacks Of FLIR Cameras Flexibility and high resolution come at a price, though. One of the disadvantages of the camera is that it is fairly large and not as portable as the GasFind cameras. It is designed to be used in a fixed position in a laboratory or other workspace. For this application, CleanAir designed a custom mobility solution allowing the camera to move from a stationary position in a lab out onto the production floor and be deployed as a mobile leak detector. This custom OGI system allowed the identification and repair of many N2O leaks across the production line. Short-term fixes were then put in place to either decrease or eliminate the leaks. Periodic inspections are still being conducted until longer-term solutions are implemented.
The Trump EPA's new Affordable Clean Energy (ACE) rule proposal announced today aims to replace the Obama EPA's Clean Power Plan (CPP) for limiting CO2 emissions from coal-fired power plants. The new proposal finds that the Best System of Emission Reduction (BSER) for such plants is Heat Rate Improvements (HRI) -- that is, to have each affected plant figure out how to generate more electricity with less fuel. This approach is in stark contrast with CPP which contained a complex "building block" approach to BSER. But aside from the controversy that will inevitably surround the less stringent CO2 reductions required, there are also proposed changes to EPA's New Source Review (NSR) permitting program that may stir up just as much hoopla. NSR is one of EPA's bedrock programs that has been around almost as long as EPA itself. The NSR program requires sources to undergo a pretty expensive, time-consuming, rigorous (some would say "onerous") review to determine whether constructing a new facility or modifying an existing facility would result in the "significant increase" of a regulated pollutant. If there is a significant increase, the plant would then be subject to potentially much more stringent (i.e., costly) requirements. Needless to say, most plants avoid NSR entanglement like the plague. The current NSR approach to determining whether there is a significant increase is incredibly complex and detailed but in broad strokes goes something like this... Step 1: Is there a physical or operational change? If yes, go to Step 2. If no, end. Step 2: Is there an ANNUAL increase in actual emissions greater than the EPA significance threshold? If yes, go to Step 3. If no, end. Step 3: Is there a significant increase in NET ANNUAL emissions? If yes, our condolences... you are subject to NSR rules. If no, congrats, you are not subject to major source NSR (maybe minor though). The key takeaway here is that a significant increase in emissions is determined on an annual basis. That creates a potential problem from the power plant's perspective. How? At the present time, there is no system in place to store the power produced by power plants. So the output of all the power plants on the electrical grid must be continually adjusted based on the electrical demand. This process is called dispatching. The more efficiently a plant operates, the more likely it is to be dispatched at a higher output or for longer periods of time. Therefore, if a plant improves its efficiency through a heat rate improvement project under ACE (a good thing), it will likely be operating at higher loads over a longer period of time. This may trigger NSR applicability (a not-so-good thing). This may happen even though the plant's pollutant emission concentrations remain unchanged or even are reduced. It's simply a matter of ANNUAL operating time. Yes, the efficient plant is generating electricity in place of a less efficient plant, but that offset is not recognized by the NSR approach. Now I'm not going to get into a debate about NSR stringency here and whether that's a good thing or a bad thing. I'm simply stating that from a power plant's perspective, NSR can be viewed as inhibiting potential efficiency increases. And the ACE proposal is all about power plant efficiency. To address this issue, the ACE proposal changes the NSR significant increase procedure for coal-fired plants from three steps to four... Step 1: Same as now Step 2: Is there an increase in HOURLY emissions? If yes, go to Step 3. If no, end. Step 3: Same as Step 2 now Step 4: Same as Step 3 now EPA is proposing several alternatives to how this hourly test would be calculated. The overall idea is to limit exposure to NSR applicability when initiating projects to improve plant efficiency. This could be considered in the same light as EPA current NSR exemption for pollution control projects. In any case, the proposed change is not mandatory but simply an option that may be adopted by states in their State Implementation Plans to meet ACE requirements. I'm looking forward to the debate on this one...
Water flow rate is often a critical measurement for various power plant components and systems including cooling towers, pumps, and condensers. For over 40 years the Simplex-type Pitot Tube has been the industry standard for accurate water flow measurement, however the Simplex Tube is no longer commercially available. In addition, the results of from Simplex Tubes have long been suspect in the most challenging flow situations. Under contract to the Cooling Technology Institute (CTI), CleanAir conducted a research study to identify alternative pitot designs (CTI Case Study). This work culminated in 2017 with the introduction of the Elliptical Pitot Tip. Advantages of the Elliptical Pitot tube Tip include: Less sensitivity to Reynolds number Allows measurements closer to the pipe wall than other designs Better accuracy in disturbed flow situations With the new design providing more accurate flow determinations especially when the flow profile is disturbed, CleanAir will begin using the new design for flow rate measurements in 2018. Unreinforced pitot tubes have a maximum working length of 68” and are generally used for pipes that are less than 42 inches in diameter. For larger pipe sizes or pipes with higher than normal velocities, CleanAir offers an elliptical pitot “stinger” design that can be inserted into a 1-1/2 inch reinforcing rod of up to 20 ft in length. Each assembled pitot tube includes: 1-1/4” NPT packing gland with locking collar, dual O-rings, and grease fitting Quick disconnect fittings that prevent flow when not connected Locking shaft collar for ease of marking the far wall of the pipe (automatically adjusts for 1/8” distance between tip and impact port) Construction from highly corrosion resistant 316 stainless steel and brass Each pitot stinger includes: Two 1/8” NPT to ¼” barb fittings from the impact and static pressure ports Low profile hose clamps Three O-rings Construction from highly corrosion resistant 316 stainless steel and brass Each pitot will be dimensioned from the sensing tip to end where handles can be used for alignment and rotation as needed. Each pitot stinger will be dimensioned as the full length protruding from the end of the reinforcing rod. Packing glands will be included to accommodate pitot insertion in an active pipe. Calibration services are available across a variety of flow settings and fluid velocities. CleanAir will supply a procedure for how to measure flow and a flow calculation spreadsheet for pitot station calculation and flow calculation consistent with CTI methodology with each pitot tube or pitot stinger purchase.
If your facility is an EGU that complies with Mercury and Air Toxics Standards (MATS), you are probably aware of some new electronic reporting dates in the coming year. On April 6, 2017, a final rule on MATS electronic reporting was published in the Federal Register (82 FR 16736) that revised Reporting Requirements (40 CFR 63.10031). Under the final rule, performance evaluation tests (RATA, RCA, RRA, etc.), PM CEMS quarterly reports (or the approved alternatives), and compliance reports required by 40 CFR Subpart UUUUU must be reported as a portable document format (PDF) using the Emissions Collection and Monitoring Plan System (ECMPS) Client Tool. This reporting requirement is in place until July 1, 2018, at which time these reports must be uploaded to the Central Data Exchange (CDX) via the Compliance and Emissions Data Reporting Interface (CEDRI). The Electronic Reporting Tool (ERT) is a software program that is used to put your data into a proper format to be uploaded in CEDRI. Essentially, your regulatory requirements pertaining to MATS will not change this year; however, your regulatory reporting requirements will change. These new requirements are part of EPA’s Cross-Media Electronic Reporting Rule (CROMERR), which spans across all EPA regulatory programs and has two primary functions: to provide a streamlined, uniform electronic approval process; and to aggregate data in a central database that is available to the public. If you have not encountered the ERT, CEDRI, and/or CDX, it is possible that your testing contractor or consultants have dealt with the process and can guide you through this process. In fact, there is provision in the process where your testing contractor can do most of the data entry and submission preparation. If you have any questions, comments, or experiences you wish to share regarding any aspect of electronic reporting, feel free to leave a comment below, or reach me directly at firstname.lastname@example.org. Happy Holidays!
The need to reduce cycle time and drive efficiency throughout the value chain will always be a critical business focus. And with the digital transformation of environmental monitoring, we can shift these requirements away from historically being a cost of doing business to providing opportunities to generate value. This represents a paradigm shift to many and you may ask what has changed. The Industrial Internet of Things (IIoT). IIoT is a broad concept that implies that as the cost of connectivity decreases, more and more devices will become connected to the Internet. Due to rapid advances in information technology and reduction in the cost of data management, the IIoT has allowed for more automated data collection, increased data transfer, more effective data analysis and the enterprise-wide availability of data. A good example is an ongoing CleanAir project that incorporates cloud-based remote monitoring of ambient air monitoring station data and performance. Using remote monitoring, station operating parameters such as temperature, compressed gas standard cylinder pressures, sample line vacuum pressure, sample flow rate, analyzer data, among other sensor information are sent via a secure connection to a cloud-based data service for secure storage and processing. Once in the cloud, approved users have gated remote access to the data for download and real-time viewing from their offices or via mobile devices. In addition, operators can use system tools to set up alarm notifications in the form of automated phone calls, text messages or emails to be alerted if operating parameters or analyzer data fall outside of defined operating envelopes. As can be seen in this example, cloud-based remote monitoring coupled with a comprehensive quality data management system is a powerful solution that provides many benefits, such as: Proactive, efficient station operation Reduced labor and operating costs Fast response to station upset conditions Comprehensive data quality assurance Transparent and well-documented station operation Cloud-based data backup Real-time online data visualization and analysis Enterprise-wide data availability Consequently, environmental monitoring moving forward needs to take further advantage of IIoT concepts. Coupled with advanced analytics and digital labor, this will allow digitization to be moved from the field to the back office and throughout the value chain.
Automation and the internet of things is quickly moving from a magical sci-fi concept to an everyday reality. We are living in a unique time where a wide range of sensors and actuators are available ranging from low cost to robust industrial grade components. The components are just waiting for some careful planning and programmed logic to be transformed into efficient and reliable solutions. The video below provides a Dr. Dave style general introduction to automated systems. Steps for designing a custom automated system are also provided below with examples. Project Definition Identify “big picture” project goals. Determine functional requirements and restrictions. E.g., Client needs a system to monitor temperature of coolers and notify operator if the temperature is outside of an acceptable range. System Design Prepare a solution that meets project goals. E.g., Connect temperature sensor to wireless network and develop program that texts operator when temperature is outside 0-32 F. Control System Design Select sensors/actuators and create input/output map. Identify controller hardware speed and storage requirements. Identify if internet access is required. E.g., Use a type K thermocouple with wireless access and design online web portal that includes logic and texting ability. System Construction Order and assemble physical components. E.g., Wire thermocouple and install in cooler. Control Program Development Design software with scalable architecture. Provide any necessary safety precautions or permissions in software. E.g., Program that allows easy addition of wireless thermocouples or operator phone numbers where select coolers notify select operator. User Interface Development Provide easy to use and functionally sound interface. E.g., Password protected panel with federated identities to view cooler temperatures that walks user through steps to update alarm settings.
Activated carbon fiber cloth (ACFC), shown in the scanning electron microscope image above, is a novel adsorbent that can be used for volatile organic compound (VOC) control. One of the unique qualities that separates ACFC from the more conventional granular activated carbon (GAC) is that ACFC can be more readily regenerated using resistive heating. (GAC beds have contact resistance between each grain and thus have limited electrical conductivity while AFCF is a tightly woven material resulting in good bulk electrical conductivity.) Comparing ACFC to GAC Resistive heating provides the benefit that control of regeneration heating is independent of the regeneration carrier gas flow rate. This means that the carrier gas flow rate can be minimized such that the regeneration exhaust gas is highly concentrated with previously adsorbed material for cost effective disposal or reuse as feedstock (e.g., > 60% VOC). By contrast, GAC beds are typically regenerated by passing heated gas streams such as nitrogen or steam through the adsorbent bed, which dilutes the adsorbed material and may require additional treatment for reuse or disposal. Consistency in ACFC electrical resistance values also provides the potential to use resistance as a sensor for select adsorbent properties. The recent Environmental Science & Technology paper, Monitoring and Control of an Adsorption System Using Electrical Properties of the Adsorbent for Organic Compound Abatement, about the gas recovery system, demonstrates how measured ACFC electrical resistance values can be used as a temperature sensor and an adsorbed mass sensor for real time control of cyclic VOC adsorption and resistive heating regeneration cycles. This research is a collaboration between the Air Quality Engineering and Science research group at the University of Illinois at Urbana-Champaign (advised by Prof. Mark J. Rood) and China University of Petroleum (UPC), Qingdao, mainland China. Initial experiments were performed during the Ph.D. studies of yours truly (Dr. David Johnsen). Clean Air then provided air pollution control consulting, updates to system automation, and training so that UPC visiting scholar Ming-Ming Hu had the right tools to perform additional experiments to expand this research for cases with high humidity gas streams. *The gas recovery system uses activated carbon fiber cloth to selectively remove dilute VOCs from gas streams and then electrothermal heating to regenerate the adsorbent and provide liquid VOCs as feedstock for reuse or lower-cost disposal (Patent US8500853 B2: Rood, Hay, Johnsen, and Mallouk). A method to control this system based on indirect electrical resistance measurements was later developed (Patent US8940077 B2: Rood and Johnsen). Hu expanded on the indirect electrical resistance method for cases with high humidity gas streams.
One of the cool projects we are working on involves remote sensing of stack gas velocity using infrared imaging and digital image correlation. Using this technique, we can determine stack gas flow without even climbing the stack… stack-free stack testing. Another way we do stack-free stack testing is by using drones to measure stack emissions. Preliminary tests show results that agree with US EPA Method 2 or 2F to within a few percent. This would be great for a quick check of stack flow or on sources that are hazardous or hard to access. Check out the video below for a playful general overview of this method to remotely measure gas velocity using a camera. One of the cameras we used to do this is FLIR SC8313 High Speed Infrared Camera. These cameras have applications beyond measuring stack emissions. They can be used for: Measuring Flame speed in a flare Measuring Mobile Emissions from a ship, aircraft, etc Many Other applications
On a recent project, CleanAir used an open-path Active FTIR (AFTIR) system coupled with a drone (or unmanned aerial vehicle, UAV) to analyze pollutants in on a high, inaccessible stack. This is not the Passive FTIR system employed in many of the recent flare tests. The AFTIR analyzer utilized an optical telescope to transmit an infrared (IR) beam through the measurement region. The IR beam was reflected back to the analyzer by a suspended retroreflector array. The analyzer measured the absorption of the IR radiation to determine the composition of the gas in the measurement region. The retroreflector array was suspended from a UAV hovering behind the emission plume relative to the AFTIR about 100 feet in the air. This is the first time (we believe) that anyone has used a UAV-suspended mirror array as one end of an open path monitoring system. Learn more about CleanAir's drone technology for analyzing plumes in dangerous or hard to reach locations here.