Compliance Monitoring StrategyCMS

Michael Pjetraj

RCO

Compliance Monitoring StrategyCMS

• Issued April 2001• http://www.epa.gov/Compliance/resources/policies/monitoring/cmspolicy.pdf

• EPA Emphasis on TV & 80% SM Facilities

• Minimum Evaluation Frequencies– “Three categories of compliance monitoring replace

the current levels of inspection defined in the 1987 CAA Compliance/Enforcement Manual.”

CMS

• Full Compliance Evaluations

• Partial Compliance Evaluations

• Investigations

FCE

• Full Compliance Evaluation (FCE)

• AFS code - FS (On site FCE by State)

• Comprehensive evaluation of the compliance status of a facility.

• Addresses all regulated pollutants at all regulated emission units; current compliance status of each emission unit; the facility’s continuing ability to maintain compliance at each unit.

FCE includes:

• A review of all required reports and underlying records including all reported monitored data (CEM records, malfunction reports, excess emission reports).

• A review of TV annual compliance certifications, semi-annual monitoring and periodic monitoring reports, and any other permit required report.

FCE includes:

• An assessment of control device and process operating conditions as appropriate.

• A VE observation as needed

• A review of records an operating logs

• An assessment of process parameters such as feed rates, raw material composition and process rates.

FCE includes:

• An assessment of control equipment performance parameters (water flow rate, pressure drop, temp, ESP power level, etc)

• A stack test where there are no other means for determining compliance with emission limits. Factors for consideration: size of unit, duration since last test, margin of compliance in previous test, condition of control equipment, monitoring data.

PCE:

• Partial Compliance Evaluation (PCE)

• AFS code - PS (On site PCE by State)

• A documented compliance assessment focusing on a subset of regulated pollutants, regulatory requirements, or emission unit.

Investigation

• Limited portion of the facility, more resource intensive, in-depth assessment of a particular issue. It is usually based on information discovered during an FCE.

Minimum CMS Frequencies

• Full Compliance Evaluation (FCE/FS) Once every two years at all TV. Mega sites are allowed 3 years.

• FCE/FS once every 5 years at Synthetic Minors

• On site visit at a minimum of once every 5 years at TV

Data coding

• TV & SM inspections will be recorded as “FS: Full Compliance Evaluation by the State” Any “27” action types will be converted to FS once per month

• TV & SM re-inspections will be recorded as “PS: Partial Compliance Evaluation by the State” Any “54” action types will be converted to PS once per month

Data coding

• The “Result Code” for any inspection action should be coded as either In compliance “MC” or In violation “MV”

• Any non MV result for an FS action will be converted to MC

Data coding

• Tests:

• That we observe: Action Type “23”

• That we do not observe: Action Type 24 (converted to TR at the end of the month)

• Result codes are PP for pass or FF for fail. Any MV action will be converted to FF. All other action result will be converted to PP.

DAQ’s Requirements

• TV facilities - inspected once per year

• SM facilities - inspected once per year

• Minor (small) facilities - inspected once every other year

• Or a different plan as negotiated by the regional office & the central office.

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DAQ’s Requirements

• NC DAQ continually evaluates the compliance status of a facility

• Reports, Inventories, Tests, etc

• We consider the on-site inspection to be the end of the full compliance evaluation period.