Guidance on Establishing Monitoring

to Comply with CAM and Other Title

V Requirements

A Summary of Technical
and Policy Materials
Barrett Parker, EPA,
OAQPS
Presentation Overview

 Describe EPA technical guidance

documents format and content
 Discuss procedures for designing
monitoring and establishing indicator
ranges
 Discuss monitoring design evaluation
factors
Guidance Documents - Purpose and
Scope

 Provide general and detailed guidance on the

implementation of the Compliance Assurance
Monitoring Rule and Other Monitoring
Requirements
 Describe regulatory requirements and
implementation procedures
 For industry users and permit reviewers
(applicability, requirements, tools, examples)
 "Living" documents (will continue to add examples,
other information)
General Structure and Format

 Explanatory chapters
– Rule Overview - requirements, procedures
– Monitoring elements
– Description of monitoring approaches
– Technical reference of monitoring tools
– Bibliography
 Appendices
– Example monitoring plans (based on actual
case studies)
Step-by-step Process Description

 Selecting a monitoring approach (guidance

includes a work sheet)
– Review current procedures
– Compare with CAM or PM requirements
– Identify potential indicators (control device
parameters)
– Select reasonable approach
 Develop permit application submittal
Design Evaluation Factors

Monitoring frequency (rule may define continuous

monitoring)- general monitoring frequency
concerns:
 Sufficient to allow calculation over appropriate
averaging periods
 CAM rule minimum requirements:
 Data collection at least 4/hour for large units
 Data collection 1/day for other units
Design Evaluation Factors

Averaging periods:
 Sufficient to detect control device or
other potential compliance problems
 Not so short as to flag minor
perturbations as excursions
Design Evaluation Factors

Level of confidence issues:

 Subjective - provides reasonable assurance of
proper operation and compliance
 Examples of confidence levels for different
parameters for range of control measures
provided in guidance
 Permit application must include justification for
selections
Design Evaluation Factors

Equipment needs - factors to consider

 Location and installation logistics
 Maintenance and training needs
 Cost factors – inherent in source owner’s
planning and design
Design Evaluation Factors

Selecting and justifying indicator ranges -

define a basis:
 Parameter data collected during testing
 Historical data
 Design or engineering data
 From similar operations
Design Evaluation Factors

Selecting and justifying indicator ranges:

 Type of data (e.g., instrumental or
manual)
 Frequency
 Quantity of data for analysis
 Data variability
Design Evaluation Factors

Selecting and justifying indicator ranges (continued)

- performance criteria:
 Data measured during compliance test must fall
within range
 Range must be indicative of good operations
and compliance performance
 Range must be sensitive to control device
changes
 Range should account for normal operational
variability
Design Evaluation Factors

Indicator range formats:

 Mean value + set value (e.g., + 50 F)
 Mean value + percent of mean
 Max/min value(s) observed
 Max/min + set value
 Max/min values + percent of mean
 Combination of more than one of above
(e.g., if "x" and "y", then excursion)
Estimating pre-control emissions

Annual emissions = restrictions X emissions rate

Pre-controlled Post-control
Emissions Emissions

Control
Device
PSEU
Determining Emissions Rates

 Emissions testing
– EPA test methods
– Control device inlet and outlet
 Mass balance measurements
– e.g., VOC from solvents
– Chemical reactions
 Emissions factors X activities data
 Other?
Mass balance example: coal-fired
boilers

 Coal-fired boiler
– 9% ash
– 12,000 Btu/lb
 Calculate precontrol emissions:
0.09 lb ash/lb coal = 7.5 lb/mmBtu
0.012mmBtu/lb coal
 Pulv. Coal: 90%suspended ash 6.8 lb/mmBtu
 Stoker: 20% suspended ash 1.5 lb/mmBtu
Mass balance example: wood
working facility
Eo
Ei

source

source
dust collector

Eo = 8 T/Y (measured via source test)

Control Eff = 90%
Ei = 8 {1/(1 - 90/100)} = 80 T/Y
Uncertainty

 Emissions testing data

– Accurate but short term
– Do not represent process upsets
 Emissions factors (e.g., AP-42)
– Variable from SCC to SCC
– Can easily be factor of 2
 Emissions control efficiencies
– Higher efficiencies (e.g., >90%) can lead to
huge errors in calculating precontrol emissions
Part 64 applicability examples

precontrol postcontrol part 64 large?

(tpy) (tpy) applicable? other?
600 20 yes other
(1/day)
200 105 yes large
(4/hr)
90 25 no

110 110 no