Compliance Monitoring Strategy CMS

1. Compliance Monitoring StrategyCMS Michael Pjetraj RCO

2. 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.”

3. CMS • Full Compliance Evaluations • Partial Compliance Evaluations • Investigations

4. 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.

5. 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.

6. 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.

7. 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.

8. 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.

9. 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.

10. 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

11. 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

12. 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

13. 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.

14. 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.

15. 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.