Title V Compliance - Tracking the PFI Boiler Firing Fuel Oil
The Problem
When a top packaging company received an audit from the State, they were unable to provide proper documentation demonstrating compliance with their Title V permit requirements, specifically for maintaining records of inspections done when firing No. 2 fuel oil in a PFI Boiler regulated under 40 CFR Part 75.
The Implementation
As a requirement for the facility's Title V Permit, documentation was necessary to show where visual inspections were being completed in the event that the PFI Boiler ran fuel oil for more that thirty minutes. In addition to inspection and recordkeeping requirements after thirty minutes of firing No. 2 fuel oil, the facility was also required to document any use of No. 2 Fuel Oil at any time.
The Solution
The ehsSUITE solution provides many features and tools to help automate this requirement. The workflow process implemented in ehsSUITE is described below.
1. The ehsSUITE solution automates the tracking of all No.2 Fuel Oil use.
2. An ehsSUITE alarm was configured to alert the PFI Boiler operators that completion of a visual inspection is required if No.2 Fuel Oil is used for over thirty consecutive minutes.
3. PFI Boilers operators are now notified, through the facility's DCS, to complete a visual inspection and document this inspection in the "Burner Audit Checklist" or "Opacity Observation" form.
4. A report was configured to allow the Environmental Engineer to quickly determine, for any time period, compliance with the permit requirement. The report shows each event in which No.2 Fuel Oil is used, including details such as Start Time, End Time, Duration, and the appropriate form completed by the operator.
The Result
Although the facility was in compliance with the Title V permit, the facility now has a system in place that automates these requirements and provides an auditing tool, easily demonstrating that all requirements have been met.
1. Automated tracking of when No.2 Fuel Oil is being used.
2. Alerting after thirty minutes of continuous use linking to an inspection form documenting the visual inspection.
3. Recordkeeping and reporting of all use of No.2 Fuel Oil and inspections completed after thirty minutes of continuous use.
The ehsSUITE Benefits
1. Automated tracking of No.2 Fuel Oil firing using the real-time data collection and validations in ehsSUITE.
2. Linking an alert of thirty minutes of continuous firing to a form for documenting the inspection using ehsSUITE's alarm functionality.
3. Auditing tools showing compliance using ehsSUITE's reporting and searching functions.
The Savings
1. Operators are now able to focus on production and use an automation tool to document compliance. Time is saved searching for and then completing the correct forms.
2. Environmental compliance professionals now have immediate access to all permit requirements to determine compliance without devoting resources to tracking events and insuring proper visual inspections and documentation.
Please contact us if you have any questions about this case study or about how ehsSUITE can help your corporation achieve their compliance objectives.
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