By Steve Haroz
For those at electric utility facilities who work with it daily, environmental, health, and safety (EHS) compliance is synonymous with long, confusing, and stressful hours of sorting through paperwork and regulations. Trying to navigate through the maze of EHS regulations and requirements can create disorganized havoc in a company, and when multiple facilities are added into the mix, the confusion is only amplified.
EHS regulatory compliance requires continual maintenance and the focused attention of management. From properly disposing of waste streams to sufficiently capturing particulate matter and minimizing chemical emissions, the plant manager’s time is regularly demanded by EHS compliance tasks. This constant workload must be managed efficiently, or a facility’s valuable time will be wasted and compliance problems will result.
As a whole, electric utilities were the largest contributor to air releases in 1999, with 41 percent of all reported air emissions. In an industry with such an impact on national air quality, environmental issues are always a major concern. And with a trend towards economic deregulation in the industry, changing legislation may place stricter environmental standards on electric utilities. As a result, electric utility companies may feel increasingly vulnerable to environmental regulation. In the midst of this changing landscape in the industry, facilities need to ensure EHS compliance. Fortunately, tools are readily available to assist electric utilities. As will be outlined in the following discussion, EHS compliance issues can be easily handled through the use of an effective EHS electronic management system.
According to some sources, electric utilities use about 75 individual technologies to control water, air, and solid waste pollution, for coal-run facilities. Just keeping up with all of these pollution prevention measures at a facility can be troublesome enough. Consider the typical burden on the person or people responsible for handling the EHS issues at an electric utilities facility.
Recordkeeping requirements can be extensive depending on a facility’s air permit conditions, especially if a Title V Permit is in effect. Electrostatic precipitators, scrubbers, and combustion control systems, along with other pollution prevention measures, must be closely monitored and data recorded. Emissions can include sulfur oxide, nitrogen oxide, carbon dioxide, mercury, and particulates. Records of these emissions must be maintained and required testing must be completed. Additionally, reports must be submitted on a quarterly, semiannual, and annual basis to the state regulatory agency.
SARA (Superfund Amendments and Reauthorization Act) Reporting
Annual reporting for all usage and storage of SARA Title III Section 312 (Tier II) and Section 313 (Form R) chemicals must be accomplished.
If an electric utility has any industrial activity exposed to stormwater, a NPDES Stormwater Permit must be obtained and a Stormwater Pollution Prevention Plan must be created and maintained. This Plan requires periodic reporting to the state, testing of stormwater samples, and performing best management practices to minimize the potential for stormwater pollution.
Both hazardous and non-hazardous waste at an electric utility must be handled properly. Each of the waste streams at a facility must be characterized as hazardous or non-hazardous waste, and then properly disposed of according to applicable regulations. Ash disposal and storage piles are of particular concern at electric utility facilities. The tasks involved in this overall waste management responsibility include managing generation rates, handling hazardous waste manifests, and performing waste testing.
Wastewater discharges from the facility need to be monitored based on wastewater permit conditions, which likely include water testing and report submissions.
Material Safety Data Sheets are required to be easily accessible by the facility and must be maintained in an orderly, organized fashion.
OSHA (Occupational Safety and Health Administration)
Extensive employee training and safety program maintenance are required by OSHA, and records of this training must be managed at the facility. The training requirements can include Bloodborne Pathogens, Electrical Safety, Forklift Safety, Hearing Protection, Lockout/Tagout, Personal Protection, Respiratory Protection, and numerous other duties.
For those electric utilities striving for ISO 14001 certification, developing an Environmental Management System that addresses environmental policy, planning, implementation, auditing, management review, and continual improvement is a significant chore by itself.
The preceding requirements are merely a subset of the overall EHS challenges that face a single electric utility, making multiple facility management a truly daunting task. Trying to keep up with all of these varied obligations can place an inordinate amount of pressure on EHS coordinators and everyone else involved in EHS compliance. One can see how this stress can result in inefficiency along with missed deadlines, missed form submission, and unaddressed issues falling through the cracks. The repercussions of such mistakes are far from harmless, as severe penalties can result in cases of noncompliance.
Fortunately, companies in the electric utility industry can now turn to a source of relief that keeps all of these EHS issues organized and helps ensure that compliance requirements are met. A growing trend in managing environmental compliance is the use of an electronic recordkeeping and reporting system. These systems allow companies to focus more time on producing high quality products and waste less time pushing paperwork.
All of a company’s EHS permits, reporting requirements, training information, and compliance statuses can be encompassed in one efficient, comprehensive management system that is easy to maintain. Instead of worrying about stacks of permits, regulations, and reports, a software program designed to manage this information can aid in keeping track of a facility’s EHS responsibilities.
There are certain essential elements in an effective EHS management system. In order for the electronic system to really solve the problem of handling EHS compliance, it needs to address all of the environmental, health, and safety issues that electric utilities face, as described earlier. The system should also be customized to fit the company’s exact needs. There are a number of products on the market that are simply generic systems, and a company can easily end up paying for many unnecessary features that serve to complicate what should be a user-friendly system. If an electronic system is not user-friendly, it may actually make the task of EHS compliance more difficult rather than quicker and easier.
For a company with multiple facilities, a system that incorporates total global management is essential, so a company’s headquarters can manage the EHS data of individual facilities while still allowing each facility to also manage or simply view the information locally. An example of a “global” main screen in a typical system is shown in Figure 1, allowing a company’s EHS manager to access all areas of EHS compliance and determine the tasks that need to be completed.
There are obviously differences in the available system offerings, but some other basic features of an effective EHS management system are listed below:
“-The entire system should adhere to ISO 14001 standards, clearly organizing the company’s EHS objectives and responsibilities.
“-An EHS compliance calendar that shows reporting and update deadlines, as well as the EHS tasks for each day of the month
“-Self-auditing checklists with regard to environmental issues or OSHA regulations that allow facilities to periodically review their EHS compliance status.
“-Printable forms for each of the required reports, programs, permits, logs, etc. that make on-site inspections and evaluation simpler.
“-Inspection forms, reports, records of monitoring results, and electronic copies of regulations that allow for undemanding maintenance of the Stormwater Pollution Prevention Plan, among other EHS concerns. Figure 2 provides an example of these features in a system.
“-An indexed database containing vital MSDS information, as well as electronic copies of all MSDSs, that organize pertinent information and make it readily available.
“-Comprehensive recordkeeping and automatically-generated reports that simplify the complex air quality permit requirements. An example system screen for these air quality concerns can be seen in Figure 3.
“-Records of OSHA training and maintenance and inspection logs that create an efficient management structure for all health and safety issues.
Spotlight Analysis: Air Quality
Performing a more exhaustive study of one particular EHS concern – air quality – brings to light the need for assistance in managing EHS issues. Lots of attention is given to this particular environmental aspect of electric utility facilities, by both regulatory agencies and the media. Since electric utilities produce two-thirds of the sulfur dioxide emissions and nearly one-third of the nitrogen oxide emissions in the country, electric utilities have been regularly pointed to as major contributors to air pollution and the resulting health effects. The industry has been attributed with playing a role in smog and acid rain as well. All of these issues are to say that the importance of air quality among electric utilities is of the utmost importance, as the public eye is firmly focused there. A detailed look at the work required in maintaining compliance with an air quality permit shows how an electronic management system can ease this burden on a company.
As mentioned previously, recordkeeping requirements for a facility in the electric utility industry can be especially extensive if a Title V Permit is in effect. Operations can produce emissions in the forms mentioned above, as well as carbon dioxide, mercury, and particulate matter (PM). The emissions produced create air quality concerns with regard to an electric utility’s air permit. Tracking the facility emissions is a stringent requirement of any air permit, as well as maintaining emissions control equipment such as scrubbers.
While all EHS issues must be addressed by an electric utility’s plant manager, the extensive air quality concerns must be at the forefront of facility’s agenda. The Clean Air Act Amendments’ Title V Operating Permit places significant pressure on the plant personnel assigned with environmental responsibilities. In addition to those tasks just mentioned, the facility is required to maintain daily, weekly, or monthly recordkeeping. The environmental professional(s) at a plant are responsible for compiling all these records and preparing reports (quarterly and/or semiannual) for submission to regulatory agencies.
Although the general format of the Title V permit is relatively uniform, the recordkeeping requirements vary for each facility depending on the exact operations taking place, the type of emission sources, and the pollution control equipment that is in use. The table below provides examples of typical recordkeeping requirements for various emission units. While many electric utilities will not have to face all of these types of emission units, this table delineates the extensive recordkeeping requirements of the Title V permit.
In addition to the cumbersome recordkeeping requirements of a Title V permit, facilities must also file a substantial number of reports with state offices. These include quarterly and/or semiannual reports, annual compliance certifications, annual emission fees, and notices of emission limit exceedances.
Out of Compliance Notification Reports
Electric utility facilities operating under a Title V Permit are required to submit to the state in writing, within seven days, any deviations from applicable requirements associated with any malfunction or breakdown of process, fuel burning, or emission control equipment for a period of four hours or more which results in excessive emissions. The written report must contain the probable cause of the deviation(s), duration of the deviation(s), and any corrective actions or preventive measures taken.
Facilities are required to 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.
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. Obtaining the initial Title V certification can sometimes be difficult for facilities. For the year of issuance of a Title V permit, the facility is required to complete a compliance certification for the period from permit issuance through December 31. Even if a permit is issued in December, a facility is required to provide a compliance certification covering this period. This often sends facilities scrambling to prepare and submit the report and hope that the information is sufficient for state officials.
Annual Emission Fees
Electric utilities operating under a Title V permit must calculate their annual emissions of criteria pollutants and multiply by the fee rates to determine their annual emission fees.
Facilities are required to maintain records of all required Title V recordkeeping and reporting for a minimum of five years.
Problems with recordkeeping and preparing reports
In addition to paper records being lost or misplaced, personnel assigned to recordkeeping responsibilities may fail to record data. Missing records may be due to forgetfulness, an employee being on vacation and the backup personnel not recording the necessary information, or malfunctioning equipment, such as strip recorders. Even simple problems such as pens running out of ink can cause malfunctions. Missing data is often not discovered until the required semiannual report is in the process of being prepared. Each instance of missed data may result in violations and fines that, in many cases, are very substantial.
Personnel may record data erroneously and the errors are not discovered until the semiannual reports are being prepared. This last-minute dilemma can create very stressful situations for plant managers, as well as incomplete and inaccurate reports.
Late Discovery of Excursions
Data is recorded by personnel or strip recorders to ensure there are no excursions, but many times excursions are not discovered until it is time to prepare the semiannual report. During preparation of the report the facility may find that the percentage of time the facility was not within its operating limits is greater than it should have been. Often corrective action is taken in response to an excursion and is not properly documented or worse, required corrective action is not taken.
Electronic Title V management
It seems impossible for one person at an electric utility to handle all of the Title V Permit Conditions for maintaining compliance with emission limits, testing, monitoring, recordkeeping, and reporting requirements. When the extensive requirements of other EHS issues are placed on the same personnel, the effect can be quite overwhelming.
Electronic recordkeeping can provide the optimal solution for maintaining air permit compliance at an electric utilities facility, just as with other environmental, health, and safety issues. Figure 3 displays an example system screen, providing a menu that allows access to all of these recordkeeping and reporting requirements. Here are a few of the benefits that an electronic Title V system can provide to an electric utility:
“-Every condition of the facility’s Title V permit can be specifically addressed and managed electronically.
“-The manual process of inputting required data such as pressure drops, visible emissions, etc. can be completely automated by installing a Continuous Monitoring System (CMS), which will log the data directly into the system.
“-Alarms can be provided to automatically alert the facility of excursion or non-compliance situations, such as exceeding an emissions limit.
“-Maintaining the records in an electronic recordkeeping system identifies problems early when they can be corrected, not six months later when the opportunity to take corrective action has passed.
“-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.
“-A user-friendly system allows all employees responsible for upkeep of the Title V permit to easily use the system.
“-Emission fees can be calculated by the system.
“-All facility emission units/pollution control devices can be managed with an electronic system.
“-Records of any maintenance performed on pollution control equipment and other corrective actions taken can be stored and easily accessed
“-All required reports can be automatically generated by a system from the recordkeeping database, and the responsible official can review the data electronically in a clear manner.
An effective system helps prevent the facility from being in non-compliance, minimizes the recordkeeping time requirements, and maximizes the accuracy of the reports. Systems that are fully automated require only minimal user interaction, with custom interface electronics, networkable controller, automated on-screen indicators to show range variances and standard operating conditions, e-mail notification of alarm or out of range conditions, and automated audible alarm for extreme out of tolerance conditions. This type of system will minimize time requirements and optimize accuracy for complying with the conditions of a facility’s Title V Permit.
Haroz is founder and president of SingleClick Co. in Norcross, Georgia, providing user-friendly electronic management systems. Steve Haroz can be reached at firstname.lastname@example.org, or visit www.singleclickco.com for more information.