1. Compliance Monitoring Strategy CMS Michael Pjetraj RCO

2. Compliance Monitoring Strategy CMS 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 facilitys 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. DAQs 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. 15 DAQs 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.