Everybody loves options.  Options make you think before you act. Options creates opportunity that challenge the status quo. Options gives us choices and choices lead us to solutions. Choosing the right one is the real challenge and in the compliance system maintenance game, rarely does one size fit all.

CEMS Maintenance Compliance Obligations

There is a long-standing debate about the regulatory basis, if any, for defining the maintenance obligations associated with Continuous Monitoring Systems (CMS) used for either continual compliance determinations or determination of exceedances of the applicable emission standards. In most discussions, references are made to various Federal guidance documents like 40CFR Part 60 (see Monitoring Requirements 60.13), Appendix B – Performance Specifications and Appendix F – Quality Assurance Procedures and the Part 75 – Emissions Monitoring Policy Manual (Acid Rain Sources only). In all cases, hints are given that support the need for well-maintained equipment, but definitive instructions on how to keep them running are not.

Elusive as the answer may appear, it is understood that if you are required to use CMS for compliance then by the very nature of the phrase “continual compliance determination” you must ensure your equipment is working properly at all times and therefore, must be maintained.  The challenge for facility managers is adopting a maintenance culture that will achieve the operational goal while doing so in a fiscally responsible manner.  “How we get there” is the difficult conversation that every regulated source and their management team must face.

The decision point becomes one of how best to handle the ongoing support responsibility. Do we keep this work in-house with existing maintenance personnel or are we better served contracting it out to a company that specializes in this type of work?  Which way is more cost effective? Because this program will ultimately impact your ability to be compliant, you must choose the way that guarantees the best results. It is a balancing act between Home Grown vs. Farm Out staffing and the economics of maintaining compliance through proper monitoring equipment maintenance.

QA/QC Plan First

Procedure 1. Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determination of Appendix F to 40CFR Part 60 (Quality Control Procedures) outlines the general requirements for the development of a written QC program. This requirement is to alert end users to the need for ongoing QA/QC of the monitoring equipment.  It is hard to say if anyone was dinged for not having a written plan but having one is strongly encouraged.

Before you commit to a maintenance program and assign staffing from inside or outside, you must have a proper QA/QC Plan.  This should be the basis of any maintenance program and should be built in an easy to read, easy to access format that clearly defines all your regularly scheduled, quarterly QA events/audits and the routine maintenance requirements/checks of the monitoring equipment. Ideally, you will receive one from your CMS provider as part of the initial installation contract but if all else fails, you can build one yourself with the help of the equipment providers. If you didn’t get one as part of the equipment contract and haven’t taken the time to build one yourself, then hire someone else to do it for you. How can you make an informed staffing decision if you don’t know the demand on their time? A proper QA/QC Plan is a must.

Home Grown Maintenance

The decision to use in-house staff to support your CMS maintenance program needs to be fully vetted before committing to it.  Like most situations there are pros and cons to this decision.  On the surface it may appear to be more cost effective to keep this home but when you look at the intangibles needed to support a solid program you may find that farming it out is less expensive.  Test the model before committing and apply a long-term view before deciding.  For a proper test, we recommend looking at 3, 5 and 10-year cost projections measured against historical records.

 The following is a short list of things to consider with in-house maintenance staff:

 ·         Develop a Champion: A successful home-grown CMS support program has an in-house expert on staff.  Their only responsibility should be maintaining the CMS equipment. Diluting the champion with other maintenance duties is a recipe for failure. This approach works in most cases but can put undo strain on the support department when first implemented. Choose wisely.

·         Cost of Training: A CMS system is made of many different components that can fail.  In order to do proper maintenance your technician should be trained by the experts in all aspects of the system.  This may require a large time commitment to onsite training and/or sending the techs to school with each of the major component manufacturers. Regardless on how the training is executed it will cost time and money.  The cost impact to keeping your “expert” up to speed should be part of your annual cost calculations when evaluating the future of in-house support.

·         Hire an Expert:  Depending on the complexity of your site-specific CMS footprint you may want to consider hiring a systems expert to run your maintenance program.  This approach comes with a more robust upfront cost but pays dividends later by accelerating your CMS support program avoiding other start-up costs. Hiring an expert satisfies the need to develop a “champion” and should reduce future costs needed to invest in ongoing training.

·         Inventory: Any successful in-house maintenance program will require a commitment to having spare parts readily available.  Keeping parts in stock ties up money that could be used elsewhere.  Work with equipment vendors to see about their spare parts availability commitments and emergency parts services to avoid having them in your shop.  In some cases, vendors may have an offsite, factory supported inventory program that can guarantee availability at a lower long-term cost than keeping them in-house. Selling spare parts is integral to the business model of most manufacturers so go into these discussions understanding that there will be some cost to any spare parts program you choose.

·         Hybrid Solution: One model that has proven successful in many applications is to build a follow the leader program utilizing an outside contractor to help develop your in-house champion. This hybrid approach would require you to set up an annual contract with an outside service company and have them agree to support a program where a dedicated in-house technician learns routine CMS maintenance as an “on the job” training program.  This approach may require a multi-year (2-3) commitment with the service company to properly complete the process of developing an in-house expert but can be the best play in many cases.

 Outsourced Maintenance

Once the in-house support model has been fully vetted from a personnel and cost perspective, it is time to measure your findings against the farming out method.  There are several super qualified companies in the environmental monitoring business that can assist you.  Most system integrators and monitor manufacturers will claim a strong service and support program but not every provider is created equal.  This is clearly a buyer beware situation, with so many choices on the market.  In our experience, we favor companies that started out specializing in CMS service that may have migrated into CMS integration or stack testing over time as opposed to hardware manufacturers that occasionally build systems.  Certainly, if maintenance funding is unlimited then build a combined team of monitor experts and system experts but in most cases, the service specialist offers the most well-rounded solution.

When evaluating competing service companies, the same common-sense rules outlined in our “A Carpenter’s Golden Rule” (April 15, 2019) blog apply.  Ask questions, challenge their claims, reach out to your industry specific peers and talk to references. Service companies are looking for long term relationships and will negotiate to get your business.  Their business model is built around securing geographical contracts that make for efficient field exercises, so use their strategic model to your advantage. Contract pricing is always negotiable.

Home Grown vs. Farm Out

The decision on how to support your CMS system is as unique as your site-specific installation.  There are no two situations that are identical but there are many that are close.  From our perspective we have seen both approaches work well so it is hard to favor one over the other.  When push comes to shove, we like the hybrid approach as the most cost-effective, long term solution.

The best advice we can offer is to adopt a maintenance culture that accepts that ongoing CMS upkeep is part of your overall cost of compliance. From there, do the due diligence required to make an informed decision.  If you are stuck and looking for guidance, then please give us a no obligation shout for assistance.  Our mission is to raise the environmental knowledge bar and help end users make good decisions. We are happy to help.

Thank you for taking the time to read today’s blog.  We hope you found it worth your time. As always, we welcome questions, comments, opposing views or just to start a conversation. Have a compliant day.