Compliance Assurance Monitoring (CAM) November 24, 2009

Enhanced Monitoring Rule History CAAA requires EPA to publish monitoring rules for major sources EPA proposes Enhanced Monitoring rules – CEMS based – All major sources subject EPA changes direction – Reasonable Assurance of Compliance – Focus on add-on control devices

What is the 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 is 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 source size threshold (e.g., >100 tons/year uncontrolled emissions).

Who is exempt from CAM? Exemptions are by rule type, not facility type: – Acid rain rules, – Post-1990 EPA rules, – Rules with continuous compliance determination methods (e.g., Da facilities for SO2). One exemption exception: Municipally- owned peaking units.

What does source owner do with monitoring results? Use the data to assure and assess compliance with applicable requirements by: – Operating control device(s) within designated CAM or other indicator ranges, and – Responding to excursions, excess emissions, deviations with appropriate corrective action; and – Operating other control measures in accordance with applicable conditions.

Defining Excursions and Exceedances Exceedance – condition detected by monitoring (in units of pollutant emissions) that emissions are beyond limit Excursion – departure from indicator range established in accordance with part 64

Elements of a CAM Plan

Outline of Requirements Background information Monitoring approach description and level of detail Justification and support

Basic Background Emissions unit (Pollutant Specific Emissions Unit - PSEU) Applicable regulations, emission limits, and monitoring requirements Control technology (e.g., control device (CAM), compliance fuel or raw material, process controls, operation and maintenance protocols)

Monitoring Approach Measurement method (what and how) Monitoring frequency and averaging procedures Excursion or exceedance definition (indicator range for CAM) Performance criteria – QA/QC procedures

Other Factors Commitment to corrective action Reporting and recordkeeping Verification of operational status QIP Threshold (optional) Data availability (optional) Table format (for clarity in permit)

Justification Brief description of source/control device Rationale for selecting indicators Rationale for selecting indicator ranges Supporting information (e.g., test data, design factors, historical data, margin of compliance)

Monitoring Approach– Title V Permit Table (example) Indicator Combustion TOutlet CO conc. Measurement approachThermocoupleCO CEMS Indicator rangeExcursion: 50 ppmv Data representativenessInstalled in incinerator PS 4, 40 CFR 60, App. B chamber QA/QCRedundant t-couple and span gas Monitoring frequencyMeasure continuouslyDaily zero (+ 30F) Measure continuously (10 sec) Data collectionRecord continuously Record 1-min averages procedureson chart recorderby DAS (electronic) Averaging periodNone1-hr average QIP thresholdNo more than six No more than 10 excursions excursions 15