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Title V Permit Writer's Tips - Monitoring, Reporting, Recordkeeping and Testing

A.  Periodic Monitoring

If an applicable requirement does not contain adequate monitoring to assure compliance, the Title V permit must "fill in the gap" by including sufficient monitoring, recordkeeping, reporting, or periodic testing to assure compliance (this is the meaning of the term "periodic monitoring" or "gap-filling"). Most SIP requirements, many NSR terms, and some (especially older) NSPS and NESHAP terms will require "gap-filling" periodic monitoring. Generally, each emission unit with a control device should have parametric monitoring (similar to CAM).

Does the monitoring for each applicable requirement--and for each emission unit--assure compliance? If not, "fill in the gaps."

If the chosen periodic monitoring regime is not obvious, include an explanation of source-specific circumstances in the Statement of Basis (e.g., how does the monitoring regime assure compliance). If it is determined that no periodic monitoring is necessary because the worst-case emissions are substantially below the emission limit, include supporting calculations in the Statement of Basis.

EPA has developed periodic monitoring guidance entitled "Periodic Monitoring Guidance for Title V Operating Permits Programs" (September 15, 1998) which can be found on the internet at http://www.epa.gov/ttn/oarpg/t5pgm.html. This guidance explains the basis for requiring periodic monitoring, the periodic monitoring evaluation process, and enforceability issues of periodic monitoring provisions.

 Example #16 

This is an example of a demonstration (in the Statement of Basis) that periodic monitoring for a particulate matter emission limit may consist of keeping records of the type and percent sulfur content of the fuel burned. The calculations show that no monitoring of actual emissions or parametric monitoring is necessary because the source’s worst-case emissions are substantially lower than the applicable limit. Note that the permitting authority is relying on limits on the type and the percent sulfur content of the fuel burned as a basis for compliance with the particulate emissions limit.

Statement of Basis:

Emission units W-1, W-2, W-3, W-4 and W-5 are each 24.8 MMBtu/hr boilers, fired on No. 6 fuel oil. The boilers are subject to Regulation No. 4, Particulate Emissions from Fuel Burning Equipment, Section 2.1. This regulation limits emissions of particulate matter to 0.3 lb/MMBtu. Based on the requirement to burn only fuel with less than or equal to 1% sulfur, the worst-case particulate emissions are:

lb/MMBtu = EF
                 HHV
where:

EF = AP-42 emission factor (lb/1000  gal)
       = 9.19(S) + 3.22, where S= % sulfur content of  fuel

HHV = Higher Heating Value of No. 6 fuel oil (150 MMBTU/1000 gal)

lb/MMBtu = [9.19(1)+3.22] lb/1000 gal
                          150 MMBtu/1000 gal

lb/mmBtu = 0.083

Firing on No. 6 fuel oil with a sulfur content of 1% or less by weight, the emissions of particulate matter is 0.083 lb/MMBtu and does not exceed the Regulation No. 4 emission standard of 0.3 lb/MMBtu of heat input. Therefore, no actual monitoring of emissions or parametric monitoring is needed for the particulate emissions limit, and the source may demonstrate compliance by keeping records of the type and sulfur content of the fuel burned.

B.  Reporting Requirements

 The permit should be specific about when reports must be submitted, and what period of time reports must cover.

Example #17 

Compare the following example language. Example (2) is more clear, and leaves less room for mis-interpretation about reporting obligations:

1) The permittee shall submit a report on a quarterly basis. [A separate permit condition specifies what information must be included in the report].

2) The permittee shall submit a report beginning on January 15 of each year, and on the fifteenth day of each calendar quarter thereafter. Each report shall include information from the previous calendar quarter. [A separate permit condition specifies what information must be included in the report].

C.  Testing Requirements

In general, the permit must explicitly define the applicable testing requirements, including the identification of the appropriate reference test method(s) to be conducted. The permit must also clearly establish a schedule for the performance of the required testing.

Permits Should Require:
  • Initial testing of capture efficiency and destruction efficiency under representative operating conditions using approved methodologies
  • Repeat testing if operating conditions significantly change operation of the control system in a manner consistent with testing conditions
  • Monitoring of appropriate parameters

When compliance with a permitted emissions limit depends on the use of a control system, the permit must require the source to demonstrate overall control efficiency through both capture efficiency and destruction or removal efficiency testing. One possible exception is the case where the source has already conducted such tests under conditions representative of current operating conditions and approved methodologies were used. The permit should require such testing to be repeated if the source significantly changes any of the pollutant emitting portions of its production processes. To assure continued compliance, the permit should also require the source to operate the control system in a manner as it was operated during the compliance testing. To demonstrate continued compliance, the permit should require the source to periodically monitor appropriate operating parameters of the control equipment.

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