Start-up and performance test planning
Emissions unit source controls can become required due to a wide variety of routes. These include BACT under PSD, LAER under NNSR, MACT, NSPS, state rules, and others. In all cases the new equipment must be correctly installed, prepped for startup, started up, shaken down (debugged while operating), and given a performance test. Sage is very well qualified to provide assistance for these kinds of activities to facilities.
The keys to a successful startup and operation of a control device include a competent and comprehensive design of the new equipment and a good startup plan. While the design of the equipment being installed would be typically out of Sage purview, the preparation of (or modification to) a startup plan is an important service that Sage can provide. The startup plan must encompass or address the process unit startup and emissions unit startup for which the control technology is being installed in addition to the control device and all monitoring equipment. Sage can also provide on-site presence during the startup and shake-down period to help identify and deal with emissions control and monitoring issues as they arise.
Following the startup and shake-down period, the emissions unit must be tested with approved performance test methods that demonstrate compliance with the emissions standards and permit requirements and also fulfill the Relative Accuracy Test Audit (RATA) requirement necessary to certify any continuous emissions monitoring system (CEMS). Since performance testing and RATA testing may have different sample period durations, it is necessary to design a test plan that accommodates both. For this key step, it is necessary to have both a performance test plan and a monitoring quality assurance plan that work together. Sage is both experienced and capable in the preparation of these plans.
Sage personnel have a great deal of experience with various control devices, including wet gas scrubbers, electrostatic precipitators, vapor combustors, carbon adsorbers, etc. Some of the Sage personnel also have plant and facility backgrounds where they were exposed to various control technologies for different kinds of emissions units in some detail. Many of our personnel have Chemical Engineering degrees and include a number of registered Professional Engineer (P.E.) certifications in a variety of states. Sage also has personnel that have stack testing experience, both hands-on and in management of performance testing programs.
In order to help plan the startup and develop subsequent performance testing and monitoring system certification plans, Sage recommends that they be notified well before (2 to 3 months are recommended) the equipment startup is to begin so that Sage can help in the planning and produce the necessary written plans. Sage would assess the type of process unit, emissions unit, control equipment, and monitoring equipment and then produce a startup plan (or modify an existing plan), a monitoring quality assurance plan (which would include the CEMS certification and continuing QA requirements), and a performance testing plan. Sage would review these plans with the facility, make changes as required, issue the plans for the record, review plans with facility personnel, and assist in the implementation of the plans as directed by the facility.
Sage personnel have considerable experience in helping clients with startup and testing of emissions controls. A client list can be furnished upon request, along with a statement of qualifications.