RMB has obtained a copy of EPA's Draft Periodic Monitoring Guidance Document dated May 11, 1998. Please feel free to download this document from our FTP library. For your convenience, the file is provied in both WP6.0 (.wpd) and Word 6.0 (.doc) formats. This guidance document is somewhat troubling in that it seems to go beyond the requirements of the Compliance Assurance (CAM) rule with respect to compliance determinations. For example, instead of using the CAM rule phrase "reasonable assurance of compliance," it frequently uses the phrase "to assure compliance." The guidance document confirms rumors that we have been hearing from State regulatory personnel that EPA is pushing periodic "monitoring based on CAM principles" prior to the CAM rule's effect. In other words, EPA plans to circumvent the 5-year CAM rule delay that would have impacted many sources. It is implied, but not specifically stated, that EPA will reject Title V permit applications that do not contain "appropriate" periodic monitoring (read CAM) provisions - not withstanding a completeness determination.
An interesting feature of the guidance is that it dictates that SO2 and NOX monitors used under the Acid Rain Program be specified as periodic monitoring for SIP and NSPS limits. In a couple of sentences, EPA makes a total mockery of 30 years of compliance determinations and regulatory intent. It is a lesson in how to rewrite regulations without having to put a pen to paper. We also note that the guidance requires "a correlation between the parameter(s) and compliance with the emission limit" when using parametric monitoring. What is not clear is how the word correlation is defined or just how precise EPA expects the correlation to be.
We believe all industries affected by the Title V permit program are going to have one hell of a struggle with periodic monitoring!!
RMB Consulting &