Process Instrumentation for Title V Compliance the Only Reasonable Route, 2001 Environmental Conference Proceedings

Frank H. Lobb, Edward Hardy--EPA’s Title V Program and its dramatic shift in how compliance is defined is nearing full implementation in most states. Title V has been perceived by mills as a regulatory consolidation of existing air requirements and the associated monitoring as little more than expanded documentation of past practices. Moreover there is a perception that the bulk of work to implement Title V is done. In simple terms, this perception is false! The combination of the requirement for continuous compliance and EPA’s Credible Evidence Rule create an entirely new technical and legal basis for determining compliance. This new basis insures the large volume of existing mill instrumentation, control systems and computer based management systems will become the primary elements in determining defensible Title V compliance.

This paper analyzes the role of existing process instrumentation, control systems and computer based management systems in achieving, not only defensible compliance, but also the most cost-effective approach to compliance.