Monitoring & Recordkeeping
Requirements
Donna Cavaliere, MCAQ
What and Where Are They?
• Specific Condition: “Monitoring and Recordkeeping Requirements”
• Table Format
• Different requirements for different types of emission sources or
control devices
Examples:
• Fabric Filters (baghouses) – pressure drop and temperature
• Scrubbers – flow rate, pressure drop, pH
• Thermal Oxidizer – chamber temperature
• Monitoring is required to ensure proper operation of equipment
Example Monitoring Table
MONITORING AND RECORDKEEPING REQUIREMENTS
S-12. In accordance with MCAPCO Regulation 1.5111 “General Recordkeeping, Reporting and Monitoring Requirements”, the facility shall monitor and record the
following operating parameters for the emission control devices as listed below:
EMISSION SOURCE/
CONTROL DEVICE
OPERATING PARAMETER
PARAMETER RANGE
MINIMUM
MONITORING
FREQUENCY
(Once per...)
Regenerative thermal
oxidizer (RTO, CD-01)
Chamber Temperature
Fabric Filter (CD-02)
Pressure drop across the fabric filter
NSPS
40 CFR 60 Subpart SSS
emission sources
Refer to 40 CFR 60.7, 60.714 and Specific Condition and Limitation
S-5 of this permit for specific monitoring and recordkeeping
requirements related to 40 CFR 60 (NSPS) emission sources
Refer to 40 CFR 60.7
and 60.714
MACT
40 CFR 63 Subpart 6X
emission sources
Refer to 40 CFR 63.10 and 63.11517 for specific monitoring and
recordkeeping requirements related to 40 CFR 63 (MACT) emission
sources
Refer to 40 CFR 63.10
and 63.11517
> 1500 °F
3 – 8” Water
Operating shift
Month
Parameter Range AKA Indicator Range
• “Parameter Range” on the Monitoring table, also called “Indicator
Range”
• Is a range of normal operation for the equipment
• Readings outside of the normal range are not necessarily violations – They
are an indication that maintenance or adjustments may be required
• CAUTION: Readings outside of the normal range can be a violation if there is a
regulatory requirement or permit limit which requires the equipment be operated
within the indicator range
• Ranges are provided by you in your application – Section C of the Application
Forms asks for ranges of values
Application Form
Application Form Instructions
• OPERATING PARAMETER INDICATOR RANGES - List all ranges that
the facility will use as an indication of proper operation. Indicate whether or
not there is an alarm or interlock system associated with the operating
parameter by writing yes or no in the “Alarm?” or “Interlock?” columns. An
example of an indicator range would be a baghouse that operates properly
between the pressure drop range of 3 to 8 inches of water column. Any
reading below 3 inches of water or above 8 inches of water may
indicate a problem with the filter. A facility should be prepared to
inspect and perform corrective action on a control device that is
operating outside of the proper operation ranges listed here.
NSPS and MACT Monitoring
• Applicable regulations may have monitoring / recordkeeping
requirements
• MCAQ permits will often refer you to those regulations for more
details – citation numbers are included in the monitoring table
• Due to complexity of the requirements, and/or multiple options
• Or because the requirements may change – parameters may change
with repeat testing, etc.
How to Comply
• You are responsible for recordkeeping format – there may be some
existing recordkeeping/reporting forms for certain types of records,
but most facilities design their own
• Records must be available for review during MCAQ inspections
• When readings are shown to be outside of the indicator ranges,
associated explanations and/or maintenance logs should be available
as well
• Be cognizant of the required frequency – continuous, daily, monthly,
per shift, etc.
• If the equipment did not run during the monitoring time frame, make
a note of that. Do not just leave it blank.
How to Comply
• Monitoring violations are common. Most are a result of personnel
changes or extended leave. Make sure there is a designated backup
during absences.
• Not performing the required monitoring is a violation of your
permit and will likely result in a notice of violation (NOV).
• It is the facility’s responsibility to make sure the equipment is being
monitored and records are being kept.
Monitoring and
Recordkeeping
Requirements
Presented by:
Evan Shaw
Where’s a Good Place to Start Digging?
• http://airquality.charmeck.org
Equipment Monitoring & Recordkeeping
• Monitoring requirements for three of our most common
equipment types:
• NSPS Subpart OOO Wet Suppression Monitoring Log
(crushers, screens, conveyors, etc.)
• MACT Subpart 4Z Maintenance & Recordkeeping
Records (engines)
• Pressure Drop Monitoring Records (baghouses,
scrubbers, etc.)
NSPS Subpart OOO Wet Suppression Monitoring
Subpart 4Z Impacts Many Facilities…
Typical Requirements for emergency engines:
• Non-resettable hour meter
• Minimize idle time (<30 mins)
• Oil and filter change 500 hours OR annually
• Inspect air cleaner 1,000 hours OR annually
• Inspect hoses/belts 500 hours OR annually
**Additional/other requirements if peak-shaving engine or non-emergency engine
• Keep records of inspections that were completed that show:
o Company that performed activity
o Items addressed
o Date performed
Pressure Drop Monitoring
The area of focus…
What you are saying yes to…
2%
11%
48%
39%
A resource we all value…
Questions???