One Answer to Better CEMS/DAS System Maintenance - Training & Then More Training
Knowledge is power is a phrase most commonly attributed to Sir Francis Bacon published in 1597. This isn’t exactly the literal translation of what was said, but it is the common interpretation of what he did say. There is evidence of earlier references from Imam Ali (599-661 CE), as recorded in the tenth-century book Nahj Al-Balagha[1] and others who expressed similar words of wisdom in their writings. The deeper you dig into the origin of the phrase the more references appear throughout history and across all cultural landscapes. This saying, in one form or another, has been a foundation of true beliefs for centuries and will likely hold true for several more.
It is the relatable phrase of scholars and poets of philosophers and teachers of kings and the common man. The more we know the stronger we are as individuals or as a society. If we commit to more knowledge, we gain insights that increase our value to a group and our ability to contribute to the good of the whole. This concept applies to any subject and any situation.
Manufacturing companies that have operations governed by air emission regulations have the responsibility to keep their monitoring systems in good working order. To properly ensure compliance they are further obligated to maintain this equipment by following a regular, well defined QA/QC Plan (see 40CFR Part 60 Appendix F – Procedure 1: Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determination). The key to a good QA/QC Plan is outlined in those sections and procedures tied to preventative maintenance activities. In order to properly execute the maintenance program, you need trained personnel.
Training is the name of the game when it comes to proper care and feeding of CEMS equipment and compliance reporting. Every CEMS integrator, analyzer manufacturer, system component supplier and DAS software provider in the air compliance game that is worth their salt should offer training for end users. The goal here is to allow their clients the opportunity to be self-sufficient in support of the equipment they purchased. Training options should be flexible, accessible and audience driven. They should also provide periodic opportunities to bring training to the masses, run in conjunction with user groups, CEMS conferences, environmental meetings and if all else fails, through webinars. You can never get enough training. If you are working with a supplier that does not routinely offer training on their stuff, then you may need to find another provider.
Initial or startup training is just as it implies. It is a service provided following the installation, commissioning and startup of the monitoring system. Depending on the product purchased it may be provided as a factory service, onsite training class or some combination of both. When evaluating this type of training you want to think about who should be receiving the training and the level of training needed for each group. Remember in a compliance situation you want some level of training for every discipline that comes into to contact with the system on a regular basis. Analyzer level training may be limited to I&C Technicians, but some level of CEMS/DAS training would be valuable to operations, production, maintenance, I&C techs and environmental staff. Training should be custom fit for the situation.
After the initial training you must determine your best path forward. First you must decide if you are going to support your system maintenance with in-house staff or if you are going to farm it out to a professional service company. Assuming you are going to keep it home, I suggest refresher training about 3-months after startup. The installation, commissioning and startup period is typically jammed into a compressed time-frame with a lot of intense activity involving representatives from several departments. Training is often left to the last onsite day of the vendor. The vendor rep is tired, your staff is tired, and the regular daily work is backing up. All intentions are good and the training itself may be stellar but, in this environment the finer details for ongoing maintenance will more times than not be lost. Three months down the road there is a high probability that key support personnel will not remember everything they need to maintain the system properly. This sets up a bad precedent going forward easily addressed by scheduling follow up training.
Refresher training should be complimented with intensive training addressing the more specialized areas of the system. Consider developing in-house experts through specialty training targeting I&C and environmental staff. Most vendors offer this kind of training to assist end user partners in supporting their own stuff through offsite events and/or factory run courses. Many offer online or webinar series which lighten the commitment load for the staff. I am a big fan of face to face and student/teacher interaction so my preference is to be in front of folks when training, but webinars can be an effective, lower cost alternative.
To improve training efficiency, you might want to add a train the trainer component to your learning model. This is a further step towards self-help, requiring cooperation of the vendor. Once the trainers are trained you can build a regular schedule for subordinate personnel to keep up to speed on the latest developments and for training new recruits. If this option is not immediately offered, then you should ask your vendor if it can be added to the mix.
If train the trainer is not an option, then consider a shadowing program which utilizes vendor staffing for support while being teamed up with an in-house team member. This is a hybrid approach to system QA/QC typically managed under a maintenance contract agreement with the support supplier. The vendor provides regular visits to the site to cover routine maintenance and is shadowed by a designated plant representative. Over time you should be able to wean yourself off the vendor and be self-sufficient.
Access to the knowledge needed to build a sustainable environmental system support program has improved significantly over the years. Performance visibility through available diagnostic outputs from analyzers, tied to local DAS screens and integrated into plant DCS HMIs certainly helps. Availability of system manuals and online help screens are more usable, further enhancing the preventative maintenance mission. All these improvements are great additions but are not substitutes for the learning that comes from training. Apply every advantage offered but back it up with a solid training commitment.
Regardless of its origins, the old adage about knowledge is as true today as it ever was. You can never know too much but you can be caught off guard by not taking the opportunity to know more. Thank you for taking the time to read my views on improving CEMS performance through training. We wish you all the luck and success going forward through your diligent commitment to compliance excellence.
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[1] Scientia potentia est - from Wikipedia, the free encyclopedia