Continuous Monitoring Systems (CMS) in Pennsylvania – Important Reminders and Considerations
Posted: August 16th, 2022Authors: Megan S.
If you are new to Pennsylvania and are responsible for continuous monitoring systems (CMS) for your facility, you may be surprised by all the requirements that need to be followed, most of which do not apply in other states. Even if you have experience with CMS in PA, you likely won’t be doing all these activities regularly and may need a refresher on what considerations to keep in mind when changes are being made at the facility (e.g., installation of new CMS due to a new permit or regulation, replacement of existing CMS or components, maintenance activities being conducted on CMS, impacts of new regulations on existing CMS, etc.).
Knowing what activities trigger action on your part is critical for maintaining compliance and understanding the potential impacts on your facility’s operations. The goal of this article is to summarize some important requirements and actions you should be aware of if you deal with CMS in PA.
PADEP CMS Monitoring Manual and Online System
If your PA facility uses CMS for compliance with emissions and/or operating limitations, there may be specific PA Department of Environmental Protection (PADEP) CMS requirements that apply. These state-specific requirements are for continuous emissions monitoring systems (CEMS), continuous opacity monitoring systems (COMS), stack flow, and temperature monitoring systems and are contained in the latest Continuous Source Monitoring Manual (CSMM) Revision 8, dated December 2, 2006. CSMM Revision 8 details initial certification/recertification, performance testing, recordkeeping, reporting, and ongoing quality assurance/quality control (QA/QC) requirements that must be followed for CMS that are subject to the manual.
There is also a Frequently Asked Questions (FAQs) document to support CSMM Revision 8 that was last updated on October 8, 2019. This document contains some important supplemental information and clarifies/corrects some information contained in the manual. See our previous article series that details some of the changes to this most recent version of the FAQ document:
PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated!
PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated! (Part 2)
PADEP’s CSMM Rev. 8 Frequently Asked Questions Document Updated! Article 3, Operational Test Period
Unlike most other states, CMS certification and reporting in PA are completed through an online system rather than through hardcopy submittals. PADEP uses the Continuous Emission Monitoring Data Processing System (CEMDPS) for certification of CEMS, testing notification and reporting (initial certification and RATA), and quarterly data reporting. Access to this system is obtained through PADEP and a facility can designate viewers (can view information only), editors (can add/edit new submittals), and a submitter (designated facility representative that is able to submit items to PADEP). CEMDPS submittals must be approved by PADEP. If the submittal is incorrect or incomplete, PADEP will reject the submittal and note the corrections that are required.
CMS Installation / Replacement
If you are planning to install new CMS or replace existing CMS (full system or just components), you need to be aware of the Phase I – III certification process. This process is detailed in CSMM Revision 8 and must be completed to certify new/replacement CMS prior to any data reporting in CEMDPS. Here is a general breakdown of that process:
Phase I – Monitoring Plan Submittal
A monitoring plan (MP) that details information on the new/replacement CMS must be completed in CEMDPS. This process includes a combination of data entry in the online system and inclusion of supporting information (e.g., QA/QC plan, manufacturer’s specifications, process diagrams, etc.). The MP provides the information that PADEP needs to evaluate whether the planned monitoring systems will meet the CSMM Revision 8 specifications and requirements.
Phase II – Performance Testing
Depending on the type of CMS being installed/replaced, there are specific certification tests that are required to be conducted. A test protocol must be submitted to PADEP via CEMDPS to demonstrate the testing will satisfy all requirements. Testing is then completed pursuant to the test protocol.
Phase III – Test Result and Sample Report Submittal
The final steps for CMS certification are to 1) submit the test results from Phase II via CEMDPS (includes test result data entry and upload of the test report) and 2) to submit a sample quarterly report (if required) via CEMDPS.
The purpose of the sample report is to demonstrate to PADEP that the emissions data files for the affected CMS are formatted consistent with CSMM Revision 8 and contain the required information. The sample report includes a sample electronic data report (EDR) text file and a sample cover letter file.
Note that CEMDPS works in a sequential manner; therefore, each Phase must have PADEP approval before moving forward with the next step (e.g., Phase I MP must be approved prior to submittal of the Phase II test protocol). Depending on the project timeline and timing of approvals, some submittals may need to be submitted outside of CEMDPS (typically via email) to meet due dates and then be submitted in CEMDPS when allowed. ALL4 can support you in preparing a timeline for your project. We can determine the applicable deadlines for your submittals and help you meet each deadline as you work through the Phase I – III submittal process.
Recertification / Diagnostic Tests
When certain maintenance activities are completed on CMS, there may be recertification/diagnostic tests that are required for the data to be considered quality assured. For example, if you replace/repair the sample cell in an analyzer, you are required to do a calibration error test and a linearity test for the data to be considered valid after that activity. If you make a change to the probe length or location, you need to submit a Phase I MP and complete several recertification tests.
The recertification guidance is included in tables at the end of CSMM Revision 8. It is important to ensure the technicians that are responsible for maintenance on the CMS are aware of these requirements so when a change is made during preventative/corrective maintenance, the necessary tests are completed. Missing a test could result in invalid/out-of-control data. This is especially important for PA CMS because there are data availability requirements that must be met; otherwise, a penalty will be assessed based on the amount of monitor downtime accrued in the quarter as mentioned in the next section.
EDR-E / Penalties
PADEP evaluates each quarterly emissions report that is submitted via CEMDPS and assesses penalties for data availability and emissions exceedances. Penalties are calculated using guidance from the PADEP Compliance Assurance Policies (CAPs). Typically, a facility will submit quarterly EDRs via CEMDPS and then wait until they get feedback from PADEP in the quarterly Continuous Source Monitoring Report (CSMR) to know definitively if there are any penalties that will be assessed. We have seen in the past where a facility is surprised by penalties assessed in the CSMR and it is discovered the penalties were due to errors in the EDR file that were not caught before submittal.
As noted on our EDR-E page, ALL4 has developed a customizable tool to evaluate EDRs and estimate data availability and excess emissions penalties in accordance with the applicable CAP(s). This evaluation helps identify errors in the EDR that need to be resolved and can identify periods of data that need to be evaluated further by the facility to ensure data is accurately tagged (e.g., an erroneous exceedance that should have been reported as invalid data due to a QA/QC activity that was not properly tagged in the database). It has been our experience that simple tagging issues can result in erroneous penalties being calculated, which once assessed, can be time-consuming to correct with PADEP.
Once initial evaluation is completed and any issues are resolved in the EDR, our tool provides a penalty estimate that can be communicated to the certifying official and upper management.
Additional Reasonably Available Control Technologies (RACT) Requirements for Major Sources of NOX and VOC (RACT III)
The PADEP RACT III rule has some CMS aspects to it that you may want to evaluate as the compliance deadline (1/1/2023) approaches. The main CMS consideration is a change to the NOX compliance averaging period from a 30-operating day average to a daily average for combustion units and process heaters. PADEP recently defined how a daily average will need to be calculated in the comment response document (i.e., calendar day sum of NOx divided by the calendar day sum of heat input, including all emissions during the calendar day including startup, shutdown, low load, and other circumstances).
If you have a source that will be subject to this shorter averaging period, it is important to start looking at your CMS data and how this new averaging period impacts your compliance strategy, especially during days that the affected unit starts up, shuts down, or both. There may be updates that are needed within your Data Acquisition System, you may need to evaluate the data substitution methodology currently in place, and you may need to consider strategies for a path forward if you cannot meet the presumptive RACT limit with this new daily averaging period. For more general information on the RACT III rule, and how it may impact you, see this article.
Please reach out to me at (610) 933-5246 extension 140, or at firstname.lastname@example.org for more information on PA CMS requirements or any other general CMS questions you may have!