Compliance Assurance Monitoring (CAM)

CAM is a method of assuring compliance with established federally enforceable emission limitations by setting forth terms and conditions sufficient to reasonably assure compliance with applicable emission limitations.  In certain situations, federal regulations do not provide sufficient methods to assure compliance with the emission limitation.  The CAM rule, codified in 40 CFR 64, establishes criteria that define what monitoring the owner or operator must conduct to provide a reasonable assurance of compliance with emission limits and standards.

 

Applicability

 

CAM is applicable to each pollutant specific emissions unit.  This means that CAM applies to an emissions unit (i.e., a boiler or process vent, not a facility).  In general, CAM applies to emissions units that meet all of the following conditions:

 

1.         The unit is located at a major source for which a Title V permit is required.

2.         The unit is subject to a federally enforceable emission limitation or standard.  This includes mass limitations (lb/hr and TPY limits).

3.         The unit uses an active control device to achieve compliance with a federally enforceable limit or standard.

4.         The unit has potential pre-control emissions of at least 100% of the major source amount.  Potential emissions should be calculated without considering the effect of any control devices.

5.         The unit is not otherwise exempt from CAM.

 

Each pollutant must be evaluated independently for CAM applicability.  CAM may be applicable for only one of the pollutants emitted by the unit, or it may be applicable to more than one.

 

The CAM requirements do not apply to:

 

1.         Emission limitations or standards promulgated by the Administrator after November 15, 1990 pursuant to Section 111 (NSPS) or 112 (NESHAP) of the Amendments (Regulations promulgated under these sections after November 15, 1990, will include monitoring requirements);

2.         Stratospheric ozone protection requirements under Title VI of the Act;

3.         Acid Rain program requirements;

4.         Emission limitations or standards or other applicable requirements that apply solely under an emissions trading program approved by the Administrator used for trading emissions within a source or between sources;

5.         An emissions cap that meets the requirements specified in 40 Code of Federal Regulations (CFR) Part 70.4(b)(12) or Part 71.6(a)(13)(iii);

6.         Emission limitations or standards for which a 40 CFR Part 70 or 71 permit specifies a continuous compliance determination method. This does not apply if the compliance method includes an assumed control device emission reduction factor (Example: A surface coating line controlled by an incinerator that calculated emissions on an assumed control device efficiency factor based on an initial performance test would not be exempt.); or

7.         Certain backup utility power units, that are municipally owned, that:

a.         Are exempt from all Acid Rain monitoring requirements;

b.         Are operated solely for providing electricity during periods of peak electrical demand or emergency situations (Some operational and contractual data will be needed.); and,

c.          Where actual emissions (annual) averaged over the last three calendar years (or shorter time if it hasn’t operated that long) are less than 50 percent of the amount in tons per year for the source to be considered major.

 

CAM Plans

 

If an emissions unit is subject to CAM, the permit applicant must submit a CAM plan.  Since CAM will become applicable upon a significant permit revision or permit renewal (these terms will be explained in detail in the “What Do I Need To Apply For?” section), the CAM plan must be included with the renewal or modification application.  A CAM Plan must be developed for each affected source for each affected pollutant emitted.  The focus of each CAM Plan should be to ensure and document proper operation of the control device which will assure compliance with the applicable emission limit.

 

The CAM Plan should use indicator ranges for one or more key operating parameters (e.g., temperature, pressure, voltage, flow measurements, etc.) to establish reasonable assurance that the control device is operating properly.  Indicators of performance may include direct or predicted emission measurements such as visible emissions observations, opacity measurements, or continuous emissions monitoring (CEM) data.  In any event, there is no restriction on the operating parameters that may be chosen, so long as they effectively assure that the control device is working properly and in accordance with the manner in which its operation is presented in the permit application.

 

Key operating parameters can be identified and indicator ranges selected using design information, historical data, data from similar sources, and test data.  Any indicators that can be used to detect any control device bypass must also be included in the CAM Plan. Indicator ranges may be presented as:

 

§  Single maximum or minimum values (e.g., a maximum condenser temperature);

§  A series of maximum or minimum values that relate to various process conditions ;

§  A function of process variables (e.g., an indicator range expressed as a minimum to maximum pressure drop across a venturi scrubber relative to process throughput) ;

§  Particular, designated operational conditions (e.g., the position of a damper in a bypass duct); or

§  Interdependent values that vary as one or more other indicator ranges vary.

 

The CAM Plan must show that the data collected for each parameter is accurate and representative.  The operational status of all monitoring equipment installed or modified for the purposes of complying with CAM requirements must be verified. Quality assurance and quality control (QA/QC) procedures that adequately ensure continuing validity of the data may be required by LDEQ.  If necessary, owners and operators must justify differences in proposed CAM Plan and manufacturers’ performance specifications.

 

In addition, the frequency of conducting the monitoring and data collection procedures must be shown.  For sources that have a potential to emit that is below the major source threshold after the effect of the control device(s) is taken into effect, the frequency must be at least once daily.  For sources that have a potential to emit that is equal to or above the major source threshold after the effect of the control device(s) is taken into effect, the frequency must be four times per hour.  Each of these four readings must be taken at evenly spaced intervals.  For any applicable time interval, it is acceptable to monitor more frequently.  The limits stated above are the minimum frequency necessary to comply with CAM.

 

What Should I Include In My CAM Plan?

 

Each CAM Plan must include a description of the:

 

1.         Indicators to be monitored;

2.         The frequency at which the indicators will be monitored;

3.         The method by which the indicators will be recorded;

4.         The averaging period for the indicator data recorded;

5.         Ranges or designated conditions for each indicator, or the process that will be used to establish the ranges and designated conditions;

6.         Performance criteria and quality assurance activities required to obtain accurate and representative data;

7.         Reasons and supporting justifications for any differences that may exist between the manufacturer’s recommended performance specifications and those proposed in the CAM Plan; and

8.         Justification for the elements in each proposed CAM Plan.

 

If a control device is common to more than one pollutant or more than unit, a single CAM Plan may be submitted for that device.  If a pollutant is controlled using more than one device, a single pollutant-specific CAM Plan may be submitted.

 

Is There Any Additional Guidance?

 

EMC Compliance Assurance Monitoring Webpage

Presentation – LDEQ CAM Plan Overview (ppt)

Louisiana Department of Environmental Quality 602 N. Fifth Street Baton Rouge, LA 70802
Call or e-mail a hotline · Office Address/Phone listing · Locate a DEQ employee
Call 1-866-896-LDEQ or e-mail our Customer Service Center with questions or comments