Should We Go Paperless With the EPA?

Aug. 18, 2003

Readers help a reader solve this control problem. Next month's problem: How to ground magmeters in non-conductive pipes?

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 unreadable 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?

3. Find out the ongoing maintenance costs. Determine how much self-maintenance and adjustment can be done. How easy is it for you to adjust bias adjustment factors, change ranges, or create new reports? Determine where the source code for the DAS programs exists.

With a good DAS, there is no need to produce and then file reports away. Reports for any selected time period can be produced on demand. If you wan to see the hourly emissions that occurred on Christmas Day two years ago, just enter the date into the appropriate form and the report will be created instantly from the data stored online.

Another key advantage of a DAS is that it can quickly and easily produce all of the data typically requested by auditors. When an auditor sees you have a good system for collection, processing, and reporting of emission data, his job of seeing to it that you are following the rules is made easier. This can make the auditing process much smoother.

Mike Fishman, Vice President

Exele Information Systems,

Paperless Recorders Can Help

Going paperless for CEM applications provides a number of advantages over traditional paper-type solutions. CEM typically requires math to calculate the periodic and rolling averages needed to monitor stack emissions, and paperless recorders can easily perform the required calculations. Honeywell paperless recorders provide Ethernet communications capability as a standard function, allowing the data to be made available in real time on a local area network or a plant-wide system. The Ethernet capability also allows the paperless recorder to send an e-mail alarm or message to a number of recipients.

Capturing the data electronically provides many advantages over traditional paper recorders: It makes analysis easier, faster, and more reliable. The data is recorded in a digital format, eliminating interpolation errors that can arise when transcribing the data from a chart to a spreadsheet for analysis. With a paperless recorder, the data is easily imported into a spreadsheet like Excel for further analysis. The paperless solution also provides a graphical display, unlike paper recorders that generally use either scales or digital displays for displaying the process variables.

As for using paperless recorders in EPA-regulated applications, Honeywell paperless recorders have features such as data encryption, password protection, audit trails, and security features (password expiration and timeouts) as outlined in the Code of Federal Regulations 21 Part 11, which covers electronic data records and signatures. Paperless recorders are successfully being used in many regulated applications and provide many benefits over traditional paper-based recorders.

Douglas Bradway, Product Manager, Data Acquisition

Honeywell Industrial Measurement and Control,

Octobers Problem

How to Ground Magmeters in Non-Conductive Pipes?

I understand that grounding rings must be installed when magnetic flowmeters are used in lined metallic piping or non-metallic piping. Can the ground be an independent ground conductor (not the neutral conductor) from the electrical supply to the flowmeter? Precisely what is the purpose of the grounding rings?

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