Everyone's favorite job....NOT
Emissions regulations can seem daunting even just to begin reading. Many standards taking up over 100+ pages in addition to basic outlines established by Title V requirements. And it will come as no surprise to readers of this blog that some of the most onerous aspects of modern emissions regulation involve emissions compliance reporting. Non-compliance with these recording and reporting requirements frequently lead to fines in excess of those related to actual emissions excursions.
But it's a lot of work, and dreadfully monotonous. So most folks look for ways to reduce the difficulty and complexity of compliance reporting, both to improve efficiency and avoid fines over incorrect reporting. Let’s looks at one way your plant can simplify its emissions compliance reporting.
Use Triboelectric Monitoring as the Basis for Your CAM Plan
The way your plant’s CAM plan (Compliance Assurance Monitoring) is written can make all the difference in whether your reporting requirements are simple or complex. Many plants, especially older ones, fall into the trap of thinking that relying on older compliance monitoring methods means less reporting liabilities and more lenient emissions limits. This however is not always the case.
In the past before more advanced particulate monitoring technology was available, the basis of most air permits was opacity monitoring via visual stack observations.This process was/is not very precise and is at best an approximation of whether there is a substantial leak or not. At the time, limits were much higher and there simply did not exist any other technology capable of doing a better job. This is how visual opacity came to be the foundation of most particulate emissions compliance. Today, emissions limits are far stricter and cover PM 2.5 as opposed to PM 10 as in the past. That being the case, by the time an observer can detect a rise in opacity the plant will already be in violation of its permit. Add to this, that visual observations require individuals to be trained and certified in EPA method 9 and 22 and be on call at all times to conduct an observation at regular intervals and at the first sign of any problems. All of these observations then need to be logged and reported accordingly.
Better Detection
A much better option is to switch to a triboelectric emissions monitoring system such as a TRIBO.dsp system from Auburn Systems. By changing from visual observation to triboelectric monitoring much of the guess work is taken out of the process. Instead of having to make subjective visual observations that vary from person to person and lack consistent reliability, triboelectric readings have a very high level of accuracy and reliability once installed. Additionally, TRIBO.dsp units are sensitive enough to detect even minor changes in emissions alerting personnel to possible problems long BEFORE they exceed permitted levels and become a reportable event.
Better logging & reporting
Finally, the triboelectric data is easily stored and accessible to your environmental compliance personnel for their reports. Further integration with Auburn Systems software such as TRIBO.vision can automate the collection of compliance data. They can thus avoid the tedious process of scraping together the required data for their reports from multiple separate source systems (clipboards, dirty log sheets and spreadsheets) and then reformatting, trying to organize and compile them all into one unified report (tediously copying and pasting over and over again).
For companies that emphasize lean process design, this eliminates lots of waste and opportunity for error. Networked detectors eliminate wasted time and clipboards and create an option for centralized monitoring.
Conclusion
Switching to triboelectric compliance monitoring makes sense on the compliance level. It delivers operational benefits while improving accuracy. But if you're responsible for regular reporting, those benefits may seem minor compared to the potential for streamlined reporting!
All of this in addition to the maintenance and operational benefits that triboelectric monitoring can bring your facility.
Learn more about how TRIBO.dsp systems can simplify your compliance reporting.
Here's a real bonus - Let us share our years of experience helping our customers to install BLDS and submit their CAM plans. Contact us today so we can discuss emissions compliance reporting at your facility.
Additional Resources
How Software and Networking Can Help You Streamline MACT Reporting
Data Collection Tips to Simplify Your Air Permit Reporting
