FACT SHEET -
PREPARED BY THE U.S. ENVIRONMENTAL PROTECTION
COMPLIANCE ASSURANCE MONITORING
The Environmental Protection Agency
(EPA) is nearing completion of a regulation that will
help facility owners conduct effective monitoring of
their air pollution control equipment. Under the
Compliance Assurance Monitoring or CAM rule, if
monitoring is conducted properly, facility owners will be
able to assure state and local agencies, EPA, and the
public that they comply with established emissions
standards [hence the title Compliance Assurance
Monitoring (CAM)]. Note that in earlier stages this
action was known as the "enhanced monitoring"
The court-ordered deadline for the Administrator to sign
the final rule is October 4, 1997.
The Clean Air Act includes provisions (Title V) that
discuss, in detail, permit programs, permit applications,
as well as permit requirements and conditions. These
provisions of the Clean Air Act define how to address
many issues associated with permits such as submission,
approval, compliance, and enforcement.
EPA requires facilities that emit pollution into the air
to obtain a permit to operate. This permit (known as an
"operating permit") contains information about
how the facility will comply with established emissions
standards and guidelines. Operating permits provide
facility owners the opportunity to learn what the air
pollution regulations apply to each facility. The
operating permits program also creates strong incentives
to improve compliance with existing regulatory
requirements and ensure that desired emission reductions
The Clean Air Act Amendments (Title VII) of 1990 also
authorize EPA to develop regulations requiring facilities
to monitor the performance of their emission control
equipment. In September 1993, EPA proposed an
"enhanced monitoring" rule that established
general monitoring criteria that facilities should follow
to demonstrate continuous compliance. Many state and
local agencies, industry representatives and other
stakeholders strongly criticized the proposed rule. They
believed the proposed rule would have imposed excessive
burden on industry to install and operate continuous
emission monitoring equipment and on State and local
agencies in implementing their operating permit programs.
Since April 1995, EPA has held numerous meetings with
major stakeholders to develop a new, more flexible
approach to enhanced monitoring. Through this stakeholder
process, EPA redrafted the enhanced monitoring rule and
in September 1995, released a new draft rule that changed
the focus to compliance assurance.
The extensive comments that EPA received on the draft CAM
rule indicated the need for additional EPA analysis of
the compliance assurance monitoring approach and other
associated issues. Based on these comments, EPA revised
the draft rule and issued a second draft for public
comment on August 2, 1996, with a public comment period
that ended October 15, 1996. The final rule will reflect
the Agency's response to those comments.
The final CAM rule will require owners and operators to
monitor the operation and maintenance of their control
equipment so that they can evaluate the performance of
their control devices and report whether or not their
facilities meet established emission standards.
If owners and operators of these facilities find that
their control equipment is not working properly, the CAM
rule requires them to take action to correct any
malfunctions and to report such instances to the
appropriate enforcement agency (i.e., State and local
Additionally, the CAM rule will provide some enforcement
tools that will help State and local environmental
agencies require facilities to respond appropriately to
the monitoring results and improve pollution control
HOW DOES THE CAM RULE DIFFER FROM THE PROPOSED
ENHANCED MONITORING RULE?
EPA's September 1993 proposed enhanced monitoring rule
focused on direct compliance monitoring which in many
cases might have required affected facilities to install
expensive continuous emission monitoring systems (CEMS)
or develop other monitoring directly correlated with
In contrast, the compliance assurance monitoring approach
builds on regulatory monitoring approaches already in
place at the facilities in question. Its purpose is to
provide reasonable assurance that facilities comply with
emission limitations by monitoring the operation and
maintenance of their control devices with the same high
level of attention that is given to the manufacturing or
production portions of the facility.
The CAM rule will define minimum applicable monitoring,
operation, and maintenance requirements to ensure that
the equipment does not deteriorate to the point of
failing to comply with emission limits. As a result of
these minimum requirements, EPA believes that the CAM
rule will improve compliance with the Clean Air Act; the
rule will help facilities achieve emission reductions as
well as decrease the need for additional regulations.
WHAT CHANGES HAS EPA MADE TO THE CAM RULE SINCE
ISSUING DRAFTS IN SEPTEMBER 1995 AND IN AUGUST 1996?
EPA received extensive public comments from stakeholders
on its initial draft of the compliance assurance
monitoring rule issued in September 1995 and a second
draft issued in August 1996. There were three principal
areas of concern revealed by the comments: 1.) who would
be affected by the rule; 2.) the requirements for the
monitoring and the relationship to the operating permit;
and 3.) compliance certification requirements including
use of data obtained from methods other than the
specified test method.
EPA has addressed these concerns in the final rule:
1.EPA greatly simplified the applicability of the rule.
In order to focus the requirements of the CAM rule on
preventing pollution control problems before they occur,
EPA determined that the CAM rule would apply only to
those units with control devices (active controls).
Further, whether an emission unit is subject to the rule
is defined by the level of emissions that would occur
without the control device in place (i.e., pre-control
emissions). This approach to defining which units must
have monitoring will ensure that control devices, which
must be operated at the highest efficiencies in order to
comply with emission limitations, are properly monitored.
2.EPA streamlined the monitoring
requirements so that only the important monitoring
elements are included in the Title V operating permit.
The operating permit will include the facility's approach
to monitoring, the acceptable range of control device
operation, and the basic data quality assurance criteria.
The detailed day-to-day monitoring operations are left to
the facility owner to maintain and are not part of the
3.The compliance certifications will
include the applicable compliance requirements, the
methods/monitoring used to determine compliance status,
the compliance status, and the identification of any
possible exceptions to compliance based on the
WHAT ARE THE MAIN COMPONENTS OF EPA'S CAM RULE?
The CAM rule establishes criteria that define what
monitoring of existing control devices that the source
owner or operator should conduct to provide reasonable
assurance of compliance with emission limits and
standards. This monitoring will help source the owner or
operator certify compliance under the Title V operating
The CAM rule will include Title V compliance
certification language that allows the source owner or
operator to use compliance assurance monitoring data to
establish their compliance status with permit terms or
conditions. They can then use this information to certify
that their facilities comply with air pollution control
requirements, as required by the Clean Air Act.
For situations where continuous compliance monitoring is
already specified in an operating permit, the rule
exempts the owner or operator from additional CAM
rule-related monitoring requirements and directs the
owner or operator to use the continuous compliance
monitoring data to fulfill all the CAM rule monitoring
and certification requirements.
For emission units with control equipment, the rule
requires the owner or operator to develop and conduct
monitoring. The monitoring will include an acceptable
range with in which to operate the control device (known
as an "indicator range"). Generally, facility
owners will use results of performance tests in
conjunction with equipment design or other information to
determine the indicator ranges that (if the equipment is
operated within those ranges) will provide a reasonable
assurance of compliance with emission limitations.
Operating control devices within acceptable ranges, as
they were designed to operate, will minimize emissions
and provide reasonable assurance that the facility is
complying with permit terms and conditions.
If control equipment is found to be operating outside
acceptable ranges, owners and operators will be required
to take prompt corrective actions to make necessary
adjustments to the control equipment as well as notify
State and local authorities that potential compliance
problems may exist.
If the control equipment is found to be operating outside
the indicator range for long periods of time, the CAM
rule provides optional tools for the State or local (or
Federal, if necessary) permitting authority to require
more intensive evaluation and improvement of control
Approximately 60 percent of the emission units with
active control devices are covered by the CAM rule.
Altogether, the control devices monitored under the CAM
rule will represent over 97 percent of the total
emissions from all units utilizing air pollution control
devices and receiving operating permits.
HOW DOES THE CAM RULE AFFECT SMALL BUSINESS?
With few exceptions, the CAM rule does not include
specific allowances to reduce the rule applicability for
small businesses; however, the actual burden associated
with the monitoring is relatively small. The EPA
estimates that of the approximately 9000 facilities
affected by the rule, about 55 percent are small firms.
Of those small firms, EPA estimates that less than 1
percent will experience a cost of more than 1 percent of
annual revenues. None would experience costs of more than
3 percent of annual revenues.
WHAT ENFORCEMENT TOOLS IS EPA PROVIDING TO STATE
AND LOCAL AGENCIES?
The operating permits program requires facility owners
periodically (at least annually) to report on the
compliance status for each requirement in the permit and
note any periods of operation outside the established CAM
indicator ranges. These compliance certification reports
along with the monitoring results are valuable tools for
the enforcement agency to use in identifying facilities
with significant compliance problems and in deciding how
to target limited enforcement resources.
To address persistent control device problems indicated
by excessive periods of operation outside the established
indicator ranges, the CAM rule allows State and local
agencies to require the owner or operator to implement a
quality improvement plan (QIP). A QIP is a comprehensive
two-step evaluation and correction process that will
require the facility owner to prepare a formal plan and
schedule for correcting control device problems. Such
activities may include significant repairs to or even
replacement of the control device.
WHAT IS THE RELATIONSHIP BETWEEN CAM AND
ENFORCEMENT RESULTING FROM THE CREDIBLE EVIDENCE RULE?
Given that operating an air pollution control device
outside the acceptable range will not necessarily
indicate that the facility is out of compliance, the CAM
rule cannot and does not replace a facility's obligation
to comply with emission limits that otherwise apply.
Nonetheless, EPA expects that a unit that is operating
within appropriately established ranges as part of an
approved CAM plan will, in fact, be in compliance with
its applicable emission limits. For this reason, units
operating within their CAM indicator ranges will be
presumed to be in compliance and will not be targets for
For more information on the credible evidence rule see
the February 24, 1997 Federal Register notice.
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Last Revised: May 22, 1998