Installing a New Continuous Monitoring System? Here Are Some Things You May Want to Consider.
Posted: June 23rd, 2022Authors: Meghan B.
The day has come – a driver such as a new regulation or a sustainability initiative has resulted in your facility needing to install a Continuous Monitoring System (CMS). We get it – that task can be very daunting. To help, we’ve put together a list of the top things to consider as you embark on this journey.
- Who is on your team?
The installation of a CMS requires a team of resources. Your stakeholders could include folks from internal facility resources such as Environmental, Instrumentation, Operations, and even Information Technology. The external resources could include consultants, integrators, and vendors. Don’t forget the internal or external resources explicitly assigned to manage this project. Without effective project management, a successful and timely CMS installation will not be achievable.
- What is the regulatory or company driver for the CMS?
The first step in installing a CMS is understanding the why behind the monitoring. Understanding why you are required to implement continuous monitoring will dictate the type of monitoring system, the resources you engage in the process, and how you will demonstrate compliance or quantify processes against key metrics moving forward. Do you need a CMS to comply with a regulation or are you installing it so you have better information? The why will define the how for monitoring including the type of CMS, the data collected by the CMS (i.e., calculation, averaging, validation, etc.), and the quality assurance of the CMS.
- How do you want to integrate and implement the CMS into your facility?
The end-goal of a CMS installation program must be considered at the beginning of the program. Be a dreamer, imagine what the ultimate success of the CMS program looks like. Who will be the accountable parties? Will the Instrumentation personnel be responsible for the recordkeeping associated with CMS downtime and Operations personnel be responsible for the recordkeeping associated with deviations or excess emissions? What other goals may the CMS or Data Acquisition and Handling System (DAHS) be able to help achieve? Use a whiteboard to outline the ultimate workflow considering notification, response, and recordkeeping responsibility. You will have to know the end result to ensure that the design of the CMS can get you there.
- What type of monitoring system do you need?
CMS is a broad term – it encompasses a variety of systems. To determine which system your facility needs, you will need to consider what type of data is going to be collected? Monitoring opacity? You will need a Continuous Opacity Monitoring System (COMS). Monitoring NOX, SO2, CO, etc? Time to start looking at a Continuous Emissions Monitoring System (CEMS). Will you need to quantify mass emissions (i.e., lb/hr)? You may need a stack flow monitor. Collecting process data (think temperature, pressure, etc.)? A Continuous Parameter Monitoring System (CPMS) will be the way to go.
- Do you know all of the different equipment needed?
Once you have made the decision on the type of monitoring system that you need, it’s time to consider what that system actually entails. What type of sampling system will you need and how will you store the data? What type of DAHS will be used? To quality assure your data, what reference gases or other calibration standards will you need? Even more importantly, what pieces of equipment will you want to keep onsite in your spare parts department in the event of required maintenance?
- Where will all of the equipment be stored?
Ok, we’ve decided on what equipment we need, but where the heck are you going to actually put all of this onsite? Some facilities opt to erect a specific CMS shelter. When doing this, it’s important to consider the footprint of the shelter and whether you have enough room in the field for it. Will this shelter need to have its own HVAC system to ensure the sampling system lines don’t freeze or the equipment doesn’t overheat? And finally, is there an easily accessible power source to run all of this equipment?
- What type of connection will the data be shared over?
This is often a question that isn’t considered until later in the installation process but can have a significant impact on the overall budget and timing. How will all of the CMS information get around your facility? What infrastructure (i.e., fiber or hardwire) is available to move the data around? Can the CMS data be collected over Modbus or will data be collected via 4-20 millamp signals?
- What is your deadline for installing the CMS?
So, we’ve determined the monitoring system we want, outlined all of the equipment that’s actually needed to run that system and decided where we’re going to store it. How long is it going to take to get this thing up and running? Right now, more than ever, it’s very important to consider supply chain issues (see Katie’s article ). What used to take about 6 weeks, could now take 6 months.
- Do you know what your quality assurance requirements will be?
Phew – we’ve planned it all out, right? Before we let you off the hook that easily, we would be remiss if we didn’t talk about a system’s certification requirements. If the CMS is being installed for a regulatory reason, there will be specific initial and ongoing certification requirements that must be followed. As part of this, you will need to consider the type of reference gases or other calibration standards that you will need to have onsite to complete the quality assurance activities. For ongoing, more intensive quality assurance activities, you will want to consider what external vendors you will need (i.e., a testing company) and how often you will need the vendor to come onsite (once a year? once a quarter?).
When you are tasked with the installation of a CMS (and maybe even after reading this), your head may be swimming. We’ve been there. However, after being involved in numerous CMS installations, these are the right questions to ask in order to bring some certainty to your CMS installation. Need help getting out of the gate? Please do not hesitate to reach out to me at firstname.lastname@example.org.