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Compliance Assurance Monitoring (CAM) Rule Highlights

Russell S. Berry

RMB Consulting & Research, Inc.

General Information

The CAM rule was signed on October 3, 1997 and published in the Federal Register on October 22, 1997. The Environmental Protection Agency (EPA) developed CAM to focus on monitoring for "reasonable assurance of compliance." CAM requirements will apply to stationary sources that (1) are equipped with post-process pollutant control devices, (2) have pre-control device emissions equal to or greater than 100 percent of the major source threshold -- discussed below -- for a pollutant, and (3) are subject to the Title V permit program.

Exemptions are provided for those sources monitoring for compliance in accordance with the Acid Rain Rules, any other post-1990 EPA rule, or any rule with continuous compliance monitoring requirements (e.g., 40 CFR Part 60 Subpart Da).

A "control device" is defined as equipment other than inherent process equipment, that is used to destroy or remove air pollutant(s) prior to discharge to the atmosphere. Examples of a control device (as defined by the CAM rule) include electrostatic precipitators, scrubbers, mechanical collectors, fabric filters, condensers, afterburners, thermal incinerators, adsorption beds, flares, spray towers, mist eliminators, selective catalytic or non-catalytic reduction systems, and acid plants.

Control devices do not include "passive control measures that act to prevent pollutant from forming, such as the use of seals, lids or roofs to prevent the release of pollutants, use of low-polluting fuel or feedstocks, or the use of combustion or other process design features or characteristics." Therefore, low-NOx burners are not control devices.

The major source thresholds are defined in 40 CFR Part 70 and Part 71 (referencing the Clean Air Act). In general, the major source threshold is defined as 10 tons per year (TPY) for any one hazardous pollutant, 25 TPY for any combination of hazardous pollutants, and 100 TPY for other air pollutant (e.g., nitrogen oxides, particulate matter, sulfur dioxide, volatile organic compounds and carbon monoxide). In specific cases, however, more stringent threshold limits may apply. For example, in nonattainment areas, the exact threshold limit will vary depending on the area classification — marginal, moderate, serious or extreme.

CAM Plan Development

To comply with EPA’s requirements, a CAM Plan must be developed for each affected pollutant emitted from each affected source. The focus of the each CAM Plan will be to ensure and document proper operation of the control device — thereby assuring compliance with the applicable emission limit.

EPA intends for affected sources to develop a CAM Plan based on current process and control device operating requirements and practices. The CAM Plan should use indicator ranges for one or more "key" (representative) operating parameters (e.g., temperature, pressure, voltage, and flow measurements) to establish reasonable assurance that the control device is operating properly and that emissions are within the compliance limits. Indicators of performance may include direct or predicted emission measurements such as visible emissions observations, opacity measurements or continuous emissions monitoring (CEM) data.

Key parameters should be identified and indicator ranges selected using design information, historical data, data from similar sources and test data. Monitor indicators to detect any control device bypass (if such bypass can occur based on the design of the device) must also be included in the CAM Plan. Indicator ranges may be presented as:

  • Single maximum or minimum values (e.g., a maximum condenser temperature)
  • A series of maximum or minimum values that relate to various process conditions
  • A function of process variables (e.g., an indicator range expressed as a minimum to maximum pressure drop across a venturi scrubber relative to process throughput)
  • Particular, designated operational conditions (e.g., the position of a damper in a bypass duct)
  • Interdependent values that vary as one or more other indicator ranges vary
  • Absolute or percent maximum and minimum deviations (e.g., 50 F, 10%) from a "set value." Note that the set value may be an actual value (e.g., 350 F) or a value defined in some other manner (e.g., the mean value for a process variable over the previous 720 operating hours)

The CAM Plan must be developed such that data collected for each parameter is representative and meets any applicable installation specifications. The operational status of all monitoring equipment installed or modified for the purposes of complying with CAM requirements must be verified. Quality assurance and quality control (QA/QC) procedures that adequately ensure continuing validity of the data must be developed for the CAM Plan. In addition, specifications for the frequency of conducting the monitoring and data collection procedures must be developed. "At a minimum, the owner or operator shall design the period over which data are obtained and, if applicable, averaged consistent with the characteristics and typical variability of the pollutant... Such intervals shall be commensurate with the time period over which a change in control device performance that would require actions by the owner or operator to return operations within normal ranges or designated conditions is likely to be observed." In most cases, each parameter will have to be monitored at least four times, at equally space intervals, each hour. The monitoring frequency may be less, if appropriate and approved by the permitting authority; however, at least one data point for each parameter must be recorded for each 24-hour period.

CAM Plan Submittals

CAM Plans must be proposed as part of the Title V permit application or renewal. CAM Plan revisions will be considered a permit modification unless the CAM Plan contains an indicator or indicator range setting process that has been approved by the permitting authority. Each CAM Plan must include a description of the:

  • Indicators to be monitored
  • Methods and frequencies for collecting and averaging indicator measurements
  • Ranges or designated conditions for each indicator -- or the process that will be used to establish the ranges and designated conditions
  • Performance criteria and quality assurance activities required to obtain accurate and representative data
  • Reasons and supporting justifications for any differences between the manufacturer’s recommended performance specifications (this is how EPA is referring to the QA/QC requirements for the equipment used to monitor indicators) and those proposed in the CAM Plan
  • A justisfication for the elements in each proposed CAM Plan

Owners and operators may submit any data supporting justifications for differences in proposed CAM Plan and manufacturers’ performance specifications and may refer to generally available sources of information (such as pollution engineering manuals or EPA or permitting authority publications on appropriate monitoring for various types of control devices).

To justify the appropriateness of the proposed monitoring plan elements, the owner or operator may rely on existing, similar monitoring requirements or submit supporting data. If the CAM Plan developed for a source is similar to and complies with an appropriate existing monitoring requirement already established for other similar sources, the CAM Plan can be considered "presumptively acceptable," and thus, no further justification will be required. This type of justification will primarily apply to those proposing to use CEM, predictive emission monitoring (PEM) or some other alternative monitoring approach in accordance with requirements already approved for a similar type of source. In most cases, however, compliance or performance test data and corresponding process data will have to be used to support the selection of indicator ranges. If existing data is not available, performance testing will be required. Prior to conducting performance tests, a test plan and schedule to verify that the selected CAM parameters and indicator ranges are appropriate will have to be submitted to and approved by the permitting authority.

If a control device is common to more than one pollutant, a single CAM Plan may be submitted for that device. If a pollutant is controlled using more than one device, a single pollutant-specific CAM Plan may be submitted.

Submittal Deadlines

EPA has provided two deadlines -- one for "larger" sources and a second for all other affected sources. For the purposes of this rule, EPA has defined larger sources as units that have a potential to emit 100 percent of the major source threshold limit for a pollutant, taking into account the control device reduction (e.g., a source that has the potential to emit 100 TPY of particulate matter downstream of an electrostatic precipitator).

For larger units, the owner or operator shall submit a CAM Plan as part of the Title V permit application if the application for that source is not considered complete by the permitting authority prior to April 20, 1998. If the permit application is considered complete by April 20, 1998, the CAM Plan must be submitted as part of the next significant permit revision or permit renewal. For all other affected units, CAM Plans must be submitted as part of a permit renewal application.

CAM Plan Approval

After receiving a proposed CAM Plan (an application), the permitting authority will review the CAM Plan to ensure that it satisfies the Part 64 requirements. Approval of a CAM Plan may be conditional, requiring the owner or operator to collect additional data, as necessary, "to confirm the ability of the [CAM Plan] to provide data that are sufficient to satisfy the requirements of [Part 64] and to confirm the appropriateness of an indicator range(s) of designated condition(s)."

The permitting authority will establish one or more permit terms or conditions that specify the CAM Plan requirements. At a minimum the permit must specify:

  • The approved CAM approach including:

i. Indicators to be monitored

ii. Means or devise to be used to measure the indicators

iii. Indicator performance requirements

  • The definition of an exceedance and excursion for the purposes of responding to and reporting exceedances and excursions
  • The obligation to implement the CAM Plan and fulfill all other Part 64 requirements
  • As appropriate, minimum data availability requirements for valid data collection during each averaging period and for the averaging periods in each reporting period

If the CAM Plan requires installation, testing or final verification the permit must include an enforceable schedule with appropriate milestones.

If the CAM Plan is disapproved, the draft or final permit shall include, at a minimum, monitoring that satisfies Part 70.6(a)(3)(i)(B) requirements. The owner or operator will then be required to submit a revised plan within 180 days of issuance of the draft or final permit.

Operation of an Approved CAM Plan

The owner or operator must commence monitoring upon issuance of the Part 70 or 71 permit or by such later date specified in the permit. CAM equipment (including the necessary spare parts) must be maintained, repaired, and checked using the appropriate QA/QC at all times that the unit is operating.

For the purposes of CAM, an excursion is defined as a departure from an indicator range established for CAM under Part 64, consistent with any averaging period specified for averaging the results of the monitoring. An exceedance is defined as a condition that is detected by CAM that provides data in terms of an emission limitation or standard and that indicates that emissions (or opacity) are greater than (or less than, in the case of a percent reduction requirement) the applicable emission limitation or standard.

Upon detecting an excursion or exceedance, the owner or operator must restore the unit to its normal operation as expeditiously as practicable. The response to an excursion or exceedance shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to prevent likely recurrences. The permitting authority will determine whether or not the owner or operator has used acceptable procedures in response to an excursion or exceedance based on the information available, "which may include but not be limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process.

If the owner or operator identifies a failure to achieve compliance with an emission limit or standard that was not identified by CAM as an excursion or exceedance, the permitting authority must be notified promptly and, if necessary, proposed modifications to the permit, addressing CAM Plan revisions, must be submitted.

Quality Improvement Plans

Based on the above-mentioned assessment of the owner’s or operator’s responses to excursions and exceedances, the permitting authority may require the development and implementation of a quality improvement plan (QIP). The Part 70 or 71 permit may require the implementation of a QIP when the accumulation of exceedances or excursions exceeds 5 percent of the units operating time for a reporting period. Implementation of a QIP may also be required at other higher or lower thresholds based on a percent of operating time or any other criteria that indicates whether the unit is being maintained and operated in a manner consistent with good air pollution control practices.

A QIP must include (1) a written plan that is maintained and available for review, and (2) procedures for evaluating control device performance problems. Based on the results of the evaluation procedures, the owner or operator must modify the QIP, as necessary, to include:

  • Improved preventive maintenance practices
  • Process operation changes
  • Appropriate improvements to the control method
  • Other steps appropriate to correct control performance, and/or
  • More frequent or improved CAM

If required, a QIP must be prepared as "expeditiously as practicable." The owner or operator must notify the permitting authority if completing the improvements contained in the QIP will require more than 180 day from the date on which the need for a QIP was identified. Subsequently, the permitting authority may require the owner or operator to make "reasonable" changes to the QIP if the QIP fails to address the cause of the control device problem or fails to provide adequate procedures for correcting control device performance problems as expeditiously as practicable.

Implementation of the QIP will not excuse the owner or operator of a source from any regulatory compliance obligations (e.g., any existing emission limits or standards, or any existing monitoring, testing, reporting or recordkeeping requirements).

Reporting and Recordkeeping

Following "commencement of operation" of an approved CAM approach, the owner or operator must submit CAM reports to the permitting authority at least once every six months. The reported information must include (1) the duration and cause of each excursion and the corrective action required to resolve the excursion, (2) the duration and cause of each CAM downtime incident (other than downtime associated with daily calibration checks), and (3) a description of the actions taken to implement a QIP during the reporting period. Upon completion of a QIP, the owner or operator must include — in the next semiannual report -- documentation that the plan has been implemented and has reduced the likelihood of similar levels of excursions or exceedances occurring.

The owner or operator must maintain records of all monitoring data, monitor performance, corrective actions taken, QIP activities, and QA/QC activities. Paper copies of the records do not have to be maintained; other media such as computer files can be used, provided that the records will be available for "expeditious inspection and review."

Other Issues

  • Part 64 provides state and local environmental agencies with the minimum requirements for a CAM program. The actual CAM program requirements will surely vary between states.
  • Many stationary sources, not affected by CAM, will have to comply with other Title V continuous or periodic monitoring requirements to be established by the state and local agencies.
  • EPA is currently being sued by numerous environmental and industrial organizations over the contents of the CAM requirements. It is quite likely that specific requirements contained in the rule will change.
  • EPA has stated that CAM "Provides [a] baseline from which to build additional monitoring and compliance requirements" — i.e., EPA is not finished doling out monitoring requirements.
  • Excursions are considered possible exceptions to the compliance of a source with a pollutant emission limit, but EPA recognizes that excursions are not necessarily violations. Reports of multiple excursions or "long" durations will be used for targeting enforcement actions. CAM data may also be used as credible evidence of violations. (EPA’s words — Not RMB’s)

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Last Revised: January 15, 2003