PA DEP CEM Harmonization
Study: Project Update
Prepared for the Ad-Hoc Subcommittee on
Monitoring Technical Workgroup
William Balcke, Perrin Quarles Associates, Inc.
February 26, 2004
1
CEM Harmonization Project
Overview
6 month project beginning in October 2003
Three main phases:
Inventory
Analysis
Recommendations
Comprehensive review of substantive
requirements
Lay the groundwork for formal consideration by
PA DEP of substantive changes to CEM
program requirements
2
Inventory Efforts
Inventory effort is most time consuming portion
of the overall project
Comprehensive review is key
We have focused on details of specific elements
after initial summary where we find multiple sets
of requirements on same topic
3
Inventory Methodology
Use of Excel spreadsheets to collect and summarize
data
Can filter based on:
Pollutant/parameter (Opacity, CO, stack flow, etc.)
Source type (Fossil Fuel Combustion Source, Hazardous Waste
Incinerator, etc.)
Program (Acid Rain, NSPS, DEP, etc.)
Document/system (rule, manual, policy, etc.)
Provide citation for each element summarized
4
Inventory – Scope of Programs
CEM requirements in the Inventory:
PA DEP requirements
NSPS (general provisions and about 30 subparts)
NESHAP (general provisions and about 45 subparts)
Part 51 requirements
Part 75 (Acid Rain and NOx Budget)
OTC monitoring not included as no longer
applicable
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Inventory – Scope of Data Sources
Inventory includes review of not only regulations,
but also manuals and other materials, such as:
PA DEP Source Monitoring Manual, Version No. 7
Part 75 Emissions Monitoring Policy Manual
PA DEP policy materials
PA DEP BAQ CEM administrative and data systems
Similar items
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Inventory – General Data Categories
Design
Installation
Performance specifications
Performance testing
Performance test reporting
Quality assurance
Quality assurance reporting
Reporting
Other
7
Inventory – General Data
Categories (cont.)
Within each of these areas, we have collected
information on specific data elements, with
column for citation
Such as specific COMS design elements under the
Design category
Within some categories, separate Excel
worksheets for subcategories
Such as RATA worksheet with multiple specific
elements under Performance Testing category
8
Inventory – Results Overview
We have identified numerous key elements with
multiple requirements, such as:
Span and range
Data validity rules
We have identified other areas without
significant overlapping requirements, such as:
Flow to load QA test
Details of Part 75 missing data provisions
9
Analytical Phase – Overview
Identify areas with conflicting requirements
Identify any policy reasons to explain
differences
Examples of areas analyzed to date
10
Next Steps
11
Complete quality assurance of
Inventory
Also adding to Inventory based on DEP
feedback, as needed
Complete Analysis Phase
Discuss Analysis with DEP and identify
Recommendations
Prepare final report
Project completion scheduled for end of March
2004
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