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Compliance Assurance Associates, Inc. |
 VEO Form Instructions
Process and Control Equipment  Regulators: Include a several word description of the process and control device, indication of the current process operating capacity or mode, and the operational status of the control equipment. Note: This section in particular contains information that will probably have to be obtained from a plant official. EPA personnel asking a plant official for information requires the approval of OMB, an active case investigation, or a prominent disclaimer that the official is under no obligation to answer. Since a facility may consider their production rate or other process information proprietary, the inspector shall specifically inform them that they have a right to request that this information be submitted subject to the confidential business information provisions of 40 CFR 2, subpart 8. Facilities: The information required differs based upon the purpose for which the information is to be utilized. The comments above for the regulators apply when this is to be used for enforcement action and legal proceedings for which the regulator needs to be certain that the correct procedures for obtaining evidence are followed. Likely within the required report (NSPS or Title V submission) you will desire to exercise your rights under 40 CFR 2, subpart 8, such that all of this information is kept proprietary. For NSPS purposes it is important to completely document the make, model, and serial number of the equipment. The Operating Mode refers to the production capacity. For NSPS purposes you must reach 90% of your desired operating limit to prove that the equipment meets the environmental requirements at the desired operating limit. (i.e. if the operation is designed to produce 1000 widgets per hour the NSPS compliance test must be conducted at least at 900 widgets per hour in order to not have a de-rated production limit applied to the operation). You will then be allowed to operate 10% over the name-plate (or proposed) limit or up to 1100 widgets per hour without proving compliance at the higher rate. Achieving a greater than nameplate operational capacity Likely within the required report you will desire to exercise your rights under 40 CFR 2, subpart 8, such that all of this information is kept proprietary. Title V purposes are yet different. These are daily, weekly, monthly, at times only annual or less requirements. The make, model, and serial number does not need to be verified daily, but you do need to be sure you are looking at the correct stack (especially consultants need to verify the stack - photographs help). Process Equipment: Enter a description which clearly identifies the process equipment and the type of facility that emits (or has the potential to emit) the plume or emissions to be read. The description should be brief but should include as much information as possible (complete yet concise), as indicated in the following examples.
If the reading is for a NSPT (New Source Performance Test) then attach documentation that provides a complete process description including make, model, and serial number on the equipment. If a new unit (same make and model) replaces an old unit then the NSPT must be performed for the new unit. Operating Mode: Depending on the type of process equipment and specific situation this information may vary from a quantification of the current operating rate to a description of the portion of a batch-type process form which the opacity is being read, to an explanation of how the equipment is currently operating such as "upset condition", "start-up" or "shutdown". For NSPT purposes these "conditions" would be excluded as well as any down-time. Read and report only upon the operating time and the actual operating rate which can be documented. Other Examples include "90 percent capacity" for a boiler or "85% production rate (assumes name plate production rate previously reported to EPA as the NSPT rate) for the shake-out area of a grey iron foundry. For a steel making facility entries should include the exact part of the process cycle for which the readings are being made, such as "charging", or "tapping". In most case this information will have to be obtained from a plant official. Often this may be coordinated with the reading time in advance or after the exact timing of records will need to be matched. There may also be a delay between a process step and the actual emission occurrence. Control Equipment: Specify the types of Control Equipment being used in the process system after the process equipment in question (e.g. "hot-side electrostatic precipitator"). This may entail several steps as a modern Clean-Coal Power Plant will included an electrostatic precipitator and a wet (or dry) scrubber . A primer on Typical Types of Air Pollution Control Equipment Bag-house (Dust Collector) - Shaker Type, Reverse Air Type, Pulse Jet, Filter Type Electrostatic Precipitator - Wet or Dry, Hot or Cold, plate or tubular Scrubber - Orifice Type, Venturi-Type, Packed Column, Wier-Type, Dry-Scrubber Cyclone - Single system, Multi-Clone Thermal Oxidizer - Regenerative, Straight, Recuperative, Catalytic Flares - Standard, Steam Assisted, Enclosed Vapor Recovery Systems - Chillers, Activated Carbon SCR and nSCR Unique Systems - Good Operating - good combustion practices - i.e. no applicable control equipment is used Wet Suppression - for road ways or a primary crusher at a rock quarry Operating Mode: Indicate the manner in which the control equipment is being utilized at the time of the opacity observations (e.g. 1 field of 8 tripped on ESP, scrubber operating without water - or at flow and pH of, shutdown, offline) and the operating mode (e.g. automatic, manual, bypass). This information should be obtained from a plant official (because otherwise it is proprietary and an illegal search and potentially would not be admissible into any proceedings - SEE 40 CFR 2, subpart 8) When performing a New Source Performance Test the make, model, and serial number of the control equipment, as well as a complete operational description should be included. Operating Mode should include all parameters applicable to that type of control equipment such as: for a scrubber the air flow, pressure drop, water flow and pH or a bag-house - the pressure drop and air flow or for a primary crusher at a quarry the water flow rate (gallons per minute). |
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