ALL4 Workshop on BAAQMD Expectations for Continuous Monitoring Systems (CMS) and Source Testing

ALL4 recently hosted a workshop in the Bay Area Air Quality Management District (BAAQMD) to discuss the regulatory requirements for continuous monitoring systems (CMS) and source testing programs completed within the BAAQMD. CMS operated in the BAAQMD must comply with the Manual of Procedures (MOP), Volume V – Continuous Emission Monitoring Policy and Procedures. Source testing completed in the BAAQMD must be completed according to the requirements of BAAQMD MOP, Volume IV – Source Test Policy and Procedures. The MOPs for CMS and Source Testing were promulgated in January 1982, around the same time that the CMS Performance Specifications in 40 CFR Part 60, Appendix B were being developed. As you may imagine, because the MOPs are now over 40 years old, there are several regulatory grey areas that have created challenges for facilities operating CMS and complying with emissions limits via source testing in the BAAQMD in 2024.

The purpose of ALL4’s workshop was to bring stakeholders together, including representatives of the BAAQMD, to discuss regulatory grey areas within the MOPs and discuss options for compliance, as well as the mechanisms available to the regulated community to address those grey areas and comply with MOP requirements. Some of the key areas the workshop discussed included:

• Validation of 1-hour CMS averages,
• CMS are out-of-control (OOC) definitions,
• Overlapping Federal and BAAQMD CMS requirements,
• Analyzer over range requirements,
• Missing data substitution methodologies,
• CMS certification (initially and recertification),
• Source test method deviations, and
• Communicating with the BAAQMD.

While the intent was not to leave the workshop with new policy or updated regulations, we were able to gain an understanding of BAAQMD’s expectations for compliance and establish a path forward for stakeholders to better operate and maintain CMS and complete source testing with the BAAQMD. ALL4 is committed to shaping environmental responsibility and fostering collaboration and understanding between industry and regulatory agencies on compliance topics. If there is a regulation or revision to a regulation that you would like to see in a future workshop, you are a facility in the BAAQMD that operates CMS or completes source testing for compliance with emissions limits and want to learn more about what came out of the workshop, or just have questions about your CMS or source testing program, please reach out to me at 610-422-1139 or mcarideo@all4inc.com.