Permitting experts provide tips on preparing a CAM plan for the EPA and offer ideas on avoiding potential obstacles

Effective Nov. 21, 1997, the U.S. Environmental Protection Agency (EPA) promulgated the compliance assurance monitoring (CAM) rule, 40 CFR 64. The purpose of this rule, according to EPA, is "to provide a reasonable assurance of compliance with applicable requirements" pursuant to the Clean Air Act Amendments of 1990.

The applicability of this rule, for major sources, is "on or after April 20, 1998, if the major source has not been filed a title V permit application or if a filed application has not been determined to be administratively complete." Otherwise, a CAM plan shall be required with the renewal of the initial title V permit, or if the initial title V permit application is amended before the first permit is issued. If such actions are anticipated, the owner or operator should include a discussion of the CAM requirements in the initial negotiations with the permitting agency.

The applicability of the CAM is interesting. The CAM applies to each pollutant-specific-emissions unit that uses a control device to achieve compliance with any emission limitation or standard. Consequently, it applies to silos with dust collectors, transfer points with dust collectors, and kilns for particulate matter that have dust collectors. On the other hand, it does not apply to kilns for nitrogen oxides or sulfur dioxide unless there is a control device for one or both of these pollutants.

The CAM also does not apply to control devices that are inherent process equipment. The quickest way to understand this applicability is to think "finish mill." Control devices for finish mills are inherent process equipment. Without them, the product is lost to the atmosphere. Furthermore, it is not a reach to draw the same conclusion for a coal mill. The pulverized coal is captured in inherent process equipment (bag house) before being placed in a feed hopper. You can make an argument for the kiln if the dust collected in the bag house is returned to the process. However, it is not likely that you can get anyone on the other side to agree. Finally, the raw mills are beyond reach as the grinding circuit requires discharge of the air to the atmosphere and the bag houses are truly dust collectors to prevent particulate matter from being released to the atmosphere.

Now that the date of application is established and the equipment to which the CAM applies is identified, what constitutes the CAM plan? Pursuant to ??? 64.3(a)(1), you shall design monitoring to obtain data for one or more indicators of emission-control performance for the control device and any associated capture system such as ducts and fans. Examples of indicators are differential pressure changes between the inlet and outlet of a dust collector (a particulate-matter-control-device, PMCD), fan amperage, and an inspection and maintenance (I&M) program.

In a CAM plan recently prepared by the authors, visible emissions (opacity), a continuous opacity monitoring (COM) system, fan amperage, pressure drop, and an I&M program were initially proposed following the guidance of a state agency and EPA guidance documents. Also, in anticipation of the compliance date of June 10, 2002, for the portland-cement MACT, similar monitoring requirements were proposed for the CAM. This was to avoid having two sets of monitoring requirements, one for MACT standards and another for NSPS standards.

Because of the difficulty of predetermining standards for fan amperage and pressure drop, especially for utility dust collectors, after extensive negotiations, visible emissions including the COM system and an I&M program were selected. On the other hand, with modern systems, fan-amperage and pressure drop are readily available at centralized data-gathering locations.

Unless your first CAM plan is included in a permit action in Arizona, it is likely that you will experience a learning curve on both sides of the table. Obstacles you may face include:

1. An expectation of frequent performance testing of all your dust collectors.

2. A lack of knowledge about the technical specifications and operations of dust collectors as these characteristics are related to their performance.

3. A distrust of an I&M program to assure manufacturer's guaranteed performance.

4. An expectation to include more than one indicator in the CAM plan.

5. An expectation of the preparation of a CAM plan before it is required.

The first item is easily handled. Frequent performance tests are not required. I&M programs are recommended in the guidance document and strongly supported by the author of the rule 64, EPA's Peter Westlin. However, experience has shown that it is the state agency that is initially skeptical of I&M programs. By the way, many companies already have I&M programs in place that can be readily adapted to satisfy CAM requirements.

Be prepared to present a technically sound and defensible description of the operation of a dust collector, including its associated capture system in simple words. This should include technical specifications of the bags and their affects on PM capture; discussion of the design characteristics of the bag house, fan, and ducts; problems that develop with the control devices and their affects on the operations of the control device; and the affects on fan amperage and pressure drop on blinding and bag rupture.

Item 3 has been adequately discussed. Item 4 is a regulatory phenomenon. If the rule states one or more, the regulator wants more.

Finally, Item 5 is, again, a regulatory phenomenon. Several states have continued their construction and operation permit program until the unified permit program is in place, which is after the title V permit is issued. Therefore, a modification to an existing C&O permit does not trigger CAM plan applicability. However, the authors' experience came from this very conclusion by a state agency. After the argument reached a juggernaut, it was decided that it was cheaper to write than fight. That is also a case-by-case decision.

EPA has available several documents that will aid in the preparation of a CAM plan. These include a technical guidance document (MRI Project No. 4701-05), and frequently asked questions concerning the CAM rule. The final rule was promulgated Oct. 22, 1997 in the Federal Register 62 FR 54900.