Continuous Parameter Monitoring Systems: Regulatory Changes to Affect Over 1/4 Million Sources & Cost Over $175 Million

Long Awaited New Installation and Quality Assurance Requirements Proposed by U.S. EPA for Systems Installed Under 40 CFR Parts 60, 61, and 63

On October 9, 2008, U.S. EPA proposed for comment the long awaited Performance Specification 17 (PS-17) and Procedure 4 (P-4) to evaluate the acceptability of continuous parameter monitoring systems (CPMS) that monitor specific process or control device parameters pursuant to 40 CFR Parts 60, 61, and 63 (with exemptions).  PS-17 describes the requirements for the initial installation and performance procedures for the CPMS while P-4 describes the requirements for ongoing quality assurance (QA) and quality control (QC) of those CPMS.  PS-17 and P-4 would apply to CPMS that are used to monitor temperature, pressure, liquid flow rate, mass flow rate, pH, and conductivity as indicators of good control device performance or emission source operation.

Will my facility be affected when PS-17 and P-4 are published as final?

Any facility that was required to install a CPMS under any applicable subparts of 40 CFR Parts 60, 61, or 63 will be subject to PS-17 and P-4.  U.S. EPA estimates this action will affect over a quarter of a million sources and cost facilities $175 million in the first five-year period.  A few subparts under 40 CFR Part 63 will not be affected by PS-17 and P-4 since those subparts specify that 40 CFR §63.8(a)(2), which implements monitoring requirements upon promulgation of performance specifications, does not apply.  Those subparts include F through I, U, AA through DD, DDD, III, JJJ, LLL, OOO, PPP, TTTT, IIIII, and LLLLL.

When will my facility be required to comply?

When published as final, PS-17 and P-4 will apply to your facility when any new applicable CPMS is installed or an existing CPMS is relocated or replaced.  At the latest, PS-17 and P-4 will become effective upon the next Title V permit renewal or within five (5) years for area sources.

How will my facility be affected if PS-17 and P-4 are published as proposed?

If published as proposed, all affected facilities will be required to install and validate new, relocated, or replacement CPMS pursuant to PS-17.  PS-17 requires that CPMS satisfy basic equipment design, installation, validation, and recordkeeping requirements.  If PS-17 is finalized as proposed, all affected facilities may be required to:

• Evaluate existing CPMS. Your facility may be required to purchase new CPMS if the current CPMS do not met the basic equipment design requirements of PS-17.
• Evaluate existing CPMS location. Your facility may be required to relocate the existing CPMS if current CPMS do not meet the installation requirements of PS-17 and representative measurements cannot be demonstrated at its location.
• Conduct an initial validation check. Your facility will be required to conduct an initial validation check to assess the accuracy of the CPMS pursuant to the procedures in PS-17.

All affected facilities will be required to quality assure the CPMS at the frequency described in P-4.  P-4 provides weekly, monthly, and quarterly QA/QC activities for various types of CPMS including temperature, pressure, liquid flow rate, mass flow rate, pH, and conductivity.  For example, pressure transducers require monthly inspection of mechanical connections, quarterly accuracy audits, and quarterly visual operational inspections.  CPMS for pH require weekly accuracy audits and monthly visual operational inspections.

If P-4 is finalized as proposed, all affected facilities may be required to:

• Conduct accuracy audits. Your facility will be required to conduct accuracy audits on a weekly, monthly, and/or quarterly basis depending on the type of CPMS.  Your facility will be required to purchase equipment to conduct accuracy audits as well as install any ancillary equipment (i.e., test ports, platforms, etc.) to support the QA requirements of P-4.
• Implement a QA/QC program. Your facility will be required to develop and implement a QA/QC program (or update an existing QA/QC program) to describe the procedures and tolerances for ongoing CPMS QA activities.
• Update existing Operations, Maintenance, and Monitoring (OM&M) Plan. If your facility was required to develop an OM&M Plan that included the CPMS, a revised plan must include the procedures in P-4, as well as certain aspects of PS-17.

What should my facility be doing to prepare for PS-17 and PS-4?

U.S. EPA is accepting comments on proposed PS-17 and P-4 until December 8, 2008.  Your facility should be evaluating your existing CPMS to assess the impacts that PS-17 and P-4 will have on your equipment and internal QA procedures.  The promulgation of PS-17 and P-4 will require additional responsibility for the validation and quality assurance of the CPMS that are used to monitor temperature, pressure, liquid flow rate, mass flow rate, pH, and conductivity.