Continuous Monitoring Systems (CMS) in Pennsylvania: The Devil’s in the Details
Posted: May 22nd, 2019Authors: Matt C.
Does your facility operate a continuous monitoring system (CMS) in Pennsylvania? If so, it’s possible that you, or someone at your facility, is familiar with Pennsylvania Department of Environmental Protection (PADEP) Continuous Source Monitoring Manual (CSMM) Revision No. 8 (Rev. 8). If you are not familiar – CMS used for compliance demonstrations in Pennsylvania are often required to satisfy the system design, performance, testing, recordkeeping, reporting, and quality assurance (QA) requirements of CSMM Rev. 8. The requirements of CSMM Rev. 8 has many nuances that differ from Federal monitoring programs such as 40 CFR Part 60 or 40 CFR Part 75, and can be thought of as more stringent than Federal monitoring programs. As a facility with CMS in Pennsylvania, it is critical to understand the requirements of CSMM Rev. 8, as they can directly impact your facility’s compliance demonstration.
Continuous Source Monitoring Manual Revision No. 8
One example of a CSMM Rev. 8 nuance is found in the QA requirements – specifically, the data validation criteria detailed in §I(A)(1)(e) on page 62 as it relates to zero/upscale calibration error (CE) checks following process startup. CSMM Rev. 8 necessitates that a successful zero/upscale CE check be completed within 8 process operating hours following startup if the process has been shut down “for at least one complete clock hour during the time from the 19th clock hour through the 26th clock hour following the previous successful zero or upscale CE check”.
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The Revisions Impact
This requirement can impact the validity of CMS data following shutdowns. Why is that? §I(A)(1) specifies that data must be considered invalid if a zero/upscale CE check is not successfully completed following the aforementioned shutdown scenario. Thus, CMS data is considered invalid starting with the 9th process operating hour following startup, and until a successful zero/upscale CE check is completed. The details here are important – the requirement specifies that data becomes invalid the 9th process operating hour following startup. During reviews of client CMS data, ALL4 has found examples of data acquisition systems (DAS) incorrectly applying this Pennsylvania-specific validation criteria, or in some cases, not applying it at all. Consequently, manual data review is needed to ensure the truth and accuracy of certain compliance demonstrations.
A specific example we have encountered occurred when a DAS was programmed to incorrectly invalidate data beginning with the 9th clock hour following startup, rather than the 9th process operating hour following startup. During periods of rough startup (i.e., the process goes on and off), this caused process operating hours to be inaccurately tagged as invalid CMS data, which impacted the data availability of the CMS. Manual data reconciliation was needed to accurately report the data for compliance demonstration purposes.
We have successfully worked with our clients and their DAS vendors to both implement, and to correct this Pennsylvania-specific data validation criteria in their facility’s DAS. If you have questions about CSMM Rev. 8, data validation criteria used at your facility, or any other aspects of CMS, please reach out to me. I can be reached at (610) 933-5246 extension 139, or at firstname.lastname@example.org