An electronic EHS management system maximizes compliance for single or multiple facilities.

For those 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. This constant workload, if managed inefficiently, can cause a company's valuable time to be wasted.

The problem

Consider the typical burden on the person or people responsible for handling the EHS issues at a facility:

* Air quality: Recordkeeping requirements can be extensive, depending on a facility's air permit conditions, especially if a Title V permit is in effect. Emission records must be maintained from pieces of on-site equipment, and 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 111 Section 312 (Tier II) and Section 313 (Form R) chemicals must be accomplished.

* Stormwater: A stormwater pollution prevention plan must be created and maintained, requiring periodic reporting to the state, testing of stormwater samples and performing best management practices.

* Waste management: Both hazardous and non-hazardous waste must be handled properly. This includes managing generation rates, hazardous waste manifests and waste testing.

* Wastewater: Wastewater discharges from the facility need to be monitored based on wastewater permit conditions, which likely include water testing and report submissions.

* MSDS management: 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.

* ISO 14001: For those facilities 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 facility, 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.

The solution

Fortunately, companies can now turn to a source of relief that keeps all of these EHS issues organized and helps ensure that compliance requirements are met. With an electronic record-keeping and reporting system, companies can 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. 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.

The S-C environmental, health and safety management system is a unique software package designed to do just that. It helps simplify organization, monitoring and management of EHS compliance at a single facility or multiple facilities. From a global main screen (figure 1), a company's EHS manager can access all areas of EHS compliance and determine the tasks that need to be completed. Each individual facility has custom buttons tailored to its needs. Additional features of the system include:

[FIGURE 1 OMITTED]

* The entire system adheres to ISO 14001 standards, clearly organizing the company's EHS objectives and responsibilities.

* An EHS compliance calendar 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 allow facilities to periodically review their EHS compliance status.

* Printable forms for each of the required reports, programs, permits, logs, etc., make on-site inspections and evaluation simpler.

* Inspection forms, reports, records of monitoring results and electronic copies of regulations allow for undemanding maintenance of the stormwater pollution prevention plan (figure 2).

[FIGURE 2 OMITTED]

* An indexed database containing vital MSDS information, as well as electronic copies of all MSDSs, organize pertinent information and make it readily available.

* Comprehensive recordkeeping and automatically-generated reports simplify the complex air quality permit requirements.

* Records of OSHA training and maintenance and inspection logs create an efficient management structure for all health and safety issues.

Any and all other EHS issues can be managed from the same single software application, and new EHS data are integrated into the system as the company's needs and requirements change.

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. 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 can be especially extensive if a Title V permit is in effect. The Clean Air Act Amendments' Title V Operating Permit places significant pressure on the plant personnel assigned with environmental responsibilities, such as daily, weekly or monthly recordkeeping, environmental professionals responsible for compiling all these records and preparing the reports (quarterly and/or semiannual), and on the responsible official, the signing authority for the Title V permit application. The first Title V certification can be a problem for many 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 mad hope that the information is sufficient for state officials.

Recordkeeping requirements

Although the general format of the Title V permit is relatively uniform, the recordkeeping requirements vary for each facility, depending on the type of facility, the type of emission sources and the pollution control equipment that is in use at the facility. Table 1 provides examples of typical recordkeeping requirements for various emission units.

Reporting requirements

In addition to the cumbersome recordkeeping requirements of Title V, a substantial number of reports must also be filed 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

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.

Semiannual reports

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.

Annual emission fees

Companies operating under a Title V permit must calculate their annual emissions of criteria pollutants and multiply it by the fee rates to determine their annual emission fees.

Maintaining records

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

Missing data

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 are 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 are in many cases very substantial.

Erroneous data

Personnel may record data erroneously, and the errors are not discovered until the semiannual reports are being prepared.

Late discovery of excursions

Data are 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.

It seems impossible for one person 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, just as with other environmental, health and safety issues. Data can be automatically recorded and alarms are provided when excursions are approached. Even if data are still recorded by personnel 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 successful system should be user-friendly, so that all employees responsible for upkeep of the Title V permit can use it, and it should be customized to address the facility's specific Title V permit conditions. 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 Title V recordkeeping and reporting software. The system should also generate all required reports and enable the responsible official to review the data electronically in a clear manner. The user should be alerted to any non-compliance issues, and an effective system helps prevent the facility from being in non-compliance, minimizes the recordkeeping time requirements and maximizes the accuracy of the reports.

The S-C Title V automated electronic recordkeeping and reporting module meets these criteria and also provides other beneficial features. This module works as a part of the S-C environmental, health and safety management system previously described. Fully automated and requiring minimal user interaction, the module offers 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 if needed, and an automated audible alarm for extreme out of tolerance conditions. The main screen of the module provides a menu with buttons to access all recordkeeping and reporting requirements. A "permit" button opens the Title V permit and an "emission units" button opens the emission units that have operating conditions. Clicking on the "baghouses" button, for example, opens a screen that shows all of the facility's baghouse systems, and each baghouse has its own buttons for the required recordkeeping, such as visible emissions, shutdown and startup times, and preventive maintenance. The "scrubbers" button opens a screen with all scrubbers and the buttons for their required conditions, while the "reports" button provides access to all of the reporting requirements. All of the required reports are automatically generated from the recordkeeping database.

The module also features extensive drop-down menus that enable the selection of entries from a pre-selected list, including details regarding:

* Proper operation of equipment;

* cause of excursions and other pertinent operating parameters and corrective actions taken;

* operating conditions existing at the time of sampling or measurements;

* adjustments and maintenance performed on the various systems and devices;

* description of routine maintenance performed on all air pollution control equipment; and

* description of actions taken to suppress fugitive dust.

The module also features out of compliance warnings that are automatically activated when:

* Any twelve-consecutive-month total emissions limit is reached from sources;

* any one-hour period during which the average emissions from any source are equal to or greater than the permitted limits;

* any baghouse pressure drop is out of the permitted limits;

* any scrubbant flow rate is out of the permitted range;

* may ESP secondary voltage and amperage is out of the permitted range; and

* thermal oxidizer temperatures are below the permitted limits.

All electronic records are stored in an easily accessible database. Included in the database is a tracking system with the location of all paper records required for Title V permitting. The module interfaces with the signals from the process and pollution control equipment to gather necessary recordkeeping information. A compliance schedule automatically keeps track of compliance due dates, as well as a list of actions that need to be done on an hourly, daily, weekly, etc., basis for the facility to stay in compliance with the Title V operating conditions. Additionally, the Title V recordkeeping module calculates emission fees. It will also prepare the required reports and provide responsible officials a better comfort level prior to compliance certification of the annual reports. This type of system will minimize time requirements and optimize accuracy for complying with the conditions of a facility's Title V permit.

This detailed glimpse into the requirements for air quality issues alone gives an idea of the workload and confusion that come along with handling EHS issues. The complexity of EHS compliance can be overwhelming, and the tasks involved are, at the very least, burdensome. Simplification and organization is the key to success in handling these issues. With an electronic EHS management system, an effective solution to the problem of maintaining environmental, health and safety regulatory compliance has arrived.

Table 1--typical recordkeeping requirements for emission units

Emission unit                 Recordkeeping requirements

Boiler                        Record daily steam usage.
                              Record, on daily basis, percent oxygen
                               at the stack exit.
                              Routine maintenance.
                              Shut down/start-up time.

Scrubbers controlling         Record pressure drop.
 particulate matter (PM)      Record scrubbant flow rate.
                              Routine maintenance.
                              Shut down/start-up time.

Electrostatic precipitator    Record secondary voltage and amperage.
  (ESP) controlling           Routine maintenance.
  particulate matter (PM)     Shut down/start-up time.

Baghouses                     Record if visible emissions are present.
                               If visible emissions are present, the
                               permittee shall permittee shall record
                               the cause of the visible
                               emissions, pressure drop, any other
                               pertinent operating parameters
                               and the corrective action taken.
                              Record pressure drop across the baghouse
                               and ensure that it is within the
                               appropriate range.
                              Routine maintenance.
                              Shut down/start-up time.

Cyclones and/or multiclones   Record results of inspections for
                               holes in the equipment or evidence of
                               malfunction in the interior of the
                               cyclones and/or multiclones.
                              Pressure drop across the multiclone.
                              Routine maintenance.
                              Shut down/start-up time.

Conveyor and transfer point   Weight of coal conveyed.
                              Routine maintenance.
                              Shut down/start-up time.

Primary crusher               Weight of coal crushed.
                              Routine maintenance.
                              Shut down/Start up time.

Fugitive dust                 Maintain a record of all actions taken
                               to suppress fugitive dust from roads,
                               storage piles or any other source of
                               fugitive dust. Such records shall
                               include the date and time of occurrence
                               and a description of the actions taken.