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Periodic Monitoring (PM) and Compliance Assurance Monitoring (CAM)

Periodic Monitoring (PM) and Compliance Assurance Monitoring (CAM). Dan Sims Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2012. Overview. Regulatory basis Exemptions CAM specifics Submitting PM/CAM for SOPs Examples. Regulatory Basis PM.

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Periodic Monitoring (PM) and Compliance Assurance Monitoring (CAM)

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  1. Periodic Monitoring (PM) andCompliance Assurance Monitoring (CAM) Dan Sims Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2012

  2. Overview • Regulatory basis • Exemptions • CAM specifics • Submitting PM/CAM for SOPs • Examples

  3. Regulatory BasisPM 40 CFR §70.6(a)(3)(i)(B) and 30 TAC §122.602 Assure compliance with applicable requirements PM required for rules with insufficient monitoring frequencies

  4. Regulatory BasisCAM 40 CFR Part 64 and 30 TAC §122.604 CAM applicability Subject to emission limitation or standard; Using control device; and Pre-control emissions ≥ major source thresholds

  5. PM Exemptions • PM is covered in the rule (i.e., monitoring frequency) • VOC/HAP fugitive rules • Regulations proposed by the EPA after November 15, 1990 • Rule citations that require monitoring or recordkeeping to demonstrate exempt status

  6. CAM Exemptions • Regulations proposed by the EPA after November 15, 1990 • Continuous compliance determination method • Acid rain regulations • Certain municipal utility units

  7. CAMIn NSR Permits • Policy Memo - CAM Incorporation Into NSR Permits • NSR alteration for CAM incorporation must be completed prior to Title V public notice • CAM for standard permits and PBRs

  8. CAMApplication Timelines • 40 CFR §64.5 • Initial issuance for large PSEUs • Significant revisions for affected large PSEUs • Renewals for small PSEUs • Submit revision application to revise existing CAM plans

  9. CAMAdd’l Notes • Minimum monitoring frequency • Four times per hour for large PSEUs • Once per day for small PSEUs • CAM is effective upon issuance of Title V permit • Up to 180-day extension may be granted

  10. CAMAdd’l Notes • CAM submitted must satisfy 40 CFR §64.3 • Indicator ranges • Design and performance criteria • CAM satisfies PM • Separate CAM evaluation is required for each applicable emission limitation or standard

  11. Submitting PM/CAM for SOPs Form OP-MON Identify monitoring method Use guidance for pre-approved monitoring options; or Submit case-by-case determination Establish deviation limit Submit additional information as necessary

  12. Example 1 A liquid-fuel fired heater: PM options SO2 CEMS Sulfur content of fuel once per quarter and within 24 hours of any fuel change

  13. Example 1Option 2

  14. Example 2 A stationary reciprocating IC engine (small PSEU): CAM options Fuel consumption and inlet gas temperature once per day Inlet gas temperature once per day and NOX concentration once every two years

  15. Example 2Option 2

  16. Example 3 A thermal oxidizer header > 100 tpy of VOC (large PSEU): CAM option Combustion temperature and exhaust gas temperature four times per hour Case-by-case determination

  17. Example 3Option 2

  18. Contact the TCEQ Air Permits Division at:airperm@tceq.texas.gov(512) 239-1250

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