ESP:Electronic Recordkeeping and Reporting
Any plant that operates under a Clean Air Act Amendment Title V Operating Permit has undoubtedly been frustrated by the permit’s labor-intensive recordkeeping and reporting requirements. These requirements place significant pressure on the environmental staff responsible for recording information and preparing the reports, as well as on the “responsible official”—the signing authority for the Title V permit application. The first Title V certification can be especially difficult for many facilities—for the year the Title V permit is issued, the facility must complete a compliance certification for the period from the date the permit is issued through December 31. Even if a permit is issued in December, a facility will have to provide a compliance certification covering this period. This often means spending a great deal of time scrambling for information and then hoping that the submitted reports won’t raise any red flags with state officials.
Further complicating the situation is the fact that recordkeeping and reporting requirements vary for each facility, depending on the type and amount of emissions, as well as on the control equipment used. Meeting these requirements through manual tracking and reporting efforts can be costly and time-consuming and presents numerous chances for human error.
Recordkeeping RequirementsThe recordkeeping requirements for plants operating under a Title V permit vary depending on the emission control equipment used. For plants using venturi scrubbers to control particulate matter (PM) emissions, detailed records must be kept for any three-hour average measurement of the scrubber pressure drop that is less than or equal to 90% of the average value established during performance testing. Records must also be kept for any three-hour average measurement of the scrubbant (reagant) flow rate that is outside the range of 80 to 120% of the average value established during performance testing. Any routine maintenance and shut down/start up times must also be tracked.
For plants using an electrostatic precipitator (ESP) to control PM emissions, any three-hour average measurement of the secondary voltage of each field that is less than 70% of the value established during performance testing must be recorded. Companies must also record any three-hour average measurement of the secondary amperage of each field that is less than 70% of the value established during performance testing, as well as any routine maintenance and shut down/start up times.
Companies that operate baghouse systems must perform regular checks—at least once for each day or portion of each day of operation—to determine whether visible emissions are present. If the baghouse is releasing visible emissions, the company must determine the cause of the emissions and correct the problem as quickly as possible. The company must then record in a “maintenance log” the cause of the visible emissions and any pertinent operating parameters, as well as the corrective action taken. Facilities operating baghouse systems must also record any pressure drop across the baghouse to ensure that it remains within the appropriate range, as well as any routine maintenance and shut down/start up times.
For cyclones and/or multiclones, companies must inspect the exterior of the system for holes in the body or evidence of malfunction in the system’s interior for each week or portion of each week of operation. Any adverse condition discovered by the inspection must be corrected as quickly as possible and must also be recorded, along with any pressure drop across the cyclone/multiclone and all shut down/start up times.
Facilities that operate regenerative thermal oxidizers must record eight-hour averages of combustion zone temperatures, 12-hour averages of gas stream pressure in the plenum, 12-hour averages of the fan motor speed and 24-hour averages of the fan static pressure, as well as any routine maintenance and shut down/start up times; while plants operating thermal oil heaters must record any routine maintenance performed on the system. Any facilities with fugitive dust emissions must maintain a record of all actions taken to suppress fugitive dust from roads, storage piles or any other dust sources, and these records must include the date and time of occurrence and a description of the actions taken.
Companies operating under a Title V permit must keep a number of records for at least five years, including:
- Sampling of measurements—including the date, place and time of sampling or measurement; the date(s) analyses were performed; the company or entity that performed the analyses; the analytical techniques or methods used; the results of such analyses; and the operating conditions as existing at the time of sampling or measurement.
- Records describing the routine maintenance performed on all air pollution control equipment.
- Monthly records of the amount of product processed through some emission units (this information is necessary to confirm compliance with the production limit).
- Files of all measurements, including continuous monitoring systems, monitoring devices and performance testing measurements; all continuous monitoring system or monitoring device calibration checks; and any adjustments and/or maintenance performed on these systems or devices.
- Records of all actions taken to suppress fugitive dust from roads, storage piles or any other sources of fugitive dust.
Reporting RequirementsIn addition to the cumbersome recordkeeping requirements of Title V, a substantial number of reports must also be filed with state offices. These include quarterly and/or semiannual reports, annual compliance certification, annual emission fees and notices of emission limit exceedances.
Out of Compliance Notification Reports. Any company operating under a Title V permit must submit a written report to their state within seven days of any deviations from applicable requirements associated with any malfunction or breakdown in the process, fuel burning or emissions control equipment that lasts for four hours or more and that results in excessive emissions. The report must contain the probable cause of the deviations(s), duration of the deviations(s) and any corrective actions or preventive measures taken.
Semiannual Reports. Companies must also submit written reports of any failure to meet an applicable emission limitation or standard contained in the permit and/or any failure to comply with or complete a work practice standard or requirement contained in the permit. Such failures are typically determined through observation, data from monitoring protocol or any other monitoring that is required by the permit. The reports must cover each semiannual period ending June 30 and December 31 of each year; they must be postmarked by the 30th day following the end of each reporting period (July 30 and January 30, respectively); and they must contain the probable cause of the failure(s), duration of the failure(s) and any corrective actions or preventive measures taken.
The reports must also document any excess emissions, exceedances and/or excursions as described in the permit, as well as any monitoring device malfunctions that have occurred within the reported timeframe. If no excess emissions, exceedances, excursions or malfunctions have occurred during a reporting period, this must be stated in the report. The report must also contain:
- The total process operating time during each reporting period.
- The magnitude of all excess emissions, exceedances and excursions computed in accordance with the applicable definitions as determined by the state, and any conversion factors used, as well as the date and time of the commencement and completion of each occurrence.
- The date and time identifying each period during which any required monitoring system or device was inoperative (including periods of malfunction), except for zero and span checks, and the nature of the repairs, adjustments or replacement. When the monitoring system or device has not been inoperative, repaired, or adjusted, such information must be stated in the report.
Annual Compliance Certification. All reports that are submitted for operation under a Title V permit must be certified by a “responsible official” within the company that the statements and information in the report are true, accurate and complete based on information and belief formed after reasonable inquiry.
Annual Emission Fees. Companies operating under a Title V permit must calculate their annual emissions of criteria pollutants and multiply it by the fee rates to determine their annual emission fees. Miscalculations due to human error can be costly—typically, minor miscalculations require back payment of fees, while gross miscalculation can lead to fines, depending on the circumstances.
An Electronic SolutionThe foregoing requirements are only a few examples of the many different conditions for maintaining compliance with the Title V emission operating limits and its testing, monitoring, recordkeeping and reporting requirements. These conditions can be overwhelming for many of today’s plants, which must operate with increasingly fewer employees to remain competitive. In addition, the “responsible official” at the facility must depend on operations and maintenance personnel to conduct the periodic activities required by the conditions and record them correctly.
The optimal solution for maintaining compliance with a facility’s Title V Permit is an electronic recordkeeping and reporting system. A successful system should be user-friendly, so that all employees responsible for upkeep of the Title V permit can easily use it. It should be customized to address the facility’s specific Title V permit conditions, and it must allow for user input of the data to be recorded as required by the facility’s permit, such as pressure drops, visible emissions, etc. The system should also generate all required reports and enable the responsible official to review the data electronically in a very friendly mode. It should alert the user to any non-compliance issues, prevent the facility from being in non-compliance, minimize the recordkeeping time requirements and maximize the accuracy of the reports. Finally, it should also be affordable.
One such system* meets these criteria and also provides other beneficial features. The main screen provides buttons to access all recordkeeping and reporting requirements. A “Permit” button opens the Title V Permit, and an “Emission Units” button opens the emission units that have operating conditions. Clicking on the “Baghouses” button, for example, opens a screen that shows all of the facility’s baghouse systems, and each baghouse has its own buttons for the required recordkeeping, such as visible emissions, shut down and startup times, and preventive maintenance. The “Scrubbers” button opens a screen with all scrubbers and the buttons for their required conditions, while the “Reports” button provides access to all of the reporting requirements. All of the required reports automatically retrieve information from a recordkeeping database.
The system also features extensive drop-down menus that enable the selection of entries from a pre-selected list, including details regarding the proper operation of equipment, the cause of excursions and other pertinent operating parameters and the corrective actions taken, operating conditions existing at the time of sampling or measurements, adjustments and maintenance performed on the various systems and devices, descriptions of routine maintenance performed on all air pollution control equipment, and descriptions of actions taken to suppress fugitive dust.
Out of compliance warnings are automatically activated for any 12-consecutive-month total emissions from sources, any one-hour period during which the average emissions from any source are equal to or greater than the limits, and any period during which the sulfur content of the fuel fired in any source exceeds 0.5 wt %.
All electronic records are stored in an easily accessible database, and another database shows the location of all paper records required for Title V permitting. Additionally, a compliance schedule automatically keeps track of compliance due dates, as well as a list of actions that need to be done on hourly, daily, weekly, etc., basis for the facility to stay in compliance with the Title V operating conditions, and it also calculates the annual emission fees.
Instead of spending hours filling out piles of paperwork and writing numerous reports, plants with an electronic recordkeeping and reporting system can record their data with a few simple clicks of a computer mouse. The system then uses that data to automatically generate the necessary reports within the required timeframes while minimizing errors.
Stress-Free ComplianceThe complexity of the recordkeeping and reporting requirements of most Title V operating permits is overwhelming. While an electronic recordkeeping and reporting system can’t perform the required monitoring, testing and inspections, it can ease the operator’s task of inputting the data, help environmental managers report the necessary information, and provide alarms when emission limit exceedances are approached. It will also prepare the required reports and provide responsible officials a better comfort level prior to compliance certification of the annual reports. With electronic recordkeeping and reporting, manufacturers can meet successfully Title V operating conditions while minimizing labor requirements.
For More InformationFor more information about electronic recordkeeping and reporting, contact Conversion Technology Inc., 2190 Norcross Tucker Road, Suite 202, Norcross, GA 30071; (770) 263-6330; fax (770) 263-8348; e-mail firstname.lastname@example.org; or visit http://www.singleclickco.com or http://www.conversiontechnologyinc.com.
*The SingleClick™ Title V electronic recordkeeping and reporting system developed by Conversion Technology Inc., Norcross, Ga.