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www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Validity and Increased Scrutiny of Data Used for
Compliance Purposes
Eric Swisher| [email protected] | 610.933.5246 ext. 117
October 18, 2016
Presented to AFPM by All4 Inc.
2 Your environmental compliance is clearly our business.
Next Generation Compliance
Five components
• Advanced monitoring
• Electronic reporting
• Regulation and permit design
• Innovative enforcement
• Transparency
Source: Next Generation Compliance. U.S. EPA.
3 Your environmental compliance is clearly our business.
Transparency
USA Today Toxic Schools Report
• “The Smokestack Effect”
4 Your environmental compliance is clearly our business.
“Old vs. New” Compliance
Current Next Generation
Hardcopy Stack Test Reports Electronic Reporting Tool
(ERT)
Hardcopy CMS Performance
Evaluation Reports CEDRI Electronic Submittals
Hardcopy Excess Emission
and CMS Performance
Summary Reports
CEDRI Electronic Submittals
Freedom of information act
(FOIA) File Reviews Web Access
5 Your environmental compliance is clearly our business.
Increased Scrutiny & Exposure
Increased Scrutiny Regulatory Exposure
• Regulatory Agencies
• Audits
• Public Interest
6 Your environmental compliance is clearly our business.
CMS Data
Understanding your data system
• Measured values
• Calculated values
• Validation process
• Quality assurance process
• Reporting conventions
7 Your environmental compliance is clearly our business.
Data Management
Platform
Understanding
Consistency
Reproducibility
8 Your environmental compliance is clearly our business.
Platform - Database
Date Time Value Process
Code
Monitoring
Code
02/19/2015 06:59 4.2 Normal Valid
02/19/2015 07:00 0.6 Normal Calibration
02/19/2015 07:01 0.1 Normal Calibration
02/19/2015 07:02 42.0 Normal Calibration
02/19/2015 07:03 56.4 Normal Calibration
02/19/2015 07:04 35.2 Normal Calibration
02/19/2015 07:05 8.2 Normal Calibration
02/19/2015 07:06 4.2 Normal Valid
9 Your environmental compliance is clearly our business.
Process Codes
Normal Operation
Process Down
Operational Status
• Startup
• Shutdown
• Additional Operating States (e.g., changing operating loads, abnormally low production, etc.)
Others?
10 Your environmental compliance is clearly our business.
Monitoring Codes
Valid
Analyzer Malfunction
Excess Calibration Error
Calibration
Preventive Maintenance
Corrective Maintenance
Sample Interface Malfunction
Data Handling System Malfunction
11 Your environmental compliance is clearly our business.
DCS - Historian
Analyzers DCS Spreadsheet Historian
Source: Environmental Systems Corporation 4C Workshop Presentation
12 Your environmental compliance is clearly our business.
DCS/DAHS (Parallel) – Historian
Analyzers DCS Spreadsheet Historian
DAHS
Source: Environmental Systems Corporation 4C Workshop Presentation
13 Your environmental compliance is clearly our business.
DAHS – DCS – Historian
Analyzers
DCS Historian DAHS
Source: Environmental Systems Corporation 4C Workshop Presentation
14 Your environmental compliance is clearly our business.
Validation
How much and what kind of measured data is needed to build a valid average?
Example…“any 3-hour average”
1. Rolling or Block?
2. Building?
3. Validating?
15 Your environmental compliance is clearly our business.
CMS Data Recommendations
Establish a process for interpreting regulatory requirements to built a data management compliance approach that:
• Satisfies the applicable regulatory requirements,
• Is well understood,
• Is documented, and
• Provides database structure needed to generate compliance reports.
16 Your environmental compliance is clearly our business.
Innovative Enforcement
State CEMS example
• Electronic submittal of data
• Automated comparison to all applicable limits
• Automated generation of fines
• Limited review by regulatory agency personnel
17 Your environmental compliance is clearly our business.
CMS Data Takeaways
Next Generation • Electronic Reporting
• Transparency
Understanding • Collected, Quality-assured, Calculated, Validated, and
Determined to be Representative
Review and Document
Certification
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions
Eric Swisher| [email protected] | 610.933.5246 ext. 117
