Validy and Increased Scrutiny of Data Used for Compliance Purposes - AFPM Conference Presentation

1. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Validity and Increased
Scrutiny of Data Used for
Compliance Purposes
Eric Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117
October 18, 2016
Presented to AFPM by All4 Inc.

2. 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. 3 Your environmental compliance is clearly our business.
Transparency
 USA Today Toxic Schools Report
• “The Smokestack Effect”

4. 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. 5 Your environmental compliance is clearly our business.
Increased Scrutiny & Exposure
 Increased Scrutiny Regulatory Exposure
• Regulatory Agencies
• Audits
• Public Interest

6. 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. 7 Your environmental compliance is clearly our business.
Data Management
 Platform
 Understanding
 Consistency
 Reproducibility

8. 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. 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. 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. 11 Your environmental compliance is clearly our business.
DCS - Historian
Analyzers DCS SpreadsheetHistorian
Source: Environmental Systems Corporation 4C Workshop Presentation

12. 12 Your environmental compliance is clearly our business.
DCS/DAHS (Parallel) – Historian
Analyzers DCS SpreadsheetHistorian
DAHS
Source: Environmental Systems Corporation 4C Workshop Presentation

13. 13 Your environmental compliance is clearly our business.
DAHS – DCS – Historian
Analyzers
DCS HistorianDAHS
Source: Environmental Systems Corporation 4C Workshop Presentation

14. 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. 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. 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. 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

18. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions
Eric Swisher| eswisher@all4inc.com | 610.933.5246 ext. 117