Читать книгу Continuous Emission Monitoring - James A. Jahnke - Страница 31

The compliance assurance monitoring program (CAM) was initiated from a congressional requirement included in the 1990 Clean Air Act Amendments (§702 (b) of the amendments). This amendment to Section 114 of the Clean Air Act states:

The Administrator shall in the case of any person which is the owner or operator of a major stationary source, and may in the case of any other person, require enhanced monitoring and submission of compliance certifications. Compliance certifications shall include (A) identification of the applicable requirement that is the basis of the certification, (B) the method used for determining the compliance status of the source, (C) the compliance status of the source, (D) whether compliance is continuous or intermittent, (E) other such facts as the administrator may require.

The amendment addressed the concern of Congress that the compliance status of most emission sources was determined only periodically by conducting manual stack tests. It was viewed that since source operations may be highly tuned during such testing, operations may not necessarily be representative of day‐to‐day performance. Congress gave EPA the task to devise a strategy that can assure Congress (and the public) that emissions standards and limitations are being met continually, not just intermittently.

The Compliance Assurance Monitoring (CAM) rule was developed as a response to the requirement that essentially places the burden back upon the source. The CAM rule applies to sources required to obtain a Part 70 or 71 air permit and having emission units with active control devices, whose potential pre‐control device emissions are at or above the emission thresholds that define a “major” source (such as 100 tons per year). Affected sources are to develop a “CAM Plan” that will provide assurance to the agency that they are meeting their emissions limitations (Neulicht et al. 1996). The CAM plan provides for the recording of work practice procedures, equipment monitoring, and inspection procedures related to pollution control compliance. CEM systems that measure pollutant emissions directly or by parameter monitoring techniques that provide indirect determinations may also be used. A guidance document on how to write a plan has been prepared by the U.S. EPA (OAQPS 1998).

Methods incorporated into the plan are to specify indicator ranges, within which the emission source is assumed to be in compliance. The range may be simply a range of pollutant concentration, or a range of pressure drops, temperatures, voltage settings, fuel flow, gas flows, and so on. Exceeding the range then triggers a requirement for initiating corrective action.

The CAM program emphasizes the use of plant sensors and parameter monitoring techniques to avoid the installation of CEM systems. This was due to public comment on an earlier “enhanced monitoring” rule intended to meet the requirements of §702 (b) of the 1990 CAA amendments. This earlier rule, viewed as a “CEM rule,” was withdrawn, due in part to outcry over assumed CEM system costs. However, the costs associated with developing CAM plans, modifying plans when plant operations change, and reporting parameter data may ultimately be comparable to the cost of CEM systems and process monitors. If a CEM system is already installed for compliance monitoring through a permit, NSPS, or other requirement, additional monitoring is not required.