Continuous monitoring systems (CMS) have become a critical part of a facility’s ongoing compliance demonstration. U.S. EPA and individual states agencies are focused on expanded transparency, increased scrutiny, and the use of data analytics and targeting for enforcement purposes. This makes effective CMS management more crucial than ever before.
Businesses that prioritize continuous monitoring — and work with external consulting firms who know how to align system integration and data management with their strategic goals — will be better positioned to succeed in an increasingly complex and technical regulatory environment.
What Is a Continuous Monitoring System?
A Continuous Monitoring System is a tool that continuously measures and records actual data and information from an emissions source. The measured data is often used in real-time to operate the source and also demonstrate compliance with applicable regulations. A CMS must meet specific criteria depending on the nature of your operation, which may include formal certification.
The U.S. EPA distinguishes between four types of CMS:
- Continuous emission monitoring systems (CEMS): To directly measure actual emission levels from a stationary source, such as nitrogen oxides of a flue-gas.
- Continuous emission rate monitors (CERMs):A sub-type of CEMS that measures pollutant rates in a standard such as mass per unit time.
- Continuous opacity monitoring systems (COMS):A relative indicator of particulate matter emissions by measuring the opacity of flue-gas.
- Continuous parametric monitoring systems (CPMS):To measure a specific parameter(s) and also used to extrapolate emissions data from it.
ALL4’s CMS Expertise
ALL4 can work with your team and assist with all aspects of CMS data management related to 40 CFR Part 60, Part 63 and Part 75. Our team includes air quality regulatory experts with experience in:
- CMS procurement assistance
- CMS system integration
- Data acquisition and handling system (DAHS) implementation and optimization
- Initial CMS certification and ongoing quality assurance
- Site-specific monitoring
- State-specific data management and reporting
- CMS auditing
- CMS data forensics and expert witness testimony
- CMS permit condition review, development and negotiation
- Alternative Monitoring Petitions (AMP)
- Training and optimization
We’ll work with your technical departments and senior management to put together a package of services appropriate for your organization. Though we specialize in large and complex projects, we have the customer focus to work on continuous emissions monitoring projects of any size.
CMS and DAHS Reviews
There are several situations which may trigger a review of your CMS or DAHS. These include:
- Changes to 40 CFR Part 60, Part 63 or Part 75, or other governing regulations
- Poor data availability or quality, or changing data end use
- System errors that lead to lost allowances and subsequently cost you money
- Installation or modification of air pollution control equipment
- Inadequate or unavailable data substitution or validation capabilities
- Aging equipment
- Poor monitor availability
- Plant modifications
To learn more about how ALL4 can help with proactive CMS design and system integration, or any other air quality monitoring issue, please contact ALL4’s Practice Area Leader – CMS, JP Kleinle, directly (firstname.lastname@example.org or 610.933.5246 x120).
Posted: October 2021
On August 25, 2021, the New Jersey Department of Environmental Protection (NJDEP) issued a Compliance Advisory to facilities in the state that have an air permit that requires a Continuous Emissions Monitoring System (CEMS) with a 3-hour rolling average based […]Read article
Posted: May 2020
Welcome to ALL4’s 4 The Record – Quarantine Series (4TR-QS)! 4TR-QS is a publication of our RegTech Group and our intent is to provide timely and applicable insight for environmental professionals during a time when the “new normal” is anything […]Read article
Posted: April 2020
First off, a big THANK YOU to all of our clients and others working at essential business facilities that are out and about and keeping our manufacturing facilities running! Our readers are used to receiving technical content from us year-round […]Read article
Posted: March 2020
Welcome to the third blog of our series related to the Pennsylvania Department of Environmental Protection’s (PADEP or Department) Continuous Emissions Monitoring (CEM) Section’s release of an updated Frequently Asked Questions (FAQs) document to support Continuous Source Monitoring Manual Revision […]Read article
Posted: December 2019
The Pennsylvania Department of Environmental Protection’s (PADEP’s or Department’s) Continuous Emissions Monitoring (CEM) Section within the Division of Air Quality released an updated Frequently Asked Questions (FAQs) document to support Continuous Source Monitoring Manual Revision No. 8 (CSMM Rev. 8) […]Read article
Posted: November 2019
Did you know that the Pennsylvania Department of Environmental Protection (PADEP or Department) Continuous Emissions Monitoring (CEM) Section within the Division of Air Quality released an updated Frequently Asked Questions (FAQs) document to support Continuous Source Monitoring Manual Revision No. […]Read article
Posted: October 2019
As we near the start of the third quarter reporting season for continuous monitoring systems (CMS), ALL4’s CMS Practice Area felt it was timely to recommunicate the ending of two years of compliance demonstration uncertainty involving the regulatory interpretation for […]Read article
Posted: August 2019
Does your facility operate a continuous monitoring system (CMS) to demonstrate compliance with Federal and/or state monitoring requirements? If so, we want to reiterate the importance of maintaining records/logbooks of events associated with your CMS. In addition to potentially being […]Read article
Posted: July 2019
Within various subparts of 40 CFR Part 63, there are General Provisions applicability tables, detailing which general provisions are applicable to the source category regulated by the corresponding subpart. The format and location of this table often varies between subparts, […]Read article
Posted: May 2019
Does your facility operate a continuous monitoring system (CMS) in Pennsylvania? If so, it’s possible that you, or someone at your facility, is familiar with Pennsylvania Department of Environmental Protection (PADEP) Continuous Source Monitoring Manual (CSMM) Revision No. 8 (Rev. […]Read article