Will the Changes to the PM CEMS QA/QC Requirements Impact my PM CPMS?
Posted: August 31st, 2017Authors: Eric S.
The answer is probably not. U.S. EPA has recently revised certain quality assurance requirements for sources using particulate matter (PM) continuous emission monitoring systems (CEMS) under 40 CFR Part 60 Appendix F, Procedure 2 (P2). P2 includes quality assurance/quality control (QA/QC) procedures for PM CEMS used for compliance determinations at stationary sources. The revisions may be welcomed for those with certified PM CEMS, however, many facilities use PM CEMS as a continuous parametric monitoring system (CPMS) because the applicable rule allows it. Therefore, the changes will not likely entice sources that currently use PM CPMS to rush out and certify their CPMS under P2. The cost and effort associated with the certification still outweighs the benefit of having a PM CEMS.
The revisions to P2 were proposed in the Federal Register on November 21, 2016 and specifically address the procedure for conducting the annual Relative Correlation Audit (RCA) or Relative Response Audit (RRA) QA/QC test. The annual RCA or RRA requires that a minimum amount PM CEMS response values be measured with the PM CEMS response range used to develop the PM CEMS correlation curve. U.S. EPA noted that PM emissions from some sources that accepted tighter PM emissions limitations and/or installed better PM control devices now fall below the levels used to establish the initial correlation curve causing facilities to not be able to meet the RCA or RRA requirements. The revisions to P2 remove the requirement that the PM CEMS response values must not be higher or lower than the values used to develop the correlation curve for that PM CEMS. The final rule becomes effective on September 13, 2017. More information can be found here.
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