Dixon Environmental has a long-term relationship providing air permitting and compliance assistance to a batch manufacturer of lubricants. Dixon Environmental enabled this client to manage their compliance program more efficiently and improve recordkeeping completeness and accuracy through the implementation of an EMIS system. This client’s EMIS system began with a regulatory compliance database and included the addition of optional features such as a “Smart Environmental Logging System” that instantly monitors data when it is logged.

The facility found the EMIS system particularly useful, as their Title V permit required them to certify compliance on their control devices every 8 hours. The control devices had multiple batch plants feeding into it, with approximately 30 steps per batch. Approximately 50 operators utilized the smart environmental logging system software each day. The operators were required to enter 12 environmental logs for each 8-hour shift each day of the year. Therefore, in order to assure compliance for the manufacturing of hundreds of various products at this site, over 11,000 different operating limit comparisons were required. Now, every 8 hours, the operator selects the appropriate log sheet, declares the product being manufactured, declares the process step, and enters the data for the required parameters. The “smart” program tells the operator which parameters are required to be entered, the operating range, and the permit range for each parameter for each step. If an entry is outside either the operating range or the permit range, the operator is immediately notified. The operator can change the entry if the entry is incorrect. The purpose of the immediate notification is to fix the problem as soon as it occurs to avoid permit deviations. After the environmental log is complete, it is posted to a database where queries incorporate requested data into reports for streamlined compliance management, audits, and reporting.

Dixon Environmental’s expertise in regulatory compliance for batch chemical facilities benefited this client by:

• Improving facility compliance,
• Streamlining record-keeping and reporting, and
• Reducing response times for compliance deviations.

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