Subpart TTTT: What to Know About Greenhouse Gas Emissions from Electric Utility Generating Units

With contribution from ALL4 Staff

On December 20, 2018, the U.S. Environmental Protection Agency proposed amendments to its “Standards of Performance for Greenhouse Gas (GHG) Emissions from New, Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units (EGUs)” (i.e., 40 CFR Part 60 Subpart TTTT).  Originally promulgated on October 23, 2015, Subpart TTTT was intended to limit the emissions of GHG from steam generating units, integrated gasification combined cycle units (IGCC), and stationary combustion turbines, collectively referred to within the rule as EGUs.  In response to the March 28, 2017 Presidential Executive Order on Promoting Energy Independence and Economic Growth, U.S. EPA announced on April 2, 2017 that it was “reviewing, and if appropriate, will initiate proceedings to suspend, revise, or rescind” the rule.

U.S. EPA has completed its review, and is now proposing changes relating to the following:

  • Rule applicability requirements.
  • The Best System of Emissions Reduction (BSER) for newly constructed coal-fired steam generating units.
  • The standards of performance for newly constructed steam generating units, reconstructed steam generating units, newly constructed and reconstructed coal refuse-fired EGUs, and large modifications of steam generating units.
  • The establishment of three subcategories of steam generating units: large units, defined as units with heat input greater than 2,000 Million British Thermal Units (MMBtu)/hour (hr); small units, designated as units with heat input less than or equal to 2,000 MMBtu/hr; and units of any size (that meet the general Subpart TTTT applicability criteria) and that are fired with coal refuse.
  • Miscellaneous technical changes in regulatory requirements.

It is noteworthy to mention that U.S. EPA is not proposing to amend and is not reopening the standards of performance for newly constructed or reconstructed stationary combustion turbines.  Consistent with the October 2015 version of the rule, U.S. EPA is also not proposing standards of performance for stationary combustion turbines undergoing modification.

Let’s dig a little further into the amendments as currently proposed…

Proposed Revisions to Rule Applicability Requirements

U.S. EPA is proposing the following changes to the applicability criteria for combined heat and power (CHP) and non-fossil fuel-fired EGUs:

  • To revise the definition of non-fossil EGU from EGUs capable of “combusting 50 percent or more non-fossil fuel-fired” to EGUs capable of “deriving 50 percent or more of the heat input from non-fossil fuel at the base load rating.”
  • To revise the definition of “base load rating” to include the heat input from non-combustion sources (e.g., solar thermal).
  • To allow alternative methods (as approved by the Administrator on a case-by-case basis) for determination of electric sales applicability as opposed to strictly using the design efficiency.
  • To change the applicability of paragraph 40 CFR 60.8(b) from “no” to “yes” so that the Administrator can approve alternatives to the test methods specified in Subpart TTTT.
  • To determine net electric sales for CHP units based upon the percentage of thermal power provided to the host facility by the specific CHP facility.

Proposed Revisions to BSER

U.S. EPA is proposing to relax what constitutes BSER for newly constructed or reconstructed EGUs.  In the October 2015 version of the rule, partial carbon capture and storage (CCS) constitutes BSER for a newly constructed or reconstructed EGU.  U.S. EPA is now proposing that BSER for a newly constructed or reconstructed EGU be operation of the EGU at the most efficient generating technology (i.e., the most efficient demonstrated steam cycle) in combination with best operating practices (BOPs).

What is the most efficient demonstrated steam cycle?  Well, it depends on the size of the unit in question.  For a “large EGU,” this would mean a system which uses steam under supercritical conditions.  For a “small EGU,” or any coal refuse-fired EGU that meets Subpart TTTT applicability criteria, the most efficient demonstrated steam cycle would be a system which uses steam under best available subcritical conditions.

Proposed Revisions to Emissions Standards

U.S. EPA is proposing revision to the emissions standards of performance for newly constructed steam generating units, reconstructed steam generating units, and steam generating units undergoing modifications.  Additionally, the proposal includes separate emissions standards for EGUs firing coal refuse.  The proposed emissions standards are summarized in Table 1 below:

Table 1

Proposed Revisions to the EGU Standards of Performance

You may recall that the initial Subpart TTTT rule only established standards for EGUs undergoing large modifications which would increase hourly CO2 emissions by 10% (large modification), when compared to the highest emissions from the EGU during the previous five years.  The proposed emissions standard for an EGU undergoing a large modification can be no more stringent than the emissions standards established for new and reconstructed EGUs, as laid out in Table 1 above.  With respect to EGUs undertaking small modifications (i.e., modifications that result in an increase in hourly emissions of 10 percent or less), U.S. EPA is soliciting comment on standards of performance based on a unit’s historical performance and how to best account for emissions variability due to changes in the mode of operation.

Closing

In this article we’ve shared an overview of the proposed amendments.  For information concerning the Subpart TTTT proposal or how it might impact a project that is being considered, please contact our team at info@all4inc.com or 610-933-5246.  ALL4 would be pleased to have a site-specific discussion with you concerning how the proposed amendments could impact your future projects.

What Makes a “Good Neighbor?”: A Look at Ozone Standards

Since the government shutdown ended and many Federal programs that were hanging in the balance have returned to service, the impact on U.S. EPA is beginning to show.  Our CFO, Kevin Romito, recently published an article giving some insight into how the U.S. EPA regulatory process functions during a government shutdown.  One such process that was put on hold is the implementation of the “Good Neighbor” provision of the Clean Air Act (CAA) and how it relates to the Ozone Transport Region (OTR).  The OTR was established under Section 184 of the CAA, currently containing 11 states: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont.  These states implement stricter regulations for controlling emissions of volatile organic compounds (VOC) and nitrogen oxides (NOX), the precursor pollutants to ozone.  Despite the emissions reductions that are being implemented, many of these “downwind” states struggle to meet air quality standards, threatening the welfare of large metropolitan population bases in many of these states.

The ongoing debate started in 2013, with an original petition to add “upwind” states (i.e., Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, Tennessee, Virginia, and West Virginia) to the OTR.  This petition was filed in accordance with the “Good Neighbor” provision, which requires states to implement measures to reduce emissions if it is determined that pollution generated in their state is contributing to poor air quality in another.  The plaintiff states claimed that VOC and NOX emissions blowing from power plants and other sources in the upwind states are causing increased levels of ozone, a main component of photochemical smog.  No action was taken by U.S EPA at this time, prompting a Federal lawsuit to compel a decision.  An October 27, 2017 deadline for decision was given and the petition to expand the OTR was denied by then- U.S. EPA Administrator Scott Pruitt, claiming that the current Cross State Air Pollution Rule (CSAPR) sufficiently addressed the 2008 ozone standards.  This determination was finalized December 6, 2018, to much dispute from environmental groups and states in the current OTR.  In response, New York Attorney General Barbara D. Underwood is planning to file a lawsuit, seeking to join ongoing suits brought by Maryland, Delaware, and environmental interest organizations.   This suit requests that the U.S. Court of Appeals in D.C. to review denial of the previous petition, with more suits from OTR states expected.

While the shutdown put a hold on this case, we will be closely monitoring the final verdict as it could have significant ramifications for facilities both within and outside of the OTR.  If you have any questions on how this ruling, or any other shutdown-related backups may impact your operations or compliance, please feel free to contact me at mgray@all4inc.com or 610.422.1172.

RACT 2 Compliance Reporting… No Reason to Wait

January 1, 2017 feels like forever ago, but for most of us at ALL4, that date sticks with us.  Why?  January 1, 2017 was the final compliance deadline for Pennsylvania facilities subject to the Reasonably Available Control Technology (RACT) 2 Rule, and since that date (and for some time before it), we have worked with facilities from various industries to develop compliance strategies and compliance demonstrations for the RACT 2 Rule.  Many of our clients are using continuous emissions monitoring systems (CEMS) to demonstrate compliance with the RACT 2 Rule, and those clients are at different stages of the RACT 2 Monitoring Plan process with Pennsylvania Department of Environmental Protection (PADEP or “the Department”).  ALL4’s CMS Practice Area has successfully helped our clients navigate the murkiness of numerous RACT 2 Monitoring Plan submittals.

This article will detail what we have learned from our experiences and will help guide you on the next steps you should be taking based your facility’s current RACT 2 Monitoring Plan status.  So, what’s the status of your facility’s RACT 2 Monitoring Plan?

You have not submitted a RACT 2 Monitoring Plan…

If your facility’s RACT 2 method of demonstrating compliance requires the use of CEMS and you have not yet submitted a RACT 2 Phase I Monitoring Plan, the time is now!  PADEP is accepting RACT 2 Phase I Monitoring Plans and will work with facilities to determine the correct Monitoring Plan configuration to be entered in PADEP’s Continuous Emission Monitoring Data Processing System (CEMDPS).  If you are waiting to hear from PADEP regarding when to submit your RACT 2 Monitoring Plan, don’t wait any longer! PADEP will not be actively requesting Monitoring Plans and expects that facilities required to submit a Monitoring Plan will do so on their own accord.

You have submitted a RACT 2 Monitoring Plan…

If your facility has submitted a RACT 2 Monitoring Plan and you’re not sure where it stands in the review process, do not be afraid to reach out PADEP to request a status update.  PADEP is processing RACT 2 Monitoring Plans that have been submitted, but the possibility exists that your facility’s Monitoring Plan has not been processed.  That is – the Department may have looked at parts of the RACT 2 Monitoring Plan but has not finalized.  The message here is we all get busy, so reach out to PADEP about your RACT 2 Monitoring Plan, they want to wrap these up too!

You have provided PADEP a summary of your proposed RACT 2 Monitoring Plan configuration…

Some facilities elect to provide a proposed RACT 2 Monitoring Plan configuration to PADEP for review and comment.  This optional step is an informal outline allowing a facility to receive preliminary technical feedback on their proposed monitoring plan (e.g., are the required technical elements included).  If you submitted a summary of your proposed RACT 2 Monitoring Plan configuration to PADEP but have not heard back, reach out to them!  Either go ahead and submit the Monitoring Plan as you proposed in your original summary, or alternatively, reach out to PADEP to get concurrence on your facility’s approach to the Monitoring Plan.

Okay – we’ve set the foundation for where your facility might be in this process.  What else has ALL4 learned during this process?

  • System-wide averaging (i.e., averaging emissions from sources across different facilities under common control of the same owner/operator) will NOT be handled within CEMDPS. Compliance will be demonstrated through reporting to the PADEP Regional Office assigned to your facility.
  • Facility-wide averaging (i.e., averaging emissions from sources at a single facility) programming in CEMDPS has been completed and PADEP is able to receive Monitoring Plans for this method of demonstrating compliance. PADEP is open to stepping the facility through how to set up this type of Monitoring Plan as needed.
  • Penalties for RACT 2 30-operating day average exceedances will be assessed in accordance with the current compliance assurance policies (CAPS). This means that the 30-operating day RACT 2 averages calculated by PADEP’s software will be used for compliance assessment and that the penalties assessed will be based on the ratio of the exceedance value in comparison to the RACT 2 emissions limit.  A few comments relative to penalties for RACT 2 30-operating day average exceedances:
    • PADEP is open to supplying a sample Continuous Source Monitoring Report (CSMR) as part of the sample report process to confirm that the compliance averages calculated by your facility’s data acquisition and handling system (DAHS) are consistent with the averages calculated by the Department. We recommend doing this comparison to ensure that there are no surprises when your facility starts to submit compliance reports, and to provide added confidence in your facility’s real-time compliance averages.  If desired, the sample CSMR should be requested by the facility during the sample report process.
    • Make sure that if your facility is required to use data substitution, the facility has put thought into what data substitution procedures are appropriate. PADEP is reviewing proposed data substitution procedures to ensure that the type of data substitution selected won’t result in potentially biased emissions results (e.g., substituting high heat input values which results in biased, low NOX lb/MMBtu compliance averages).  In addition, keep in mind that if you choose a data substitution procedure that would result in overly conservative compliance averages, it could result in additional exceedances or more penalty assessed by the applicable CAP.

If you have questions about where your facility is in the RACT 2 Monitoring Plan process, how to set up a RACT 2 Monitoring Plan in CEMDPS,  or any other components of RACT 2 compliance, please reach out to Megan Stroup (610.933.5246 x140 or mstroup@all4inc.com) or Matt Carideo (610.933.5246 x139 or mcarideo@all4inc.com).  Additionally, to ensure that you do not miss out on future articles, signup for our 4 The Record here for timely updates of current hot issues, plus an in-depth article each month that highlights a regulatory topic.

The Green New Deal: What Is It, Really?

On Thursday, February 7th, 2019, Rep. Alexandria Ocasio-Cortez (D-NY) introduced H.Res.109, a resolution calling for a “Green New Deal”.  There are many articles and opinion pieces floating around about the Green New Deal, so I thought taking an objective look at H.Res.109 to determine exactly what it is (or isn’t) would be helpful.

 

IMPORTANT DISTINCTION:  The Green New Deal is a non-binding resolution that does not, by itself, create any new laws or programs.  So everyone can put down the pitchforks for now.  The Green New Deal is a blueprint for the types of programs that Rep. Ocasio-Cortez and supporting lawmakers believe need to be instituted for the U.S. to meet the goals presented in H.Res.109.

Now first things first – why was H.Res.109 introduced?  The Intergovernmental Panel on Climate Change and the U.S. Global Change Research Program released an October 2018 report titled “Special Report on Global Warming of 1.5°C” and a November 2018 report titled “Fourth National Climate Assessment”, respectively, which concluded:

  1. Human activity is the dominant cause of observed climate change over the past century;
  2. Climate change is causing rising sea levels, an increase in wildfires, severe storms, droughts, and other extreme weather events;
  3. Global warming ≥ 2°C beyond pre-industrialized levels will cause:
    1. Mass migration from regions most affected by climate change;
    2. More than $500,000,000,000 in lost annual economic output in the U.S. by year 2100;
    3. Wildfires that, by year 2050, will annually burn at least twice as much forest area in the western U.S. than in the years preceding 2019;
    4. A loss of more than 99% of all coral reefs;
    5. More than 350 million more people to be exposed to deadly heat stress by year 2050;
    6. Risk of $1,000,000,000,000 in damage to infrastructure and coastal real estate in the U.S.; and
  4. Global warming < 1.5°C will avoid the most severe impacts of a climate change. This will require:
    1. Global reductions in greenhouse gas (GHG) emissions of 40 – 60% by year 2030; and
    2. Net-zero global emissions by year 2050.

 

The Green New Deal was introduced in response to these reports to provide a massive, comprehensive policy package to combat the reported future impacts of climate change.

What actually is the Green New Deal?  In broad terms, the Green New Deal aims to eliminate U.S. GHG emissions and remake the economy/energy sector by investing in new jobs and infrastructure, all while protecting “frontline and vulnerable communities” such as indigenous people, rural communities, low-income workers, the disabled, the elderly, and minorities.

The Green New Deal challenges the U.S. to meet the following goals in a 10-year period:

  1. Achieve net-zero GHG emissions;
  2. Create millions of good, high-wage jobs and ensure prosperity and economic security for all people of the U.S.;
  3. Invest in infrastructure and industry to sustainably meet the challenges of the 21st Century;
  4. Secure clean air and water, climate and community resiliency, healthy food, access to nature, and a sustainable environment for all people; and
  5. Promote justice and equity by stopping current, preventing future, and repairing historic oppression of frontline vulnerable communities.

 

By now you might be thinking, “How would we pull this off”?  This is the main question on everyone’s mind.  The fact is, that’s unknown.  Again, H.Res.109 provides a blueprint for the programs that some believe would allow the U.S. to meet those 10-year goals. However, in practice, the actual programs would need to be designed, engineered, funded, and ultimately accepted by impacted communities as appropriate.  For reference, the types of programs and projects presented in H.Res.109 include, but are not limited to:

  1. Meeting 100% of U.S. power demand through zero-emission energy sources by expanding and upgrading existing renewable power sources and establishing new sources;
  2. Upgrading existing buildings for maximum efficiency and durability and ensuring all future infrastructure bills address climate change;
  3. Removing GHG emissions from manufacturing, agriculture, and transportation industries as much as technologically feasible. This would be achieved through investments into programs such as renewable energy manufacturing, family farming/sustainable land use, and public transit/high speed rail; and
  4. Removing existing atmospheric GHG through soil carbon storage techniques (e.g., carbon sequestration, afforestation).

 

The Green New Deal recognizes that accomplishing these goals is an enormous undertaking and will completely alter our current economy and workforce.  Since many of these projects will need to be carried out by the affected communities themselves, H.Res.109 is attempting to incentivize community mobilization by providing community “safety nets”, such as:

  1. Providing public ownership stakes and returns on investment, adequate capital, technical expertise, and supporting policies;
  2. Creating high-quality union jobs and/or guaranteed jobs for workers who transition to “clean” jobs;
  3. Enforcing and creating trade regulations to promote domestic job and manufacturing growth; and
  4. Providing universal health care and affordable housing.

 

Senate Majority Leader Mitch McConnel (R-KY) has announced that he plans to bring the Green New Deal to a Senate vote.  As of March 19th, the vote has not occurred and is not yet scheduled.  Again, it is important to note that even if this resolution is passed, it does not itself create any new laws or programs.  It would only provide a target for future programs and a political consensus on climate change ideology.  It is curious that a few of the community “safety nets” cited in the document are currently political “hot potatoes” that are not universally embraced by the primary political parties and their constituents.  The evolution of the Green New Deal will likely play out over the next several years in a contentious manner and it will be interesting to see how it either evolves into a workable policy or is driven to extinction.

That’s all for now.  As always, we will continue to watch closely for developments.  Please comment your thoughts below or reach out to me directly at kturney@all4inc.com.

Representing MSS Emissions in the Emissions Inventory

A good portion of the Texas refineries are taking a deep breath as the Refinery Sector Rule (RSR) compliance date is behind us, but the work isn’t over yet. The end of January means the environmental reporting season is upon us, but there’s no need to worry. The ALL4 team is on top of everything new in the world of Annual Emissions Inventories (AEI) in Texas. The Texas Commission on Environmental Quality (TCEQ) held an Emissions Inventory Workshop on January 24, 2019, where permit writers and technical experts described updates to AEI and discussed pitfalls as well. A particular topic that has caused confusion among the audience is the concept of representing Maintenance/Startup/Shutdown (MSS) emissions in the AEI.  Read on for some further details and explanations.

Just as the TCEQ staff begins their presentations with necessary definitions, the same strategy is being done here. Taking time to define the terminology that isn’t always intuitive can offer clarity around a confusing situation.

Understanding Key Definitions

The TCEQ has offered many resources that define the following terms.

  • MSS Emissions
  • Scheduled Maintenance/Startup/Shutdown (SMSS) Emissions
  • Emissions Event (EE)

The definitions can offer a comprehensive understanding of the terms, but I have included brief descriptions and an example to guide you through.

MSS emissions are abnormal emissions that are expected and defined in the permit. SMSS emissions are not defined in the permit, yet are known in advance, allowing TCEQ to be notified beforehand. EEs are not permitted and not known in advance. These are the unexpected upsets at a facility.

Let’s go through this with some scenarios…

Imagine you work in a chemical plant. A planned annual turnaround that has been worked into your permit falls under the MSS emissions category. Different activities such as increased flaring, vessel cleaning, or maintenance procedures will be taking place resulting in non-routine emissions. These are all planned for and happen periodically.

Now consider the turnaround has been completed and normal operations have resumed-a normal day at the plant. An operator walks into your office and says that the distillation column outside is running fine, but the walls are thinning too fast. No excess emissions are happening at this point, but you now realize that you need a new column. However, the next turnaround is in two years. You will have to shutdown the unit in the current year, but the excess emissions from a shutdown and cleanup are not written into your plan or your permit. This is a SMSS event. You have the time to alert TCEQ because nothing is urgent (for now), but this is still outside of your permitted emissions. This is not routine, but you do have time to discuss this with TCEQ.

Consider a final scenario, perhaps a few weeks later, a pinhole leak bursts from that same column that resulted in emissions greater than permit limits. This would be considered an unexpected EE.

Representing MSS Emissions in the Emissions Inventory

Now that the terms are clear, it’s important to understand how these different situations should be represented within the AEI. Our focus will be representing MSS emissions.

TCEQ has developed a hierarchy for representing MSS emissions in the AEI because there is a preferred way of including this information. Disclaimer to those attempting this for the first time: TCEQ suggests gathering your data, building a plan, and calling them to propose it before taking next steps.

The hierarchy for inputting MSS emissions data is as follows:

1. No Structure Change- Enter all the emissions as if they occurred from the one emissions point. There should be no structural addition (e.g., no changes to emissions sources, points, abatement devices, or emissions data) to the AEI. The emission point should contain both normal operational emissions and MSS emissions.

2. New MSS Emission Point Number (EPN)- Under the same Facility Identification Number (FIN) there would be two different  EPNs: one for regular emissions and another for MSS emissions.

3. New MSS Group FIN and EPN- This option would allow a new FIN that was broad and contains the MSS emissions of multiple pieces of equipment grouped together. In the example of a group of tanks, report regular emissions as their normal FIN and EPN. Then create a FIN and EPN called “Tanks 1-10 MSS” and report all their MSS emissions in that line.

4. Site Wide MSS Path- This is similar to the above example except there are no groups. There would be a “Site Emissions MSS” path that contained all the MSS emissions lumped together.

5. New Path with New FIN- This is not preferred. It involves a new FIN and path for each piece of equipment that is labeled “MSS.” It creates a lot of duplicates in the system and therefore should be a last resort.

These are the options that TCEQ laid out at the workshop. We recommend that you give TCEQ a call before embarking on a large emissions inventory and/or revisions. If none of this is your cup of tea, feel free to connect with me about this topic or a wide range of others.  I can be reached at rhenn@all4inc.com or 281-201-1244 .

Reflections from 2018 Year End Reporting – Part 5: Production Data Discrepancies

Welcome to the last of a five-part blog series hosted by ALL4’s Continuous Monitoring Systems (CMS) Practice Area that looks back at some of the key points of discussion that came up while completing reports for the second half and fourth quarter of 2018 reporting periods.  In Part 5, we review the importance of accurate production data and how discrepancies between production records could create compliance issues.

Facilities that use CMS to comply with applicable emissions or operating parameter limitations often track facility production in the data acquisition and handling system (DAHS), as well as outside of the DAHS in a separate system, file, or other record type.  And while the DAHS may use certain monitoring inputs and calculations to continuously track production, the methods to calculate facility-specific production records might differ from what is programmed in the DAHS.  So, what are potential implications if DAHS production records differ from facility records?

Discrepancies between production records creates risk when used for compliance demonstrations – which data should be used for compliance?  Is there a written procedure?  Is the approach consistent across facilities within the same company?  Emissions limitations are often written in terms of mass of pollutant per unit of production (e.g., lb NOX/tons of product), so if production data is incorrect, do the operators really know their facility’s compliance status with an applicable emissions limitation?  Likely not, which means the operators are working “in the dark” with respect to certain emissions limitations.  This could potentially lead to excess emissions being missed, in addition to the immediate notification to the regulatory agency required for those excess emissions.

Additionally, if production data is incorrect in the DAHS, it is possible that the DAHS is not correctly identifying periods of process on, process off, startup, shutdown, or idle.  Therefore, if a facility has process status-specific emission limitations or operating parameter limitations, the limitations could be incorrectly applied during the erroneous process status.  Like the previously mentioned scenario, this could result in a facility failing to be alerted of excess emissions during specific periods of operations.  The point we want to make here is simple – that is, it is critical to verify that DAHS production records align with facility specific production records to minimize potential compliance issues that could creep up because of a discrepancy.  If you have questions about how your DAHS calculates production data, or any other aspects of CMS, please reach out to me.  I can be reached at (610) 933-5246 extension 139, or at mcarideo@all4inc.com.

If you have not done so yet, don’t forget to read Part 1: Validation Sequence Impact on Data ValidityPart 2: Ancillary Analyzer Impacts on Data Validity, Part 3: Temperature Monitoring Impacts on Data Validityand Part 4: DAHS Server Upgrades of this five-part blog series that reflect on other topics that came up during ALL4’s 2018 year-end CMS reporting.  To ensure that you do not miss out on the action, signup below for our 4 The Record articles to receive timely updates of current hot issues, as well as in-depth articles that highlight important regulatory topics.

Reflections from 2018 Year End Reporting – Part 4: DAHS Server Upgrades

Welcome to the fourth of a five-part blog series hosted by ALL4’s Continuous Monitoring Systems (CMS) Practice Area that looks back at some of the key points of discussion that came up while completing reports for the second half and fourth quarter of 2018 reporting periods.  In Part 4, we review potential issues that can result from a CMS data acquisition and handling system (DAHS) server upgrade.  Be sure to check out Part 1: Validation Sequence Impact on Data Validity, Part 2: Ancillary Analyzer Impacts on Data Validity and Part 3: Temperature Monitoring Impacts on Data Validity

The DAHS is a critical component for any CMS because it is the common link between all other components of the monitoring system, and often, for all CMS at a facility.  The DAHS functions to receive, calculate, manage, and record the data outputs from all analyzers (or monitors) and components of a CMS.  As the common link in a system (or multiple systems), issues with the DAHS can potentially cause invalid data for multiple CMS and can potentially affect the process at the facility.  In this past reporting period, we saw issues arise when DAHS software was upgraded as part of periodic maintenance completed by the DAHS vendor.  As an unintended consequence, the DAHS software upgrades caused missing data across multiple CMS.  The validity of data was affected while the upgrade was being completed.  Unfortunately, the impacts continued undetected by the facility for many days after the upgrade was complete.  As a result, operators were working “in the dark” with respect to certain compliance calculations and averages that were affected by the upgrade.  DAHS upgrades are periodically completed by the DAHS vendor; therefore, the facility can take steps to minimize any potential issues that may arise.  So, what can be done?

Well first off, establish a protocol that requires the DAHS vendor to ensure assigned plant personnel are notified prior to and during the DAHS server upgrade.  Consider including a plant personnel approval prior to actual work being performed.  The intent is to make sure that affected parties are in the know – the timing of the upgrade, what CMS are affected, when the CMS come back online, and can any lost data be restored.  Additionally, the facility should ensure that any site-specific changes that were made to the DAHS in the past are carried through to the upgraded DAHS.  Any of these site-specific changes that were made to the DAHS should be documented, and after the DAHS server is upgraded, the facility should confirm the DAHS is operating as expected.  In other words, what procedures does your DAHS vendor follow to manage change during these necessary upgrades to minimize downtime and ensure that the compliance demonstration within the DAHS remains unchanged.

If you have questions about planning for these upgrades or to get more information on what questions to ask you DAHS vendor, please reach out to me.  I can be reached at (610) 933-5246 extension 139, or at mcarideo@all4inc.com.

Don’t forget to look for Part 5, the last of this five-part blog series where we review the importance of accurate production data in the DAHS relative to facility records.  To ensure that you do not miss out on the action, signup below for our 4 The Record articles to receive timely updates of current hot issues, as well as in-depth articles that highlight important regulatory topics.

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