Compliance Assurance and Title V Monitoring.ppt

Compliance Assurance and Title V Monitoring A Summary of the Rules and Applications Peter Westlin, EPA, OAQPS Presentation topics Title V monitoring principles Part 64/CAM rule summary Other Title V Monitoring Part 70/Title V permit responsibilities Compliance certification Enhanced Monitoring Rule History 1990 - CAAA requires EPA to publish monitoring rules for major sources 1992 - EPA proposes Enhanced Monitoring rules CEMS based All major sources subject 1995 - EPA changes direction Reasonable Assurance of Compliance Focus on add-on control devices Part 64 (CAM) design principles Monitoring sufficient to provide a reasonable assurance of compliance with the applicable requirements (e.g., emissions limits) and to ensure operators pay the same level of attention to pollution control measures as to production activities. What is CAM rule? 40 CFR Part 64 - Compliance Assurance Monitoring Implements the monitoring design principle for a reasonable assurance of compliance Targets facilities with add-on control devices Requires source owners to design monitoring to fit site and incorporate into permits What are CAM design criteria? Build on current requirements and practices: Select representative control device operational parameters (e.g., temperature, flow, pressure drop, electrical voltages, component concentration); Establish indicator ranges for reasonable assurance of compliance Accounting for site-specific factors such as margin of compliance, emissions control variability, correlation with emissions, Relying on design information, historical data, similar sources, test data; and Establish data collection method and averaging time. Who will be affected by CAM? Rule applies to each pollutant-specific emissions unit (PSEU) that: Is located at major source subject to Title V operational permits program, and Is subject to emission limitation and has a control device to meet that limit (e.g., ESPs, scrubbers, fabric filters), and Has precontrol emissions major sourc