EPA has released its final periodic monitoring guidance document and RMB has posted the document, along with the related EPA fact sheet and cover memorandum, to our FTP library for your download. This guidance document is interesting in that it appears to change EPAs compliance approach for many SIP and NSPS regulations. In addition, it appears to implement the essence of the Compliance Assurance Monitoring (CAM) rule through the periodic monitoring guidance - so much for the 5 year phase-in of the CAM rule. The guidance also implements the CAM concept of "reasonable assurance of compliance" and even expands that concept to include "continuous compliance."
Of particular interest to many industries will be the strong recommendation that CEMS and COMS be strongly considered for periodic monitoring on sources that are otherwise "grandfathered" from NSPS. EPAs assertion is the CEMS and COMS have been shown to be cost effective for the NSPS so it follows that they are cost effective for similar non-NSPS sources. We also found the enforceability section of the guidance to be interesting.
This periodic monitoring guidance document is an excellent example of EPA attempting to change and invent new regulations without having to go through the formal rulemaking process. Give us a call if you need assistance with your permitting and periodic monitoring activities.
RMB Consulting &