Is your Title V permit renewal imminent? All Title V permitted sources equipped with a control device (e.g., an electrostatic precipitator (ESP) for particulate control) must include a compliance assurance monitoring (CAM) protocol in the Title V permit renewal application for every major emission point. Since the final CAM rule allows the use of continuous emission monitoring (CEM) to serve as CAM for SO2 and NOX, the primary hurdle facing utilities is the development of CAM protocols for particulate control devices. The development of a CAM protocol for an ESP can be a complex and time consuming task. The owner/operator must (1) develop a CAM protocol, (2) conduct testing to verify that the monitoring approach is feasible and (3) develop a corrective action plan. Additionally, RMB recommends that sufficient time be allotted to perform a trial run of the CAM plan prior to submittal of the final protocol to avoid potential compliance issues. This process can take up to three to six months to complete. In accordance with 40 CFR 70.5(a)(1)(iii), a permit renewal application must be submitted no later than six months prior to the expiration date of the current Title V permit.
RMB has conducted two extensive research projects for EPRI on the development of CAM protocols for ESPs. Additionally, RMB is currently providing CAM-related consulting services to several utilities. For more information concerning the CAM rule or our CAM consulting services, please contact Richard McRanie at (919) 510-0483 or at email@example.com.
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