Should We Go Paperless With the EPA?

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A Reader Writes:

We are considering changing from paper-based to paperless record-keeping and reporting to the EPA for continuous emissions monitoring (CEM) compliance. Our present system works well and we are dealing with just three stacks, but the new plant manager wants us to be "state-of-the-art." What problems have people had with paperless CEM? Are the benefits significant?

--From June 2003 CONTROL


Its Straightforward and Worthwhile

Currently the EPA does have an almost paperless method for record-keeping and reporting on CEM systems. The EPA mechanism for reporting emissions from fossil fuel stacks is the Electronic Data Report (EDR). The steps for CEM record-keeping and reporting are:

1. Air permit: There may be some paper in this step, and it may be state-dependent.

2. Monitoring plan: The most common method is to fill out forms that document the method of monitoring, i.e. the monitoring plan. Once the forms are completed and verified, the data can be entered into a computer that records the monitoring plan electronically. Subsequent changes to the monitoring plan can be made electronically.

3. Perform the monitoring activities: Most data acquisition and handling systems (DAHSs) can automatically log the data from the CEM analyzers and the fossil fuel flow and load (steam and/or megawatts). This data can be kept electronically (typically 1-min. averages) in the computer with no paper trail.

4. Perform the quality assurance activities: EPA systems and most state systems require various quality assurance tasks to be performed on a regular basis. The three-point linearity analyzer test or Cylinder Gas Audit (CGA) test can be done electronically with no paper trail. The Relative Accuracy Test Audit (RATA) test can be performed without paper depending on whether the stack tester can provide an electronic report.

5. Submit the electronic data report quarterly: As its name implies, the EDR is electronic. A good DAHS will accumulate the hourly averages that need to be reported and create the EDR file. This file can be sent to the EPA over the Internet. As a matter of fact, I think this is the only way it can be sent. The EDR file includes electronic signature and is transmitted to the EPA quarterly. Acceptance of the EDR by the EPA is transmitted back to the environmental engineer as an e-mail.

...So, with the exception of the air permit and a small amount for the monitoring plan, the EPA offers a paperless solution to CEMS reporting. Some states also allow for electronic reporting, but most states still require some paper reports.

...Problems of the paperless CEM include:

1. The DAHS must be highly reliable since any lost data may need to be entered by hand or at least substituted using special EPA data substitution rules.

2. Some stack test vendors are unable to provide results electronically.

3. The monitoring plan needs to be "aged"--in other words, if the monitoring plan changes in the middle of the quarter, the DAHS must be able to report the data accurately before and after the change. An example of a change in the monitoring plan would be changing the range of an analyzer.

4. The EDR report is unreada ble to humans since it is not formatted for presentation (it is just data).

...What are the benefits?

1. More accurate, not hand-entry of data.

2. The monitoring plan is stored in one location: no more questions like "Who has the latest monitoring plan?"

3. No shipping costs to send in the EDR report.

4. More accurate receipt of the report (EPA loads the data just as it was received--no data input errors).

5. Quicker transmittal of the reports.

6. Quicker turnaround from the EPA that the EDR report is accurate and correctly formatted.

...Overall the EPA and the CEM DAHS vendors have done a great job of turning CEM reporting into a paperless solution.

Rick Whiffen, software manager, KVB-Enertec CEMS product line

GE Power Systems,

Beware Half-Baked Solutions

The relatively short history of computer-based CEM reporting has many success stories but there are also cases where things did not work out so well. There are three common pitfalls:

...First, there was a flood of providers entering the data acquisition system (DAS) market, sometimes offering solutions at impossibly low prices. Many of these are now out of the DAS business or out of business completely, thus leaving the owners of their systems without support.

...The second problem is more technical in nature. There are instances where the technology applied is inappropriate or ill suited for the functions of a DAS. Systems have been provided using the wrong hardware and software and although they are forced to work, they prove to be unreliable, unmaintainable, and in general, poor performers.

...The third problem lies in the area of total cost of ownership. Some packaged systems are sold as "black boxes" with very little information provided about the internal workings or configuration. Owners of these systems find themselves completely dependent on the provider for even the smallest modification such as re-ranging of an analyzer.

...Based on these three areas of potential problems, a prospective owner of a DAS should:

1. Be confident in the stability of the provider. How many systems have they provided? Who are their customers? Are these customers happy?

2. Make sure that the technology used is suitable and able to support the required functions. Is the system reliable, maintainable, flexible, and expandable? How much data can be stored online? How long does it take to access data that is one, two, or five years old? How easy is it to audit the behavior of the system to prove reported emissions are based on the raw CEM values?

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