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Assuring Compliance With Air Emissions Limits

Fortnightly Magazine - March 15 1998

mill will perform operational checks daily. Each year, the mill will measure the accuracy of the thermocouple and strip chart. %n14%n

EPA notes that the indicator range may be proposed with the plan based on equipment specifications or prior equipment use, or the source may propose establishing the indicator range after operation and testing of the control device. %n15%n

Q. What is monitored? CAM monitoring is required for any "emission limitation or standard," which denotes a limitation or requirement that is federally enforceable in an operating permit. An emissions limitation or standard may be pounds per hour of a pollutant, or as a relationship between different numbers or as a work practice or procedure. %n16%n

The final CAM rule exempts several categories of emissions, some of which may be relevant to industrial sources. Emissions limitations or standards under the New Source Performance Standards program proposed after Nov. 15, 1990 are exempt. EPA intends that future federal rulemaking will include monitoring requirements as part of the standard that would satisfy the CAM rule. Emissions limitations that apply to an emissions trading program are exempt since monitoring requirements already apply. Also exempt are emissions limitations in a Part 70 operating permit that includes continuous compliance monitoring, stratospheric ozone protection requirements and acid rain program requirements. %n17%n

Besides monitoring the control device, CAM also requires monitoring of any emission capture device and control device bypass system. Both systems are important to the proper functioning of the control device. The final rule eliminates monitoring, however, for fugitive emissions. By definition, fugitive emissions do not pass through a control device so the operation of the control device is not relevant to controlling fugitive emissions. %n18%n

Q. What to report? The CAM rule requires at least semiannual reporting of any problems with the control device and a certification as to compliance of the source with applicable requirements. The report must identify any "exceedances," (an emissions limitation was exceeded) and any "excursions," (a departure from the indicator range established in the Part 64 monitoring plan for the device). %n19%n The report must also describe action taken to correct an exceedance or excursion and any downtimes or incidents with the monitoring equipment.

Sources must certify that compliance was "continuous or intermittent," which means only that the source has CAM data available that, because of the type of monitoring performed, can show compliance on a continuous or an intermittent basis. %n20%n (By contrast, the 1993 proposed rule would have interpreted the term "continuous or intermittent" to require the source to determine whether compliance was in fact continuous (em essentially requiring self-reporting of violations, rather than simply self-reporting of evidence capable of showing a violation.)

Q. When are plans due? Part 64 monitoring plans must be submitted as part of the Part 70 operating permit application if by April 20, 1998 the source has not applied for an operating permit or the permitting agency has not determined the application is complete. If the source already has a Part 70 operating permit, then the Part 64 monitoring plan must be submitted when the