Refinery MACT I – Do You Really Know What Your DAHS is Doing?

This article is available as a podcast episode on ALL4’s Air Quality Insider

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 to your facility, including updated monitoring provisions.  In general, increased monitoring also means increased recordkeeping and reporting.  Have you included updating and implementation of your monitoring plan as part of your compliance strategy?

I recommend that everyone affected by the Refinery MACT take another read through the monitoring plan documentation provisions.  Refinery MACT I includes a unique set of continuous parametric monitoring systems (CPMS) requirements for inclusion in your facility’s monitoring plan.  Specifically, 40 CFR §63.671(b) requires that a facility document “What data acquisition system algorithms are used to reduce the measured data into the reportable form of the standard and to calculate the applicable averages”. This provision means that you must truly understand what your data acquisition and handling system (DAHS) is doing and how it is doing it.  The time has passed when your answer for how you demonstrate compliance could simply be “My DAHS does it”.

Unfortunately, Refinery MACT I does not explicitly list which details regarding your data reduction methodologies are required for a complete compliance solution.  Such is life.  There is hope – the process for developing a CPMS data management schema is systemic and certainly reproducible. As a starting point, your facility will need to determine what parameters to consider for developing a defensible CPMS data management schema.  Other items to address while developing your strategy include the identification of what information needs to be monitored, the interpretation and decisions on how the monitoring needs to be completed (considering industry standards and guidance), the development of specifications documenting the various what’s and the how’s, and finally the implementation of the your solution.

Diving into each of these compliance algorithms and documenting the process will reduce your compliance risk and provide confidence for on-going compliance demonstration.  Conversely, not understanding and documenting the basis of a compliance demonstration puts your facility at risk of violating an emissions standard.  It’s time to buckle up and really dig in. Give me a call at 610-933-5246 extension 130, or email me at mbarber@all4inc.com or contact Eric Swisher at 610-933-5246, extension 117, or eswisher@all4inc.com and we can help you.