Meeting the Reporting Challenges of the MACT Standards Defined Under 40CFR Part 63 Subpart S Throught the Use of an Event Logging/Reporting Software, 2002 Environmental Conference Proceedings

M. J. Radigan, D. Rogers. K. Sullivan

Under the NESHAPS regulatory guidelines for the Pulp & Paper industry defined by 40CFR 63, Subpart S, the mill is required to demonstrate continuous compliance of specified control devices, continuous parameters monitoring devices, and computer-controlled valves at all times. Any paper mill process that utilizes such devices is subject to this requirement, whether it is called out in the list of monitored parameters or not. For those not called out in the Rule, the plant must propose and demonstrate to the local Department of Environmental Quality (DEQ) a set of monitoring parameters proving continuous compliance that is in line with the standards that have been set. Given the number of devices and possible monitoring points in the average mill, management of this data and demonstration of continuous compliance may be a real challenge. This paper addresses one software solution which uses electronic data gathered from the operating statuses of the regulated processes on a 1-minute average basis. Transitions in operating mode and excess emissions are logged by the software and reported chronologically as Event Logs. The software accounts for every minute of every day including out-of-service periods and flags reported data appropriately and prepares a Summary Report and Excess Emissions Report pursuant to 40 CFR 63 Subpart A. The introduction of this type of software solution in conjunction with the mill standard operating procedures allows for full compliance with minimal operator intervention.