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Assuring Compliance With Air Emissions Limits

Fortnightly Magazine - March 15 1998

rounds of public comment, numerous stakeholder meetings and significant rule rewrites, EPA produced the final CAM rule. %n9%n

The rule requires major sources of emissions to submit for approval a plan to monitor performance indicators for air pollution control equipment. The source must include its plan and the acceptable performance indicator ranges in its Title V federal operating permit. %n10%n Reported excursions from the acceptable ranges may trigger corrective action requirements, but they may not necessarily be Act violations. The consequences of repeated excursions illustrate the difference. Under the rule, the source must submit a quality improvement plan that suggests an evaluation procedure to find the reason for the excursions and a series of steps to correct any problems. Although repeated excursions may prove relevant evidence, it is not conclusive evidence of a violation of an emissions limitation or standard under the Act.

Dealing With Compliance: Who, What, When

The CAM rule targets emissions units that achieve compliance by using an active control device. EPA believes that a control device that is not properly operated or maintained would result in significant emissions. CAM applies to pollutants that, lacking a control device, would exhibit a "potential-to-emit" equal to or greater than the "major-source" limitations for an operating permit under part 70 of C.F.R. title 40. %n11%n

Q. Who is covered? "Control device" is equipment used to destroy or remove pollutants, as distinguished from inherent process equipment. For example, the CAM rule preamble notes that duct work and roof vents are not control devices, but a burner operating at a higher efficiency than required by the process to control emissions is a control device. %n12%n Application of CAM requirements is evaluated based on each regulated pollutant from each emissions unit, and not the facility. One facility may have several emissions units for different pollutants.

EPA's regulatory analysis estimates that 10 percent of the processes at major industrial facilities contain active control devices. Of those, the CAM rule will cover about 60 percent, which accounts for more than 97 percent of emissions from sources using control devices.

Q. What to submit? In general, the source must submit a plan for monitoring its control device, indicator ranges of acceptable operation, performance and operating criteria for the monitoring device, and a form and frequency of reporting of monitoring results. In addition, the source must certify compliance at least annually. %n13%n The submittal is focused on the four fundamental requirements of the rule: (1) monitor the control device to obtain data that allows certification of compliance, (2) take corrective action if the data suggests a problem, (3) report the results to the permitting authority and (4) maintain copies of the records.

As an example, in the rule preamble, EPA recites a hypothetical monitoring plan for a Kraft pulp mill. The mill will monitor the combustion temperature in the incinerator, recording it continuously using a strip chart. It will determine compliance with the indicator range of the incinerator over a five-minute rolling average. (The thermocouple used to measure the combustion temperature must be accurate to within 1 percent.) The