DAS Compliance

Over time, small problems and inconsistencies that creep into system configurations and processes can become large sore spots, causing extra effort and concern. Also, the ESC DAS software and hardware have both evolved and you may be using workarounds or doing without features that are currently built-in to newer versions. It is likely that things have also changed around the DAS, like new hardware, new staff or plant operations. Is the DAS still in synch with your current needs?


Ask yourself things like:
  • Am I manually creating or editing any reports outside of StackVision?
  • What problems do I deal with that might be solved by new features?
  • Am I confident that we can still demonstrate compliance adequately?
  • Are nuisance alarms driving everyone crazy?
  • Can we be more efficient?


Take a little time now, to save yourself more time and trouble in the future. Need Guidance? ESC provides a service we like to call the DAS Evolution Process.


The DAS Evolution Process

  • Discover – Review your daily processes to identify areas to better use software functionality
  • Implement – Work with your staff to implement as many changes as time allows
  • Document – Outline changes made and recommendations for future improvements
When ESC assists customers with a DAS Evolution, it is normally a two-day engineering engagement that begins with a half-day review with your staff of your DAS and daily processes. Together we would create a prioritized list of improvements and fixes. The engineer would then work through as many items as possible with you during the engagement and provide a follow-up list of any remaining items.

Examples of areas you would consider reviewing as part of your own DAS Evolution (or with ESC assistance) may include, but are not limited to:

Review of actions being done outside of the DAS
  • Are you exporting data and creating reports manually? Why?
  • Are you using outside programs to analyze data? (Excel™ graphs, PI, Access™, etc.)
  • Are any hand edits being made to reports and why?
  • Are calibrations automated or done one-off? (And where is the gas bottle inventory kept?)  
Review of data Quality Assurance (QA) processes
  • Is the DAS automatically marking Start-Up and Shut-Down periods?
  • Is the DAS configured to correctly apply Reason and Action Codes?
  • Is the DAS set up to print and/or email daily reports? Do they include what the person receiving them needs?
  • Are custom Views set up to display quickly, the exact data needed?
Review Reports
  • Do you have a report menu structure that includes each compliance report with preselected sites, parameters, and intervals?
  • Are your reports configured so you can just set the dates and go?
  • Are new report functionalities, such as Cal Graph, Average Data Query, and Matrix being incorporated?  
Review of any additional equipment that is collecting data
  • Are your alarms still accurate following configuration changes?
  • Do you have nuisance alarms that interfere with knowing when to act?
Review of any additional equipment that is collecting data
  • Generators, auxiliary boilers, baghouses etc.
  • Should you bring in sources that are used in emissions inventories, etc?
Review new configuration tools that may solve issues:
  • Delay on alarm for digital bits
  • Out-of-Control (OOC) clocks and how to best use them
  • XScript in Condition Manager – To address non-standard issues
8864 Consolidation
  • Combining of older controllers i.e., CEMS logger vs. HG logger
Review additional communications we provide:
  • Accepting data from Modbus, PI/OPC
  • Implementing Parallel Modbus – Highly recommended
The list you create with your assigned engineer will be unique to your facility, these are just a few sample possibilities that we think you could benefit from.

How about Permit Compliance? A good compliance review should consist of three distinct stages:
  • Permit Review
  • DAS Permit Analysis
  • Configuration Updates
ESC's review uses the following checklist for performing the 3 stages to a good compliance review with a customer:

1. Permit Review (CEM Compliance requirements detailed):
  • ESC performs the permit review and creates an initial draft of the document
  • ESC and Customer discuss initial draft document via conference call
  • Customer responds to questions/issues discussed during the call
  • ESC incorporates responses into final draft document
  • Customer confirms accuracy of ESC’s final draft document
  • ESC issues final document after confirmation of accuracy
2. DAS Permit Analysis (Engineering Design Review):
  • ESC performs a system design review based on the approved compliance review from the previous phase
  • ESC documents the findings, including a list of recommendations for potential changes to monitoring, calculating, & reporting to improve compliance, then provides the findings to the customer
  • The findings are reviewed with the customer via a conference call
  • The customer then responds to questions/issues discussed during the call
  • ESC incorporates the responses into the DAS Permit Analysis
  • Customer confirms the accuracy of DAS Permit Analysis
If there are changes recommended in the DAS Permit Analysis, the customer will determine the priority of the changes that ESC would perform.

3. Configuration Updates
  • Includes 20 hours of configuration services to implement changes
  • Includes 2 day(s) FAT at ESC's office

Final Compliance Review documentation would include:
  • Permit Review
    • Includes an explanation of ESC’s interpretation of Customer’s permit requirements
  • DAS Permit Analysis
    • Defines how the DAS monitors, calculates & reports permit compliance
  • Recommendations
    • Potential changes to monitoring, calculating, & reporting
      • (Note: All of the above may be combined into a single document, depending on complexity)
  • Project Closure Document outlining changes made to the DAS configuration
 
Whether you need our DAS Evolution or a Compliance Review, ESC is here to assist you.
 

Contact the ESC Sales Team to inquire about purchasing an 8864 or any of the ESC Engineering Services.
512-250-7902  •  sales@envirosys.com
 

The ESC Engineering Staff    Published: 7/26/2018 12:27:08 PM

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