The ability to continuously monitor and gather data to assist our client’s air compliance programs is an important part of ALL4 services. Whether we are supporting a client in identifying the optimum continuous in-stack, pollutant monitoring system to address the requirements for a new rule, gathering real time ambient pollutant concentration data for regulatory planning purposes, or monitoring meteorological data to as part of the permitting effort around a client’s new project , ALL4 staff have years of experience with these activities. Our monitoring work is often a critical aspect of the strategic planning process intended to support our client’s growth and success. Our capabilities in each monitoring area are discussed in the following subsections.
Continuous monitoring systems or CMS may take the form of continuous emissions monitors (CEMs) that directly measure stack emissions, continuous parametric monitors (CPMs) that measure source operating parameters that are ultimately related to emissions, or continuous opacity monitors (COMs) that measure the opacity of the flue gas as an indicator of particulate emissions. Procurement, design, installation, maintenance, data handling, certification, and operation of CMS have typically been handled by facility engineering and maintenance departments over the years. As these data become more and more critical to a facility’s compliance management program, it is imperative that CMS are managed by those with a thorough understanding of the regulatory requirements for the systems in addition to the purpose and end-use of the data generated. Collecting accurate CMS data has a direct impact on facility costs for compliance with pollutant allowances under a budget trading program such as the Acid Rain or NOX Budget Programs. As cap and trade, and budget programs proliferate and become a common method for regulating air emissions sources, effective CMS program management is more important than ever. Instead of relying on the system vendors for consulting assistance; ALL4 offers sources third-party consulting assistance. We have assisted clients with CMS management services related to 40 CFR Part 60, 40 CFR Part 63, and 40 CFR Part 75. These services have saved our clients valuable time and money.
The following situations may trigger a review of your CMS:
- Change in the governing regulation (40 CFR Part 60, 40 CFR Part 63, and 40 CFR Part 75)
- Aging equipment
- Data end use (i.e., measured concentration historically but now need mass)
- Poor monitor availability
- Plant modifications
- Installation or modification of air pollution control equipment
- System errors are costing money in the form of lost allowances
ALL4 has experienced professionals that can assist with the following CMS service areas:
- Functional Specification Development/Procurement Assistance
- System Audits
- Certification Test Management
- Reporting Assistance
- Monitoring Plans
- QA/QC Plans
- Data Acquisition System Design and Implementation Assistance
Ambient air and meteorological monitoring programs have become extremely efficient during the past 20 years. Programs that once required large monitoring trailers, elaborate data communication protocols and extensive "baby-sitting" now consist of small shelters, wireless communication and extended periods of remote operation. ALL4 has substantial experience designing, operating, managing and ensuring the quality of ambient air and meteorological monitoring programs. These monitoring programs can be short-term or long-term projects including a single station or multiple stations. ALL4 has integrated new approaches to monitoring program design and operation including posting of data to secure web-sites and using personal data assistant (PDA) technology to collect and retrieve monitoring data.
ALL4 has conducted third-party quality assurance audits for a diverse base of industrial clientele as well as state and Federal agencies. These audits have taken place over a broad geographic area that includes not only the continental
ALL4 has experience with ambient air monitoring programs for a variety of pollutants, including:
- Sulfur Dioxide (SO2)
- Oxides of Nitrogen (NOX)
- Particulate Matter less than 10 Micron (PM10)
- Particulate Matter less than 2.5 Micron (PM2.5)
- Ozone (O3)
- Carbon Monoxide (CO)
- Air Toxics
Meteorological monitoring programs range from small scale monitoring programs where measurements are made with 10-ft. tripod to multi-level tall towers and remote sensing equipment with Doppler Sonic Detection and Ranging (SODAR) systems. The design of the meteorological monitoring programs considers the end use of the data and typically incorporates long-range planning for additional uses of the data.
The implementation of USEPA's AERMOD air dispersion model could result in a requirement to collect on-site meteorological data if "representation" data are unavailable. ALL4 recommends discussing your meteorological data situation with your state meteorologist now instead of waiting for your project to be delayed because there are no available representative meteorological data.
Related Case StudiesContinuous Ambient Sulfur Dioxide (SO2) and Meteorological Monitoring System
Revision 8 Implementation
Meteorological Monitoring System