Compliance Data System Health – Preventative Maintenance Checks for Your DAS
If you are an environmental engineer or an analyzer technician responsible for compliance with emission regulations, then this article is for you. If you are responsible for risk management or EHS in your facility and you have compliance obligations related to stack emissions, then this article is also for you. If you are a plant manager or work in operations at a facility that is required to report emissions data in order to operate your process, then you can benefit from reading this as well.
Any production facility that produces emissions as a byproduct of combustion and emits them to the atmosphere is likely to be governed by one or more environmental regulation. As designated source, you must manage your process within the limits set out in your State issued operating permit. Once you agree to your set limits, you are obligated to take whatever steps are required by the rules to demonstrate that you comply. In order to demonstrate compliance, you may need to install pollution controls, add a monitoring system, collect/validate data and maintain a reporting system that are all subject to review by the regulators. Routine maintenance of all these components are the key to the long-term health of air compliance.
Those of us with a history supporting air compliance applications are very tuned into the mechanical parts of the demonstration process. Most facilities maintain a well-defined QA/QC plan for daily, weekly, monthly and annual checks of the system. With most of our attention going to process controls and monitoring components we often overlook the data collection, validation and reporting system. Data collection and reporting is the most visible part of the compliance system and should demand the same level of attention as your pollution control system, stack monitoring system and your stack gas monitors.
Since the regulations do not dictate what you use to collect, validate, average and report your emissions data there is no one size fits all answer to data system maintenance. If you use a 3rd party, standalone data acquisition system then you should follow the manufacturers recommendations for routine maintenance. If you do all your data acquisition in house through process control or operations or the information technology department then a site-specific maintenance plan needs to be developed. Data system health is a lot of gut feel and commonsense. Before you implement any maintenance practices you should consult your software provider and/or defer to your IT department for best practice guidance on your site-specific solution. Regardless how your system was built, there are some general guidelines we can suggest that will be useful regardless of which method you employ.
Data System Health Check – Top 10 Commonsense Practices to Headache Free Compliance
Top 10-Commonsense Data System Habits
Your compliance data system is not a static system that you only deal with at the end of every quarter when it is time to report data. There are data QA and data system upkeep activities you can perform on a regular basis that will make your life easier when it comes time to report. Time invested well in advance of deadlines relieves stress, minimizes errors and provides early warnings to possible problems that may present themselves at the worse possible moment. Care and feeding of your data system are every bit as important as CEMS or monitor maintenance. Develop a routine you can easily follow and stick to it. If you have not already integrated your compliance data system into your Facility QA/QC Plan, then you should either take the time to do so or pay a consultant to do it for you. Routine checks and maintenance are the key to the long-term health of your data system.
Daily checks must be part of your routine. Someone should be looking at your compliance system every day monitoring overall performance, alarms, calibration results, communications and other activities that impact the quality of the data you will be reporting to the regulators. Monitoring of high level, real-time data activity is usually a shared responsibility between plant operators, I&C technicians and the onsite environmental engineer. Each discipline in your plant level accountability chain should have access to the data that tells them exactly how the compliance system is performing prior to initiating any emission generating operations. If you are a 24/7 facility, then daily checks should follow established shift routines to ensure everyone is tuned into the status of the monitoring system when they start work each day.
Beyond the daily real-time data checks there is no hard and fast rule as to the best way to manage data system maintenance. Develop a routine that is effective but manageable. You want a simple process that easily integrates into your regular QA and maintenance program. It is easy to say more is better but at the end of the day it comes down to how well your system is performing normally and how well is it supported when you need help. You will be on a learning curve so begin with higher frequency checks (i.e. weekly) and as confidence builds back it down to a more reasonable rate. Under normal conditions, we recommend conducting QA/QC checks of the data system on at least a bi-monthly basis (2x per month).
Dig in and go below the surface. Use history to guide you in developing your plan. Chances are that problems of the past will repeat themselves in the future. Create procedures that target known or repeatable problem areas. Use system logs and audit trails in your software to help guide you and consult your service records to help identify common, repeatable issues. As you develop patterns and insights to how your system is working, you can add site-specific QA checks that will minimize effort and maximize results.
Conduct regular quality control on the underlying data that will be used to feed your reporting system. Data validation for air compliance typically starts at the minute level. Once validated, these minutes feed the higher-level validations and averaging that will be used to populate your reports. If you collect unchecked, “bad” minutes over the course of a reporting quarter then those same minutes will taint, skew and generate bad averages over time. Bad averages make bad reports. Reporting outliers and errors are red flags for the regulators and put your facility at risk. The sooner you evaluate the quality of the data feeding your reportable averages the better the results. It highlights potential problems before they become significant ones.
Check alarm functions of the system. There are usually two types of alarms in a data management system used for air compliance; system alarms and compliance events. System alarms indicate a mechanical problem within the overall compliance system or that an unacceptable performance threshold has been reached. These alarms are typically a digital signal from a device and generally don’t impact reportable data. Other alarms, classified as compliance events, register as a downtime or excess emission and significantly impact your reportable data. These alarms go directly against your compliance obligations and should not be ignored. Routine checks of alarm functionality and associated alert systems is recommended to help prevent data degradation and inaccurate reporting.
Review RCAC entries to ensure acknowledgment accuracy and problem traceability. Along with the alarm system, compliance software systems usually have an interactive Reason Code/Action Code (RCAC) interface that is used to complete the alarm acknowledgement records. These entries are usually made real time by the person that is answering or clearing the alarm from the system. The RCAC system typically builds a historical log of events and tracks how people react to common issues. Even though this data is not usually reportable, it is an important component of your credible evidence trail when you must “explain” why your system is behaving in a manner not consistent with regulatory expectations. By reviewing alarm history and the associated RCAC entries on a regular basis you gain insight to how the system is used and if alarm answering improvements are required.
When reporting data to the regulators you want to present the cleanest record possible. As part of your routine health checks you may come across data outliers that are not easily explained from the review of underlying data and/or digging into alarm/RCAC history. Cross check data entries to the various environmental logbooks and audit trails built into your compliance maintenance program. Most software systems used to support air compliance applications have an audit trail system to help keep track of changes made by the personnel that interface with the system on a regular basis. The CEMS maintenance logbook located with the equipment also offers valuable information that can be used to track down data anomalies or issues that impact availability. The more frequently you reconcile your logbooks and audit trails the better understanding of data issues when they occur and how to explain them if necessary.
Run and review your reports. Test generating followed by a thorough review of your compliance reports during non-reporting periods is an easy way to determine if your data system is working properly. First and foremost you want to ensure your report engine Is working properly. Data systems no matter how robust, can develop bugs over time. You don’t want to get caught without a working reporting system when the reports are due. Secondly, comb through the report details and analyze what the system generated against your compliance requirements. Look for outliers and anomalies in the higher-level averages and validation periods that may tip you off to issues that may reside in the underlying data. Finally, if you are subject to Acid Rain Reporting and/or some other electronic submission format, you should run periodic electronic data reports (EDRs) through the submission system to further QA the data before the reporting deadline.
Verify that your formulas are correctly calculating data that will be used in your reports through periodic spot checks. Formulas in general aren’t subject to frequent modification or changes but software systems have been known to develop bugs over time through version upgrades and regular servicing. In most cases it can be easily rectified with little or no impact to your historical database, but it is a hassle when it occurs at an inopportune time like a reporting month. Testing formulas offline, using outside tools like spreadsheets or calculators can easily be integrated into your bi-monthly routine. You might consider setting up a regular rotation focusing on one validation type per month to make the task more manageable. Regardless on how you implement the check, having one as part of your regular maintenance program is a good idea.
Thank you for taking the time to review this article and we sincerely hope it is helpful. Our goal is to see everyone impacted by air compliance meet their obligations efficiently and as cost effectively as possible. Every attempt was made to make this message concise and to the point so some of the details may have fallen out during the editing process. No worries. If you have any questions, comments or concerns about how this information was presented or if you need more details please give us a call. We are standing by and happy to help.