Reflections from 2018 Year End Reporting – Part 5: Production Data Discrepancies
Posted: March 6th, 2019Authors: Matt C.
Welcome to the last of a five-part blog series hosted by ALL4’s Continuous Monitoring Systems (CMS) Practice Area that looks back at some of the key points of discussion that came up while completing reports for the second half and fourth quarter of 2018 reporting periods. In Part 5, we review the importance of accurate production data and how discrepancies between production records could create compliance issues.
Facilities that use CMS to comply with applicable emissions or operating parameter limitations often track facility production in the data acquisition and handling system (DAHS), as well as outside of the DAHS in a separate system, file, or other record type. And while the DAHS may use certain monitoring inputs and calculations to continuously track production, the methods to calculate facility-specific production records might differ from what is programmed in the DAHS. So, what are potential implications if DAHS production records differ from facility records?
Discrepancies between production records creates risk when used for compliance demonstrations – which data should be used for compliance? Is there a written procedure? Is the approach consistent across facilities within the same company? Emissions limitations are often written in terms of mass of pollutant per unit of production (e.g., lb NOX/tons of product), so if production data is incorrect, do the operators really know their facility’s compliance status with an applicable emissions limitation? Likely not, which means the operators are working “in the dark” with respect to certain emissions limitations. This could potentially lead to excess emissions being missed, in addition to the immediate notification to the regulatory agency required for those excess emissions.
Additionally, if production data is incorrect in the DAHS, it is possible that the DAHS is not correctly identifying periods of process on, process off, startup, shutdown, or idle. Therefore, if a facility has process status-specific emission limitations or operating parameter limitations, the limitations could be incorrectly applied during the erroneous process status. Like the previously mentioned scenario, this could result in a facility failing to be alerted of excess emissions during specific periods of operations. The point we want to make here is simple – that is, it is critical to verify that DAHS production records align with facility specific production records to minimize potential compliance issues that could creep up because of a discrepancy. If you have questions about how your DAHS calculates production data, or any other aspects of CMS, please reach out to me. I can be reached at (610) 933-5246 extension 139, or at firstname.lastname@example.org.
If you have not done so yet, don’t forget to read Part 1: Validation Sequence Impact on Data Validity, Part 2: Ancillary Analyzer Impacts on Data Validity, Part 3: Temperature Monitoring Impacts on Data Validity, and Part 4: DAHS Server Upgrades of this five-part blog series that reflect on other topics that came up during ALL4’s 2018 year-end CMS reporting. To ensure that you do not miss out on the action, signup below for our 4 The Record articles to receive timely updates of current hot issues, as well as in-depth articles that highlight important regulatory topics.