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Compliance Assurance Monitoring (CAM)

Compliance Assurance Monitoring (CAM). November 24, 2009. 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

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Compliance Assurance Monitoring (CAM)

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  1. Compliance Assurance Monitoring(CAM) November 24, 2009

  2. 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

  3. 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

  4. 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.

  5. 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).

  6. 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.

  7. 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.

  8. 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

  9. Elements of a CAM Plan

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

  11. 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)

  12. 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

  13. 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)

  14. 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)

  15. Monitoring Approach–Title V Permit Table (example) Indicator Combustion T Outlet CO conc. Measurement approach Thermocouple CO CEMS Indicator range Excursion: <1500°F Excursion: >50 ppmv Data representativeness Installed in incinerator PS 4, 40 CFR 60, App. B chamber QA/QC Redundant t-couple and span gas Monitoring frequency Measure continuously Daily zero (+ 30F) Measure continuously (10 sec) Data collection Record continuously Record 1-min averages procedures on chart recorder by DAS (electronic) Averaging period None 1-hr average QIP threshold No more than six No more than 10 excursions excursions 15

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