Compliance Assistance

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Compliance Assistance

Industry:
Cement

Service Area:
Air Quality Compliance

Client's Challenge

Lehigh Cement Company located in Evansville, PA is a subject to 40 CFR 63 Subpart LLL and 25 Pa. Code 139.102(3). These rules require that compliance with the facility’s emission limits be demonstrated using continuous monitoring systems (CMS). The CMS data collected during the reporting period must be evaluated for validity and representativeness.

Managing the recordkeeping and reporting processes are very involved and requiring an in-depth understanding of the applicable regulations. ALL was tasked with overseeing of all aspects of the compliance program.

ALL4's Solution

ALL4 worked with facility personnel to generate, quality assure, compile the required reports on a quarterly and semi-annual basis. The process involved both on-site and remote access to the facility. Periodically, ALL4 would review the facility records and develop the compliance reports for presentation to the facility. From time-to-time an incident would require further investigation involving operational or instrumentation personnel. ALL4 would provide a summary of any compliance impacts contained in the reports.

The Results

ALL4 was able to evaluate the reports with respect to excess emissions and data availability and provide a summary of any occurrences prior to submittal of the appropriate plant personnel. This information was utilized to evaluate the compliance approach and implement improvement where applicable. By preparing the reports in a timely manner, the facility was able to review any incidents to evaluate the representativeness and implement further corrective action.