Update on the CEMDPS and Manual Implementation

September 12, 2008

CEM Data Processing System (CEMDPS) Online Application and timeline for the implementation of Revision No. 8 of the Continuous Source Monitoring Manual (Manual)

A draft version of the "Applicability Determination and Implementation Procedures for Continuous Source Monitoring Manual Revision No. 8" will be posted in the PA Bulletin for public comment on September 13, 2008.  The public comment period will be from September 13 - October 13, 2008.  A copy of the Bulletin Notice (which contains the instructions for commenting) will be placed on the CEM and Air Quality websites.  Please review the document and provide comments as needed.

CIBER is nearing completion of the repairs of the defect and gap items with the CEMDPS Online Application that were identified during the CEMDPS trial and warranty period.  All remaining items pertain to the Department side of the application (Internal) and will not impact the ability of industry users to utilize the application.  Any new defects and gaps found with the application will be addressed by CIBER through the service contract they have with the Department.  CIBER has and will continue to make improvements to the application, based upon comments that we have received from the owners/operators of those facilities involved in the trial and Department use of the application.  One substantive improvement is an enhanced explanation of errors that are generated when the user validates a submittal.  Hyperlinks to the location of the error were established in order to save users time and make the application more user friendly.

CIBER will be providing Department users with additional training on the use of the Internal side of the application during the week of September 22, 2008.  Department staff will be able to evaluate the submittals received during the CEMDPS trial upon completion of this training.  The Department has received monitoring plans, test protocols, and test results from those taking part in the CEMDPS trail.  The Department is requesting that sample quarterly reports be submitted for the companies involved in the trial as soon as possible.

The disconnected client application of the CEMDPS Application requires reconstruction to incorporate the numerous changes that CIBER has made to the application.  A strategy to distribute the disconnected client to industry users will be established in the near future.

The Department and CIBER have developed a 12-step process that will be utilized to migrate the facility system configuration, historical test, and emissions data information into the new CEMDPS.  The Department will contact the owners/operators of each facility to work through the process.  Priority will be based upon the Revision 8 Manual implementation date for each facility.

April 21, 2008

CEMDPS Trial Meeting with Reliant Energy:  On April 10, 2008, representatives from the Department, CIBER, Reliant Energy, and ESC met in the Rachel Carson State Office Building to discuss the specifics of the trial concerning the new CEM Data Processing System (CEMDPS).  Reliant’s configuration and historical data will be migrated into the production environment of the new CEMDPS in the next week or two and Reliant will perform various tasks in the new system (submitting and uploading a monitoring plan, test protocol, performance testing data, and quarterly emissions data).  Two other companies (Merck, and Sun Refining & Marketing Co.) will also take part in the trial in the near future. 

The following requests were made by Reliant:

1. To allow the person exercising managerial responsibility (responsible official) to formally delegate authority to submit information to the Department in the new CEMDPS. 
2. Instructions on how to perform various activities in the new system.
3. A copy of the Question & Answer Document for Revision 8 of the Manual and the new CEMDPS.

Review the Draft Meeting Minutes

The Department has posted the Question & Answer Document on the CEM website and will address items 1 and 2 in the near future.

March 14, 2008

The Department/CIBER has been able to successfully migrate the configuration and history associated with two of the trail facilities in our development server and we are close to resolving the errors in the third.  There were several system errors that were generated when each facility was run, requiring work on our end to resolve.  These were errors within our system, so those involved in the trial should not be concerned, other than knowing that they occurred and will occur when data is migrated.  This process has taken some time, but it has proven fruitful, since we were able to make corrections and write scripts that will reduce the number of errors encountered when other facilities are migrated.

The next step in the process will be the migration of this information into the production environment so that it can be accessed by the trial companies.  This should happen early next week (it can take place in less than a day).  If there are any errors that could not be resolved by making corrections in the current system or by writing migration scripts, a manual edit of the database would need to be conducted.  We anticipate a limited number of these, if any, and they can be resolved quickly.

We will be getting in touch with the companies involved in the trial next week to discuss participation in the trial.  Discussion will center around the current capabilities of those involved in the trial (i.e. can they submit emissions data in the new format?), how/where to log into the new system, confirming the migrated information is correct, activities to accomplish in the new system, etc.

January 31, 2008

1. The CEMDPS*Online application was deployed into the production environment by our Bureau of Information technology as of January 29, 2008.  We have started the migration of the trial facilities configuration data and are working through the errors that have been generated.  We are close to resolving the errors for one facility.  Access to the application has been temporarily limited to Department and CIBER staff involved in this process.
2. The CEMDPS Q&A document is up to 34 pages and will continue to grow.  It's format is similar to the 40 CFR Part 75 Emissions Monitoring Policy Manual.   A few things need to be completed before the current draft can be posted.  Attached is a link to EPA's manual so that you have a better idea of the format that has been followed:http://www.epa.gov/airmarkets/emissions/monitoring.html
3. We are still on track to provide the disconnected client application for testing during the trial.
4. The Department is currently working with CIBER to resolve defects that have been identified with the new CEMDPS; this effort will continue.
5. The Department is currently discussing the timing of the next meeting for those involved with the trial.  We will still provide you with a summary of the kick-off material and guidance so that you will have an opportunity to review it before the meeting.   We will follow-up with additional details when they become available.

December 27, 2007: The Department anticipates that the CEM Data Processing System (CEMDPS) project will be completed by the end of December of 2007.   A 90-day warranty period will begin upon completion of the project.  Completion of the project is contingent upon the following:

1. It is understood and expected that review of the User Guides (Internal and External) will continue through the 90-day warranty period.   Corrective action for reported system defects during the warranty period may also require CIBER to update the User Guides as appropriate.
2. CIBER will continue to work with the Department to categorize items that are identified in the “CEMDPS Defects and Potential Future Requirements Document” during the warranty period.  Those items identified as “Defects” will be addressed by CIBER.
3. The successful completion of user acceptance testing (UAT) for the disconnected client application.

In an effort to ensure that the new system will function as designed, the Department has begun a trial to migrate facility information for the owners/operators at selected facilities that have voluntarily elected to start the process of coming under Revision 8 of the Continuous Source Monitoring Manual (Manual) prior to the announced implementation date.  Presently, it appears that the Department will not be able to deploy the application into the production environment until the middle of January 2008.  Once the deployment is completed, the migration of trial facility information will commence.

The Department will work closely with the owners/operators of these facilities to develop implementation procedures and to determine the appropriate time to announce in the PA Bulletin that updated CEMDPS has become functional.  It is anticipated that this announcement will occur sometime during the first or second quarter of 2008.

A question and answer document concerning the new CEMDPS, Manual, and the implementation of the Manual is currently being developed.  It is anticipated that a draft of this document will be posted to the CEM Website in early January 2008.  It is also the Department’s intent to present a copy of the disconnected client application to those involved in the trial for UAT.

The Department is tentatively looking to set-up a meeting with those involved in the trial in early February 2008.  The timing is dependent upon the deployment of the application into the production environment and the speed at which the Department can migrate facility data.  A summary of the kick-off material and guidance for the trial will be developed prior to the next meeting.

If you have any questions, comments, or concerns with this process, please contact Charles Zadakis at (717) 772-3944 or by e-mail at czadakis@state.pa.us.