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Overview


This Electric Utility Company has operations in three states serving 1.5 million electric customers and about 500,000 gas customers. Committed to corporate and personal accountability, this company has a strong environmental pledge.

The Challenge - Emissions Control



Title V of the 1990 Clean Air Act amendments required the Environmental Protection Agency to develop a Federal Permit program that applied to major stationary sources of air pollutants and air toxics. The program applies to thousands of industrial facilities nationwide; the utility industry being one of the ones heavily affected.

To complicate matters, each state has their own unique permitting requirements. As a consequence, generators needed a flexible and easily customized solution.

A further issue the utility faced was that of designating a Responsible Official. Every facility that has been issued a Title V Operating Permit is required to complete and submit an annual compliance certificate to its respective State signed by the Responsible Official. The regulatory (40 CFR 70.2) definition of a Responsible Official sets the bar high and requires the designed executive to attest to accuracy of the compliance data. Unlike the past when an environmental professional often signed reporting forms, today it is more likely to be a Vice President, or Plant Manager that is required to sign the annual compliance certificate forms. The Responsible Official, by signing the document, is certifying the veracity of the information being submitted and is now liable for any civil or criminal penalties for an inaccurate report.

As a major coal-burning operation, the utility company was primarily interested in a solution that would help it meet the increasing compliance requirements of Title V of the Clean Air Act. As Title V permits were being re-authorized, new permit conditions were being added that would require an increasing level of effort to ensure that the utility was in daily compliance. The basic challenge that was posed by the new permit conditions was for a seamless integration between Continuous Emission Monitoring (CEM) and control technologies, such as scrubbers, fuel feedstock and plant operations. All of these elements had to operate together in a real-time context, meaning that emission excursions would need immediate intervention to avoid a permit excursion.

The GreenSuite Solution



The GreenSuite Title V solution consisted of a web-based information management implementation of the GreenSuite database that integrated the utility's Title V permit requirements with data feeds from the CEM technology that was installed at each generating facility in the three states.

Project Success



The Title V project had the following major milestones:
  1. Build the integrated application
  2. Integrate the external databases (CEMs, Fuels, etc.)
  3. Pilot the integrated application
  4. Production launch
Items 1 and 2 above were completed in 60 days from project commencement. A 60-day pilot commenced, that would be followed by a company-wide production rollout.

As a result of the GreenSuite project, the utility has a solution that enables all elements of the Title V permit operating model to be managed in real-time with immediate notification via email, etc. of permit excursions allowing for a rapid response for correction.

Return On Investment



The utility expected to realize an Internal Rate of Return on the Title V project that is in excess of 130%.

 




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