Eric Swisher of All4 Inc. presents "Fuel Monitoring Requirements" and "Alternative Monitoring Petition" in order to educate industry about the options available regarding alternative monitoring or various processes.

1. Fuel Monitoring
Requirements
Presented to AF&PA, AWC, & NCASI by All4 Inc.
Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17
March 14, 2013
www.all4inc.com
Kimberton, PA | 610.933.5246
Columbus, GA | 706.221.7688

2. Fuel Monitoring Requirements

Recordkeeping
• Type and amount of fuel combusted on a monthly basis

Monthly Fuel Analysis
• Each type of fuel combusted
• Sampling programs separated by at least 14 calendar days

Quarterly Fuel Analysis
• Each type of fuel combusted
• 12 consecutive monthly fuel analyses are ≤ 75% of the
compliance level
• Resume monthly fuel analysis for new fuels or if quarterly
fuel analysis is > 75% of the compliance level
2
Your environmental compliance is clearly our business.

3. Alternative Monitoring
Petition
Presented to AF&PA, AWC, & NCASI by All4 Inc.
Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17
March 14, 2013
www.all4inc.com
Kimberton, PA | 610.933.5246
Columbus, GA | 706.221.7688

4. Alternative Monitoring Petition (AMP)


4
Operating limits for specific control device not
listed in Table 4
Establish an alternative operating limit with
alternative monitoring parameter(s)
Your environmental compliance is clearly our business.

5. AMP Elements

Process & Control Device Description
• Diagrams

Four (4) elements of monitoring
•
•
•
•


5
Indicator(s) of performance
Measurement techniques
Monitoring frequency
Averaging time
Performance Evaluation Test Plan (if applicable)
Quality Assurance Activities
Your environmental compliance is clearly our business.

6. AMP Process


Alternative Monitoring Identification
Alternative Monitoring Strategy
• Review U.S. EPA’s Applicability Determination Index
(ADI)


Application Development
Submittal to U.S. EPA
• At least 60 days prior to the Performance Test

Approval or intention to deny from U.S. EPA
• Within 30 calendar days after AMP (and any additional
information) has been received by U.S. EPA

6
Expect Several Iterations
Your environmental compliance is clearly our business.

7. Questions ?
Eric M Swisher| eswisher@all4inc.com | 610.933.5246 ext. 17
www.all4inc.com
Kimberton, PA | 610.933.5246
Columbus, GA | 706.221.7688