Maintaining CMS Compliance and Reducing Unnecessary Downtime
Posted on April 18, 2018
Continuous monitoring systems (CMS) can be required by federal law or by facility permits to continuously monitor specified emissions.
We will touch on two types of CMS, continuous emission monitoring system (CEMS) and continuous opacity monitoring system (COMS). As defined by the EPA, “A CEMS is the total equipment necessary for the determination of a gas or particulate matter concentration or emission rate using pollutant analyzer measurements and a conversion equation, graph, or computer program to produce results in units of the applicable emission limitation or standard.” COMS is relatively the same but monitoring percent opacity rather than a gas pollutant.
With a target of 100% uptime, maintaining compliance with a system such as this can, at times, be exhausting. There are a few conditions that can make this task a smoother process and reduce downtime.
- Preventative maintenance is key to keeping these systems running in their best condition and eliminating system failures. Maintenance can reduce uptime slightly; however, regulations do account for calibration and maintenance time. A little thought and attention to the timing of when this preventative maintenance is performed can reduce the amount of downtime during these tasks. The goal should always be 100% uptime, but typically 95% uptime is also acceptable. Some preventative maintenance examples are replacing consumable parts such as filters, sample pump rebuilds, O-rings, and critical orifices, just to name a few. The frequency of this maintenance will be dependent on the specific environment and processes that the equipment is exposed and subject to.
- Maintaining spare parts will also greatly increase the success in maintaining compliance. Having spare parts on hand and available on-site can significantly reduce downtime. Downtime can accumulate rapidly when waiting for a part to be delivered. It is good practice to have the frequently used preventative maintenance parts available on-site as well as parts that may have a long lead time when ordered.
- A reliable and user-friendly DAS (Data Acquisition System) is also a feature that makes compliance easier to track. Being able to easily view trends and review one-minute data on a frequent basis (daily in most cases) can ensure that the data is accurate. Any suspect data can be addressed quickly and a determination made on whether or not there is a problem with the CMS. Being diligent with verifying the data is properly “flagged” when performing maintenance is essential for accurate data. Those minutes of maintenance cannot be included in averages for reporting purposes. A good DAS is designed to make these tasks easy for the user and provide confidence in reporting emissions.
- Communication between the environmental department and technicians responsible for the maintenance of the CMS is also an area that can help result in accurate data. Communicating about maintenance, troubleshooting, quarterly audits, calibration failures, corrective actions, potential regulation changes, schedules for relative accuracy testing, and changes in equipment needs are a few examples that will create a solid relationship and keep the accuracy of the data more sound.
This is a very brief overview of tips to maintain CMS compliance and reduce unnecessary downtime. If you have questions or concerns about your CEMS and COMS, please contact E360 today to see what we can do to help you reach 100% uptime.
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