Revision 8 – Continuous Source Monitoring Manual (CSMM)

PA Department of Environmental
Continuous Source Monitoring
Manual (Manual, Revision 8)
In September of 2003, the Department released
Revision 7 of the Manual after a multi-year discussion
with affected stakeholders on the appropriate changes.
In the fall of 2003, the Department issued a contract to
Perrin Quarles Associates, Inc. (PQA) to develop a
study of the impacts of harmonizing the Manual
requirements with those of other applicable federal
and regional programs. The need for the study was
identified, as a cooperative effort, between the
Department and the Air Quality Technical Advisory
Committee (AQTAC).
Background (Cont.)
The study examined PADEP, regional, and
federal CEM requirements in depth and
provided a technical basis for future
changes in the Manual and the program.
Development of Manual Revision 8
The AQTAC Technical Workgroup met on six
occasions between October 2004 and March 2005
to develop a finalized draft of Revision 8 of the
The AQTAC concurred (at their June 16, 2005
meeting) with the Department’s recommendation
to publish the notice of availability of the draft
revisions to the Manual and request public
Development of Manual Revision 8 (Cont.)
The Department accepted public comments
pertaining to Revision 8 of the Manual and the
corresponding applicability determination
(September 9, 2005 – October 31, 2005).
The Technical Workgroup met in February and
March of 2006 to review the Department’s
responses to comments received during the public
comment period and other outstanding issues.
Development of Manual Revision 8 (Cont.)
The Technical Workgroup met on April 26, 2006.
Concurrence with the Department’s
recommendation to present the draft version of the
Manual and the corresponding Applicability
Determination (with a few minor modifications) to
the AQTAC was given.
On April 27, 2006, the AQTAC concurred with the
Department’s request to finalize the documents
and notice in the PA Bulletin.
Summary of Major Changes from
Revision 7 to 8 of the Manual
Significant changes were made in the following
sections of the CSMM:
 Introduction
 Submittal and Approval
 Initial Application Tables (Phase 1)
 Performance Testing (Phase 2)
 Record Keeping and Reporting
 Quality Assurance
 Attachments
Major Changes (Cont.)
 Explanation of terminology change to Part 75
definitions for performance specification (PS) testing.
Submittal and Approval
 Addressed changes to process operational conditions
that could require additional monitoring approvals.
Initial Application Tables (Phase 1)
 Include requirements for “highest” and “optional
lower” ranges.
 Eliminated requirements for 2-hr drift testing.
Major Changes (Cont.)
Sources may petition (in many instances)
to use either a more stringent applicable
federal requirement or less stringent
applicable federal requirement with
proper justification.
 Added an alternative 2 PPM calibration
error specification.
Major Changes (Cont.)
Performance Testing (Phase 2)
 Changed the language for PS testing to be more
consistent with federal requirements.
Record Keeping and Reporting
 Language added to explain the reporting of
“substitute” data and when the use of
“monitoring not required” is allowed.
 Language to explain information to be reported
relative to tests, audits, recalibrations,
delinquency penalties, timeliness issues and
potential consequences.
Major Changes (Cont.)
Quality Assurance
 Changed requirements for addressing
“infrequent operation/extended
 Provisional validation of data.
 Language added to make data validation and
data reduction provisions more consistent with
federal requirements.
 Added language to explain invalidation of data
by the Bureau if reports are not submitted in a
timely manner.
Major Changes (Cont.)
Changed language with respect to notifications
and testing required due to component
maintenance or replacement.
 Changed language to make provisions for
“operating hours exemptions” and “grace
periods” more consistent with federal
 Added language relative to determination of
compliance with “stack” flow measurement
device installation specifications for “leak
Major Changes (Cont.)
 Reference latest versions of PS 1 and PS
 New PA EDR Version 2.00 Record Type
Formats and Reporting Instructions.
 New Recertification Guidance.
PA EDR Version 2.0
DEP’s existing, custom electronic emission data
reporting formats have been in use for more than 20
Were developed prior to EPA's institution of EDR
formats for the Acid Rain and NOx Budget Programs.
Program restraints allow only very limited use of
existing EPA EDR emission record elements.
During the fall and winter of 2005, the Department
accepted and reviewed requests for proposals to
develop a new CEM Data Processing System
PA EDR Version 2.0 (Cont.)
In April 2006, the Department awarded the
contract to develop a new CEM Data Processing
System (CEMDPS).
Because of the complexity involved with
harmonizing the numerous PADEP and federal
requirements for roughly 1,000 CEMSs, the
incorporation of a new PA Electronic Data
Reporting Format (PAEDR 2.00) is integral to
handling the changes proposed for the Manual.
Where Do We Go From Here?
Finalize changes and publish in the PA Bulletin
in June or July of 2006.
Ongoing development and testing of the new
Implementation delay (June or July of 2006
until the first day of the second quarter after
the new CEMDPS has become functional).
Revision 8 of the Manual was developed through a
cooperative effort between the Department and the
Changes to the Manual were made in an effort to
harmonize requirements of multiple programs,
provided that such changes were appropriate for
achieving the accuracy necessary to provide credible
data from CEMS subject to those programs.
Implementation the Manual and the new CEMDPS
will occur simultaneously. The Department anticipates
that the effective date of the new Manual and
CEMDPS will occur during the fall of 2007 or first
quarter of 2008.