Site Specific Monitoring Required by the PC MACT: Answering Your Questions

Compliance with the PC MACT requires multiple plans to be developed.  These plans include the Operation and Maintenance (O&M) Plan, Site-Specific Performance Test Plan, Emissions Monitoring Plan, Site-Specific Monitoring Plan, and particulate matter continuous emission monitoring system (PM CEMS) Correlation Test Plan (if applicable).  One could argue the importance of each plan; however, for the purpose of this blog post the focus is on the Site-Specific Monitoring Plan.

What Is The Site-Specific Monitoring Plan?

The Site-Specific Monitoring Plan is required for the continuous monitoring system (CMS) that will be operated as part of your PC MACT compliance strategy.  The Site-Specific Monitoring Plan defines the procedures that a facility will follow as part of the initial performance evaluation, as well as the procedures for the ongoing operation and maintenance of the CMS.

Imagine that your facility is installing monitoring systems for compliance with the PC MACT for which your facility has limited operational experience such as mercury (Hg), hydrogen chloride (HCl), total hydrocarbon (THC), or Particulate Matter (PM).  If this sounds a lot like you, then your CMS Site-Specific Monitoring Plan should be developed and address the following elements:

• Documentation of the representativeness of CMS installation location.
• Performance and equipment specifications.
• Data collection and reduction systems.
• Procedures to complete the initial performance evaluation (and to what pass/fail tolerances).
• A system for ongoing operation, maintenance, data quality assurance, and ongoing recordkeeping and reporting of the CMS data.
• Supporting calculations.

To further emphasize the importance of the Site-Specific Monitoring Plan, I would ask you to consider whether or not you plan on having your stack testing firm perform a relative accuracy test audit (RATA) on your THC analyzer.  Hint take a look at Section 6.1 in Performance Specification 8A of 40 CFR Part 60, Appendix F.

CMS Installation By A Third Party?

Are you assuming that a third party will be completing the CMS performance evaluation as part of their scope?  Now is the time to confirm how the CMS are going to be certified after installation and by whom.  Some third parties may only complete the tasks that are necessary to ensure that the CMS data being collected are representative of operations and are not completing the CMS performance evaluation required by the PC MACT.  If a third party will be contracted to complete the CMS performance evaluation, a well-designed CMS Site-Specific Monitoring Plan will ensure that the CMS will meet the requirements of the PC MACT and the underlying Performance Specifications or Procedures in 40 CFR 60 Appendix B & F respectively (as applicable).

Who’s Responsible For The Ongoing CMS Requirements?

After installation and certification of the CMS, who will be responsible for the ongoing operation, maintenance, and quality assurance of the data collected by the CMS?  Assuming that your plant instrument technicians will be responsible for these items, the CMS Site-Specific Monitoring Plan is required to outline the procedures (and tolerances) for the ongoing quality assurance of the CMS.  Your CMS Site-Specific Monitoring Plan should be a usable document, referencing information supplied by the equipment vendor (including manufacturer’s recommendations), and meeting the regulatory requirements of the PC MACT to ensure that the procedure are followed to quality-assure the CMS data.  Don’t forget that although a thorough CMS Site-Specific Monitoring Plan is needed to ensure that your instrument technicians are in a position to quality assure the collection of your ongoing CMS data, training your staff on the implementation of the CMS Site-Specific Monitoring Plan is also needed for your monitoring plan to be successful.

When Should You Develop Your CMS Site-Specific Monitoring Plan?

Now! From a regulatory perspective, a CMS Performance Evaluation Test Plan must be in place at least 60 days prior to the CMS performance evaluation (i.e., no later than January 07, 2016 based on the latest possible performance test date of March 07, 2016) and available for submittal to your state agency or the U.S. EPA.  The performance evaluation of the CMS must be completed as part of the performance test, which is required to be completed no later March 07, 2016 (i.e., 180 days after the compliance date).  The CMS Performance Evaluation Test Plan is part of the Site-Specific Monitoring Plan which must be submitted (upon request), at least 30 days before the initial performance evaluation of the CMS.

Have Additional Facilities Subject To PC MACT?

The CMS Site-Specific Monitoring Plan is an area that is perfect to take advantage of the economies of scale.  By working together you can develop a thorough, cost effective CMS Site-Specific Monitoring Plan that provides consistency amongst facilities, meets the regulatory of the PC MACT, and provides a platform for more efficient training.

How Can ALL4 Help?

The development of a CMS Site-Specific Monitoring Plan is both a science and an art.  The science is in interpreting the regulatory requirements and understanding the technical aspects of the CMS.  The art is in the development of a plan that can be used by multiple audiences with different needs including environmental and instrumentation personnel.  At ALL4 we treat the CMS Site-Specific Monitoring Plan as a resource that needs to be used as part of your PC MACT compliance solution.  Unlike what your prior experiences with others may have been, no more are plans developed solely to meet a regulatory requirement and remain on the shelf collecting dust as various quality assurance activities are missed.  We strive to create a CMS Site-Specific Monitoring Plan that provides the necessary information structured in a manner that easily used.  If you have any more questions on our approach to developing a robust CMS Site-Specific Monitoring Plan, give me a call or shoot me an email.

Give me a call (610.933.5246 x117) or shoot me an email (eswisher@all4inc.com) and we’ll get started!

As promised, ALL4 will continue a series of upcoming blog posts that will continue to dive further into the PC MACT in preparation of the September 09, 2015 compliance date.