Where Did These New Quality Assurance Requirements For Opacity Monitors Come From?
Posted: May 22nd, 2014Author: All4 Staff
UPDATED (05/16/14): Welcome back to one of ALL4’s longest running blog posts. U.S. EPA promulgated the long awaited ‘‘Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources’’ used to demonstrate continuous compliance with opacity standards specified in new source performance standards (NSPS). This has an effective date of November 12, 2014 and is codified at 40 CFR 60 Appendix F, Procedure 3 (P3). U.S. EPA “believes that most, if not all, owners/operators are already following procedures similar to those specified in Procedure 3. Therefore, there are no additional costs, or reporting burden, associated with implementing Procedure 3.” Procedure 3 establishes requirements for daily instrument zero and upscale drift checks, daily status indicator checks, quarterly performance audits, and annual zero alignments, and requires source owners and operators to have a corrective action in place for malfunctioning COMS.
Okay…You most likely complete the daily assessments already, many of you are probably doing the quarterly calibration error tests, but how many of you are doing the annual zero alignments? Zero alignments require the removal of the COMS from the stack to evaluate their operation under clear path conditions. How much fun does that sound? Procedure 3 is real and in effect soon. Update your QA/QC plans, coordinate the purchase of any additional attenuators or other equipment and get your instrumentation folks trained on requirements of P3.
UPDATED (03/28/12): As of March 28, 2012, U.S. EPA has withdrawn the direct final rule titled, ‘‘Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources’’ that was published in the Federal Register on February 14, 2012. A copy of the notice of the withdraw can be found here.
UPDATED (03/08/12): U.S. EPA has extended the comment period for the direct final rule titled, ‘‘Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources,’’ that were published in the Federal Register on February 14, 2012. The original comment period is scheduled to end on March 15, 2012. The extended comment period will close on April 30, 2012. The comment period is extended because of a request received in a timely manner. A copy of the notice of the extension can be found here.
(02/15/12): Have you noticed the recent sports-related events that have had us all wondering “where is this coming from?” We’re sure you recall the success of Tim Tebow in Denver, the N.Y. Giants winning the Super Bowl, and now “Lin-sanity” taking over the N.Y. Knicks. Not to be left out of the spotlight, U.S. EPA proposed quality assurance requirements for continuous opacity monitoring systems (COMS) at stationary sources on Valentine’s Day 2012. Where did that come from? After being initially proposed on May 8, 2003, believe it or not U.S. EPA decided to take direct final action almost 10 years later to establish quality assurance and quality control (QA/QC) procedures for COMS used to demonstrate continuous compliance with opacity standards in federally enforceable regulations. This rule will become effective on April 16, 2012, unless U.S. EPA receives adverse comments by March 15, 2012. Consistent with the sports theme, odds are that they certainly will receive adverse comments because many of the same comments submitted in 2003 were not adequately addressed in the February 14, 2012 direct final rule.
Less than two months is not sufficient time to obtain the equipment needed to conduct the QA/QC activities, develop a QA/QC Plan, train instrument technicians, etc. A logical question at this point is “What the heck do I do now?” The short answer is to figure out how these requirements will impact your operations, determine what resources will be needed, and it wouldn’t hurt to throw a couple adverse comments to U.S. EPA regarding applicability, implementation, timing, etc. For those of you that may be subject to QA/QC activities for COMS required by state programs, it is likely that the requirements are not the same and that additional actions will be required to meet both state and Federal requirements. For more information about the new COMS QA/QC requirements, click here.