Title V Permitting and CAM Planning APPA E&O Technical Conference April 19, 2005

1. Title V Permitting and CAM PlanningAPPA E&O Technical ConferenceApril 19, 2005 Robert M. Iwanchuk, C.C.M. ENSR International Westford, MA 978-589-3265/riwanchuk@ensr.com

2. Overview of Topics • Title V Monitoring Principles • Part 64/CAM rule summary • CAM applicability • Guidance on Establishing CAM Monitoring • CAM Plan example • Technical resources

3. 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

4. CAM Goals / Principles • Monitoring to provide a reasonable assurance of compliance • Ensure control device is properly operated and maintained • Define operational criteria (indicator ranges) for good O&M of control equipment • Take corrective action before it becomes a pollution problem • Compliance can be assumed if indicators within acceptable range or value

5. Compliance Assurance Monitoring • Impact on Industry • Risk of enforcement action will increase • Compliance costs will increase • Increased scrutiny of existing control devices • Marginal control devices will present higher risk

6. What is required in Title V for Monitoring? • Monitoring requirements from applicable rules • Includes CAM rule requirements • CAM only applies to certain units with control devices • Periodic monitoring • Gap filling if applicable rule 1) has no monitoring, 2) no frequency, or 3) initial testing only • If CAM not applicable, PM can still be required

7. What is CAM Rule? • 40 CFR Part 64 • Federal register citation • Regulation implementing the Title V monitoring principle • Targets facilities with add-on pollution control devices • Requires monitoring plan for affected units • Monitoring elements reflected in Title V permit

8. Who is Affected by CAM? • Facility is a major source subject to Title V • Emission unit subject to an emissions limitation or standard • Pollutant-specific emission unit (PSEU) • PSEU uses “active” control device to achieve compliance • Pre-control PTE > major source size threshold • Not otherwise exempt

9. Major Pollutant and CAM Applicability Thresholds Nonattainment Major Source CAM PSEU Pollutant Status Threshold (TPY) Applicability Level (TPY)1 Criteria/NSPS Attainment Attainment 100/250 100 VOC/NOx Marginal 100 100 Serious 50 50 Severe 25 25 Extreme 10 10 All Other Areas in OTR 50 (VOC only) 50 CO Serious 50 50 PM Serious 70 70 1Potential Pre-Control Device Emissions

10. Who is exempt from CAM? • Rule-based exemptions: • Acid rain rules • Post-1990 EPA rules (e.g. MACT standards) • Rules with continuous compliance determinations methods (e.g., Subpart Da facilities for SO2) • One non-rule based exemption • Municipally-owned peaking units

11. What is an “active” control device? • Equipment used to destroy or remove air pollutants • Inherent process equipment not included • Active controls - e.g., fabric filters, scrubbers, incinerators, catalytic oxidizer • Includes any capture system • Passive controls exempt

12. Examples of control techniques NOT covered • Combustion design features (e.g., lean-burn IC engine) • Low solvent coatings and sprays • Low pollution fuel • Low pollution materials • Low NOx burners • Roofs / covers / lids / storage tank seals

13. How are pre-control device emissions calculated? • Similar to PTE calculations for Title V except: • Capture and control efficiency not counted • May account for enforceable operational restrictions: • Hours of operation, throughput restrictions • Testing for applicability unnecessary

14. Estimating pre-control emissions Annual emissions = restrictions X emissions rate Post-control Emissions Pre-controlled Emissions Control Device PSEU

15. When does CAM apply? • For large PSEUs (post control > major source threshold): • With initial Title V application, if submitted after April 20, 1998 • Significant Title V permit revision (only with respect to the PSEUs for which the revision is applicable) • Title V permit renewal • For non-large PSEUs • Title V permit renewal

16. Applicability Logic Diagram

17. CAM Plan Implementation • CAM approved via Title V permit • CAM monitoring upon issuance of Title V permit • May be delayed if test program is necessary • Monitoring during all periods when unit is operating • Repair, maintenance, QA/QC excluded • Part 70 Periodic Monitoring remains in effect prior to CAM

18. What Must Be In The Permit? • Description of the monitoring approach • What is measured, how, frequency, averaging time • Definitions of exceedances or excursions • (e.g., excursion triggers corrective action/reporting) • QA/QC schedule and procedures • CAM Plan is a separate document

19. CAM Approach • Demonstrate controls’ ability to achieve compliance • Indicators define “envelope” of good O&M for control device • Monitor indicators • Compliance can be assumed if indicators within acceptable range or value • Basis for Title V compliance certification

20. CAM Approach, Cont. • Indicators outside of accepted range triggers: • investigation, corrective action, QIP (if necessary) • Response depends on whether an excursion or an exceedance • Report exceedances/excursions in Title V Compliance Certification

21. CAM Plan • Excursion: Departure from “indicator” range established in accordance with part 64 • Exceedance: Condition detected by monitoring (in units of pollutant emissions) that emissions are beyond limit Note: Excursions lead to corrective actions and may or may not be exceedances

22. CAM Plan Contents • Background information • Unit ID, applicable requirement, control device • Monitoring approach • General criteria • Performance criteria • Justification • Selection of monitoring approach • Indicator range(s)

23. Selection of Monitoring Approach • Identify Potential Performance Indicators (or Combination of Indicators) and Choose Most Reasonable Approach • Emphasis on current procedures • Consider Level of Confidence and Costs • Establish Indicator Ranges • Establish Monitoring Frequency

24. Selection of Monitoring Approach • Site-Specific Factors to Consider: • Existing monitoring equipment • Data representation of emissions or parameter being monitored • Adequate QA/QC practices • Frequency, collection procedures, and averaging period • Monitor’s ability to account for operational variability • Reliability of control technology • Actual emissions vs. limit

25. Performance Indicators • Selection Considerations • Direct or predicted emissions • Process and control device parameter • Recorded findings of inspection and maintenance activities • Performance Criteria • Representative data • Verification procedures • QA/QC practices • Monitoring frequency

26. Frequency of CAM Monitoring • Large PSEUs • 4 or more data values equally spaced over each hour and average the values • Other PSEUs • At least one data value per 24-hour period • Be practical • Frequency should be consistent with averaging times in the permit limits • Short enough to identify problems and do corrective action • Long enough so that minor perturbations resulting from normal variations are not flagged as excursions/exceedances

27. Establishing Indicator Ranges • Parameter data collected during testing • Historical data • Design or engineering data • From similar operations

28. Indicator Ranges • Establish range(s) or condition(s) such that operation within the ranges provides a reasonable assurance of ongoing compliance with the emissions limitations or standards within the anticipated range of operating conditions • If detailed data or test information are not readily available, a source must: • Submit an implementation plan and schedule with detailed activities • Perform activities as expeditiously as possible, but not later than 180 days after approval of the permit

29. Establishing Indicator Range

30. Part 64 applicability examples

31. Quality Improvement Plan • Agency discretion to require based on: • Failure to take proper corrective action or • Threshold of accumulated excursions/exceedances as specified in Title V permit • QIP elements - procedures to evaluate control problem and implementation schedule • Improved PM, process changes, improved control method • More frequent or improved monitoring

32. CAM Reporting and Recordkeeping • Semi annual monitoring reports • Number, duration and cause of exceedances/excursions; corrective actions • Monitoring equipment downtime (other than QA) • QIP actions • Annual compliance certifications • Records of monitoring data, monitor performance, corrective actions, QIP actions • Alternative media (computer files, microfiche, magnetic tape)

33. CAM Plan Examples

34. CAM Plan Examples (continued)

35. CAM Plan Examples (continued)

36. Examples of Presumptively Acceptable Monitoring • Table 3-3 of CAM Guidance • www.epa.gov/ttn/emc/cam.html • CEMS, COMS, PEMS satisfying Part 64 • Part 75 monitoring • Monitoring required by NSPS or NESHAP proposed after 11/15/90 (must satisfy Part 64)

37. Summary • Start planning now • TV renewals are upcoming • Modify test programs to accommodate CAM data needs • Initiate dialogue with state agency • Ongoing issues • Corrective action for excursions/exceedances • Planning for QIP, if necessary • Consider impact of actions on compliance certifications

38. CAM Guidance Documents • Working draft October 1997 • Rule Overview • Description of monitoring approaches • Monitoring equipment technical reference • Appendices: Example CAM plans & Illustrations • EPA Website • www.epa.gov/ttn/emc/cam.html

39. Questions