Ignorance may not be bliss....
Environmental regulations have evolved over the decades becoming increasingly strict around emissions standards. As this occurs, many older industrial facilities find that it's not financially viable to invest in new pollution control technology. In some cases, exceptions have been granted to older facilities to facilitate the transition to stricter standards. This has meant that some facilities have received exemptions, often called “grandfather” exemptions from certain standards or specific requires of larger sets of emission standards. Often though, these exemptions are forfeited when any significant upgrades or modifications are made to the plant’s systems.
For this reason, many plant decision-makers have developed the viewpoint that as long as they refuse to upgrade to newer systems they can continue to avoid compliance with new regulations.. This leads them to avoid at all costs any modification or upgrades to their emissions control systems in the mistaken belief that by doing so they will avoid difficulties (and costs) associated with complying with newer, stricter environmental standards.
This can be seen by some plants refusal to install a CEMS or BLDS for fear it will increase their risk of getting fined or sanctioned over emissions excursions. The reality however is the contrary...
What is a CEMS and What Kind of Data Does it Gather?
Continuous Emissions Monitoring Systems or CEMS are used in applications where it is deemed necessary to have real time emissions data from a facility. (While CEMS as a concept usually applies to gas pollutants, we will refer only to CEMS for particulate matter emissions.) For dust collection systems used to control emissions, a CEMS usually takes the form of an opacity meter or a triboelectric detection system monitoring the main emissions stack. It can run concurrently with other requirements such as the filter bag leak detection system required by many newer MACT standards. Whatever the exact setup, the key for CEMS is for the monitoring device to meet guidelines set out in EPA standards for CEMS. These outline the technical capabilities of the devices including detection range, reliability, etc. A CEMS used for tracking emissions will monitor in real time the emissions levels coming from the stack as well as record these levels for future analysis.
CEMS Data When There is a Dust Excursion
When an emissions excursion does occur, it triggers a response which depends on the specifics of a plant’s air permit, or their Compliance Assurance Plan (CAM). While some facilities may have grandfathered monitoring requirements, excursions will result in consequences.
Some might think that by not having very accurate monitoring systems or by not recording such emissions data they can avoid fines and sanctions resulting from exceedances . The reality however is quite the contrary. Most enforcement actions taken by Local, State and Federal regulators make no allowance for ignorance - certainly not if its shown to be willful ignorance caused by purposeful blindness to high emissions.
When facilities have the best of intentions and make genuine efforts to abide by their emissions limits, CEMS data can actually help. First, by having a CEMS installed, plant operators and maintenance personnel have instant notification of a problem. This means they can take immediate corrective action to remedy the situation and get their emissions back under control. In contrast, not having the CEMS data would mean hours, days or even weeks could go by before the seriousness of the problem comes to the attention of operators. By that time the severity of the exceedance will have increased as well as the scale of required remediation.
In addition, operators can use the CEMS data to make their case to the regulatory agency. For example, CEMS data can show that prior to this incident the plant had a outstanding record of abiding by its air permit. The data can also show how quickly the issue was identified and responded to by technicians, thus showing the limited impact of the excursion on the surrounding environment and health/safety of workers inside the facility. In contrast, a facility without this CEMS data would have to depend on regulators to investigate and determine how long the plant was out of compliance and then estimate the overall impact when determining a course of action. Relying on anecdotal and emotional reports from neighbors can often aggravate the regulators impression of the incident. Therefore, this course can result in far heavier fines and sanctions than for plants able to prove their rapid response and limited impact of any excursion.
Indeed, the belief that a mentality of “Hear no evil, See no evil, Speak no evil” will prevent plants from facing fines or sanctions over emissions excursions is a fallacy. Regardless of the exact monitoring requirements outlined in a plant’s air permit or CAM plan, exceedances can still result in fines and sanctions even if your air permit does not specifically require you to use advanced monitoring systems. For this reason and many others, plants that purposely avoid upgrading their monitoring systems will suffer significant disadvantages.
Are you wondering if you should or need to upgrade to a CEMS for PM emissions? Let Auburn Systems help you determine the best option for you facility. Contact us today!