Will the Changes to the PM CEMS QA/QC Requirements Impact my PM CPMS?
Posted: August 31st, 2017
The answer is probability not. U.S. EPA has recently revised certain quality assurance requirements for sources using particulate matter (PM) continuous emission monitoring systems (CEMS) under 40 CFR Part 60 Appendix F, Procedure 2 (P2). P2 includes quality…
Read articlePC MACT Carousel
Posted: July 25th, 2017
Today (July 25th) is National Carousel Day. Ironically, it is also the expiration date of the original 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance…
Read article
Reasonably Available Control Technology (RACT 2) Post-Compliance Deadline Happenings
Posted: July 21st, 2017
Major sources of NOx and/or VOC (i.e., potential to emit greater than or equal to 100 tons per year of NOx and/or 50 tons per year of VOC) subject to the Pennsylvania Reasonably Available Control Technology (RACT 2) rule had to demonstrate compliance with the applicable
Read articleRefinery MACT I – Do You Really Know What Your DAHS is Doing?
Posted: June 15th, 2017
By now, I’m sure you have familiarized yourself with 40 CFR Part 63, Subpart CC – National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (Refinery MACT I) and you have (hopefully) developed a compliance strategy for the new requirements that apply…
Read article
Re-Entrainment. What is it and should you be evaluating it for your site or next project?
Posted: May 17th, 2017
|Who should consider a re-entrainment evaluation?|Information necessary to conduct a re-entrainment evaluation|AERMOD|ASHRAE Minimum Dilution Models|Hospital Example Re-Entrainment Evaluation|Ship Example Re-Entrainment Evaluation|Recommendations| Have you ever seen a plume from a stack swirl around when it gets caught in the wake of […]
Read article
Getting Your CMS House in Order
Posted: May 4th, 2017
We are all wondering how the proposed cutbacks at U.S. EPA could influence the day-to-day compliance obligations at facilities using continuous monitoring systems (CMS). The organizations that may be affected the most by the anticipated U.S. EPA cutbacks are the state…
Read article
Continuous Monitoring System Data – The Risk of Being Isolated
Posted: April 11th, 2017
Annalise recently wrote an article called “What-If Island,” where the “island” represented “creating a story,” usually about something that is not as scary as we make it out to be in our heads. “Being on an island” can also refer to being isolated, which is something…
Read article
PC MACT HCl CEMS – Does July 25, 2017 Sound Familiar?
Posted: April 6th, 2017
July 25th, 2017 is the expiration date for the 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance with the Portland Cement MACT (i.e., PC MACT or 40 CFR Part 63, Subpart LLL) HCl emission limit.
Read article
Is Your Continuous Monitoring Data Leaving You Vulnerable and Exposed?
Posted: March 21st, 2017
The U.S. EPA announced, in a 2013 blog, the terminology “NextGen” (U.S. EPA’s Next Generation of Compliance and Enforcement) and its five interconnected components. Fast-forward to the Spring of 2017…the U.S. EPA is continuing to implement their NextGen…
Read articleRefinery Fenceline Monitoring Data of Concern: Now What?
Posted: February 14th, 2017
In the December 2016 edition of 4 The Record (4TR), Nick Leone of All4 Inc. (ALL4) provided insight on where facilities that are subject to the Petroleum Refinery Sector Rule in 40 CFR Part 63, Subpart CC (National Emission Standards […]
Read article