Revision 8 Implementation - The July 1, 2009 Monitoring Deadline is Just Around the Corner!
Are you prepared? It should be apparent by now that the new Continuous Emission Monitoring Data Processing System (CEMDPS) will require affected facilities in Pennsylvania to update their data acquisition and handling system (DAHS) to meet the new data validation and reporting requirements of Revision 8 of the Continuous Source Monitoring Manual (CSMM). The DAHS software upgrade may be the easiest part if you are working with an experienced DAHS vendor. ALL4 summarized the regulatory deadlines for the Revision 8 implementation in a January 2009 4TR Extra article. However, additional tasks must be completed to comply with Revision 8 requirements, including:
· GreenPort Access - GreenPort access will allow your facility to review the configuration of existing continuous emission monitoring systems (CEMS) and emission standards at your facility. The information present in CEMDPS is based on the data that the Pennsylvania Department of Environmental Protection (PADEP) Bureau of Air Quality (BAQ) currently has on file. This "configuration" must be reviewed and corrected to reflect the current CEMS configuration at your facility. Corrections must be made via email correspondence with BAQ.
· Streamline Requirements - The implementation of Revision 8 is a perfect opportunity to harmonize state and Federal requirements. Revision 8 requirements are similar to, but not exactly like, the requirements of 40 CFR Part 75. Your facility should identify the differences and petition BAQ to accept the Federal requirements as if you are complying with Revision 8. As a result, your facility may be able to eliminate redundant quality assurance activities.
· Amended Phase I - All facilities must complete an amended Phase I application for the upgrade of your DAHS. The Phase I must be submitted via email to BAQ (outside of the CEMDPS) and will include specific information regarding your DAHS implementation. The amended Phase I will be due as soon as the information is available.
· DAHS Verification - The DAHS verification will demonstrate that all aspects of your DAHS are functioning correctly during various operational validation scenarios and missing data periods. The BAQ is working with DAHS vendors to perform the DAHS verifications for facilities with multiple clients in PA. Your facility should contact your DAHS vendor to see how they are planning to complete this task, which must be completed by June 1, 2009.
· Certification Tests - If your facility is currently subject to Revision 6 of the CSMM, additional certification tests (e.g., 7-day drift) are required to be submitted to BAQ by June 1, 2009. A major change from Revision 6 to Revision 8 is the incorporation of the Lowest Monitored Emission Standard Equivalent (LMESE). The LMESE may tighten your daily zero and upscale calibration drift tolerances.
· Quality Assurance (QA) Plan - All facilities must update and submit a QA Plan to BAQ. Your QA Plan will change. The five (5) injection quarterly calibration error tests have been replaced with a three (3) injection linearity check. Additional corrective maintenance procedures have also been added to validate data after corrective maintenance is performed. The QA Plan update is a perfect opportunity for your facility to move from an "on-the-shelf" QA Plan to a usable plan that ensures that the quality assurance and maintenance activities are completed and documented correctly.
Have questions? Want to bounce your implementation plan off of someone? Want to hear about ALL'4 facility specific QA Plan? Contact ALL4's Eric Swisher at 610.933.5246 x17 or eswisher@all4inc.com.
